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Letter 1084
OSHA and pretreatment washer
standards
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I would like to hear how others in the industry interpert the OSHA
standards on pretreatment washers as to the confined space standard.
It it classified as a permit required, or as a non permit required
entry? What precautions are taken when you need to enter the washer
systen during the course of the day. What documentation is required
to satisfy OSHA?
Neal Pecha
Reltec Corp.
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Unfortunately every inspector interprets the CFR "his/Her" way and
there is not a whole lot of agreement. The safest thing that you can
do is to follow the CFR on confined spaces to the complete total
letter of the law, or you are at the mercy of the inspector's
opinion. There is no logic to a lot of this, but the intent is
employee safety. If there is any ultra remote way that an employee
might possibly be injured by a sequence of nearly impossible
happenings, you are still supposed to have forsaw that and provided
training, warnings and Etc. Do not forget Lock Out / Tag Out in this
training prior to entry.
Good Luck
Jim
James Watts
- Navarre, Florida
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The biggest requirement is that the managers of the operation
really believe that it is important to prepare for entry into
confined spaces. Safety should be considered a cost of production and
money should be budgeted to this area just like we budget money for
pumps, cleaner chemicals, heat exchangers. If they believe this, they
will make the time to schedule maintenance so that safety does not
interfere with the production schedule. i.e., There will never be a
time that someone feels forced to break safety rules to get a line
back into production.
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