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printreg, June, 2001
Confined Spaces


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From:Gary Jones(gjonesprinting@aol.com )
Date:Thu, 5 Jul 2001 17:25:57


Answering your question with a simple yes/no answer is difficult as you have not provide any details with respect to the size and shape of the maintenance pit under your sheetfed press. Therefore it is difficult to provide a definitive answer to your question. In examining the confined space entry requirements for maintenance pits under presses, you must first establish if it is a confined space and then is it a permit-required confined space. Confined spaces in an of themselves do not require a formal entry program, only permit-required confined spaces require them. According to 29 CFR 1910.146, a confined space must meet three criteria: 1) It is one that has limited or restricted means of entry or exit. 2) Is large enough for an employee to enter and perform assigned work. 3) It is not designed for continuous occupancy by the employee. If for example, you have steps that are used to access the pit and they are 28" wide and have the proper handrails, then condition 1 would not apply and you would not have a confined space. However, if you do meet the three above conditions, then the space must be evaluated to determine if it is a permit-required confined space. There are four requirements for permit-required confined spaces and they are: 1) It contains or has the potential to contain a hazardous atmosphere. 2) It contains a material that has the potential for engulfing an entrant. 3) It has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or a floor that slopes downward and tapers to a small cross section. 4) Contains any other recognized serious safety or health hazards. If for example, you maintenance pit had live exposed electrical wires or circuits or contained less than 19% oxygen in the air, it would be considered a permit-required confined space. If ink or solvent is spilled either in the space or above it so that the solvent leaks into the space, it could become a temporary permit-required confined space. With all of the possible scenarios it is difficult to answer your question directly without additional information. I would strongly suggest that you read the standard, especially the definitions and evaluate your particular situation relative to the standards requirements. The standard can be found on-line at www.osha.gov.



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