Would this be considered a confined space
We have a cooling tower which is open to atmosphere, and the sides of the cooling towers contain louvers, which are also open to the atmosphere. There is a 4' manway on the side of the cooling tower to allow people to enter if need be. I wanted to see if this would be considered a confined space. Although it's not "designed for continuous occupancy", it's open to the atmosphere (so we're not really worried about O2 deficiency), and there's the manway on the side to allow people to go in and out when they have to do maintenance. How would you guys treat this space?
Comments (3)
I managed cooling tower repair projects for a short time (during an unplanned major plant outage). Our confined space permitting rules and interpretations were very conservative and all of my internal work (maybe all but one) was done under confined space entry permit. That however was unusual for our cooling tower crews. I was told they typically were allowed to work (with energy sources isolated) without a confined space entry permit.
In general, yes it’s a confined space. Not intended for occupancy and that 4x4 manway isn’t a walk-through opening.
Is it a permit required confined space? That’s dependent on the tower design. How deep is the basin under the tower, and what is the walking/working surface like above the basin? Is there a “serious safety or health hazard? Example - One of our cooling towers has an 18” walkway between the louvres and over the basin. Others had a much wider path plus railing. I think it’s case by case. I’m not sure my memory is 100%, but I think one smaller tower had a full size doorway, and full internal walkway with railing. That one maybe didn’t require permit.
Don’t forget to do bacteria / Legionella tests.
https://www.osha.gov/laws-regs/standardinterpretations/1995-10-27
Question
Are cooling towers considered confined spaces?
Answer
We cannot categorically state whether all cooling towers fit the definition of a confined space since the term "cooling tower" covers such a broad category structures and configurations. Whether a cooling tower that meets the definition of a confined space is also a permit-required confined space it depends on whether there are potential or actual serious safety and health hazard(s) in the space at the time of entry. We note that cooling towers that are confined spaces would be permit (permit-required) spaces if there is exposure to moving parts such as fan blades, belts and pulleys. Where exposure to the moving parts can be permanently controlled through physical guarding, these hazards would not trigger the classification of the space as a permit space.
I would treat it as a non-permit confined space. How large is the space inside? Perhaps if the door was 36"x80" you could say that you do not have limited means of access, given there are no obstructions inside the manway.. but a 4' doorway in an emergency situation would certainly be considered limited.