Confined Space Alternate Entry Procedure vs. Reclassification
We have several vaults on our property that contain pumps and filters for some hot tubs. Because of the hazards involved, I believe these are Permit required spaces. There is a potential for a hazardous atmosphere due to the chemicals used (Sodium hypochlorite and muriatic acid).
I am hoping to either use the Alternate entry procedure or reclassification for entry. I can control all hazards from outside the vault using an appropriate LOTO procedure. This includes eliminating chemical and atmospheric hazards. The chemicals are supplied from 15-gallon carboys that are not in the confined space. The chemicals are pumped through tubing into the water lines. I can eliminate the chemical hazard and the potential atmospheric hazard by disconnecting the carboy and locking out the pumps that supply the chemicals.
So my question is, can I use reclassification, or should I use the alternate entry procedures?
Comments (7)
If you can eliminate all hazards from outside the space and there's no potential hazards, then you could reclassify.
The question is, however, what are you seeing to gain? Eliminate manpower by not needing an attendant, rescue service, etc.?
I would say as long as you all physically “disconnect the cartboy,” the space could be reclassified based on the info provided. Simply locking out a line still connected to a space still provides the potential failure pathway for a hazardous atmosphere.
Do you all need to consider flushing the lines prior to entry and line breaking? What percentage or baume of HCl are you using? Do you also need to worry about mixtures that would release Cl2 or ClO2? NaClO and HCl don’t play nicely together.
I did not consider myself a PRCS expert three years ago. A that time I would not even be sure wat you were even talking about. However, in the last couple years I have had to deal with PRCS and taken a couple classes in them at the local technical college. Although not even close to being in Drew's league and many of you I am coming along! Who says you cannot teach an very old dog knew tricks???
First I agree with everyone above! I dealt with a customer just last month that called me into evaluate a large card board and paper compactor. The employees were entering the compactor, which when told about it scared the heck out of me! They thought they were locking out but using an e-stop to do it! I told them that was not OK! I even had posting on SK on it. Through discussions we forbade access and welded the access door shut, the end opens up so they will open that and clear away jam ups without entering! I did an analysis (even checking the air with a monitor like Drew taught me) and determined the space to be a "Non-Permit Required Confined Space". I suggested some additional remediations and called it a day!
As long as you have completely eliminated the hazards I would reclassify.
Yes but make sure you have a detailed confined space assessment with several signatures for a cross functional group. That way you have e your bases covered ! But eliminating all hazards from outside the space is the ideal reclass permit.