Confined Space for large HVAC units on monthly filter change outs

[mizkn]

Confined space has many things to consider, however, when changing the filter on large HVAC units or other small maintenance items the concept of this being a confined space for emergency rescue coverage seems to be overkill. Especially when there is a door on both sides of the unit or the arms and hands are the part of the body that enters the confined space. Typically these filters are changed by one contractor and the job can run past normal hours of confined space/ emergency rescue coverage. The HVAC units in question supply air to the process building--there is no chemical asphyxiation issue. It is not an area where personnel typically reside therefore confined space is being mandated.

There has been difficulty within the plant site to agree to a variance for the outside contractor to have full emergency rescue coverage on all maintenance issues including these simple filter changes. Is there any experience on this confined space issue?

 

[cablepro]

I feel that with regards to the legalities, in case there is an injury, and recognizing the upwards liabilities, your best resolution would be to contact OSHA direct either through your local OSHA Field Office or State Safety Office, and be sure you are able to get their determination in writing (this is the normal practice, but insure that you request it in writing).

 

[mizkn]

Cablepro,
Thanks for your response. I am concerned that formal writing may bring a visit that with my limited experience in this arena could lead to a situation issue (not there are "sleeping dogs" but I have no experience here). Our site safety personnel want this issue documented before they "rule"...whether that ruling would include what you have suggested I suspect so.
If a shoe lace trip happened with this HVAC confined space entry...I am sure you are correct w.r.t. the legalities.
Regards.

 

[omar12]

Hi,

HVAC units like the ones you describe above are not permit required confined spaces so you do not need anybody standing by regulatory requirements. Take a look at your OSHA standard for confined space and read the standard.

 

[mizkn]

Omar12,
The standard is part of the problem...we have several folks that read it as their job specific requirement and they are the ones stating they are confined space...even though the outside contractor says he does not do this for any other client.

Thanks for your feed back. At least we read it the same.

 

[RPG]

The definition of a confined space has three items listed: An enclosure not normally designed for human occupancy, with known or potential hazards and a limited means for entry or exit, which may restrict egress so that a person would have difficulty in escaping from such a space in an emergency. All three of these must hold true for it to be considered by OSHA to be a "confined space". If you have a "confined space" and are questioning whether it is now a "Permit Required Confined Space" it only has to have any one of the many listed hazards present.