RECENT enforcement activities by the Occupational Safety & Health Administration (OSHA) have grain handling facilities reconsidering whether their boot pits qualify as permit-required confined spaces (PRCS), as defined by OSHA.
It appears that boot pits are the new focus for OSHA enforcement.
In general, the boot pit of a grain handling facility contains the bucket elevator and other conveying equipment, while some may also contain other essential equipment like dust collection systems and sump pumps. Although different types of boot pits do exist, the majority of boot pits fall under the "priority housekeeping area" of OSHA's grain handling standard.
As a result of National Grain & Feed Assn. (NGFA) members reporting that numerous citations have been issued, the association's safety, health and environmental quality committee recently released a guidance document, available at www.nga.org, to assist grain handlers in evaluating if a boot pit meets the criteria to be declared as a PRCS.
In accordance with federal OSHA regulations, employers are required to evaluate their workplace to determine if a PRCS is present. If such an area exists and employees must enter the area, then OSHA requires certain safety procedures to be implemented.
To determine if a boot pit is a PRCS under OSHA standards, it must first be decided if the boot pit fits all three characteristics listed in OSHA's definition of a "confined space," meaning the space: (1) is large enough and so configured that an employee can bodily enter and perform assigned work, (2) has limited or restricted means for entry or exit and (3) is not designed for continuous employee occupancy.
In the guidance, NGFA explained that most boot pits are usually "large enough" or "configured" in a way that employees can enter regularly to perform assigned tasks. Boot pits are also designed to be entered under normal operating conditions and typically have adequate ventilation.
Nevertheless, boot pits may or may not have limited entry or exit. The OSHA standards do not have an official definition, but the agency states that a space has "limited or restricted means for entry or exit" when "an occupant must crawl, climb, twist (or) be constrained in a narrow opening."
NGFA presented three questions to help grain handlers decide if limited access exists: (1) Does the boot pit have a door that is standard size? (2) Does the employee have to climb up a ladder, articulated stairs or use some other means of escape that would be more difficult than using regular, fixed stairs? (3) Would the employee have to crawl through or around equipment to reach the door?
If a boot pit is determined to qualify as a confined space, then physical and other hazards need to be assessed to determine if the present hazard would prohibit an employee from escaping from the boot pit.
According to OSHA standards, a PRCS also has one or more of the following characteristics: (1) contains or has a potential to contain a hazardous atmosphere, (2) contains a material that has the potential for engulfing an entrant, (3) has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section or (4) contains any other recognized serious safety or health hazard.
If the boot pit qualifies as a PRCS, then exposed employees should be informed by posting danger signs, the location of the permit space and the danger posed. Employers need to develop and implement a written permit space program for any PRCS that requires entry.
The NGFA guidance concludes that, under normal conditions, most boot pits do not fit all of the required characteristics. However, the association is advising all grain handlers to consult with an experienced safety and health legal counsel or a third-party expert.