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Sorghumrunner

confined space entry

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For those who enter their fermentation vessels and stills to clean, how are you handling confined space entry requirements?  While I don't believe that there are hazardous vapors present, i would say that the entry and exit is restricted.  It seems to me that it's not a 'permit-required' entry.  so is any documentation or attendant required?

from OSHA:

Definitions

By definition, a confined space:

  • Is large enough for an employee to enter fully and perform assigned work;
  • Is not designed for continuous occupancy by the employee; and
  • Has a limited or restricted means of entry or exit.

These spaces may include underground vaults, tanks, storage bins, pits and diked areas, vessels, silos and other similar areas.

By definition, a permit-required confined space has one or more of these characteristics:

  • Contains or has the potential to contain a hazardous atmosphere;
  • Contains a material with the potential to engulf someone who enters the space;
  • Has an internal configuration that might cause an entrant to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; and/or
  • Contains any other recognized serious safety or health hazards.

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The idea of confined spaces makes me queasy. I had a wine-making friend who was overcome by CO2. He and his assistant, who went to assist him upon seeing his distress, died. It happened so fast. Take every precaution.

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You need a permit. No question about it (my job in the Air Force involves responding to HAZMAT incidents, as well as identifying and entering confined spaces--so I'm fairly well versed).

A fermentation vessel indeed Has the potential to contain a hazardous atmosphere (CO2). There is really no arguing against that, and it's very unlikely you'll win that argument against an OSHA inspector.  These rules are carefully written and spelled out clearly as to avoid interpretation which could result in deaths.

http://halmapr.com/news/crowcon/2013/07/22/co2-gas-hazards-in-the-brewing-industry/

Quote

Just last year in Germany, which has a good safety record, two workers died in separate incidents at the same brewery.

In the first incident, the owner was found dead with his head and torso in a beer mixing tank. It is thought that, after bottling and subsequent cleaning, the owner had leaned in to check the container and was overcome by CO2. 10 months later in the same brewery a worker was found dead in a pressure tank used to recirculate wheat beer. He had probably forgotten to fit a yeast plug and had leaned into the tank – which was already pressurised with CO2 – to fit one. He was found up to his hips in the container and had been poisoned – probably in seconds – due to the high concentration of CO2.

https://www.osha.gov/Publications/osha3138.html
https://www.brewersassociation.org/wp-content/uploads/2014/09/Confined-Space-Power-Hour.pdf

 

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Thank you for those links Skaalvenn, very helpful.  So my reading of the Brewers association article about Stone's practices would be that if a fermentation tank is empty, ventilated and tested for CO2, as well as any pipes disconnected or LOTO, then the space would no longer be a permit required space.  Seem correct?

The only time tanks are entered at my facility is for cleaning and sanitization, so they would not be entered when mash is present.  My goal is osha approved safety, but just trying to figure out what the simplest form of that would be.  I do CIP cleaning in our still and mash tun, though the still needs some scrubbing to remove cooked on grains completely.  The fermenters could be CIP cleaned, they are the standard Letina 1000L tanks from St. Pats.  Hadn't bought the CIP ball for them because it is easy enough to climb in and scrub and spray, but being a one man production team, it'd be hard to have an attendant present any time i'm cleaning for safety.

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1 hour ago, Sorghumrunner said:

Thank you for those links Skaalvenn, very helpful.  So my reading of the Brewers association article about Stone's practices would be that if a fermentation tank is empty, ventilated and tested for CO2, as well as any pipes disconnected or LOTO, then the space would no longer be a permit required space.  Seem correct?

The only time tanks are entered at my facility is for cleaning and sanitization, so they would not be entered when mash is present.  My goal is osha approved safety, but just trying to figure out what the simplest form of that would be.  I do CIP cleaning in our still and mash tun, though the still needs some scrubbing to remove cooked on grains completely.  The fermenters could be CIP cleaned, they are the standard Letina 1000L tanks from St. Pats.  Hadn't bought the CIP ball for them because it is easy enough to climb in and scrub and spray, but being a one man production team, it'd be hard to have an attendant present any time i'm cleaning for safety.

Sorghumrunner, this is in line with what we do. We have a written tank entry procedure and signage modeled off of examples we found on the internet. For our cooker we have additional lock-out instructions and signage because of the agitator and steam nozzle. 

We have documented staff training of our procedures and have a buddy system for the entrant and the attendant.  We log the date, time, oxygen level (from a sensor worn by the entrant), time in the tank, reason to enter, and who entered and who attended. Our attendees are required to stay near the tank during the entry.

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what brand of o2 sensor did you go with

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On 9/6/2018 at 2:13 PM, Sorghumrunner said:

Thank you for those links Skaalvenn, very helpful.  So my reading of the Brewers association article about Stone's practices would be that if a fermentation tank is empty, ventilated and tested for CO2, as well as any pipes disconnected or LOTO, then the space would no longer be a permit required space.  Seem correct?

The only time tanks are entered at my facility is for cleaning and sanitization, so they would not be entered when mash is present.  My goal is osha approved safety, but just trying to figure out what the simplest form of that would be.  I do CIP cleaning in our still and mash tun, though the still needs some scrubbing to remove cooked on grains completely.  The fermenters could be CIP cleaned, they are the standard Letina 1000L tanks from St. Pats.  Hadn't bought the CIP ball for them because it is easy enough to climb in and scrub and spray, but being a one man production team, it'd be hard to have an attendant present any time i'm cleaning for safety.

It's been a while since I took my class, but I seem to remember the above applying ONLY if the confined space is not vertical entry. So if you're monitoring the air and something goes south, or your attendant notices the entrant acting funny they can get the entrant out without exposing themselves to the hazardous atmosphere. The only situation that is feasible is if the attendant can pull the entrant out, which is not possible with vertical entry and is why it requires a permit as well as equipment to necessitate a safe and timely extraction. I definitely recommend taking a class on confined space, it will clear a lot of things up. It is also not something to screw around with, as if something does happen and you aren't following safety protocol, you are not only going to kill yourself but likely the person that finds you. A class is well worth the couple hundred bucks it will cost, and many places have confined space attendants you can hire out for the day (they have monitoring and extraction equipment too) which makes way more sense if you're cleaning infrequently. 

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@Sorghumrunner we use a P-sense portable C02 meter for confined space entry. Its simple has a loud alarm and a lanyard for the worker to carry it easily when entering an empty vessel. They may not be the cheapest meter we paid like $300 for it but it is cheap insurance to keep your employees out of harms way

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