Occasionally, I receive a question with regard to "confined spaces" and what prerequisites must exist for them to be considered OSHA "permit required confined spaces."  I recently wrote a letter on this subject, and I believe the contents of this letter simplifies the matter of confined spaces and clearly explains when one such space is considered a permit required confined space.  

January 5, 2005

Mr. James Grein
President, Nashville Local APWU
PO Box 290033
Nashville, Tennessee 37229

Dear James:

At the joint USPS/APWU ERRP quarterly meeting in Phoenix this past December, Nashville P & DC Site Coordinator Lynda Crane described an ERRP modification during her presentation that may have created a safety hazard that could be an OSHA violation.  The purpose of this letter is to inform you of this hazard so that steps can be taken to correct it and thus afford full protection to all employees at the Nashville P & DC of any safety and health issues.

The problem that existed at your site that was brought to the attention of the ERRP core team was the parcel drop storage bin in the customer service area. This bin is about 7' high, 10' wide, with a roll-up door that was about 3' high and almost 8' wide. It also has three chutes in the front of the storage area for parcels mailed by customers, and it stored one container per chute. 

This created an ergonomic problem because it required the worker to bend down to the floor to grasp the handle to lift the heavy roll-up door to take out the full containers.  The core team, to their credit, took the necessary action to alleviate the problem by adding a door on the bin's side so that a worker could walk in and push out the bins via the new door as opposed to the old roll-up door.  However, in so doing, for reasons outlined below, the core team may have unknowingly created another hazard that OSHA defines as a "confined space."

According to 29 CFR 1910.146, a "confined space" is a space that meets all of the following requirements: (1) it is large enough and so configured that an employee can bodily enter and perform assigned work (as in this situation); (2) it has a limited or restricted means for entry or exit (e.g. one door, with a roll up door that is always locked, again as in this situation); and (3) it is not designed for continuous employee occupancy (e.g. no lights, no ventilation, no creature comforts).  The parcel drop storage bin discussed above appears to meet each of these three requirements.

Further, as per the same standard, OSHA also describes some confined spaces as "permit required confined spaces." These spaces meet all of the requirements of a confined space plus one of the following: (1) it contains or has the potential to contain a hazardous atmosphere (i.e. one that is flammable, or has toxic gases); or (2) contains a material that has the potential for engulfing an entrant; or (3) is so configured that an entrant can become trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or (4) contains any other serious safety or health hazard (e.g. rodents, reptiles, electrical or mechanical hazards).  With the information we have at hand, the APWU contends that requirements #1 and #2 are met because of the possible flammable nature of the parcels, and requirement #4 is met because of the undetermined contents of many of the parcels that are being stored.

In view of this, it is the APWU's opinion that this storage bin could be considered a permit required confined space.  As such, the APWU strongly urges you to take any action necessary to correct this matter.  At this time, since craft/management cooperation has been and still is a hallmark of ERRP, you are encouraged to first discuss this with Site Coordinator Lynda Crane whom we feel will be open to assist in the resolution of this problem.  You, the local National Mail Handlers Union President, and Ms. Crane may also want to jointly confer with a local OSHA representative to bring this situation into compliance.  Further, the matter should be brought up for discussion and possible resolution at the next local safety and health committee meeting particularly since this is now strictly a safety matter and no longer an ergonomic one. 

If OSHA deems it necessary, a written program may have to be developed to control the space and protect employees from hazards, and for regulating employee entry.  A copy of this standard can be sent upon request.  Also, another structural modification may be possible that could eliminate the bin from consideration as a confined space altogether.

Though we have been told that this work is completed only by mailhandlers, we are concerned about all employees.  If you have any questions regarding this or any other safety and health matter, please feel free to contact me at your convenience.  I have included a business card for easy reference, and my cell phone number is 954.552.4777.

Sincerely,

Bob DelPrete
Southern Region Safety/Health Rep, APWU

cc: Frankie Sanders, APWU Regional Coordinator
Corey Thompson, APWU Safety/Health Specialist
Martha Kidd, USPS Field Coordinator
Lynda Crane, USPS Site Coordinator
Kerry Braell, Local NPMHU President