Another international brand of cooling towers/evaporative condensers is marketing their product as if it is NOT a Confined Space or a Permit-Required Confined Space. For those who follow my safety rampages, know how this enrages me! As shown by the pictures below, this Cooling Tower is without question a Permit-Required Confined Space (PRCS); however, as shown below, one would never get this from their manual, and the lack of OEM labeling on the unit.
I will walk us through their flawed reasoning and marketing, and provide the facts as if we are having to perform the 1910.146 (c)(1) evaluation on this space (as I did this morning).
This is a Permit-Required Confined Space campaign I have been involved in for 20 years, focusing on cooling towers and evaporative condensers. OEMs like to market their products as if they come without all the “compliance burdens” of being a Permit-Required Confined Space. They use fancy legal language to dance around the fact that their product is indeed a CONFINED SPACE and the vast majority rise to the level of Permit-Required Confined Space (as does the one shown below).
See Pic1 below, as I have cut and pasted their “marketing” literature, claiming that their product is indeed ”non-confining” due to the “large access door” that “allows for safer” entry.
They provide no hazard/danger labels on their product, indicating it meets the THREE (3) criteria that make a space a Confined Space, so I have to assume they are making the business decision to sell their product as if it is not a CS/RRCS.
Pic2 shows the size of the opening that they claim is “large” and “non-confining”. I had an operator stand next to the door as a point of reference for its size. OSHA has defined this for us… If that opening were a full-size personnel door and anyone could walk inside without having to turn sideways, bend/duck, contort their body in anyway, then we can discuss the lack of “limited means of ingress/egress”. But as we can see, this opening is indeed “confining” as we would have to crawl to get inside this space.
Pic3 below shows what the Entrant is faced with once inside; this UNGUARDED fan is a “serious safety and health hazard,” turning our CS into an actual PRCS.
This space can be reclassified using 1910.146(c)(7), but it is undoubtedly a PRCS.
Moral of the story… never trust a salesperson or the OEM manual to define and quantify our hazards.
The OEM’s video (below) discussing “Accessibility” is quite insane, but it makes my point that this space is a PRCS. But please note, when he talks about being 6’2″ and he can walk inside, be sure to stop the video at the 12 and 14-second marks. You will notice the screen says the door is 48″ and although the top of the door is above his head in the video, pay close attention to the bottom of the door at his waist. No way in hell he “walked inside”; he is even duck squatting as he talks, and you can get an idea of what a 48″ tall opening is RESTRICITIVE. Then we go crazy (38-second mark in video)… one of his selling points is how he can stand inside and touch the “mechanical equipment” (fan shaft, blades, etc.). The blades and power transmission are protected from the outside/top, but they are not protected from within, posing a serious mechanical hazard to an entrant.