(503) 263-2858tanks@jvnw.com April 28, 2017
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Confined Space Entry for Brewers

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Thank you Alaskan Beer for supplying the following OSHA information:

To answer your most basic question, the easiest way we found to be compliant with OSHA’s confined space requirements was to stop entering confined spaces totally. Obviously this can’t always be helped, but in the case of our beer tanks we bought a portable cleaner made by Toftejorg (now Alfa Laval owned) that we could stick in through the manway door of the tank to clean the tanks better than the supplied tank sprayball was doing. This prevented us from having to climb in and scrub the tanks and made the OSHA inspector happy.

You could also just upgrade the type of sprayball you have inside the tank instead of buying a portable unit. Don’t forget your brew vessels too.  We had one inspector that only was worried about tanks for years, but when we changed to a new inspector he started telling us our brew kettles counted as confined space as well and we had to adjust our program to fit. As a simple explanation, they consider anything as confined space if it is an area where you can’t enter or exit easily and there is a chance for harm to the employee from various sources such as gas, water, steam, etc.

So at some point in your future, you’ll more than likely have to set up a confined space program anyway. We were able to get by for many years without entering tanks and avoiding the OSHA program, but as we expanded and bought more equipment (and got new inspectors!) we ended up with more confined spaces that we couldn’t work around not entering, so we finally went ahead and put in a full program.

To get started you will need an air tester and a ventilation fan. We bought our own air tester; it has to measure carbon monoxide, explosive gases, and oxygen levels. These are pretty standard testers and will run you about $2,000 for a good one; I would highly recommend a tester that has an air pump so you can keep the tester out where it is dry while monitoring the air inside the tank. Also note that the air tester will need recalibrated yearly which is another little kit that you have to buy.  Since you are in the real world and have access to equipment rental companies, you might just be able to rent one of these whenever you need to enter a confined space.

Then for the ventilation fan, we bought a cheap fire ventilation fan (part 1983K1), see www.mcmaster.com page 642 and the duct is on page 643.  These fans have a back cowling that the ducting will fit into for storage and they are easily portable and move a lot of air. They are small enough to hang in front of a tank manway door as well.

You may need other equipment based on your state laws, so I’d check with the local OSHA office if they have a consultation department (not enforcement); they were really helpful to us when we set up our system. The other big issue you have to look at is whether you can easily get a person out of a confined space if they pass out or get hurt. In the case of our tanks, when someone goes in we have to put a body harness on them with a rope that a person stands outside of the tank holding in case we need to retrieve them.  You are also required to make sure the second person is always outside keeping watch. And unless you can lock out the chance for gas entry into the tank you must also monitor the air inside the confined space the entire time, so having the air tester is critical for entry. With any confined space program, OSHA is very strict on having proper paperwork in place before you even consider going into a confined space, so you’ll need to set up a confined space form and keep those on file. I have a sample form that we worked up that works for our state that I can email you if you like, so just let me know.

This is a brief nutshell of what you’d need to do. There are lots of options or requirements based on the different types of confined spaces that you might have onsite, so read up on it a lot and it could save you some money and hassle from getting into it further than you need. OSHA’s web site has some really good info (www.osha.gov) as well.

- Alaskan Brewing Company

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