Rank: New forum user 
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Evening all,
We have a silo at work which usually holds a powder (free flowing solid). During use you can safely enter the silo base through two doors and look up to see the cone of the silo itself so this area is enclosed. Due to performance issues the maintenance team would like to remove the silo valve for inspection. Clearly if you have many tonnes of powder in the silo this is a specified risk but if the powder is not present, surely this is not a confined space?
To me this is an "eliminate the hazard" problem and without the powder (and no other specified risks) then the definition of confined space is not met.
Has anyone else hasld a similar problem or advice? We have previously treated these as confined space out of habit so happy to continue as such but think a robust challenge is needed.
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Rank: Forum user
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If you look at the HSE ACOP - Guidance 1, paragraph 12 (freely available from HSE website)
Under these Regulations a ‘confined space’ must have both of the following defining features: (a) it must be a space which is substantially (though not always entirely) enclosed; and (b) one or more of the specified risks must be present or reasonably foreseeable. Based on your description the specified risks has been eliminated and therefore you can declassify the structure for the duration of the task - I would still document the risk assessment / method statement on how the team will perform the task & ensure the specified risk has been fully eliminated
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Rank: Forum user 
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Look at the whole operation and work required and that will aid you in making a decision.
I would be considering what was the powder and will it have left any fumes vapours or combustible dusts in the silo itself which could tumble down into the lower work area when the valve is removed which could be either toxic, flammable or form an asphyxiant.
Also when is the work to be carried out. If it was to take place in the middle of summer in 30⁰C heat there is the potential risk of unconsciousness due to overheating as the inside of the silo might be at a much higher temperature. Consider how is the valve is to be removed, is there any grinding or heating of the metalwork required where fumes from such grinding operations or a flammable/Oxygenating gases could leak from cutting equipment into the space causing an asphyxiation/enrichment or fire and explosion risk.
Once you have covered all these based then perhaps it can be deemed as not being a confined space.
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 1 user thanked John Elder for this useful post.
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Rank: Forum user
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Morning, I have worked in various industrial bakeries with a number of silos. If your silo is emptied, then get the to open the hatch, which will be located on the conical part in the lower silo housing, and let it air. You can then use a multimeter before they start working in the area. I would not class this as confined space but as other chaps have already said, just ensure you have a good RA and method of work considering the risk for any potential explosive atmostpheres in the area.
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1 user thanked Juan Carlos Arias for this useful post.
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