The University of New Mexico s Ford Utilities steam distribution tunnel system presents a unique situation in regards to confined space entry procedures and compliance with OSHA s Confined Space Standard 29 CFR 1910.146. The steam tunnel system falls within a regulatory gray area. It is difficult to define the entire system as a confined space, and it is equally difficult to identify specific areas or passages as confined spaces. More importantly, normal confined space entry procedures are both impractical and do little to protect the health and safety of employees entering the steam tunnel system.
Authorization is required to enter the steam tunnel system.
Signs are posted on steam tunnel access doors stating that the steam tunnel system is a restricted access area. Specific steam tunnel entry procedures have been developed and implemented. A considerable portion of the main tunnel system is designed for employees to enter through building equipment room doors, walk through the tunnel passages and perform equipment maintenance. Blind ends, smaller tunnels of approximately 4' by 4' and tunnel sections accessible only through manholes do exist in certain areas. Mechanical forced ventilation is provided throughout the main tunnel system.