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CONFINED SPACES IN CONSTRUCTION

Van Henson

SC OSHA Voluntary Programs

Van.henson@llr.sc.gov

803-896-7769

Useful Resources

• Small Entity Compliance Guide - https://www.osha.gov/Publications/OSHA3825.pdf

• OSHA Standard – Subpart AA (reader friendly version) - https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

Scope of the Standard

• This standard does NOT apply during the following operations:

– Diving operations

– Excavations

– Underground Construction

• Where the confined space standard applies and there is a provision in another applicable standard, employer must comply with BOTH

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5 Key Differences vs. 1910

1. More detailed provisions requiring coordinated activities when there are multiple employers at the worksite.

2. Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces.

3. Requiring continuous atmospheric monitoring whenever possible.

4. Requiring continuous monitoring of engulfment hazards. 5. Allowing for the suspension of a permit, instead of

cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space.

General Requirements 1. Competent person to identify any confined

spaces on the job, identify & evaluate those that are permit required

2. If permit spaces found - employer to inform workers, controlling contractors & unions of their location and dangers in a timely manner by means other than posting

3. Inform exposed employees of permit spaces by posting notices or other equally effective means and take effective measures to prevent unauthorized employees from entering permit spaces

New Definitions under 1926

• Controlling Contractor – employer that has overall responsibility for construction at the worksite

• Entry Employer – employer who decides that an employee they direct will enter a permit space

• Host Employer – employer that owns or manages the property where construction work is taking place

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New Definitions under 1926 cont.

• Qualified Person – one who has the recognized degree, certification, professional standing, extensive knowledge, training, or experience; has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work, or the project

• Entry Rescue – when a rescue service enters a permit space to rescue one or more employees

What is a Confined Space?

• A space that is:

Large enough and configured so that

an employee can bodily enter

Has limited/restricted means for entry

and/or exit AND

Not designed for continuous human

occupancy

Bodily Enter

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Limited Means of Entry or Exit

• A person could not readily escape in an emergency – Contort your body in some

way – Must use your hands – Hard to get in/out – Use of a ladder or

moveable stairs – Door that is difficult to

open – Need to travel a long

distance to the point of safety

Not Designed for Continuous Occupancy

• No ventilation

• No permanent lighting

• Insufficient room to work and move around as you would normally

Large enough to enter

Restricted means of

Entry or exit

Confined Space

All 3 elements are required to have a Confined Space

Not designed for continuous occupancy

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Is This a Confined Space?

Has limited or restricted means for

entry or exit

Is not designed for continuous

employee occupancy

Means a space that is large enough

and so configured that an employee

can bodily enter and perform

assigned work

Requirements

Is This a Confined Space?

Has limited or restricted means for

entry or exit

Is not designed for continuous

employee occupancy

Means a space that is large enough

and so configured that an employee

can bodily enter and perform

assigned work

Requirements

Examples in Construction

• Manholes

• Sewers

• Storm Drains

• Tanks

• Pits (elevator, valve, etc.)

• Bins

• Boilers

• Incinerators

• Scrubbers

• Heating, ventilation and air conditioning ducts

• Enclosed Beams

• Air Receivers

• Crawlspaces

• Attics

• Basements (before stairs are added)

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Permit vs. Non Permit Space

Non-Permit Required Confined Spaces

Means a confined space that does not contain or, with respect to atmospheric hazards, does not have the potential to contain any hazard capable of causing death or serious physical harm.

Pipe Chase

Permit Required Confined Space

Contains a material that has the potential for

engulfing an entrant OR

Contains or has a potential to contain a

hazardous atmosphere OR

AKA Permit Space

Has an internal configuration such that an entrant

could be trapped or asphyxiated by inwardly

converging walls or by a floor which slopes

downward and tapers to a smaller cross-section;

OR

Contains any other recognized serious safety or

health hazard

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A PRCS has been identified. Now what?

• Any ER who identifies or receives notice of a PRCS must inform exposed employees. How?

- posting danger signs or

- equally effective means. Example?

• What types of information required?

- Existence, location and danger of each PRCS

General Requirements

• Employers that will NOT have workers enter the space must take effective measures to keep them out

• Employers that WILL have workers enter the space must implement a written permit space program (1926.1204).

- this program must be available prior to and during entry operations to employees

Multi Employer Coordination

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Employer Responsibilities Host: • Location of permit spaces, hazards of those

spaces, implemented precautions for the spaces • Provides information to the controlling contractor Entry Employer: • Give the controlling contractor info about their

entry program • Obtain info and inform controlling employer of

hazards and permit space system • Debriefing after the entry has occurred

– hazards they encounter in the space

Controlling Contractor

• Controlling contractor, rather than host employer, primary point of contact for info on permit spaces at the work site

• Obtain info from host employer and Entry employer

• Controlling contractor is also responsible for ensuring that employers outside a space know not to create hazards in the space, and that entry employees working in a space at the same time do not create hazards for one another’s workers

Its all about the HAZARD…

Hazardous Atmosphere Engulfment Entrapment

Steam Energy Sources

Corrosives

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Some Recognized Hazards of PRCS

• Atmospheric

–Oxygen deficiency

– Toxic atmosphere

• Engulfment

– Sawdust

–Grain

–Water

• Mechanical

–Augers

–Mixers • Fire

• Explosion

• Struck by

• Falls From

Hazardous Atmosphere • Flammable

gasses/vapors > 10% LFL

• Combustible Dusts ≥ LFL

• Oxygen < 19.5%

• Oxygen > 23.5%

• IDLH

• How Hazards Occur

– Previously stored products/chemical

– Manufacturing process

– Operations/work being performed

– Adjacent areas

N2 Ar CH4 CO2 H2S

Engulfment

Surrounding and effective capture of a person by a liquid or finely divided solid substance that:

• Can be Aspirated. Causing death by filling or plugging the respiratory system OR

• Can exert enough force on the body to cause death by strangulation, constriction, or crushing

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Entrapment

• All about the internal shape!!

– Inwardly converging walls

– Floor slopes to a taper

• Can cause the entrant to be trapped and/or asphyxiated

Energy Sources STRICTLY adhere to LOTO program

Electricity

Hydraulics

Springs

Gravity

Battery Powered

Pneumatic

Chemical Reactions

Thermal Energy

IF no one is EVER going to enter

STOP HERE

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General Requirements

1. Competent person to identify any confined spaces on the job, identify & evaluate those that are permit required

2. If permit spaces found - employer to inform workers, controlling contractors & unions of their location and dangers in a timely manner by means other than posting. How?

3. Inform exposed employees of permit spaces by posting notices or other equally effective means and take effective measures to prevent unauthorized employees from entering permit spaces.

EVERY employer in construction whose employees must enter a permit space is required to have written permit-required confined

space program which complies with 29 CFR 1926 Subpart AA

What must written program address?

1. Measures to prevent unauthorized entry

2. Identify and evaluate the hazards of permit spaces before entering

3. Means, procedures and practices for safe PRCS entry ops

4. Provision of necessary equipment

5. Evaluation of PRCS conditions during entry

6. Provision of attendant(s)

7. Means and procedures for one attendant assigned to multiple PRCS

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What must written program address? 8. Designate EACH person having active role in entry ops, ID their

duties and provide training

9. Procedures for summoning rescue services and preventing unauthorized rescue

10. System for entry permits

11. Procedures for coordination of entry ops

12. Procedures for concluding the entry (closing off, cancelling permit)

13. Review entry ops when measures may provide insufficient protection and revise program to correct deficiencies found

14. Review permit space program using canceled permit and revise as necessary

Training 1926.1207

• Employer must provide training to each affected employee whose work is regulated by this standard

• In a language and vocabulary the employee understands

• Ensure that the employee possesses the understanding, knowledge, and skills necessary for the safe performance of the duties

• Must establish employee proficiency in the duties required by this standard

Training Training must result in

• Understanding of the hazards in the permit space and

• Understanding of the methods used to isolate, control or protect employees from these hazards, and

• Understanding of the dangers of attempting rescues for those employees not authorized to perform entry rescues.

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Training Documentation

• Training records for mandatory training are required!

• Records must include

- Employee’s name,

- trainer’s name,

- dates of training

• Maintained by employer for period of time the employee is employed by that employer.

Useful Resources

• Small Entity Compliance Guide - https://www.osha.gov/Publications/OSHA3825.pdf

• OSHA Standard – Subpart AA (reader friendly version) - https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

Contacts

• OSHA Compliance (Standards Office)

-Health Standards (803) 896-7661

- Safety (803) 896-7682

• OSHA Consultation

- Harvey Jessup (803) 896-7787

• OSHA Training

- Van Henson (803) 896-7769

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Have a SAFE day!!