New OSHA Construction Standard – Part II

Last week in our Toolbox Talk about the new confined space regulation (29CFR 1926.1204 Permit-Required Confined Space Program), we defined and listed examples of confined spaces we commonly find in construction activities. Briefly, a confined space is one that:

  • Is large enough and configured so that an employee can bodily enter it;
  • Has limited or restricted means of entry and exit; and
  • Is not designed for continuous employee occupancy.

Confined spaces can present many hazards or conditions that are hostile to your well-being. This week, we’ll cover steps to keep employees safe while working in a confined space.

Once the competent person has identified a confined space, it is the responsibility of the employer to do the following:

  1. Implement the measures necessary to prevent unauthorized entry.
  2. Identify and evaluate the hazards of the space before allowing employees to enter.
  3. Develop and implement the means, procedures and practices necessary for safe entry and operations in the space, including, but not limited to, the following:
    1. Specify acceptable entry conditions;
    2. Provide each employee authorized to enter (or his/her authorized representative) with the opportunity to observe any monitoring or testing of the space;
    3. Isolate the space and physical hazard(s) within the space; and
    4. Eliminate or control atmospheric hazards by purging, inerting, flushing or ventilating the space. [Note to paragraph §1204(c)(4): When an employer is unable to reduce the atmosphere below 10 percent lower explosive limit, the employer may only enter if he/she neutralizes the space to render the entire atmosphere non-combustible and the employees use personal protective equipment (PPE).]
  4. Put monitoring procedures in place that can detect an increase in atmospheric hazard levels in sufficient time for employee(s) to safely exit the space should the ventilation system stop working.
  5. Provide pedestrian, vehicle or other barriers as necessary to protect employees in the space from external hazards.
  6. Continuously verify conditions in the space are acceptable throughout the duration of the authorized entry.
  7. Ensure that employees have the appropriate PPE needed to work in a confined space with a hazardous atmosphere.

Remember: Manage or mitigate the hazards of a confined space before you enter. Your safety depends on it.

New OSHA Construction Standard – Part I

OSHA published the final rule covering confined space in construction in the Federal Register on May 5. The rule will become law before the end of this summer. With this in mind, all workers and supervisors should understand the general expectations of the law and be ready to comply with the specific requirements.

We rarely encounter confined space issues in some types of construction work. However, because there is a new and specific regulation, compliance officers should be aware of the hazards of confined space and be watchful for possible situations where confined space protocols should be applied.

In order to understand the requirements for this new regulation, we must first understand the definition of confined space. A confined space is one that:

  • Is large enough and configured so that an employee can bodily enter it;
  • Has limited or restricted means of entry and exit; and
  • Is not designed for continuous employee occupancy.

Some of the more common confined spaces we encounter on construction sites include:

  • Pits (elevator, escalator, pump, valve or other equipment. A pit can have a wide-open top and still be a permit-required confined space.);
  • Manholes (sewer, storm drain, electrical, communication or other utility);
  • Tanks (fuel, chemical, water, or other liquid, solid or gas) and machinery (incinerators, scrubbers, concrete pier columns and sewers);
  • Vaults (transformer, electrical connection and machinery);
  • Ducts (heating, ventilation, air-conditioning and all forms of HVAC, air receivers, air preheaters and ID fan systems, bag houses and exhaust);
  • Storm drains (water mains, precast concrete and other pre-formed units);
  • Drilled shafts;
  • Enclosed beams;
  • Vessels;
  • Digesters;
  • Lift stations;
  • Cesspools;
  • Silos; and
  • Sludge gates.

This is by no means a comprehensive list. In fact, the basic definition of confined space can apply to hundreds of situations where workers might be in a hazardous situation, and escape would be difficult.

Part II of this discussion will cover programs to put in place that will provide maximum safety for workers in a confined space.