New Confined Space in Construction Rule;
Tips on Training, Safety, Communication
October 27, 2015
Compliance with OSHA’s new ruling on confined spaces, which began earlier this month, requires training and a thorough understanding of the sometimes-complex procedures formulated to protect employees in the workplace. During a free member webinar last week, Gary Roberts, environmental health and safety director of ShoffnerKalthoff Mechanical Electrical Service, Knoxville, Tenn., guided PHCC members through the new rule and explained how the addition of specific requirements will affect the plumbing and HVAC industries.
While many contractors are familiar with and have been following OSHA’s previous confined space requirements, the new rule – 1926.1201-1213 – provides more guidance and establishes a permit system to document that safety is being considered before, during, and after the job is completed. According to OSHA, “the rule emphasizes training, continuous worksite evaluation and communication requirements to further protect workers’ safety and health.”
The new regulation – which applies to the repair of existing facilities and not just new construction – also outlines more details about situations with a number of different employers at a worksite. OSHA estimates that its new ruling on confined spaces could reduce the average number of fatalities and injuries by 96 percent.
What steps should you take to comply? Here are key recommendations provided during the webinar:
- Training is critical. This is probably the number one requirement of the ruling. The training must be in a language and vocabulary familiar to the employee, and he or she must have the knowledge and understanding of the hazards of the confined space. Training records and dates of training must be kept and maintained.
- Test, test, test. “Buy a meter to test atmospheric conditions each time,” Roberts advised. He said it is the best way to determine if attics and crawl spaces are safe, especially in light of how often HVAC techs find themselves in these situations.
- Be proactive. If you are contracting with an emergency responder service, you must make arrangements for them to contact you if they are going to be unavailable for a period of time. Rescues involve 50 percent of all contained space fatalities. Tip: make sure your response team is capable of reaching the potential victim in your job site.
- Constantly survey and analyze confined spaces and the evolving nature of the workplace. Look ahead for the worst-case scenario.
- Make sure permits are posted and contain very specific information, such as the duration of the job, the hazardous conditions, who can enter, etc.
Check out the Q & A below for more details:
What is a confined space and a permit-required confined space?
A confined space is one that is large enough for an employee to enter it to do work but small enough to have limited or restricted ways of getting in and out. Also, to fit the definition, the space cannot be designed for continuous employee occupancy. All three of these criteria must be met in order to meet the definition. Some examples of confined spaces include boilers, manholes, pits, sewers, storm drains, HVAC ducts, storm drains, water mains, attics, crawl spaces, air receivers and chillers. An OSHA-approved set of fixed stairs typically would not be a limited means of entrance or exit, but a ladder or removable or spiral set of stairs might be. A permit-required confined space only has to have one characteristic met to qualify: hazardous atmosphere, engulfing materials, inwardly converging wall, or other serious hazards. Hazardous atmospheres may be caused by flammable gas, vapors or mists, airborne combustible dust (grain silos, for example), too much or too little oxygen, acute acting air contaminants, and other atmospheric conditions.
Roberts said carbon monoxide is a good example of a hazardous atmosphere. Being colorless and odorless, it has to be measured to make sure you stay within the acceptable range. Too much oxygen increases flammability, while an extreme loss of oxygen can cause coma, asphyxiation or impairment. The minimum acceptable oxygen level is 19.5 percent, while 4 percent to 6 percent can cause a coma in 40 seconds and lead to death. “You need to really be cognizant of that oxygen level and pay attention,” Roberts added. There are some hazards, such as a few inches of water, which are not necessarily permit-required but, combined with other hazards, such as trip or fall potential, could result in the confined space becoming a permit space. Review of the various hazards is an important part of the training needed to make decisions concerning safety.
Who is the competent person? Who are the other important players?
A competent person is someone who is trained to correctly identify the hazards (unsanitary, hazardous or dangerous) in the working space and who has the authority to either correct or eliminate the hazard immediately. An attendant is the person located outside the permit space who monitors and assesses the status of authorized entrants and performs certain duties. An authorized entrant is an employee who is authorized by the entry supervisor to enter the permit space. An entry supervisor is a qualified person such as the foreman, employer, or crew chief responsible for determining if the conditions are acceptable for entry, for authorizing entry, and for overseeing operations and possibly terminating the entry (an entry supervisor also can be an attendant or an authorized entrant if properly trained). The host employer is the employer owning or managing the property where construction work is taking place. The controlling contractor is the employer with overall responsibility at the worksite. It is possible to be a host employee and a controlling contractor.
The full ruling is available here.
For the complete webinar and answers to questions posed by participants, click here.