OSHA’s new confined spaces in construction standards (29 CFR 1926,
Subpart AA) became effective August 3, 2015. The date may be misleading
because OSHA has regulated work in confined spaces since 1993. There are
some differences though from the general industry rule and the new construction
rule. First, we need to discuss what a confined space is:
- Large enough for a worker to enter;
Has limited means of entry or exit;
- Not designed for continuous occupancy.
The most common examples, but not limited to, for spray foam contractors
would be attics, crawl spaces, basements, and, possibly, trailers. There
may be occasions the work may include tanks, vaults, and blending vats
like we have in our manufacturing environment.
A permit-required confined space (permit space) means a confined space
that has one or more of the following characteristics:
- Contains or has a potential to contain hazardous atmosphere;
- Contains a material that has a potential for engulfing an entrant:
- Has an internal configuration such that an entrant could be trapped or
- Contains any other recognized serious safety or health hazard.
Key differences and clarifications introduced by the new construction rule includes:
- A requirement for contractors to communicate and share vital information
at the worksite. Every construction site has to have a controlling contractor
and/or host employer to coordinate all the confined space information.
This will ensure hazards are not introduced into a confined space by workers
performing tasks outside the space.
- Requiring a competent person to evaluate the worksite and identify confined
spaces, including permit spaces, before any employee enters a confined space.
- Requiring continuous atmospheric monitoring whenever possible.
The general requirements are still the same from both rules and every confined
space program must have:
- Confined Space administrator who documents all aspects of the program;
- All permit confined spaces identified by posting danger signs;
- Inform all employees and third parties of permit confined spaces;
- Prevent non-authorized personnel from entering permit confined spaces;
- Written permit confined space program;
- Documented training to each employee.
Both rules also allow you to use an alternate procedure for entry to permit
space by ensuring:
- All physical hazards are eliminated or isolated;
- Continuous forced air ventilation controls hazardous atmosphere;
- Entrance opening guarded by railing or temporary barrier;
- Internal atmosphere tested for oxygen content, flammable gases, & air toxins;
- Documented continuous monitoring and inspection data;
- A safe method of entering and exiting the permit space;
- A posted written certification including date, location, and signature.
If all of the safety hazards cannot be eliminated or isolated, and there
is a potential for a hazardous atmosphere then all of the elements of
the permit-required program must be implemented, including these additional,
but not limited to:
- Documenting acceptable entry conditions;
- Isolating physical hazards with the permit space;
- Purging and flushing of permit space to control atmospheric hazards;
- Protecting entrants from external hazards;
- Providing trained attendant(s) outside the permit space;
- Procedure for summoning rescue and emergency services;
- Documenting the entry permits; and,
- Annual review of the permit space program and entry permits.
OSHA has delayed full enforcement of the construction standard until October
2, 2015. During this 60-day temporary enforcement period, OSHA will not
issue citations to employers who make good faith efforts to comply with
the new standard. Employers must be in compliance with either the training
requirements of the new standard or the previous general industry standard.
Technically, Demilec follows both the construction (Technical Service Representatives)
and the general industry (manufacturing) rules. If there are any conflicts
within the rules then the newly adopted construction standard takes precedence.
Confined Space rules can be confusing and open to different interpretations,
but, the bottom line is to protect employees from unforeseen hazards.
Whether in the field or back at the home office, take the time to train
employees on types of confined spaces, best application techniques, proper
PPE, and document a pre-job assessment.
Additional information or questions on this article can be directed to
John Paraskevas, Demilec’s Environmental Health & Safety Director