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STANDARDS UPDATE:

US Federal OSHAProposed Rule for Confined Spaces in Construction

MSA WebCastJuly 17, 2008

Presented by:

Joseph Feldstein Manager Technical ServicesMine Safety Appliances Company

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Today’s WebCast Topic Background on the history

and need for new rulemaking

Review of Requirements Safety Equipment for

Confined Spaces Costs and Implications for

Industry Question and Answer

Session

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Background on the OSHA Proposed Confined Spaces Rule

New requirements Training, hazard analysis, classification Entering, working, exiting and rescue

History Litigation Role of the ACCSH

Need for new rulemaking Annual average of 6.44 deaths and 967

injuries

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Summary of the Proposed Standard What is a Confined

Space? Space large enough and

arranged so an employee can enter

Limited or restricted means of entry/exit

Is not designed for permanent occupancy

Examples of Confined Spaces in Construction pits tanks sewers silos turbines

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Worksite Evaluation and Coordination

Controlling Contractors and Host Employers

Information to be shared: Location of confined spaces Hazardous conditions Precautions taken to address hazards Classifications of the confined spaces

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Atmospheric Testing Test or monitor for:

Oxygen deficiency Combustible gases and

vapors Toxic gases and vapors

As necessary, based on Results of tests Regularity of entry Effectiveness of

monitoring Provide information like

MSDS

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Classifications of Confined Spaces

Continuous System Permit Required Confined Space (CS-PCRS)

Permit Required Confined Space (PCRS)

Controlled Atmosphere Confined Space (CACS)

Isolated Hazard Confined Space (IHCS)

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Continuous System Permit Required Confined Space Definition

Confined space that is part of, and contiguous with a larger confined space

Subject to release from the larger space that would overwhelm protective equipment

High risk category Example

Space contiguous to a sewer system

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Permit Required Confined Space A confined space that has:

A hazardous atmosphere Inwardly-converging,

sloping surfaces An engulfment hazard or

other physical hazard Physical Hazards

explosives mechanical, electrical,

hydraulic and pneumatic energy

radiation temperature extremes falls noise

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Controlled Atmosphere Confined Space

A confined space where ventilation alone will control its atmospheric hazard

Cannot be a CACS if it has a physical hazard (unless that hazard is isolated)

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Isolated Hazard Confined Space A confined space in

which all physical and atmospheric hazards have been isolated

Isolation includes: Blanking and binding Misaligning or removing

section of lines A double-lock-and-bleed

system Machine guarding Blocking or

disconnecting all mechanical linkages

Installing guardrails, stairs or platforms

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Classification Options

Employers can classify a confined space in any classification, so long as all of the characteristics and requirements for that classification are met

Exception is that a space with the characteristics of a CS-PRCS cannot be given a different classification

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Reassessment Whenever conditions

change, the space must be reassessed

Prior to reassessment, entrants must exit the space

No one may re-enter until hazards have been evaluated and protection has been provided

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Permit Required Confined Spaces

Identification of Hazards Isolation or other protective measures

must be provided If isolation is not feasible, then PPE may

be required Monitoring procedures are required

Detect atmospheric hazards in time for entrants to safely exit the space

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Continuous System Permit Required Confined Space

For a CS-PRCS, employers must complete all requirements for PRCS, as well as: Monitor continuously for atmospheric

hazards Monitor continuously for non-isolated

engulfment hazard using an early warning system

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Controlled Atmosphere Confined Spaces

For each physical hazard, determine and implement an isolation method

Test the atmosphere while using ventilation equipment to verify that ventilation alone can control at safe levels

Monitoring procedures must include an early warning system in the event of a ventilation failure

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Isolated Hazard Confined Spaces

Determine and implement an isolation method for each physical and atmospheric hazard

Isolate the hazards without entering the space

Verify in writing that all physical and atmospheric hazards in the space hav been isolated

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Training Training would be

required for all hazard classifications

Employees to be trained: Entry supervisors Attendants Authorized entrants Rescue Service

Employees Exit procedures Records Retraining

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Rescue from Confined Spaces Non Entry Rescue

Requires a retrieval system Harness and retrieval

line Rescue anchor point

Structural anchor Heavy equipment

(locked out or tagged out)

For retrievals involving a vertical distance over 5 ft, a mechanical retrieval device would be required

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Rescue from Confined Spaces Entry Rescue

Respond to a rescue summons in a timely manner

Have appropriate rescue plans and practice rescue operations

Entry rescue services must be provided with adequate training and equipment for the task

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Safety Equipment for Confined Spaces Equipment required in proposed

rule: Atmospheric testing and

monitoring equipment Forced-air mechanical ventilation

equipment Personal protective equipment,

such as respirators Any other equipment necessary for

safe confined space operations PPE must meet applicable OSHA

regulations Equipment must be maintained

and calibrated according to applicable OSHA requirements and manufacturers’ instructions

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Safety Equipment for Confined Spaces

Portable gas monitoring instruments Oxygen Flammable vapors Toxic gases

Continuous air monitoring instruments

Air purifying respirators and SCBA

Confined space entry and retreival equipment Tripods and anchorages Personnel hoists 3-way rescuers

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Cost Impact of the Proposed Rule

640,000 confined spaces per year 20,000 construction companies with

employees working in confined spaces Estimated annual cost of compliance is

$76.8M $11.7M atmospheric monitoring $10.0M respiratory protection $9.6M rescue capabilities $8.1M training

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Public Comment OSHA will hold public hearing on the

proposed rule in Washington DC on July 22, 2008. For further information, contact Garvin Branch, Directorate of Construction, U.S. Department of Labor, 200 Constitution Avenue, NW, Washington, DC 20210.

Copies of the proposed rule are available online at the OSHA website (http://ww.osha.gov), select "Federal Register," and "Date of Publication," (November 28, 2007).

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Schedule for Publication of the Final Rule

OMB advises OSHA no new regulations after July 2008

Second quarter 2009 is earliest expected publication of final rule

OSHA usually gives at least 90 days before rule takes effect

Much depends on comments received by OSHA on the proposed rule

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Conclusions New requirements

would be placed on construction companies for evaluating, planning, training and monitoring confined spaces

New knowledge and skills required for construction personnel

Proposed requirements for prompt rescue will favor on-site rescue teams

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Thank you for your participation!

To Contact the Presenter:

Joseph FeldsteinMSA Fall Protection2250 South Tejon StreetEnglewood, CO 80110ph: (303) 975-2304fax: (303) 934-9960email: joseph.feldstein@msanet.comwebsite: www.msanet.com