CONFINED SPACES IN CONSTRUCTION Useful Resources€¦ · 2/17/2016 1 CONFINED SPACES IN...
Transcript of CONFINED SPACES IN CONSTRUCTION Useful Resources€¦ · 2/17/2016 1 CONFINED SPACES IN...
2/17/2016
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CONFINED SPACES IN CONSTRUCTION
Van Henson
SC OSHA Voluntary Programs
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!!