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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: [email protected]: www.msanet.com
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