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New OSHA Standard 1926 Part AA – Confined Space Safety for Construction Sector

IES STATEMENT:
OSHA CONSTRUCTION STANDARD 1926 SUB PART AA

EFFECTIVE August 3, 2015

In May 2015, OSHA adopted regulations creating new safety standards and requirements for construction projects related to confined spaces. These requirements affect both owners and contractors of construction projects. The regulations went into effect August 3rd, with limited enforcement until October 2nd if parties adhere to certain minimum standards. We encourage project owners, safety managers and planners to familiarize themselves with the interim and final requirements.

Sub Part AA of OSHA 1926 provides requirements for protecting workers on construction sites from potential hazards involving enclosed and confined spaces.

Having provided Confined Space Rescue services for over a  decade,  IES is uniquely qualified to provide Rescue Services and Training to safeguard construction sites involving Confined Space Entry. IES offers assistance with Confined Space Program development, training, as well as confined space site evaluation and site-based consultations.

Similar to long-held practices regarding Industrial Sector Confined Space conditions, this standard focuses rather on specific applications across many sectors with respect to work environments found in and around construction sites. Examples of confined spaces on a construction site may include, but are not limited to: manholes, sewer systems, storm water drains, water mains, crawl spaces, attics, heating, ventilation, and air-conditioning (HVAC) ducts, and pits.

Here are several links to reference assets that offer details into the application of 1926, Part AA regarding Confined Space Entry, Safety and Rescue in the Construction Sector.

OSHA_1926_Part_AA

IES_NAHB_Brief

NAHB_1926-PartAA_Original

 

NAHB Logo

BRIEF:

National Association of Home Builders … Labor, Safety & Health Policy

Overview of the OSHA Confined Spaces in Construction Final Rule

 

On May 4, 2015 the U.S. Occupational Safety and Health Administration (OSHA) issued the Final Rule on Confined Spaces in Construction. Confined spaces, such as manholes, tanks, or sewers are work areas that are not designed for continuous occupancy and may be difficult to exit in the event of an emergency. OSHA has determined that this new standard (Subpart AA of 29 CFR 1926) will help prevent construction workers from being hurt or killed by eliminating and isolating hazards in confined spaces at construction sites and is expected to prevent eight fatalities and 812 non-fatal injuries each year.

The requirements of this rule will become effective Aug. 3, 2015.

Similar, but different …

A confined space has

  • Limited means of entry and/or exit
  • Is large enough for a worker to enter it
  • Is not intended for regular or continuous occupancy

Similar to long-held practices regarding Industrial Sector Confined Space conditions, this standard focuses rather on specific construction activities across may sectors with respect to work environments found in and around construction sites including civil, architectural and home building projects. Examples of confined spaces in home building may include, but are not limited to: manholes, sewer systems, storm water drains, water mains, crawl spaces, attics, heating, ventilation, and air-conditioning (HVAC) ducts, and pits.

A permit-required confined space (permit space) has one or more of the following characteristics:

  • Contains or has a potential to contain a hazardous atmosphere
  • Contains a material that has the potential for engulfing an entrant
  • Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section
  • Contains any other recognized serious safety or health hazard

 

Who are you?

Host Employer … Controlling Contractor … Entry Employer

  • The Host Employer is the employer that owns or manages the property where the construction work is taking place.
  • The Controlling Contractor (i.e., general contractor) is the employer that has overall responsibility for construction at the worksite. The rule makes the controlling contractor the primary point of contact for information about permit spaces at the work site.
  • The Entry Employer is the employer whose employees enter a permit-required confined space.

NOTE: If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer.

The Controlling Contractor is required to:

  • Pass information—if available—about permit confined spaces at the worksite (i.e., location of permit space, hazards in each space, precautions previously taken when working in the space) to the employers whose employees will enter the spaces (entry employers). Likewise, entry employers must give the controlling contractor information about their entry program and hazards they encounter in the space, and the controlling contractor passes that information on to other entry employers. See Figure 1
  • Make sure employers outside a space know not to create hazards in the space, and that entry employers working in a space at the same time do not create hazards for one another’s workers. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.

 

Host Employer Provisions include …

  • Providing that a Competent person onsite who will inspect and define all confined spaces on property
  • Provide Notification & Signage for personnel to make easy identification of confined space hazards
  • Assure that a written CFR program is in place addressing the means, procedures and practices to eliminate or control hazards necessary for safe permit space entry operations
  • Maintenance of a Permitting program including archiving of all cancelled permits for one year
  • Provision of Employee Training with respect to safe entry practices and dangers of entry into confined spaces for non-entry personnel
  • Necessary equipment & training for safe confined space entry
  • Evaluating Permit Space conditions including Engulfment Hazards

 

Confined Space “Entry Team” Assignments

Authorized Entrants, Duties & Requirements:

  • Know and understand space hazards, including information on the means of exposure such as inhalation or dermal absorption, signs of symptoms and consequences of the exposure
  • Use equipment properly
  • Maintain communication with attendants as necessary to enable them to monitor the entrant’s status and alert the entrant to evacuate when necessary
  • Alert the attendant when a prohibited condition exists or when warning signs or symptoms of exposure exist
  • Exit from the permit space as quickly as possible when:
  • Ordered by the attendant or entry supervisor
  • There is a warning sign or symptom of a dangerous situation
  • A prohibited condition exists
  • An evacuation alarm is activated

 

Attendant, Duties & Requirements:

  • Remain outside the permit space during entry operations unless relieved by another authorized attendant
  • Perform non-entry rescues when specified by the employer’s rescue procedure
  • Know existing and potential hazards, including information on the mode of exposure, signs or symptoms, consequences and physiological and behavioral effects
  • Maintain communication with and keep an accurate account of those workers entering the permit space
  • Order evacuation of the permit space when:
  • A prohibited condition exists
  • A worker shows signs of physiological or behavioral effects of hazard exposure
  • An emergency outside the confined space exists
  • The attendant cannot effectively and safely perform required duties
  • Summon rescue and other services during an emergency
  • Ensure that unauthorized people stay away from permit spaces or exit immediately if they have entered the permit space
  • Inform authorized entrants and the entry supervisor if any unauthorized person enters the permit space
  • Perform no other duties that interfere with the attendant’s primary duties

 

Entry Supervisor, Duties & Requirements:

  • Know space hazards including information on the mode of exposure, signs or symptoms and consequences
  • Verify emergency plans and specified entry conditions such as permits, tests, procedures and equipment before allowing entry
  • Terminate entry and cancel or suspend permits when entry operations are completed or if a new condition exists
  • Verify that rescue services are available and that the means for summoning them are operable
  • Take appropriate measures to remove unauthorized entrants
  • Ensure that entry operations remain consistent with the entry permit and that acceptable entry conditions are maintained

 

It’s up to you …

Emergencies and Rescue

Employers must ensure that responders are capable of responding to an emergency in a timely manner. There are several options for responding to emergencies:

  • Employers must provide capable rescue and emergency services. Rescue service personnel must be properly equipped and trained to to perform rescue duties.
  • If considering local rescue and emergency services, employers must evaluate the rescue capabilities and timeliness to respond.

 

* As a contracted Rescue Provider, IES can provide exemplary services where and when needed in a cost efficient manner

More information on OSHA’s Final Rule on Confined Spaces in Construction can be found at https://www.osha.gov/confinedspaces/index.html

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