Tool Box Talk. Confined Space Entry New Construction Standard (2015)

Transcription

1 Confined Space Entry New Construction Standard (2015) What s all this about Confined Space Entry and how does it affect the construction industry? On May 4, 2015 the Occupation Safety and Health Administration (OSHA) published its final rule regarding confined space entry, as it pertains to the construction industry, in the federal register. A new subpart has been created within 29CFR1926 which will directly address the hazards of confined space entry, attendance and permit writing, specifically focusing on the construction industry. The new standard shares much of its language with the existing general industry standard with several important differences which are outlined in this document. What is the purpose of the Confined Space Entry Standard? The Confined Space Entry standard is organized so as to prevent accidents, injuries and fatalities during entry into confined spaces. OSHA defines a confined space as a space which meets each of the following criteria: Large enough and so configured that an employee can bodily enter and perform assigned work, has limited or restricted means of entry or exit and is not designed for continuous occupancy. OSHA has created a new standard, including construction industry specific provisions to directly address the specific hazards and conditions that do/may affect workers entering confined spaces in the construction industry. This revision has manifested as 29CFR1926 subpart AA. How will this revision affect my organization and our existing operations? The new standard will go into effect August 3, OSHA has granted a sixty (60) day temporary enforcement grace period during which no citations will be issued under the new standard. The standard will go into full effect October 2, These considerations have been made to give organizations more time to develop policies, training and familiarity with the new standard. Existing confined space operations, policies, procedures and equipment will need to be reviewed and revised to meet the requirements of the new standard. Employers must retrain their employees to the requirements of the new standard. What are the major changes I need to be aware of? Several major changes have been made to the old standard, which address the challenges of the construction industry: OSHA has imposed specific requirements for confined spaces where multiple employers may enter the space. Among these requirements are responsibilities for the posting of proper signage by the controlling contractor, prevention of the introduction of new confined space hazards by another employer working in or around the space(s) in question, and a requirement for reevaluation and/or reclassification of a confined space when any changes to conditions, configuration or any other potentially risk causing factors are present. Subpart AA requires that all employers seeking to enter a confined space have a competent person evaluate the space(s) in which employees it directs may work, and requires a two-step process for the evaluation: (1) The competent person must evaluate whether a space meets the definition of a confined space, and if so, (2) the competent person must identify, in accordance with other provisions of this final rule, any confined spaces that are permit required confined spaces through consideration and evaluation of the space, including testing of the space as necessary. The final rule specifies both the two-step approach and the competent-person requirement more explicitly than in the general industry standard. OSHA added this provision following the commenting period during which several commenters raised concerns that the determination of a permit vs. non permit required confined space requires some degree of familiarity or expertise with the standard itself. (see general requirements ) Page 1 of 5

2 The new standard contains language pertaining to air quality monitoring which differs from the general industry standard. The new construction standard requires continuous air monitoring be used whenever possible during confined space entry. The new standard states that employers must ensure their monitoring methods give ample warning for safe exit from the space. It is the responsibility of the employer to factor safe exit into the choice of monitoring methods and equipment ( (e)(1). The new standard will require continuous monitoring of any identified engulfment hazards either via remote means (sensors), physical means (lock out / tag out, double block & bleed etc.) or through the use of an attendant who will monitor non-isolated or eliminated engulfment hazards inside the space while work is being done. As part of the revision process for subpart AA, OSHA added a provision to allow for the suspension of a permit required confined space permit in lieu of cancellation should the conditions in a permit required confined space return to the previously acceptable entry conditions outlined within the original permit. A full reassessment of the evacuated space must be completed prior to re-entry however; the employer may retain the original permit so long as the event which required evacuation is recorded on the permit itself. This provision as added to remove the burden of fully canceling and reissuing a permit for the same space in a short period of time. The cancelation provision may be found under 29CFR (e). When will all this happen? The changes will happen over the next 2 months. The new standard does not contain any provisions for phasing in the new regulatory requirements. A 60 day grace period has been granted by OSHA prior to regular enforcement of the standard. May 4, 2015 OSHA released the final rule pertaining to confined spaces in the construction industry August 3, CFR will go into effect under a sixty (60) day discretionary grace period October 2, 2015 Regular enforcement of the new subpart will go into effect. All policies, procedures and training must be updated to reflect the criteria requirements of the new standard. During the 60 day grace period, employers may comply with the existing standard, the revised standard, or both while showing they are working toward compliance with the new standard. Why do we have to complete the training now? Employers are required to train employees before they may enter, attend to, or write permits for confined space entry. The new standard maintains this requirement. The changes and differences between this new standard and the old standard will require retraining of all affected employees. Per : The employer must provide training to each employee whose work is regulated by this standard, at no cost to the employee, and ensure that the employee possesses the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this standard. This training must result in an understanding of the hazards in the permit space and the methods used to isolate, control or in other ways protect employees from these hazards, and for those employees not authorized to perform entry rescues, in the dangers of attempting such rescues Page 2 of 5

3 Is my company required to have a confined space program? Yes, if employees enter confined spaces, the company must have a program. This program must outline the requirements for continuous atmospheric/engulfment monitoring. If employees are not allowed to enter permit spaces then the company does not need to have a program but must prevent their employees from entering spaces. Note: Employers are required to review their confined space program, referencing canceled permits for each entry within one year of each permit required confined space entry. Employers must make revisions to their permit required confined space entry program as necessary to ensure that employees participating in entry operations are protected from permit space hazards. Employers may complete a single yearly audit, covering all entries from the previous year. If no entries occurred in the previous year, no review is necessary. See (n). Do I have to be trained to enter a confined space? Yes. Workers must be trained to the level of their entry duties. This can include duties of the entrant, attendant, entry supervisor, and rescue. Often a worker is trained on all of these roles. It is important to note that contractors that enter confined spaces must be trained also. There are two types of confined spaces: "Non-permit confined space" means a confined space that does not contain or, with respect to atmospheric hazards, have the potential to contain any hazard capable of causing death or serious physical harm. "Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics: 1. Contains or has a potential to contain a hazardous atmosphere; 2. Contains a material that has the potential for engulfing an entrant; 3. 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 4. Contains any other recognized serious safety or health hazard. If certain conditions are met, it may be possible to make a permit required confined space a non-permit required confined space under alternate entry procedures or to reclassify the space to a non-permit confined space. The use of alternate entry procedures or reclassification must follow the alternate entry or reclassification criteria, which may be found listed under (e) and (g).. What are some of the hazards in confined spaces? The hazards associated with confined spaces and permit required confined spaces vary and are the result of individual conditions associated with that particular space. The hazards encountered when entering and working in / around confined spaces are capable of causing bodily injury, illness, and death to a worker. It should always be considered that the most unfavorable situation exists in every permit required space until proven otherwise. Some of the most common hazards that must be considered before entry for work are: Atmospheric Hazards Oxygen Deficient Atmospheres (O2) % or less Oxygen Enriched Atmospheres (O2) 23.5 % or greater Flammable Atmospheres 10% Lower Explosive Limit (LEL) or more Toxic Atmospheres Carbon Monoxide (CO) 25ppm 35ppm or more Toxic Atmospheres Hydrogen Sulfide (H2S) 10ppm or more Others Page 3 of 5

4 Physical Hazards Engulfment Mechanical Hazards Electrical Hazards Excessive Noise Excessive Vibration Excessive Thermal Effects Height (falls) Configuration Hazards (such as baffles, tunnels, collapsed areas) Others What does Acceptable Entry Conditions mean? "Acceptable entry conditions" means the conditions that must exist in a permit space, before an employee may enter that space, to ensure that employees can safely enter into, and safely work within, the space. ( Definitions) What does Isolating the Permit Required Confined Space mean? "Isolation" means the process by which a permit space is removed from service and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tag out of all sources of energy; blocking or disconnecting all mechanical linkages; Purging, inerting, flushing, or ventilating the permit space as necessary to eliminate or control atmospheric hazards; o Note paragraph 1204(c)(4): When an employer is unable to reduce the atmosphere below 10 percent LFL, the employer may only enter if the employer inerts the space so as to render the entire atmosphere in the space noncombustible, and the employees use PPE to address any other atmospheric hazards (such as oxygen deficiency), and the employer eliminates or isolates all physical hazards in the space. Subpart AA also requires employers to develop and implement the means, procedures, and practices necessary for safe permit entry operations, including: o Determining that, in the even the ventilation system stops working, the monitoring procedures will detect an increase in atmospheric hazard levels in sufficient time for the entrants to safely exit the permit space; o Provide pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards; o Verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry, and ensuring that employees are not allowed to enter into, or remain in, a permit space with a hazardous atmosphere unless the employer can demonstrate that personal protective equipment (PPE) will provide effective protection for each employee in the permit space and provides the appropriate PPE to each employee; and o Eliminating any conditions (for example, high pressure) that could make it unsafe to remove an entrance cover. Page 4 of 5

5 Is atmospheric testing important? It is important that the atmosphere of the confined space is tested before any entry. Subpart AA encourages continuous atmospheric monitoring in confined spaces whenever feasible unless the employer can prove sufficient equipment is commercially unavailable or periodic testing is sufficient for the specific application. Several different types of devices can be used for testing. When testing for atmospheric hazards, test first for oxygen, then for combustible gases and vapors, and then for toxic gases and vapors. Most automated monitors will test in this order by design. Testing of the space should begin at the entry point and cover as many areas of the space as possible. The configuration of certain spaces can cause contaminates, gases, and other atmospheric hazards to pocket, rise when they should fall, and a host of other oddities. If sludge, water, or other materials are accumulated in the space be aware that once disturbed these items can immediately and dramatically change air readings in the space. If combustible dust is present, visual inspections must be performed. Vision obscured at approximately 5 feet indicates a non-entry condition for spaces that contain combustible dusts. Monitors must be well maintained, calibrated and capable of running continuously. All calibrations should follow manufactures instructions. A bump test should be performed in the field before use. It is important to familiarize yourself with your monitors. This takes practice and requires using the monitor as much as possible. Page 5 of 5