Lessons from a Deep, Dark Confined Space: A Case Study and A Brief on the New Construction Standard

Transcription

1 Lessons from a Deep, Dark Confined Space: A Case Study and A Brief on the New Construction Standard Presented by Sally K. Miller, CIH and Patrick Walz, PE AECOM September 17, 2015

2 Confined Spaces in Construction: OSHA s Final Rule History and Timeline of the Final Standard Construction Standard Overview Main Differences between the General Industry and Construction Standards Effect on Other OSHA Standards Minor Differences, Subtle Effects and Nuanced Interpretations

3 History and Timeline 29 CFR 1926, Subpart AA: Confined Spaces in Construction 1979: Const. CSE Training Provision issued OSHA agreed to propose Const. CSE Std. 2007: Proposed Const. CSE Rule published Aug. 3, 2015: Rule effective, but extension granted 1993: Gen. Ind. CSE Std issued 2003: Draft Const. Std. developed May 4, 2015: Final Rule published Oct. 3, 2015: Const. CSE Std. EFFECTIVE

4 Confined Spaces in Construction 29 CFR 1926, Subpart AA Scope Definitions General Requirements Permit Required Confined Space Program Permitting Process Entry Permit Training Entrants Attendants Entry Supervisors Rescue Employee Participation Provision of Documents

5 General Industry vs. Construction? Final Construction Confined Space Standard = General Industry Confined Space Standard Plus

6 Construction CS Standard: Overview What is a confined space? Large enough to enter Limited or restricted means for entryand exit Not designed for continuous employee occupancy Examples in Construction: Tanks, bins, boilers, vaults, sewers, elevator pits, manholes, crawl spaces, attics

7 Construction CS Standard: Overview What is a PermitSpace? A confined space with one or more of the following: Contains or has potential to contain hazardous atmosphere Contains engulfment hazard Configured so as to pose entrapment or asphyxiation risk Contains any other recognized serious hazard

8 Construction CS Standard: Overview What does the Employer need to do? Competent person must identify CS and evaluate Are they Permit Spaces? Decide if your employees will enter permit spaces If no, must take steps to prevent your employees from entering If yes, employer becomes Entry Employer Post DANGER signs to inform all on site Develop and post permits for entrants

9 Construction CS Standard: Overview Entry Employer must develop Permit Space Program Plans for training for exposed employees, attendants, entrants & entry supervisors; also rescuers Plans for elimination or isolation of physical hazards Plans for testing, monitoring and ventilating Determination of required PPE Plans for rescue and summoning emergency help Annual program review

10 Confined Spaces in Construction: What s Different? Continuousmonitoring of atmospheric required Early-warning system for engulfment hazards required Emergency responders required to agree to notify employer if they are unavailable

11 Confined Spaces in Construction: Multi-Employer Worksites Specific information exchange for multiemployer worksites required Host Employer Owns or manages property Controlling Contractor Has overall responsibility for construction at site Entry Employer One who decides that an employee it directswill enter a permit space

12 Confined Spaces in Construction Information Exchange Host Employer Pre-Entry Post-Entry Controlling Contractor Pre-Entry Post-Entry Pre-Entry Post-Entry Entry Employer Coordinate during entry Subcontractor

13 Confined Spaces in Construction: What s Different? Alternate Procedures: It s now allowable to prevent exposure to physical hazards through isolation (not just elimination) Permits may be suspended (instead of cancelled) in response to temporary changes If you re doing both construction and maintenance, follow Construction Standard

14 Confined Spaces in Construction: Effect on Other Standards Rule does replace any other construction standard (except old CS standard) Subpart V-Power Transmission, Generation & Distribution Now requires compliance with Subpart AA Enclosed Space -one designed for periodic employee entry under normal conditions Do hazards interfere with escape? What is a normal atmosphere in the space?

15 Confined Spaces in Construction: Effect on Other Standards Explicitly excluded from the rule: Subpart Y -Diving Subpart P -Excavation Subpart S -Underground Construction, Caissons, Cofferdams OSHA taking this opportunity to clarify scope of Subparts P and S Key question is: Excavation vs. non-excavation work?

16 Home construction is NOT exempted Other Exemptions? Crawl spaces, basements, cabinets, etc., are notinherently free of atmospheric or physical hazards But, in new construction, employers should organize work practices to avoid placing workers in confined spaces

17 Clarifications in Subpart AA Controlling a hazard An action that reducesthe hazard level in the space Isolating a hazard Process used to completely protect entrants from the release of energy or other hazard into the space Eliminating the hazard Removing the hazard from the space completely

18 Clarifications in Subpart AA Limited or restricted means for entry or exit Applies when an entrant s ability to escape in an emergency would be hindered Includes trip hazards, poor lighting, slippery floors, inclining surfaces, ladders and even stairs -if they impede egress

19 Clarifications in Subpart AA Noise is a physical hazard Will only trigger permit space procedures if it reaches a level at which it can cause death or serious physical damage In other words, if it is loud enough to interfere with critical communication Can address in permit program by using nonauditory cues (flashing lights)

20 Clarifications in Subpart AA Training must be in the language and vocabulary that employees can understand

21 Confined Spaces in Construction OSHA s Final Rule: Summary Numerous clarifications plus 5 key differences: Employers on site must coordinate activities Competent person must evaluate site Employers must conduct continuous air monitoring Employers must conduct continuous monitoring of engulfment hazards Employers can suspend a permit for temporary changes

22 Lessons from a Deep, Dark Confined Space: Amistad Dam Case Study Background Scope: Penstock Inspection Pre-Task Planning Hazard Identification Hazard Mitigation Implementation and Change Management Lessons Learned September 17, 2015

23 Amistad Dam: Background Constructed by International Boundary Water Commission (Joint US/Mexico agency that controls the Rio Grande) in 1969 Located 12 miles northwest of Del Rio, Texas MS14 September 17, 2015

24 Slide 23 MS14 Shoulde this say "via vertical gate shafts"? Miller, Sally, 9/13/2015

25 Amistad Dam: Background Penstock connects reservoir to power generating stations ~12-foot diameter circular tunnel Located 200 feet below dam deck, 150 feet below reservoir level Significant side slope degrees Only access points from downstream (requires SCUBA) or vertically via gate MS13 shafts September 17, 2015

26 Slide 24 MS13 Shoulde this say "via vertical gate shafts"? Miller, Sally, 9/13/2015

27 September 17, 2015 Insert dam surface photos

28 Scope: Penstock Inspection Damage to penstock rendered it ineffective; IBWC desired design to permanently plug the penstock Required personnel to enter in order to inspect and document current conditions of steel and concrete Use instruments (electrodes and other sensors) and collect chip samples of concrete and steel Sounds simple, right? September 17, 2015

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30 Pre-Task Planning: Hazard Identification & Evaluation Lockout/Tagout of gate Unsophisticated safety protocols on-site September 17, 2015

31 Hazard Identification Confined-Space entry Engulfment (from upstream) Drowning (if slide downstream) Very slow retrieval from space Isolated work site September 17, 2015

32 Pre-Task Planning: Hazard Mitigation Developing Lockout/Tagout protocols Designing back-up engineering control for steel gate suspension by structural engineer (use of I-Beams) Below each beam is two 2 x12 boards (8 ft long) Beams secured via webbing to handrail and column. Tied with a clover knot. September 17, 2015

33 Pre-Task Planning: Hazard Mitigation Hiring qualified subcontractor to design fall protection system and confined space rescue protocol September 17, 2015

34 Pre-Task Planning: Hazard Mitigation Developing a comprehensive Entry Permit, HASP & Contingency/Rescue Plan, reviewed at highest levels of organization s Safety management team Performing safety inspection and practice run prior to actual entry September 17, 2015

35 HASP Development/Review took approximately 100 person-hours, compared to approximately 45 person- hours for the actual inspection. September 17, 2015

36 Implementation & Change Management LOTO procedures implemented. Engineering controls (beams) required modification; required concurrence from structural engineer before proceeding. September 17, 2015

37 Implementation & Change Management Fall protection/rescue zone establishment Practice run indicates extraction is too slow for comfort AECOM personnel trained to assist with lift (pulling ropes) during rescue September 17, 2015

38 Implementation & Change Management Air quality checks (probe dropped from surface) find conditions in penstock ideal. Safety inspection finds no odors, relatively good traction, comfortable temperature, little mud, good setup by subcontractor. September 17, 2015

39 Implementation & Change Management Scaffold tie-offs insufficient and improved prior to inspection. Inspection completed 8 hours without incident. Project scope successful. AECOM awarded additional work. September 17, 2015

40 Lessons Learned Pre-Task Planning crucial; short-duration projects are no exception Client procedures Trust, but Verify! Staff projects for safety: Employee expertise, experience & comfort level (fear of heights, claustrophobia) Subcontractor expertise and flexibility Teamwork! September 17, 2015

41 Thank you! Sally K. Miller, CIH AECOM Denver, CO Patrick Walz, PE AECOM Austin, TX

42 September 17, 2015 Questions?