OSHA S CONFINED SPACES IN CONSTRUCTION STANDARD C. Gary Lopez AJ Gallagher Risk Management
Today We Will Cover How we got where we are What the proposed standard should look like How it differs from existing GI and ANSI standards Terminology you will have to become familiar with Challenges you will have complying with the standard.
Who Am I? Spent 30 years in chemical/pharmaceutical industy Developed SWP system Developed emergency response rescue systems Sat on ANSI Z117 85 committee Worked with and in the construction industry in developing CSE
Standards Covering CFE s ANSI Z117.1 OSHA 1910.146 ANSI A10.43 (draft) OSHA 1926.1200
Standards Comparison Requirement Z117.2009 1910.146 1926.1200 A10.43 (Draft) Types of Conf. Spaces Two + One One + Two One + Two Three (Colors) Survey & Eval of CSs Yes Yes Yes per event Yes Non Permit Allowed Yes Defacto Defacto Yes Written procedure Yes Yes Copy of Std Yes Permit System Yes Yes Yes Yes Atmospheric Testing Yes Yes Yes Continous Yes Trained Entrants Only Yes Yes Yes Yes Entry Supervisor Yes Yes Yes Yes Ventilation/Decontam Yes Yes No Specifications Yes Rescue Training Yes Yes Yes Yes Written Rescue Plan Yes No No Yes Audit of Plan Yes No No Yes Audit of Permit System No No Yes No Posted Signage for CSs Yes Yes Requires Barriers and Barricades in addition Red Only Contractor Requirements Yes Yes Yes Yes (defacto)
Evolution of CFE Standards OSHA comes into existence in early 70 s with no CSE std. 1980 OSHA issues NPRM for construction CSE std..it goes nowhere. Continued CSE fatalities in early 80 s prod ANSI to re-write old standard ANSI Z117 sits down in 86, writes modern standard which is issued in 1989 (basis for updates since then) OSHA sits on 80 s ANSI committee and follows with NPRM for GI std in 89 GI Confined Space Std, 1910.146 issued in 93 United Steelworkers contest scope of standard in 93 wanting it expanded to construction OSHA agrees in settlement to develop CCSE std. OSHA confers with Advisory Committee for Construction Safety and Health (ACCSH) about acceptability of Z117 or 1910.146 adequacy as CCSE standard ACCSH informs OSHA that both Z117 and 1910.146 are not adequate for construction hazards.
Evolution of a CSE Standard 94 ACCSH puts together task force that determines construction is different and GI standard won t work 96 ACCSH submits proposed standard to OSHA OSHA determines standard needs work 98 re-writes standard and conducts stakeholder meetings 03 OSHA submits rewritten standard to SBREFA 07 OSHA issues NPRM Comments are many and critical OSHA withdraws rule and decides to re-write based on comments
What were issues with 2007 NPRM? so harshly after so much Review? Four different classes of confined space were two to many New terminology that was confusing Vagueness of who was in charge Created dilemna for employers doing maintenance and construction in same confined spaces Nightmare for the little guy Did not read clearly.
What are Some Ligitimate Differences? General Industry For evaluation purposes Confined Spaces are static and normally use does not change Question of who owns the space is clear Labelling of confined spaces easier since they are static Construction On construction sites confined spaces can evolve as part of the construction process Who is in charge of entry can become blurred depending on owner, controlling contractor, subcontractor arrangements Labelling can be difficult since entries are manholes or being built Employee workforce is more stable for training purposes Workforce is fluid, often changing by the day Permit systems are consistent since it is employer controlled Permit systems can vary due to various employers involved in entry Rescue is easier to accomplish. Planning easier with static locations, proximity and consistency of rescue team Rescue is typically accomplished by local emergency response services some of which are ill equipped or trained for the task Entry supervisor training is more easily accomplished due to fixed hazards of confined spaces Entry supervisor training is much more complex due to variance of spaces and evolving hazards in spaces
So Where are We? OSHA has reworked standard to more closely reflect existing CS standards New standard expected in fall of 2013 There will still be challenges
Let s Look at the Proposed Standard Construction Confined Space Entry
Warning Will Robinson! Some of this anticipated content could change during the final review process. So don t run home and start re-writing your entry procedures just yet!
Standard Scope 1926.1200 07 NPRM 1926.1200 13 Version Intended for Construction activities only Unchanged Not intended for: Diving Operations Trenching/Excavation Underground (cofferdams, cassions etc.) Unchanged Unchanged Unchanged Unchanged
Key Definitions 1926.1200 07 NPRM 1926.1200 13 Version A space that has the following characteristics: 1. Is large enough and so arranged that an employee can bodily enter it 2. Has limited or restricted means for entry and exit 3. Is not designed for continuous employee occupancy. Of Note: This definition does not include classic PRCS definition of including potential hazards in the confined space, that s left to you in classifying of the space in one of four categories Permit Required definition will be added that includes types of hazards
Key Definitions- Types of Confined Spaces 1926.1200 NPRM Version 1926.1200 13 Version Continuous System-Permit Required Confined Spaces (CS-PRCS) Permit Required Confined Space Permit Required Confined Spaces (PRCS) Non Permit Required Confined Space Controlled Atmosphere Confined Spaces (CACS) No Similar Category Isolated Hazard Confined Space (IHCS). No Similar Category
NPRM Definitions Continuous System- Permit Required Confined Spaces (CS-PRCS)- This is a confined space that is part of or contiguous to a larger confined space from which the employer can not isolate the hazards. An example of this would be a live sanitary or storm sewer system. The implication is that in this type of confined space the sudden and dangerous release of a potential hazard is beyond the employers control and could result in a situation immediately dangerous to life and health. Permit Required Confined Space (PRCS)- Although similar in name to the General Industry and ANSI definition it is a different type of space. It is a confined space that ventilation alone will not control the risks to acceptable levels. Also in this space there are potential physical hazards such as engulfment, sloping/tapering surfaces, or other physical hazards. The key is that there are more then atmospheric hazards present, consequently ventilation alone is not an adequate precaution Controlled Atmosphere Confined Space (CACS)- This is the type of confined space that can be controlled by ventilation engineering controls. In effect this type of confined space is one in which no physical hazards are present or could be potentially present. This is a confined space dealing mainly with atmospheric hazards. If physical hazards are present and have been isolated you can classify the confined space in this category. Isolation methods must also be consistent with those outlined in the ANSI Z117 standard ie double block and bleed, linebreaking, blanking/blinding, lockout, mechanical blocking. Isolated Hazard Confined Space (IHCS)- This is a confined space in which the employer has isolated all physical and atmospheric hazards. Isolated means the removal or control of the potential or real hazards. Isolation methods must be in line with ANSI Z117 definitions such as blanking, blinding, double block & bleed, lockout/tagout or disconnecting mechanical linkages.
Key Definitions 1926.1200 NPRM Version 1926.1200 13 Version Host Employer -Owns or Manages the property at which the CSE is taking place, (note: Host Employer can also be the Controlling Contractor if the Host also acts as the GC) Unchanged Controlling Contractor -The GC, the contractor who has overall responsibility for construction on the site Could become General Contractor Contractor -Employer who has employees engaged in construction and is neither a controlling contractor or host employer Unchanged Authorized Entrant An employee who has received training in confined space entry Unchanged Entry Supervisor- A member of management who is qualified to approve a PRCS entry. Unchanged
Worksite Evaluation
Work Site Evaluation Host Employers & Controlling Contractors must evaluate the work site, and share four pieces of info: 1. Location of CS s on site 2. Hazardous conditions affecting the CS s 3. Classification of CS s 4. Any precautions or procedures that either the Host Employer or Controlling Contractor had previously used to enter the CS s Of note, in NPRM the Host Employer s or Controlling Contractor s are not required to provide information they are not aware of regarding the confined space.
Work Site Evaluation-Employer Duties The Contractor with Entrants (the Employer) must determine if there are confined spaces and if the spaces are subject to any hazards by: 1. Use of HE or CC information regarding the space and the hazards present 2. Inspection of the confined space if information from HE or CC is not sufficient 3. Conducting of atmospheric testing without the benefit of mechanical ventilation in place 4. Ensuring entrants are properly trained in use of PPE, entry requirements, rescue and other pertinent duties.
Coordinating Entry Activities
Use of Entry Permits Entry Permits may only be completed by Qualified Entry Supervisors The Entry Supervisor must fill out the permit, noting the hazards present in the confined space and the precautions that must be put in place to address such hazards Once precautions are in place the Entry Supervisor will sign off on the permit and post it at the entry site.
Entry Requirements that should be noted on an Entry Permit Place and date of entry Potential hazards noted Atmospheric Testing Results PPE that will be required Barricades or barrier types required at the entry point Mechanical ventilation required Method of safe access to the Confined Space Special illumination requirements for the Confined Space Rescue Requirements Names of entrants
Other Requirements Must barricade off spaces that are being entered Must provide a safe means of entering and exiting the confined space Must provide proper illumination once you are in the confined space Must provide continous atmospheric monitoring when you are in the confined space
Reassessement of a Confined Space The Entry Supervisor must reassess the confined space if: Conditions change within the confined space The configuration of the confined space changes New work tasks will be introduced into the confined space New entrants will be introduced into the confined space.
The Players
Entry Supervisor Must be at least one Entry Supervisor assigned to a site with confined spaces Entry Supervisor must be Qualified Qualified means he understands the potential hazards of confined spaces, how hazards affect or enter the body, recognizes symptoms of exposure, how to conduct atmospheric testing, how to fill out an entry permit, verifies rescue procedure and has the authority to sign off on the permit.
Attendants Commonly referred to as Safety Watch or Man Watch Must have communication with entrants Must have communication with rescue team Must be trained in duties Must be trained to recognize onset of hazards One per entry unless equipped with specialized tools to allow monitoring of multiple entries, i.e. video or other electronic equipment that provides feedback on confined space and allows for summoning of rescue team.
Authorized Entrants Must designate who the entrants are for each confined space Must be trained in hazards of space, Must be trained in signs and symptoms of hazards increasing in the space.
Training
Confined Space Training- General The CC must insure that employees entering or near CS s are trained in duties specific to what they will be expected to do i.e. entry supervisors, attendants, authorized entrants and rescue Training must be prior to entries Training records must be maintained for each employee Records must : 1. Show the employee accomplished training requirements 2. Contain the employees name, name of trainers and dates of training Retraining- employers must retrain employees who deviated from correct PRCS procedures or do not have adequate skills to conduct safety entries.
Training-Rescue Only rescue trained individuals may take part in a rescue Rescue must be on a timely basis Rescue team should have practiced simulated rescue Before entry employer should inform rescue team of physical or atmospheric hazards in the CS.
Training- Entry Supervisor Shall be trained on how to fill out Entry Permits How to recognize hazards in a confined space How to apply precautions to address identified hazards How to recognize the limitations of precautions applied to address hazards How to formulate a proper rescue plan How to read atmospherice monitoring results Understand terms such as IDLH and PEL s as applied to entries.
Training-Entrants Shall be trained on the dangers of confined space entry Shall be trained in the use of PPE required in confined spaces Shall be trained on atmospherice hazards Shall be trained on unique exposures that could be encountered in entries.
Training- Attendants Must be trained to never leave the confined space while on duty Must be trained to be in constant communication with entrants Must be trained to recognize deteriorating conditions in a confined space Must be trained how to summon aid in the event of an emergency Must be trained never to enter the confined space to perform a rescue.
Where Are We Headed?
Challenges Clarifying Ownership, including use of GI or Owner or Construction standard during entry Who s permit system to use Rescue Ensuring training of entrants Ensuring the quality of training of Entry Supervisors Enforcing use in the field.
The Gary Lopez One Sentence CSE Standard Complete a permit for all entries and take atmospheric air tests.
Lives Can be Saved by What you do Next!
Questions?