What You Need to Know About Confined Space Entry

The new standard places an emphasis on training, monitoring and evaluating, as well as communications requirements.
What You Need to Know About Confined Space Entry
Workers enter a 42-inch sanitary sewer. They had completed training, and conducted a thorough hazard analysis before entry. The workers used multiple ventilators, a gas monitor, a fall-protection/retrieval system, personal protective equipment, and a Confined Space Entry Permit to safely complete the job.

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On May 1, 2015, the Occupational Safety and Health Administration (OSHA) issued new standards aimed at increasing protections for construction workers in confined spaces. The new regulations went into effect in most states on Aug. 3, 2015.

The construction industry now has its own Confined Spaces Standard (29 CFR 1926, Subpart AA), which is similar to the already well-established standards that cover general industry. The new standard covers all construction employers whose employees may be subject to confined space hazards (with the exception of specialized construction activities such as excavations, underground construction, caissons, cofferdams, compressed air and diving, which are separately regulated).

This new standard differs from the General Industry Standard in that it incorporates construction-specific provisions, it reflects advances in technology, and it includes improved enforceability of the requirements. The new standard places emphasis on training, monitoring and evaluating, and communications requirements.

In 2014, two workers were asphyxiated while repairing leaks in a manhole. The second worker went down to save the first and died, which is not uncommon in confined spaces.

“In the construction industry, entering confined spaces is often necessary, but fatalities like these don’t have to happen,” says Secretary of Labor Thomas E. Perez. “This new rule will significantly improve the safety of construction workers who enter confined spaces. In fact, we estimate that it will prevent about 780 serious injuries every year.”

The Assistant Secretary of Labor for Occupational Safety and Health, Dr. David Michaels, concurs. 

“Unlike most general industry work sites, construction sites are continually evolving," Michaels says. "The number and characteristics of confined spaces change as work progresses. This (new) rule emphasizes training, continuous work site evaluation, and communication requirements to further protect worker safety and health.”

What exactly IS a Confined Space?
OSHA defines a confined space has having the following three characteristics:

  • It is large enough for a worker
  • It has limited entry and exit
  • It is not designed for continuous occupancy

The new Confined Spaces in Construction Standard — in Sec. 1926.1201(a) — provides more than 30 examples of confined spaces, and that list is not exhaustive. Common examples include bins, boilers, manholes, tanks, storm drains and air conditioning ducts.

Additionally, a confined space may also qualify as a permit required confined space (often called a “permit space”) if it presents other potential dangers, such as a hazardous atmosphere, an engulfment hazard, or other serious hazard which might impede a worker exiting the space. Other provisions apply to a permit space. For example, if an employer requires employee(s) to enter permit spaces, the employer will first be required to have a written confined space program.

How does the new standard compare to the general industry version?
OSHA identifies five differences between the new Confined Spaces in Construction Standard and the General Industry rule:

1. Multi-employer work sites — Recognizing that the construction industry often involves many different contractors and subcontractors, the rule provides for a more coordinated approach. This includes pre-entry planning including having a competent person:

  • Identify the confined spaces
  • Further identifying permit spaces
  • Evaluate potential hazards, and
  • Ensure that those hazards are eliminated or controlled

That information will be relayed to the various on-site employers whose job it is to train their respective employees, and designate which employees are authorized to enter a permit space. Another provision for permit spaces requires an attendant to be positioned outside the permit space for the duration of work being performed.

2. Ensuring that hazards are not introduced to a confined space by workers performing tasks outside the space. One example is a gasoline-powered generator running nearby, but outside, the space that causes carbon monoxide to build up inside the confined space.

3. Requiring continuous atmospheric monitoring whenever possible.

4. Requiring continuous monitoring of engulfment hazards.

5. Allowing a permit to be suspended, rather than canceled.

Three new provisions clarify existing requirements in the General Industry Standard:

1. Requiring employers to prevent worker exposure to physical hazards through elimination or control.

2. If and when an employer is relying on local emergency services, the employer should alert the emergency services of this, and ensure that the emergency services, in turn, inform the employer if something arises which would prevent them from responding to an emergency.

3. Training must be in a language and use vocabulary that is understood by the employee. If work assignment or conditions change, further training may be required.

Employers are responsible for making sure that only authorized employees enter a permit space. Employers must take effective steps to ensure that non-authorized personnel do not enter.

Further, when there is a permit space at a work site, an employer is not absolved of responsibility by NOT making a decision about whether its employees can enter the space. According to OSHA, not making a decision will be construed as tacit approval. Additionally, entering the permit space is defined as any part of a person’s body breaking the plane of an opening into the space.

Under the Occupational Safety and Health Act, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to ensure these conditions for workers by setting and enforcing standards, and providing training, education, and assistance. For more information, visit www.osha.gov.

For more about the new regulation, and compliance assistance documents and other OSHA resources, visit www.osha.gov/confinedspace/index.html.

Confined space info for sewers
OSHA has created a “Fact Sheet” (FS-3789) with information specifically for confined space hazards associated with sewer systems, and how employers can protect workers in these environments. The quick-read publication also has links to other related resources. It is available for download (a PDF file) here: www.osha.gov/Publications/OSHA3789.pdf

Thanks to OSHA and attorney Tressi L. Cordaro for information contained in this article.

About the author
David Dow is chair of the training committee of the North American Excavation Shoring Association (NAXSA) and co‑founder and vice president of TrenchSafety and Supply, Inc. NAXSA was formed in July 2014 with the core purpose of promoting the safe and effective use of excavation shoring equipment and practices. The ultimate goal of the association is zero deaths and injuries in the excavation construction industry. For more information, visit www.naxsa.com.

This article and all photos are copyright 2015 TrenchSafety and Supply, Inc. Used with permission of TrenchSafety and Supply, Inc., for this specific article.



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