READER QUESTION:
Is a new construction manhole considered a permit required confined space with the following activities being performed inside the space: overhead rigging, cutting welding, working off of six foot (6') step ladders? The task being performed is installation of new steam and condensate piping. Entry into the manhole vault is through a thirty six inch (36") round manhole opening into a vault. The vault is sixteen feet (16') deep. Entry is made by descending a twenty foot (20') extension ladder placed into the manhole opening. No other entry holes or exit holes. A 2000 cfm air mover is also in use for ventilation of the space. The area inside is congested with piping and valves being installed. Would this be considered a permit required confined space and would a rescue team be required?

ROCO TECH PANEL RESPONSE:
The answer to this question is complicated, and without actually seeing the space and without having familiarity of all the specifics surrounding the construction of the space, we cannot give you a definitive answer. However, there are several things you must consider when evaluating the situation.

You must determine whether the space falls under General Industry (29 CFR 1910) or Construction (29 CFR 1926) requirements. If the work is considered “maintenance,” the General Industry standards are applicable. If it is considered “Construction,” the Construction standards are applicable. OSHA generally considers any work that entails “keeping equipment in its existing state, i.e. preventing its failure or decline,” as “maintenance” work covered by the General Industry standard, even if the work is construction “type” work. 

From your description, it appears that the installation of new steam and condensate piping is part of the initial “construction” of the vault. However, other factors could affect that determination, such as whether the new steam and condensate lines are actually part of maintenance of an already existing piece of equipment. In that case, the vault itself may be new, but the work on the lines might be maintenance. 

If the General Industry standard applies, OSHA takes the position that the PRCS standard (29 CFR 1910.146) does not apply to welding, cutting, and brazing activities as long as the hazards introduced by the welding are the only hazards in the space, and the protective measures of Subpart Q - Welding, Cutting and Brazing, are adequate to prevent a hazard from developing. 

The protective measures of the welding standard would be applicable to the work in this space, specifically the following paragraphs of Subpart Q: 1910.252(a)(4)(i), 1910.252(b)(4)(i) to 1910.252(b)(4)(vii), 1910.252(c)(4), 1910.252(c)(9), and 1910.252(c)(10). All other hazards must be considered when making the determination of whether the PRCS standard applies. For example, if piping or other equipment will be lowered into the vault from overhead while workers are in the space, there would be a potential physical hazard not covered by Subpart Q that might require the space to be classified as a PRCS.

The General Industry standard for welding, cutting, and brazing activities does have certain requirements that are similar to some of the PRCS requirements. 

For example, it requires that where a welder enters a confined space through a manhole or other small opening means shall be provided for "quickly" removing him in case of an emergency. If harnesses or "safety belts" are used for this purpose, they have to be attached so that the welder's body cannot be jammed in a small exit opening. It also requires that "an attendant with a preplanned rescue procedure shall be stationed outside to observe the welder at all times and be capable of putting rescue operations into effect."

The General Industry welding standard also has certain specific ventilation requirements for spaces that are less than 10,000 cubic ft per welder, or in confined spaces where there are partitions or other obstructions that would obstruct cross ventilation. The minimum rate for such ventilation is 2,000 cfm per welder. It is important to keep in mind that the 2,000 cfm per welder is the actual air movement provided by the air mover, not the rated air movement. The ventilation must be configured to ensure that the air mover is not recirculating contaminated air back into the space. This would usually involve moving the air mover away from the entry point when there is a single opening, and ducting the air into the space. However, the use of ducting reduces the actual air movement. For example, an air mover rated at 2,000 cfm maximum will not actually be moving 2,000 cfm with 50’ of ducting having a 90 turn into the space. Each foot of ducting and each turn in the ducting reduces airflow. You stated that a 2,000 cfm air mover is being used. It is important to conduct the calculations for your ventilation configuration to determine whether you are actually moving the minimum 2,000 cfm. 

Until OSHA issues its final rule on confined space safety for the construction industry (ruling is expected in 2013), there is no detailed standard at this time. However there is a construction standard for welding that has specific requirements for welding, cutting, and brazing in confined spaces (29 CFR 1926.353). The rescue requirements are the same as for the General Industry welding standard. Additionally, the Construction welding standard requires that if sufficient ventilation cannot be obtained without blocking the means of access, the employees in the confined space must be provided with airline respirators, and there must be an employee outside the space assigned to maintain communication with the employees in the space and to provide assistance in an emergency. 

Obviously, to us, rescue capabilities are always at the top of the list. If the decision is made to follow the General Industry standard and consider the vault to be PRCS, then rescue capabilities and a plan need to be put in place. Depending on the conditions that exist in and around the space, rescue retrieval may be an option, such as a tripod and winch system with retrieval line attached to the entrant. In your description, however, you mention that internal elements that may hinder the ability to do external retrieval. If this is the case, then some type of internal rescue capability will be needed. 

When it comes to the response time, we think Appendix F 1910.146 explains it best… 

"What are the needs of the employer with regard to response time (time for the rescue service to receive notification, arrive at the scene, and set up and be ready for entry)? For example, if entry is to be made into an IDLH atmosphere, or into a space that can quickly develop an IDLH atmosphere (if ventilation fails or for other reasons), the rescue team or service would need to be standing by at the permit space. On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutes might be adequate."

Thank you for your question, and we hope this information has been helpful. If we may be of further service, please don’t hesitate to contact us.


NOTICE: 
The information provided on our website or by our Tech Panel is a complimentary service for our readers. It is a general information resource for rescuers and is not intended as legal advice in any way. Because standards and regulations are typically performance based, and compliance with those standards and regulation is often dependent on the specific circumstances and conditions at hand, it is always important to carefully review all relevant standards and regulations, and to follow the proper protocols specific to your company or agency.

Roco Rescue Releases Two New Fall Protection Programs for OSHA Compliant Workplaces
Are you concerned about the potential for falls from height at your workplace?

Do you feel that your workers are not adequately trained in recognizing fall hazards, or do not have the proper training in the inspection and use of their fall protection equipment?

Does your fall protection program consider all the angles regarding work at height and fall protection?

Download our free Roco safety poster on the Hierarchy of Fall Protection.

 

New Roco Fall Pro Course: Competent Person for Fall Protection

Roco Rescue is proud to announce the addition of a comprehensive Competent Person for Fall Protection course as an addition to our already extensive catalog of Technical Rescue, Compliance, and Safety courses.

The two day (16 hour) Competent Person course focuses on OSHA and ANSI requirements and guidance to provide the Competent Person the knowledge and skills that will enable them to provide their employer a solid foundation for establishing or improving their comprehensive fall protection program

This course emphasizes legislated as well as consensus standard fall protection requirements and guidance for various industries as well as exposing the attendees to a variety of modern fall protection equipment solutions and techniques. The hierarchy of fall protection is used as the building block for the most protective approach for abating fall hazards in the workplace. The attendee will have a solid understanding of how to evaluate fall hazards in the workplace by completing a field exercise using a “Fall Hazard Survey Report Template” that identifies fall hazards and uses the hierarchy of fall protection to provide the most protective and feasible solution to address the identified hazards.

Exposure to modern fall protection equipment and emerging technologies -especially the availability of pre-engineered fall protection solutions- arms the student with an extensive toolkit for addressing existing fall hazards in their workplace. Equipment and equipment systems such as body support, connectors, modern lanyards, self-retracting lanyards, horizontal and vertical lifelines, anchor connectors, as well as other specialty equipment will be covered and examples will be available to employ during the class.

The often overlooked need to understand and provide a rescue capability for fallen/suspended workers and workers isolated at height will be covered. The use of the “Roco Suspended Worker Rescue Pre-plan” will be covered in a live field exercise. Included will be a demonstration and practice rescues utilizing a pre-engineered rescue system that may provide the “prompt rescue capability” of fallen workers for most situations as required by both OSHA and ANSI.

New Roco Fall Pro Course: Competent Person - Train the Trainer:

Upon completion of Roco’s Competent Person for Fall Protection Course we offer the option to stay on for our Competent Person Trainer course. This course includes an additional two days (16 hours) that prepares the Competent Person to train their own employees to the level of Authorized and Competent Persons. The course opens with a thorough lecture/discussion on the adult learner.

Tried and proven steps that are invaluable in providing a systematic workforce education program specific to Competent and Authorized Persons for fall protection are covered. Areas such as gap analysis, instructional triads, three part learning objectives, measurements, dealing with the adult learner and their varied backgrounds are just some of the preparatory lessons. This is followed by a thorough section on preparing and utilizing lesson plans which are then put into practice as the attendees prepare for and deliver actual lessons to their fellow students on the various teaching modules.

The Competent Person for Fall Protection and the Competent Person Trainer Courses are available as private training at Roco Training Center in Baton Rouge, Louisiana or Roco can deliver the course at your facility as a private class. Please call (800) 647-7626 for more details or to schedule.

During a recent Roco Fast-Track 120 class in Albuquerque, New Mexico, two of our students got to use the skills they had just learned during a real world event. On Day 6 of the 12-day class, NM State Police Tactical officers Hugo Munoz and Jose Urbano received a call for assistance in the recovery of an individual that had been swept into one of the many arroyos that crisscross the region following a sudden rainstorm.

Here’s a photo from the Fast-Track 120 class where Officer Urbano is shown “rescuing” Officer Munoz.

The officers responded and found the local fire and law enforcement personnel on scene in the process of devising a plan to recover the victim who was entrapped under a narrow bridge in approximately 6 feet of water. Officer Urbano and Munoz joined in the planning and recommended using some of the rope techniques that they had just learned in the Fast-Track 120 class.

The recovery plan involved the use of a mainline attached to the NM State Police Diver and a 4:1 rigged and ready to be “piggybacked” on the main line in case the diver needed immediate retrieval.

The Diver attached a second line to the recovery bag that was placed around the victim, and the Diver exited the arroyo. Officers Munoz and Urbano attached the 4:1 to the victim’s line and removed the individual from the arroyo. All of the systems used were anchored to multiple vehicles that had responded to the scene.

“Obviously, this makes us very proud that our students can take the techniques learned in our classes and put them to immediate use. Unfortunately, this was a recovery operation. However, we hope that everyone involved was just a little bit safer thanks to the training and capabilities of Officers Urbano and Munoz,” stated Roco Chief Instructor Tim Robson, who led the 120-hour training class.

 

Here's a photo of the scene of the recovery near an arroyo in Albuquerque, New Mexico.

An arroyo is defined as a small, deep gully or channel of an ephemeral stream. Arroyos usually have relatively flat floors and are flanked by steep sides consisting of unconsolidated sediments. They are usually dry except after heavy rainfall. In this area, there are several miles of open-air concrete lined drainage channels that drain an area into the main North Diversion Channel, a tributary of the Rio Grande joining upstream of Albuquerque.

Signs are posted at the constructed arroyos warning to keep out due to danger of flash flooding and other obvious dangers.

How to Videos: PATIENT PACKAGING

Roco SKED Method - Confined Space Technique

Roco Rescue Director of Training Dennis O'Connell explains alternate rigging techniques that have been developed in conjunction with SKEDCO for using the SKED stretcher in confined spaces.

Roco SKED Method - Vertical Lift with Backboard

Roco Rescue Director of Training Dennis O'Connell explains the Roco approved method of rigging a SKED stretcher for vertical lift while using a backboard.

Roco SKED Method - Traditional Method

Patient Packaging Technique from the Roco Rescue Channel features the manufacturer's approved method for traditional vertical lift using the SKED stretcher.

Roco Chief Instructor Pat Furr is conducting two workshops at the VPPPA IV Conference in Myrtle Beach this week. The first workshop, Elements of a Comprehensive Managed Fall Protection Program, clarifies OSHA and ANSI guidelines regarding the employer's responsibility to develop a comprehensive managed fall protection program.

The topic of the second workshop is Confined Space Rescue and will provide guidance that employers may use to identify, select, and evaluate a confined space rescue service as required by OSHA 1910.146.

Chief Furr is available for consulting your organization on either of these topics.

In this video, he discusses Safe Entry Into Permit Required Confined Spaces.