Worth the Wait...OSHA’s Confined Space Standard for Construction

Tuesday, December 15, 2015

Worth the Wait...OSHA’s Confined Space Standard for ConstructionIn our opinion, the new OSHA regulation for Confined Spaces in Construction (Subpart AA of 1926) was worth the wait! This new standard is well thought out and includes some significant as well as subtle differences from the General Industry Permit Required Confined Space Standard 1910.146.

In this article, we will point out additional requirements for compliance for construction activities involving confined spaces. With the exception of residential construction, the final rule became fully enforceable as of October 2, 2015.   

These additional requirements instituted by OSHA are due to the dynamic nature of the construction environment. Dynamic in terms of the continuously evolving configuration of the workplace, and also in the diverse and ever-changing makeup of employers and employees depending on the phase of construction. We feel the most significant differences are not complete shifts in an administrative or operational approach to conducting safe permit required confined space operations, but more of an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.

“We believe the new standard offers an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.”

Please pay particular attention and review 1926 Subpart AA for requirements to ensure clear communication and coordination between the varied entities that work in or adjacent to the construction areas that have confined spaces. The lack of accurate communication and coordination continues to be a cause of confined space fatalities.

The need to communicate with the controlling contractor and entry employers regarding any operations that may have introduced a hazard into a confined space is of paramount importance. The failure to do so has repeatedly led to disaster for unsuspecting follow-on entrants into those confined spaces. Likewise, understanding and communicating the types of operations adjacent to, or in the proximity of confined spaces that may negatively affect that entry operation, must be coordinated and communicated.

Worth the Wait...OSHA’s Confined Space Standard for ConstructionAlso, several new roles and responsibilities have been added to the confined space regulations. One of the most important new roles is that of the “competent person” for confined spaces.

Having a dedicated individual (Competent Person) who has the expertise and background to perform this critical function will undoubtedly result in lives saved.

OSHA has also added clarification to the need to ensure that the designated confined space rescue service is not only available at the time entry operations commence, but also that rescue service must now agree to notify the entry employer if a situation arises that renders them unable to respond to an emergency.


So let’s take a look at some of the particulars of these new requirements and clarifications.

1. Allows an Entry Permit to be suspended, instead of cancelled in the event of changes from the entry conditions list. Ref: 1926.1205(e)(2)

This differs from 1910.146(e)(5) which requires an employer to terminate entry and cancel the entry permit. This change has specific requirements and limits. Suspending a permit is only allowed when a condition that is not allowed under the entry permit arises in or near the permit space and that condition is: (a) temporary in nature; (b) does not change the configuration of the space; and/or, (c) does not create any new hazards within it.

The first action of the entry supervisor must be to terminate entry and ensure all authorized entrants have safely evacuated the space. At that point, the entry supervisor can suspend or cancel the entry permit. Prior to authorizing reentry, the entry supervisor must fully reassess the space before allowing reentry.

Worth the Wait...OSHA’s Confined Space Standard for Construction2. Includes more detailed provisions requiring coordinated activities when there are multiple employers at the worksite.

This is an important difference compared to the General Industry regulation. It is required due to the ever-changing makeup of the construction workforce and most especially when the need for workers from multiple employers must enter permit spaces at the same time, or perform work activities in the vicinity of the permit space – thus, the potential to introduce new hazards to the space that all employers on site must be aware of and prepare for.

This final provision differs from 1910.146(d)(11) by specifically addressing the need to coordinate work activities through the controlling contractor, as well as with employers working outside the permit space when their work could foreseeably affect conditions within a confined space. The new construction industry standard goes far beyond by outlining the need for coordinated activities between multiple employers by identifying specific roles – host employer, controlling contractor and the entry employer. (Refer to Chart.)

OSHA 1926.1203 General Requirements paragraph (h) includes specific communication and coordination requirements between the various employers and contractors. The host employer must provide certain information they may have about confined spaces to the controlling contractor.

Required information includes items such as:
(a) The location of known permit spaces;
(b) The nature of hazards in those identified permit spaces;
(c) The reason for classifying the space as permit required; and,
(d) Any additional precautions that the host employer, any other controlling contractor, or entry employer have previously employed to protect their employees must be provided.

It is also incumbent upon the controlling contractor to obtain information from the host employer regarding the hazards associated with the permit spaces and any information on previous entry operations into that permit space.

The controlling contractor is responsible for passing information to any entry employer that may authorize entry into that permit space as well to any other entity at the worksite that could foreseeably create a hazard that may affect that confined space.

The entry employer must obtain from the controlling contractor all the information regarding the particular permit space hazards and entry operation information. Additionally, the entry employer must inform the controlling contractor of the provisions of their permit required confined space program and any hazards they expect to confront or create during their entry operations.

It is also very important that the controlling contractor and all entry employers coordinate their activities when multiple entry employers have entrants in the same space, or when other activities around the permit space may create a hazard that affects the confined space entry operation.

At the completion of entry operations, it is equally important that all entities including entry employers and controlling contractors communicate information regarding the particulars of any given entry. This information must include the permit space program followed during the entry operation as well as any hazards confronted or created during entry. Of particular importance is to communicate any hazards created within the confined space that may still be in place. The controlling contractor in turn communicates all of this information to the host employer.

3. Requires a Competent Person to evaluate the work site and identify confined spaces, including permit spaces.

Along with the increased need for strong communications and coordination, the addition of the role of competent person for confined spaces may be one of the most important differences between the general industry standard and the construction standard.

Worth the Wait...OSHA’s Confined Space Standard for ConstructionIt may seem to be a subtle difference in the two standards’ requirements, but now there is a specific role, or an identified position for conducting an evaluation of the worksite to determine the presence of confined spaces, a determination of the known or potential hazards associated with those confined spaces, and that has the authority to eliminate the identified hazards.

The competent person for confined spaces must have a high degree of expertise in identifying confined spaces and to make an accurate determination of the nature of any known or potential hazards associated with the confined space that would trigger it to be classified a permit space. In the event that the configuration or use of a non-permit required confined space changes, or a new hazard is introduced, the entry employer must have the competent person reevaluate that space to determine if it has become a permit required confined space. This is also true for any confined space that may not have initially been adequately evaluated to identify any known or potential hazards that would require that space to be classified a permit required confined space.

4. Designated rescue service must agree to notify the entry employer immediately if it becomes unavailable.

Although it has always been implied in the general industry standard that the entry supervisor would ensure the designated rescue service is available during entry operations, 1926.1211 explicitly requires an employer to designate a rescue service – in turn, the rescue service agrees to notify the entry employer immediately if they become unavailable to respond.

5. Provide an early warning system for non-isolated engulfment hazards.

This is primarily for sanitary and storm drain entry operations, but is equally important for any entry operations of a similar nature. The type of early warning systems can be as simple as posting an individual as an “upstream watch” to more complex systems such as electronic sensors or camera systems. Whatever system is used to detect an impending engulfment hazard, it must include a means of communications to provide advanced warning to the downstream entrants in time to safely evacuate the space.

Worth the Wait...OSHA’s Confined Space Standard for ConstructionWe encourage our readers to spend time studying the new regulation, and in particular understanding the points we have highlighted in this article as well as in our downloadable Confined Spaces in Construction Safety Poster. If you have questions, or if we may be of service, please contact us at 800-647-7626.

 

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Roco Rescue Challenge 2015 Video

Thursday, October 22, 2015

To find out more about the benefits of Challenge for your team, call 800-647-7626 and join us next year!

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Watch and Learn at Challenge 2015

Thursday, July 30, 2015

Watch and Learn at Challenge 2015Take in all the action and discover what your team may be missing! With Roco Rescue Challenge 2015 right around the corner, we wanted to share some of the benefits of attending as an observer. Here’s what one of our observers had to say about last year’s event…

"You just can't get everything you need out of a classroom. Coming out and seeing the teams performing different techniques and scenarios allowed us to gain insight that will be used to kick-start our team."

Don't miss the rescue team event of the year! 

Call us at 800-647-7626 and reserve your ticket today.

Rescue teams from across the country will participate in realistic confined space rescue exercises designed by Roco’s top instructors. And, although Challenge is more of a learning event than a competition, trophies will be awarded to the teams with top scores for individual skills proficiency and the infamous “Yellow Brick Road” rescue-relay scenario.Watch and Learn at Challenge 2015

Roco Rescue Challenge meets the annual rescue practice requirements of 1910.146 while providing realistic practice drills in all six confined space types. Written documentation will be provided to each team following the event.

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Do You Need Roco's Industrial Rescue III Training?

Thursday, July 23, 2015

Do You Need Roco's Industrial Rescue III Training?"If you've been through a Roco class, whether it was Roco certification to NFPA 1006, or OSHA compliance training, our new Industrial Rescue III course can be the next step for you and your team. This course will challenge students (and rescue teams) to solve real-world confined space rescue scenarios building on previously learned skills, while introducing new techniques for more complex confined space incidents. 

This scenario-based training will serve as annual compliance documentation (NFPA & OSHA) for confirming rescue capabilities and skills proficiency in various confined space and elevated evolutions. So, if you’re looking for the next step for you or your team, check out Roco’s Industrial Rescue III  for advanced confined space rescue training!" states, Dennis O'Connell, Chief Instructor and Director of Training.
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OPPD Employees Go to Great Heights to Train for Rescues

Monday, July 20, 2015

OPPD Employees Go to Great Heights to Train for RescuesOPPD (Omaha Public Power District) rescue team members were put to the test by the elements and Roco instructors during a recent rescue class at their facility. During the week-long class, they experienced high temperatures and rain - all while working at varying heights! However, it provided to be a great learning opportunity for the team. “The training as a whole was excellent, top-notch.” quoted Jeremy Kellner, a senior I/C technician at NOS and leader of the rope rescue team.

Here's a story about the training that appeared on the company's website. Roco instructors for the class were Troy Gardner, Robert Kauer, and Dominic Velasquez. 

It's been our pleasure to work with OPPD for the past ten years. To read the full story click here
 
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