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Regulatory Compliance: New OSHA Standard for Confined Space Entry

Posted on Thu, Dec 03, 2015

Confined spaces, such as manholes, crawl spaces, and tanks, are not designed for continuous occupancy and are difficult to exit in the event of an emergency. People working in confined spaces may face life-threatening hazards including potential exposure to toxic substances, electrocutions, explosions, and asphyxiation.

In May 2015, OSHA issued a final standard, known as Subpart AA of part 1926 of the Code of Federal Regulations, regarding construction workers who work in confined spaces. According to Secretary of Labor, Thomas E. Perez, the new rule will significantly improve the safety of construction workers who enter confined spaces. “We estimate that it will prevent about 780 serious injuries every year”, said Perez.

The standard requires employers at construction sites to determine key confined space elements. Key provisions of the final standard require employers to:

  • Determine what kinds of spaces their employees will be in, what hazards could be there, and how those hazards should be made safe
  • Train each employee whose work is regulated by this standard, at no cost to the employee
  • Develop and implement a written confined space program if employees will enter permit spaces
  • Take effective steps to prevent employees from entering those spaces, if employees will not need to enter the permit spaces
  • Provide rescue and emergency services for employees who enter permit spaces, should anything go wrong

The standard applies to all construction workers who may be exposed to confined space hazards, such as those who work in boilers, tanks, storage bins, silos, stacks, vaults, pits, chambers, sewers, manholes, crawl spaces, and many more locations that have cramped spaces and narrow openings. According to OSHA, there are three characteristics of confined spaces:

  • It is big enough for a person to fit his or her entire body
  • It is restrictive for the person entering and exiting
  • The space is not meant for someone to stay in for a long period of time

The new rule provides construction employees with protections similar to general industry standard (29 CFR 1910.146). However, there are several different components tailored to the construction industry. The new Subpart AA of 29 CFR 1926, includes:

  • More detailed provisions for coordinating activities with other employers at the site
  • Competent site evaluation in order to identify confined and permit spaces
  • Requirement for continuous atmospheric monitoring, when possible
  • Requirement for continuous monitoring of engulfment hazards
  • Allowing for the suspension of a permit, instead of cancellation
  • Requiring that employers eliminate or isolate any physical hazards before directing employees to enter a space without using a complete permit system
  • Requiring that employers who are relying on local entities for emergency services to arrange for those responders to give the employer advance notice if they will be unable to respond for a period of time
  • Requiring employers to provide training in a language and vocabulary that the employee understands
OSHA uses the term permit-required confined space (PRCS) to describe a space that has one or more of the following characteristics:
  • Potential to contain a hazardous atmosphere
  • Contains a material that has the potential to engulf an entrant
  • Has walls that converge inward or floors that slope downward and taper into a smaller area which could trap or asphyxiate an entrant
  • Contains any other recognized safety or health hazard, such as unguarded machinery, exposed live wires, or heat stress

Construction site employers with PRCS must maintain a program detailing their PRCS
and comply with various safety requirements including, but not limited to:

  • Danger and warning signs that alert workers about the PRCS
  • Permits for safe entry operations, which also feature atmospheric test results
  • Certified documents detailing alternative entry procedures and safety methods for workers in the PRCS
  • A professional engineer’s written approval to ensure that employees know the provisions and limitations of using specifically designed personnel hoisting systems
  • Safety data sheets for workers who are exposed in the PRCS
  • Employee training records to confirm confined space training requirements
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Tags: OSHA, Regulatory Compliance