OSHA

Construction Standards for Confined Space Entry

Construction standards for confined space entry have been defined and set for enforcement by the Occupational Safety and Health Administration (OSHA). These standards are now specifically for the construction industry. The previous regulations only applied to general industry. Still others are covered under the American National Standard ANSI Z117.1-1989, Safety Requirements for Confined Spaces.

Construction Standards Expanded from Existing Regulations

OSHA General Industry regulation 1910.146, permit-required confined spaces, details the practices and procedures for safe entry for work in a permit-required confined space. This regulation does not specifically apply construction work.

OSHA regulation 1926 applies to construction safety and health. It does address some construction standards for a permit-required space regulation. The following portions of 1926 apply to confined space entry in construction work:

Sub-part C – 1926.21 Safety training and education covers the requirements for safety training prior to entering and working in a confined space. It defines a confined space as “any space having a limited means of egress, which is subject to the accumulation of toxic or flammable contaminants or has an oxygen deficient atmosphere.”.

Sub-part S – 1926.8 applies to the construction of underground tunnels, chambers, and passageways. It also includes cut-and-cover excavations that are connected to underground construction operations. These are covered in a manner that creates conditions characteristic of underground construction.

1926.956 covers underground electric transmission and distribution work. It includes guarding and ventilating street openings used for access to underground lines or equipment. 1926.956(a) applies to trenching and excavating. 1926.956(c), other related operations.

1926 Sub-part P contains additional requirements for confined space entry applying specifically to excavations.

1926 Sub-part J applies to welding and cutting in confined spaces.It includes requirements for ventilation and protection while welding, cutting, and heating plus other confined space related regulations.

Finally, a new standard recently adopted, OSHA 29 CFR 1926 Sub-part AA, now specifically defines construction standards for permit-controlled confined spaces and is set for enforcement. After years of feedback and analysis, OSHA felt that an updated, specific standard was necessary to more thoroughly handle the construction industry.

Other general construction standards guidelines which are applied to confined space work beyond OSHA regulations are found in American National Standard ANSI Z117.1-1989. These are Safety Requirements for Confined Spaces which provide minimum safety requirements for entering, exiting, and working in confined spaces at normal atmospheric pressure.

Confined Space Rescue

Confined space rescue teams need to be evaluated per OSHA standards. Confined space rescue criteria and guidelines are covered in OSHA CFR 29 1910.136 App F. Rescue teams or services have defined evaluation criteria to provide guidance to employers for choosing services for confined space permit areas. The criteria can be used to evaluate prospective or current rescue teams.

Before choosing or training a confined space rescue team, a satisfactory permit program must be completed, including an analysis of all permit-required confined spaces to identify all potential hazards in those spaces. Compliance with all the provisions of standard CFR 29 1910.146 should enable employers to conduct permit space operations without need for rescue services in almost all cases. However, it is still necessary to be prepared for emergency situations by selecting a on-site or off-site rescue service or team equipped and capable of minimizing harm to entrants in those situations.

Evaluation of Confined Space Rescue Teams

Evaluation in choosing a confined space rescue team has two components. An initial evaluation to decide whether a potential rescue service or team is adequately trained and equipped and whether the team can respond in a timely manner is the first step. Subsequently, a performance evaluation is needed to measure the performance of a team or service during a practice or actual rescue. In the initial evaluation, the employer can determine whether it is more cost effective to maintain an on-site confined space rescue team or to hire a rescue service. In the performance evaluation, the effectiveness of the chosen team or service can be determined and a decision made on whether to retain the current team or service based on the results or to select another service, or form an internal rescue team.

Non-Mandatory Appendix F – Rescue Team or Rescue Service Evaluation Criteria of Standard 1910.146 gives details on how to choose and evaluate a confined space rescue team or service. In addition to a description of the components of the evaluation process, it provides questions which guide the employer through the process. For the initial evaluation, answers must be determined to such questions as what is needed regarding response time; how quickly can the team or service get to the permit spaces from which rescue may be necessary; when is the rescue service available; is there an adequate method for communications between the employer and the prospective rescuer; does the rescue service have necessary skills in medical evaluation; and does the confined space rescue service have necessary equipment to perform rescues.

Confined Space Rescue Evaluation

For the performance evaluation, details must be determined such as whether all members of the service been trained as permit space entrants; are team members provided with and trained in the use of personal protective equipment (PPE); are team members trained in first aid and medical skills needed to treat victims of the type of hazards that may be encountered in the permit spaces of the facility; do team members perform their duties safely and efficiently; can the confined space rescue service properly test the atmosphere of a space and identify pertinent information from permits; and can the rescue service properly package and retrieve victims from areas with limited sized openings, limited internal space, or obstacles and other hazards. It is also important to determine if the rescue service has a plan for each type of permit space at a facility and if the plan is adequate for all types of rescue operations that may be needed at the facility.

To view the entire Non-Mandatory Appendix F – Rescue Team or Rescue Service Evaluation Criteria visit: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=9803.

Identifying Confined Space Hazards in Construction Work

Identifying confined space hazards is very important for almost all construction sites. The confined space entry standards as defined by OSHA, for General Industry and Construction are actively enforced by OSHA. There’s good reason. Confined space incidents have risen in both industries, but is amplified in Construction. Proper training, consistent inspection, documentation and preparation of a safety and rescue plan all are required under OSHA 29 CFR 1910.146 and OSHA 29 CFR 1910.146 Subpart AA.

Identifying Confined Space Hazards as Inherent or Induced Hazards

There are two types of hazards encountered in confined work spaces – inherent and induced. Inherent hazards are related to equipment and the interactions of working with them. Identifying inherent confined space hazards is based around the observation of operations and include hazards such as:

shock or burn from high voltage electrical equipment
exposure to radiation generated by certain equipment
defectively designed equipment
lack of protective features such as grounding for non-current-carrying conductive parts
high or low temperatures
high noise levels
high-pressure equipment that may rupture.
Inherent hazards cannot be eliminated from the equipment without affecting their operation, so these hazards must be used employing hazard control methods.

Induced hazards are those caused by incorrect decisions or actions during the construction process. Identifying confined space entry hazards involvingf induced hazards include:

physical arrangements that might cause accidental contact by a worker with electrical energy sources
lack of oxygen in areas like the bottom of pits or shafts
omission of protective features
lack of safe structural strength of the workspace
flammable atmospheres such as those where volatile gases may be present.

Identifying confined space hazards may involve both inherent and induced hazards. Examples of such hazardous environments include:

Vaults in which the atmosphere may be or become oxygen-deficient.
Electrical vaults which may become filled with explosive gases such as from propane, or toxic fumes that can build-up in a limited atmosphere from welding and soldering in a confined space.
Electrical shock can occur when working in any confined space with power tools, line cords, and similar equipment, where the contractor has not provided an approved grounding system, ground-fault circuit interrupters, or low-voltage systems.
In a workspace where purging agents such as nitrogen or argon are being used in an adjacent area, the fumes may displace the oxygen in a vault to the point where workers could suffer immediate asphyxiation.
Condenser pits are a type of confined space encountered during the construction of nuclear power plants which are fairly large, so that the potential for the hazards associated with a confined workspace may be overlooked. Toxic fumes and gases can accumulate in these areas from the use of argon, freon, and other inert gases, creating oxygen-deficient atmospheres for workers. Another hazard in this type of workspace is caused by workers above accidentally dropping equipment, tools, or other materials into the pit.
Pipe assemblies are another type of confined space common in construction. Identifying confined space hazards of this type, can involve other types of work spaces, such as oxygen-deficient atmospheres caused by purging with argon or other inert gases. They may contain ungrounded electrical equipment, also. They can also be very restricted spaces where there is little room for workers to move around or find a comfortable position to perform their work. Also, where bends occur in pipes communication can be cut off, and getting a worker out of the area can be extremely difficult. The heat within a pipe may cause workers to suffer heat prostration, as well.
The same types of hazards are encountered working within ventilation ducts as within pipes. Identifying confined space hazards in narrow spaces are characterized by many bends restricting movement and communication, They can contain toxic or oxygen-deficient atmospheres. In some cases electrical shock, and extreme heat all can occur within this type of space.
Tanks used for storage of water, chemicals, or other materials often require entry for cleaning or repairs. Identifying confined space hazards in these spaces can include heat, oxygen-deficient atmospheres and electrical shock. They may also contain fall hazards from climbing high ladders on the walls of a tank.
Manholes are common on construction sites. Manhole covers are sometimes removed and not replaced, or not provided at all, making it a dangerous trap where a worker may fall. Identifying confined space hazards here can many time can be easily fixed.

Other hazardous confined work spaces include sumps, containment cavities, electrical transformers, and heat sinks, all of which carry the risks of the same inherent and induced hazards associated with the spaces described above. Identifying confined space hazards in these potentially hazardous environments is critical

Awareness of the hazards found in these types of confined entry work spaces is an important step in the prevention of injuries and fatalities caused by these hazards.