Confined Spaces in Construction: Applicable Standards

Stan Liang, CIH, CSP, CETKTA-Tator, Inc.

Webinar Objectives

Brief overview of the following: OSHA Construction Standards Applicability of OSHA General

Industry Standards

Resources for additional information

Permit Required Confined Space Standard

• Industrial painting normally classified as construction

• OSHA may classify painting as maintenance on a case by case basis

• CPL 02-00-100:Application of the Permit Required Confined Spaces Standard

• Maintenance work regulated under the General Industry Standards making 29 CFR 1910.146 applicable

Permit Required Confined Space Standard

Compliance can be required by:•Contract specifications•Prime contractor’s safety program

Permit Required Confined Space Program Requirements

• Hazard identification• Hazard control• Entry permit• Specialized equipment• Employee designation

Permit Required Confined Space Program Requirements

• Testing and monitoring• Outside contractors• Emergency procedures

Construction Regulations

• Construction Standard requirements can be similar to that found in the General Industry Permit Required Confined Space Standard

Safety Training and Education 29 CFR 1926.21

• Defines confined spaces– Has limited means of

access and egress– Subject to the

accumulation of toxic or flammable contaminants

– Has an oxygen deficient atmosphere

Safety Training and Education29 CFR 1926.21

• Examples of confined spaces include:

Storage tanks Process vessels

Underground utility vaults Tunnels

Pipelines Ventilation and exhaust ducts

Open top spaces (more than 4 feet deep)

Safety Training and Education29 CFR 1926.21

• Employees must be instructed in the following:– Nature of hazards– Necessary precautions to be taken– Use of protective and emergency equipment

Safety Training and Education29 CFR 1926.21

• OSHA does not provide specific guidance on training requirements

• General requirement for compliance with applicable standards

Emergency Action Plans29 CFR 1926.35

• Plan must be in writing • Response procedure in the event of a fire or

other emergency

Emergency Action PlanElements

• Emergency escape procedures and emergency escape route assignments

• Accounting for all employees after an evacuation is completed

• Rescue and medical duties for those employees who are to perform them

Emergency Action PlanElements

• Means of reporting fires and other emergencies

• Contacts for further information

Medical Services and First Aid29 CFR 1926.50

• Provisions must be made prior to the start of the project for prompt medical attention

• The employer must ensure the availability of medical personnel for advice and consultation

Medical Services and First Aid29 CFR 1926.50

• Where medical facilities are not reasonably accessible, a person with a valid certificate in first aid training shall be available on site

• “Reasonably accessible” is defined as 3 to 4 minutes for life threatening emergencies

Medical Services and First Aid29 CFR 1926.50

• Materials in first aid kit approved by the consulting physician

• First aid contents must be in a sealed weatherproof container

Medical Services and First Aid29 CFR 1926.50

• Checked prior to the start of the job and weekly

• Must be easily accessible

Medical Services and First Aid29 CFR 1926.50

• Proper equipment for prompt transportation or a communication system for contacting ambulance services

• Telephone numbers of physicians, hospitals, or ambulances must be posted

Respiratory Protection29 CFR 1926.103

• Use feasible engineering controls

• Respiratory hazard evaluations

• Respirator selection and rescue procedures for IDLH atmospheres

Respiratory Protection29 CFR 1926.103

• Selected based on respiratory hazards to which worker will be exposed

• Reasonable estimate of employee exposures

• Estimate of contaminants physical and chemical state

Respiratory Protection29 CFR 1910.103

• Oxygen levels must be determined

• Instrumentation required for determination

Respiratory Protection29 CFR 1926.103

• Hazard evaluations for toxic atmospheres:– Review safety data sheet– Use personal sampling

equipment or other instruments to determine concentration

– Consult a safety and health professional for guidance

Respiratory Protection

• Confined spaces are classified as Immediately Dangerous to Life and Health when:– No hazard evaluation

performed– Atmospheric oxygen

level is below 19.5%

Respiratory Protection29 CFR 1926.103

Respiratory Protection29 CFR 1926.103

• Procedures for entry into IDLH atmospheres:– Communications– Rescue team – Notification of

employer prior to start of emergency entry for rescue

Fall Protection29 CFR 1926 – Subpart M

• Employers relying on personal fall arrest systems must have pre-planned rescue procedures

Fall Protection29 CFR 1926 – Subpart M

• Criteria for “prompt” rescue in Suspension Trauma/Orthostatic Intolerance OSHA information bulletin

Summary

• Industrial painting projects likely to be classified as construction

• Elements of a confined space entry plan on construction projects may be similar to 29 CFR 1910.146

Summary

29 CFR 1910.146 can apply to industrial painting projects if:•Work classified by OSHA as maintenance•Compliance required by contract or controlling employer’s written safety program

Additional Information

• www.osha.gov– 29 CFR 1926 (Construction Industry Standards)– 29 CFR 1910.146 (Permit Required Confined Space

Standards)– Letters of interpretation– Suspension Trauma/Orthostatic Intolerance Information

Bulletin

Additional Information

• http://www.ansi.org (American National Standard Institute)– ANSI/ASSE Z117.1: Safety Requirements for

Confined Spaces• http://www.cdc.gov/niosh (National Institute of

Occupational Safety and Health)– NIOSH Publication No. 87-113: A Guide to Safety in

Confined Spaces

Questions