Confined Spaces in Construction Applicable Standards Stan Liang

Confined Spaces in Construction: Applicable Standards Stan Liang, CIH, CSP, CET KTA-Tator, Inc.

Webinar Objectives Ø Brief overview of the following: ü OSHA Construction Standards ü Applicability of OSHA General Industry Standards Ø 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 Education 29 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 Education 29 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 Education 29 CFR 1926. 21 • OSHA does not provide specific guidance on training requirements • General requirement for compliance with applicable standards

Emergency Action Plans 29 CFR 1926. 35 • Plan must be in writing • Response procedure in the event of a fire or other emergency

Emergency Action Plan Elements • 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 Plan Elements • Means of reporting fires and other emergencies • Contacts for further information

Medical Services and First Aid 29 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 Aid 29 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 Aid 29 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 Aid 29 CFR 1926. 50 • Checked prior to the start of the job and weekly • Must be easily accessible

Medical Services and First Aid 29 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 Protection 29 CFR 1926. 103 • Use feasible engineering controls • Respiratory hazard evaluations • Respirator selection and rescue procedures for IDLH atmospheres

Respiratory Protection 29 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 Protection 29 CFR 1910. 103 • Oxygen levels must be determined • Instrumentation required for determination

Respiratory Protection 29 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 Protection 29 CFR 1926. 103

Respiratory Protection 29 CFR 1926. 103 • Procedures for entry into IDLH atmospheres: – Communications – Rescue team – Notification of employer prior to start of emergency entry for rescue

Fall Protection 29 CFR 1926 – Subpart M • Employers relying on personal fall arrest systems must have pre -planned rescue procedures

Fall Protection 29 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 Z 117. 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

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