Confined Spaces in Construction: Applicable Standards Stan Liang, CIH, CSP, CET KTA-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 :Application of the Permit Required Confined Spaces Standard Maintenance work regulated under the General Industry Standards making 29 CFR 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 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 Examples of confined spaces include: Storage tanksProcess vessels Underground utility vaultsTunnels PipelinesVentilation and exhaust ducts Open top spaces (more than 4 feet deep)

Safety Training and Education 29 CFR 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 OSHA does not provide specific guidance on training requirements General requirement for compliance with applicable standards

Emergency Action Plans 29 CFR 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 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 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 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 Checked prior to the start of the job and weekly Must be easily accessible

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

Respiratory Protection 29 CFR 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 Oxygen levels must be determined Instrumentation required for determination

Respiratory Protection 29 CFR 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

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

Summary 29 CFR 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 –29 CFR 1926 (Construction Industry Standards) –29 CFR (Permit Required Confined Space Standards) –Letters of interpretation –Suspension Trauma/Orthostatic Intolerance Information Bulletin

Additional Information (American National Standard Institute) –ANSI/ASSE Z117.1: Safety Requirements for Confined Spaces (National Institute of Occupational Safety and Health) –NIOSH Publication No : A Guide to Safety in Confined Spaces

Questions