AJ Gajdosik, CSP, ARM-P St. Louis ASSE Chapter Meeting July 2015

What we’ll talk about today  Necessity of the standard  Review of confined spaces  New requirements of Subpart AA  Resources available to you

Necessity of the standard

Why did we need a new standard?  Little guidance from existing construction standard  General Industry standard does not apply  Prevent almost 800 serious injuries

(b)(6) (b)(6)(i) All employees required to enter into confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas (b)(6)(ii) For purposes of paragraph (b)(6)(i) of this section, "confined or enclosed space" means 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. Confined or enclosed spaces include, but are not limited to, storage tanks, process vessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines, and open top spaces more than 4 feet in depth such as pits, tubs, vaults, and vessels.

General Industry (a) Scope and application. This section contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit- required confined spaces. This section does not apply to agriculture, to construction, or to shipyard employment (Parts 1928, 1926, and 1915 of this chapter, respectively).

Review of confined spaces

Confined space  Bodily enter  Limited or restricted means for entry and exit  Not designed for continuous employee occupancy

Permit-required confined space  A confined space with a hazard ◦ Hazardous atmosphere ◦ Engulfment ◦ Entrapment ◦ Any other serious safety/health hazard

GI requirements  Identify spaces  Inform employees  Restrict entry if not entering  Develop program if entering

Entry options  Full PRCS Program  Alternate entry  Reclassify

New requirements of Subpart AA

Dr. Michaels statement  “This rule emphasizes training, continuous worksite evaluation and communication requirements to further protect workers’ safety and health.”

 If the employer is following the construction standard, he or she is in compliance with the general industry standard

 Permits may be “suspended” instead of “cancelled”, provided the employer conducts a full evaluation prior to re-entry  Employers must develop a plan for summoning local emergency services, and to contact them before starting work if relying on them for entry rescue  During alternate procedures entry, employers may control/isolate physical hazards instead of eliminating them

Effective date  August 3, 2015 ◦ Postponing full enforcement for 60 days  October 2, 2015 ◦ No citation for “good faith efforts to comply”

Definitions  Controlling contractor  Early-warning system  Entry employer  Entry rescue  Host employer

 Space evaluation must be done by a competent person  Continuous atmospheric monitoring when technology is available  Continuous monitoring for engulfment hazards if in a continuous system (sewers)

(e) Alternate procedures  Eliminate or isolate all physical hazards  Demonstrate continuous forced air ventilation is sufficient  Develop monitoring and inspection data  If entry is required to get data the full permit is followed  Provide data to employees

Alternate procedures entry  Remove cover safely  Install railing, cover or barrier  Test atmosphere  Ventilate  Continuously monitor  Safe entrance and exit  Certify space for safe entry

(g) Reclassification  No atmospheric hazard  Eliminate all physical hazards without entry  Certify elimination of hazards

 Before entry ◦ Host Employer - give controlling contractor information if available ◦ Controlling Contractor - must give information to entry employers ◦ Entry Employer - must inform controlling contractor of their procedures

 Entry and controlling employers must coordinate work during entry if: ◦ More than one entity is in the space at the same time ◦ Other activities could result in a hazard within the space

 Post-entry information transfer ◦ Entry Employer - Must give controlling contractor information about the space ◦ Controlling Contractor - Must give information to host employer

Training  Ensure the employee possesses the understanding, knowledge and skills necessary  In both a language and vocabulary that the employee can understand

Rescue and emergency services  Time frame  Equipped and proficient  Agrees to notify the employer in the event the service becomes unavailable

Resources

 OSHA ◦ Construction Confined Spaces topics page  Standard and Federal Register  3 Fact Sheets  Fatal Facts #  Case Study

 OSHA #2264 ◦ Permit-Required Confined Space Entry  OSHA #7300 ◦ Understanding OSHA’s Permit-Required Confined Space Standard DTE is updating the learning objectives to include the new rule. Tentative – Quarter 4, FY 2015

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