Confined Spaces in Construction Subpart AA 1926.12XX Steven Grego - CSP Corp Safety & Health Officer

Up-Dated Enforcement 1. Took effect on August 3, 2015 2. Full enforcement postponed until October 2, 2015 Temporary enforcement is NOT a stay OSHA will not cite employers who are making a good-faith effort to comply Good-Faith? - Scheduling training for employees as required by the standard Ordering necessary equipment Taking alternative measures to educate and protect employees from confined space hazards

Useful References a. Under development 1. OSHA 1926.12XX – Confined Spaces in Construction a. Available on the OSHA.gov web site 2. ANSI A10.43 - Confined Spaces for Construction a. Under development b. Latest comments/vote on most recent changes 6/19/15 3. OSHA 1910.146 – Permit Required Confined Spaces a. Available on the OSHA.gov web site 4. ANSI Z117.1 – 2009 – Safety Requirements for Confined Spaces a. Currently being revised b. Possible release in 2015.

Overview 1926.1200 – [Reserved] 1926.1201 - Scope 1926.1202 - Definitions 1926.1203 - General Requirements 1926.1204 - Permit Required Confined Space Program 1926.1205 - Permitting Process 1926.1206 - Entry Permit 1926.1207 - Training 1926.1208 - Duties of Authorized Entrants 1926.1209 - Duties of Attendants 1926.1210 - Duties of Entry Supervisors 1926.1211 - Rescue and Emergency Services 1926.1212 - Employee Participation 1926.1213 - Provisions of documents to Secretary

Scope 1926.1201 (a) . . . “Requirements for practices and procedures to protect employees engaged in construction activities at a worksite with one or more confined spaces”. . . Exceptions - 1926 Subpart P - Excavations - 1926 Subpart S - Underground construction, caissons, cofferdams and compressed air - 1926 Subpart Y - Diving - Part 1915 Subpart B Shipyard Employment - Part 1928 Agriculture

Definitions 1926.1202 49 definitions in the existing standard and 22 are new additions. 5 of particular interest include: - Competent Person - Qualified Person - Host Employer - Controlling Contractor - Entry Employer

Definitions 1926.1202 COMPETENT PERSON – Means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous or dangerous to employees, and who is authorized to take prompt corrective measures to eliminate them. QUALIFIED PERSON – Means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.

Definitions 1926.1202 HOST EMPLOYER - The employer that owns or manages the property where the construction work is taking place CONTROLLING CONTRACTOR – The employer that has overall responsibility for construction at the worksite ENTRY EMPLOYER – Any employer who decides that an employee it directs will enter a permit space. NOTE: An employer cannot avoid the duties of the standard merely by refusing to decide whether its employees will enter a permit space, and OSHA will consider the failure to so decide to be an implicit decision to allow employees to enter those spaces if they are working in the proximity of the space.

General Requirements 1926.1203 1. Competent person ID’s all confined spaces and permit spaces. 2. Inform exposed employees of all spaces and ID spaces. 3. Entry control of unauthorized employees into spaces. 4. Written program for authorized entrants at the work site. 5. Alternate Procedures 6. Reclassification of space by a Competent person. 7. Communication and Coordination

General Requirements 1926.1203 1. Competent person ID’s all confined spaces and permit spaces a. Each employer must ensure a competent person ID’s all confined spaces that their employees may enter. b. Once ID’ed the employer who receives information on the space(s) must communicate to their employees by signage or “other equally effective means”. . . . 2. Entry Control / Written Program a. Each employer who’s employees will not work in the noted spaces “must take effective measures” to prevent entry. . . . b. If any employer decides that their employees will enter a permit space, that employer must have a written program at the construction site. . . .

General Requirements 1926.1203 1. Alternate Procedures . . . demonstrate that all physical hazards in the space are eliminated or isolated through engineering controls. . . b. . . . demonstrate that continuous forced air ventilation alone is sufficient to maintain the permit space safe for entry. . . c. . . . Develop monitoring and inspection data that supports a. & b. above. . . d. . . . If initial entry into the space is required the entry must be performed as noted in the standard. . .

General Requirements 1926.1203 1. Communication and Coordination NEW Before entry operations begin the Host Employer must provide the following information, if it has it, to the Controlling Contractor: a. Location of each known permit space; b. The hazards or potential hazards in each space or the reason it is a Permit Space; c. Any precautions that the Host employer or any previous Controlling Contractor or Entry Employer implemented for the protection of employees in the space

General Requirements 1926.1203 1. Communication and Coordination NEW Con’t Before entry operations begin the Controlling Contractor must: a. Provide the following information to each entity entering the permit space. . . The information received from the Host employer Any additional information the Controlling Contactor may have about the space. . . The precautions the Host employer, Controlling Contractor, or other entry employers implemented for protection of employees. . .

Confined Space Program, Process & Permits Permit Required Confined Space Program, Process & Permits 1926.1204 & 1205 Program Development 1926.1204 1. . . . If any employer decides that employees it directs will enter a permit space, that employer must have a written permit space program that complies with 1926.1204 implemented at the construction site. . . New Additions: 1. Inerting Space 2. Monitoring procedures if ventilation system fails 3. Communication equipment for attendants assessing entrants or multiple spaces 4. PPE and Lighting Equipment 5. Early warning systems for non-isolated engulfment hazards 6. Continuous Monitoring 7. Development and implementation of procedures for multi-employer entry

Confined Space Program, Process & Permits Permit Required Confined Space Program, Process & Permits 1926.1204 & 1205 Permitting Process 1. Before entry is authorized, each entry employer must document the completion of measures required by 1926.1204(c) of this standard by preparing an entry permit. Entry Supervisor(s) must sign permit Completed permit must be made available to all entrants at the time of entry . . . Permit duration may not exceed the time required to complete the assigned task. . . . . . Terminate entry when operations covered by the permit have been completed or New . . . A condition that is not allowed under the entry permit arises in or near the permit space and that condition is temporary in nature and does not change the configuration of the space or create any new hazards . . . The space must then be fully reassessed.

Confined Space Program, Process & Permits Permit Required Confined Space Program, Process & Permits 1926.1204 & 1205 Entry Permit Space to be entered Purpose of entry Date and duration of permit List of ALL entrants NEW - Means of detecting atmospheric hazards if the ventilation system stops working Name of Attendant(s) Name of Entry Supervisor(s) Hazards of the permit space Entry Permit 9. Means used to isolate, control, eliminate hazards in space 10. Acceptable entry conditions 11. Pre-entry air sampling – names, date, time 12. Rescue Services and means of summoning 13. Communication procedures used by entrants and attendants 14. Any and all equipment used to comply with this standard (PPE, Testing Equip., Alarms) 15. NEW – Any additional permits authorized for work within the space

Permit Required Confined Space Training 1926.1207 Training requirements in both 1910.146 AND 1926.1207 are identical except for these new additions to the 1926.1207 standard: NEW 1. . . . And ensure that the employee possesses the understanding, knowledge, and skills necessary for the safe performance of the duties assigned under this standard. . . 2. . . . Training must result in an understanding of the hazards in the permit space and the methods used to isolate, control or in other ways protect employees from these hazards. . . 3. . . . And for those employees not authorized to perform entry rescues, in the dangers of attempting such rescues. 4. . . . In both a language and vocabulary that the employee understands

Permit Required Confined Space Duties of Entrants, Attendants & Supervisors 1926.1208-10 No changes from 19101.146 to the new 1026.1208-10

Permit Required Confined Space Rescue and Emergency Services 1926.1211 No significant changes to this section other than the following: 1. NEW – Selected Rescue Team . . . Agrees to notify the employer immediately in the event that the rescue service becomes unavailable. 2. NEW – . . . Practice rescue is not required where the affected employees properly performed a rescue operation during the last 12 months in the same permit space the authorized entrant will enter. . . 3. NEW – . . . Non-entry rescue is required unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.

Permit Required Confined Space Rescue and Emergency Services 1926.1211 Con’t 1. NEW - The employer must designate an entry rescue service whenever non-entry rescue is not selected. 2. NEW – Whenever non-entry rescue is selected: a. . . .the Entry Employer must ensure that retrieval systems or methods are used whenever an authorized entrant enters a permit space, AND b. . . . Must confirm, prior to entry, that emergency assistance would be available in the event that non-entry rescue fails.

Permit Required Confined Space Rescue and Emergency Services 1926.1211 Con’t 1. NEW – Equipment that is unsuitable for retrieval must not be used, including . . . retrieval lines that have a probability of entanglement with retrieval lines used by other authorized entrants 2. NEW – . . . Or retrieval lines that will not work due to the internal configuration of the permit space.

Comparison Document 1910. 146 vs 1926 Comparison Document 1910.146 vs 1926.12XX and New Definitions and Requirements Email sgrego@kta.com

Confined Spaces in Construction Subpart AA 1926.12XX QUESTIONS ? Steven Grego - CSP Corp Safety & Health Officer