Confined spaces may contain hazards that can injure, sicken, or even kill the workers that enter them. The hazards may be physical in nature – examples include moving parts, electric shock, and engulfment or entrapment hazards. In addition, atmospheric hazards such as low oxygen levels or dangerous concentrations of toxic vapors and/or gases are also often found.
OSHA has had confined space regulations for both general industry and construction in place for many years, although the requirements for construction paled when compared to those for general industry. OSHA recently addressed this disparity by promulgating 29 CFR 1926, Subpart AA: Confined Spaces in Construction.
OSHA estimates that this standard will help to eliminate approximately 800 construction accidents each year. While it is very similar to OSHA’s Confined Space Standard for General Industry, Supart AA contains some important distinctions and enhancements. Read on to learn more.
Subpart AA has a broad scope – it applies to whoever owns and manages the property undergoing construction and all contractors and subcontractors working at the site. OSHA mandates that these groups designate a “competent individual” who must evaluate and identify spaces that meet the following definition of a confined space:
- Is large enough and configured to allow an employee’s entire body to enter it
- Has limited or restricted means of entry and exit
- Is not designed for continuous employee occupancy
It’s important to note that many confined spaces are not enclosed or covered. Open pits, bins, pier columns, etc. often meet the definition of a confined space because workers cannot quickly and easily escape. In addition, these spaces lack lighting, ventilation, and other features which are installed for routine occupancy. Many other construction spaces such as manholes, sewers, storm drains, water mains, crawl spaces, pits, and tanks also meet OSHA’s confined space definition.
Confined spaces that have one or more of the following characteristics must be classified as permit-required confined spaces:
- Contains or has a potential to contain a hazardous atmosphere
- Contains a material that has the potential to engulf a worker
- Has inwardly converging walls or a floor which slopes downward and tapers to a smaller cross-section that could cause a worker to be trapped or asphyxiated
- Contains any other recognized serious safety or health hazard
Construction companies who require their workers to enter permit-required spaces must develop and implement a Permit-Required Confined Space Program. This written program will become an important part of your health and safety toolbox, as it manages all aspects of confined space work, including roles and responsibilities, the permit process, confined space equipment and monitoring activities, and emergency and rescue services.
The Standard requires that the following key roles be assigned. You’ll see that in each case, topic-specific training and expertise is required in order for these individuals to fulfill their duties:
- Competent Person: must evaluate all confined spaces that may need to be entered and identify existing or potential hazards in the spaces. In addition, the competent person has the authority to take corrective actions which will eliminate confined space hazards.
- Entry Supervisor: determines if confined space entry conditions are acceptable, and authorizes and oversees the entry operations. This person is often a company representative, the foreman or the crew chief.
- Authorized Entrant: enters and works in the confined space
- Attendant: continuously monitors and communicates with the authorized entrants. The attendant determines if it is safe for entrants to remain in the space, controls activities near the space, and summons help if an emergency situation arises.
- Rescue and Emergency Personnel: these individuals rescue workers who are trapped in confined spaces. They must be able to respond in a timely manner and have the skills and equipment needed to perform the rescue.
Subpart AA requires that permit-required spaces be continuously monitored for atmospheric hazards. This differs from the periodic monitoring requirement for general industry. In addition, the Standard requires construction companies to continuously monitor for engulfment hazards, if they apply.
Finally, communication and coordination requirements acknowledge and address the unique challenges facing the construction industry – namely, that multiple jobs involving more than one subcontractor are often occurring simultaneously. In addition, each subcontractor may have different crews rotating on and off the job site.
Careful and constant communications are needed in order to inform all workers of the confined space locations, the specific hazards associated with each space, and the necessary precautions. Likewise, coordination will reduce the risk associated with multiple workers entering the same confined space at the same time – and help to ensure that contractors working near or outside of the space are not introducing hazards that could impact the confined space.
Are you a construction company that needs to implement OSHA’s new Confined Space Standard? Do you have other industrial hygiene or safety needs? Cashins & Associates can help you comply with OSHA regulations, reduce the risk of work-related injuries and illnesses, and protect your company’s reputation. Contact us to learn more about how we can help you!