New OSHA Requirements for Confined Space Entry

New OSHA Requirements for 29 CFR 1926 Subpart AA Confined Spaces in Construction

by Robert Van Hoof

             OSHA has issued required changes to the standard for construction work in confined spaces as of May 4, 2015. This new criteria will be effective as of August 3, 2015. To prevent construction workers from injury or death, the new standard Subpart AA of 29 CFR 1926 will help eliminate and isolate hazards at construction sites much in the way workers in other industries are currently protected.

            The new rule as applied to construction work performed in confined spaces requires employers to:

  • Determine the type of confined space the workers must enter
  • Identify hazards before entry
  • Determine the best hazard mitigation method
  • Train workers prior to entry operations
  • Train Workers on rescue methods
  • Ensure Emergency services are available prior to entry

OSHA lists confined spaces as:

  • Tanks
  • Vessels
  • Silos
  • storage bins
  • hoppers
  • vaults
  • pits
  • manholes
  • tunnels
  • equipment housings
  • ductwork
  • pipelines

    OSHA also uses the term “permit required confined space” (permit space). As confined spaces may be encountered in virtually any occupation, recognition is the first step in preventing fatalities. Completing a permit prior to entry ensures that all safety factors and required activities have been addressed. This permit system is designed for the employer to limit and control entry to ensure a safe operation.

    OSHA.gov has clarified the construction requirements including:

    1. More detailed provisions requiring coordinated activities when there are multiple employers at the worksite. This ensures hazards are not introduced into a confined space by workers performing tasks outside the space. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.
    2. Requiring a competent person to evaluate the work site and identify confined spaces, including permit required spaces.
    3. Requiring continuous atmospheric monitoring whenever possible.
    4. Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a storm upstream from the workers could cause flash flooding. An electronic sensor or observer posted upstream from the work site could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely.
    5. Allowing for the suspension of a permit, instead of cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space. The space must be returned to the entry conditions listed on the permit before re-entry.

    In addition, OSHA has added provisions to the new rule that clarifies existing requirements in the General Industry standard. These include:

    1. Requiring that employers who direct workers to enter a space without using a complete permit system, prevent workers’ exposure to physical hazards through elimination of the hazard or isolation methods such as lockout/tagout.
    2. Requiring that employers who are relying on local emergency services for emergency services arrange for responders to give the employer advance notice if they will be unable to respond for a period of time (because they are responding to another emergency, attending department-wide training, etc.).
    3. Requiring employers to provide training in a language and vocabulary that the worker understands.

    Finally, several terms have been added to the definitions for the construction rule, such as "entry employer" to describe the employer who directs workers to enter a space, and "entry rescue", added to clarify the differences in the types of rescue employers can use.

                 “This rule will save lives of construction workers. Unlike most general industry worksites, construction sites a re continually evolving, with the number and characteristics of confined spaces changing as work progresses. This rule emphasizes training, continuous worksite evaluation and communication requirements to further protect workers safety and health.”  Assistant Secretary of Labor for Occupational Safety and Health, Dr. David Michaels.

                Training will be a large part of educating any workforce on the hazards associated with confined spaces for entrants and attendants as well as permit writers.

    www.PPVTrain.com has the necessary training available to meet the changing requirements. 

    We recommend that a comprehensive approach be utilized that includes this training be used as an initial or refresher training course at least once a year.  Additionally, the entry team must conduct a practical exercise of rescue procedures after they have completed any specialized training such as O2/LEL meter operation, specialized respirator fitting and use, as well as any other organizational requirements such as lockout/tagout procedures.

    If you would like to preview this course for your organization’s use give us a call at 1-800-339-0642.

    Robert Van Hoof is the CEO of Strategic Vision, Inc. and its subsidiaries PPVtrain.com and SCORMstore.com.  He has
    more than 30 years of experience in the development of blended and technology-based training programs for multiple
    U.S. government departments and Fortune 500 companies, which include U.S. Army, U.S. Department of Homeland
    Security, U.S. Department of the Interior, United Technologies, Pratt and Whitney Rocketdyne and Duke Energy.
    Mr. Van Hoof can be reached at vanhoofr@stratvision.com.

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