Confined Spaces in Construction: Applicable Standards

1. Confined Spaces in Construction: Applicable Standards Stan Liang, CIH, CSP, CET KTA-Tator, Inc.

2. Brief overview of the following: OSHA Construction Standards Applicability of OSHA General Industry Standards Resources for additional information Webinar Objectives

3. Permit Required Confined Space Standard • Industrial painting normally classified as construction • OSHA may classify painting as maintenance on a case by case basis • CPL 02-00-100:Application of the Permit Required Confined Spaces Standard • Maintenance work regulated under the General Industry Standards making 29 CFR 1910.146 applicable

4. Permit Required Confined Space Standard Compliance can be required by: • Contract specifications • Prime contractor’s safety program

5. Permit Required Confined Space Program Requirements • Hazard identification • Hazard control • Entry permit • Specialized equipment • Employee designation

6. Permit Required Confined Space Program Requirements • Testing and monitoring • Outside contractors • Emergency procedures

7. Construction Regulations • Construction Standard requirements can be similar to that found in the General Industry Permit Required Confined Space Standard

8. Safety Training and Education 29 CFR 1926.21 • Defines confined spaces • Has limited means of access and egress • Subject to the accumulation of toxic or flammable contaminants • Has an oxygen deficient atmosphere

9. Safety Training and Education29 CFR 1926.21 • Examples of confined spaces include:

10. Safety Training and Education29 CFR 1926.21 • Employees must be instructed in the following: • Nature of hazards • Necessary precautions to be taken • Use of protective and emergency equipment

11. Safety Training and Education29 CFR 1926.21 • OSHA does not provide specific guidance on training requirements • General requirement for compliance with applicable standards

12. Emergency Action Plans29 CFR 1926.35 • Plan must be in writing • Response procedure in the event of a fire or other emergency

13. Emergency Action PlanElements • 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

14. Emergency Action PlanElements • Means of reporting fires and other emergencies • Contacts for further information

15. Medical Services and First Aid29 CFR 1926.50 • 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

16. Medical Services and First Aid29 CFR 1926.50 • 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

17. Medical Services and First Aid29 CFR 1926.50 • Materials in first aid kit approved by the consulting physician • First aid contents must be in a sealed weatherproof container

18. Medical Services and First Aid29 CFR 1926.50 • Checked prior to the start of the job and weekly • Must be easily accessible

19. Medical Services and First Aid29 CFR 1926.50 • Proper equipment for prompt transportation or a communication system for contacting ambulance services • Telephone numbers of physicians, hospitals, or ambulances must be posted

20. Respiratory Protection29 CFR 1926.103 • Use feasible engineering controls • Respiratory hazard evaluations • Respirator selection and rescue procedures for IDLH atmospheres

21. Respiratory Protection29 CFR 1926.103 • Selected based on respiratory hazards to which worker will be exposed • Reasonable estimate of employee exposures • Estimate of contaminants physical and chemical state

22. Respiratory Protection29 CFR 1910.103 • Oxygen levels must be determined • Instrumentation required for determination

23. Respiratory Protection29 CFR 1926.103 • 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

24. 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%

25. Respiratory Protection29 CFR 1926.103

26. Respiratory Protection29 CFR 1926.103 • Procedures for entry into IDLH atmospheres: • Communications • Rescue team • Notification of employer prior to start of emergency entry for rescue

27. Fall Protection29 CFR 1926 – Subpart M • Employers relying on personal fall arrest systems must have pre-planned rescue procedures

28. Fall Protection29 CFR 1926 – Subpart M • Criteria for “prompt” rescue in Suspension Trauma/Orthostatic Intolerance OSHA information bulletin

29. 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 1910.146

30. Summary 29 CFR 1910.146 can apply to industrial painting projects if: • Work classified by OSHA as maintenance • Compliance required by contract or controlling employer’s written safety program

31. Additional Information • www.osha.gov • 29 CFR 1926 (Construction Industry Standards) • 29 CFR 1910.146 (Permit Required Confined Space Standards) • Letters of interpretation • Suspension Trauma/Orthostatic Intolerance Information Bulletin

32. Additional Information • http://www.ansi.org(American National Standard Institute) • ANSI/ASSE Z117.1: Safety Requirements for Confined Spaces • http://www.cdc.gov/niosh (National Institute of Occupational Safety and Health) • NIOSH Publication No. 87-113: A Guide to Safety in Confined Spaces

33. Questions