Confined Spaces in Construction: Applicable Standards

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

• Brief overview of the following
• OSHA Construction Standards
• Applicability of OSHA General Industry Standards
• Resources for additional information

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Permit Required Confined Space Standard

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

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Permit Required Confined Space Standard

• Compliance can be required by
• Contract specifications
• Prime contractors safety program

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Permit Required Confined Space Program
Requirements

• Hazard identification
• Hazard control
• Entry permit
• Specialized equipment
• Employee designation

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Permit Required Confined Space Program
Requirements

• Testing and monitoring
• Outside contractors
• Emergency procedures

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Construction Regulations

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

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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

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Safety Training and Education29 CFR 1926.21

• Examples of confined spaces include

Storage tanks Process vessels
Underground utility vaults Tunnels
Pipelines Ventilation and exhaust ducts
Open top spaces (more than 4 feet deep)

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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

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Safety Training and Education29 CFR 1926.21

• OSHA does not provide specific guidance on
  training requirements
• General requirement for compliance with
  applicable standards

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Emergency Action Plans29 CFR 1926.35

• Plan must be in writing
• Response procedure in the event of a fire or
  other emergency

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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

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Emergency Action PlanElements

• Means of reporting fires and other emergencies
• Contacts for further information

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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

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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

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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

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Medical Services and First Aid29 CFR 1926.50

• Checked prior to the start of the job and weekly
• Must be easily accessible

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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

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Respiratory Protection29 CFR 1926.103

• Use feasible engineering controls
• Respiratory hazard evaluations
• Respirator selection and rescue procedures for
  IDLH atmospheres

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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

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Respiratory Protection29 CFR 1910.103

• Oxygen levels must be determined
• Instrumentation required for determination

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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

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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

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Respiratory Protection29 CFR 1926.103
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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

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Fall Protection29 CFR 1926 Subpart M

• Employers relying on personal fall arrest systems
  must have pre-planned rescue procedures

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Fall Protection29 CFR 1926 Subpart M

• Criteria for prompt rescue in Suspension
  Trauma/Orthostatic Intolerance OSHA information
  bulletin

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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

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Summary

• 29 CFR 1910.146 can apply to industrial painting
  projects if
• Work classified by OSHA as maintenance
• Compliance required by contract or controlling
  employers written safety program

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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

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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

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Questions