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29 CFR 1926 Subpart AA
Confined Spaces in Construction
AJ Gajdosik, CSP, ARM-P
St. Louis ASSE Chapter Meeting
July 2015
What we’ll talk about today Necessity of the standard
Review of confined spaces
New requirements of Subpart AA
Resources available to you
Necessity of the standard
Why did we need a new standard?
Little guidance from
existing construction standard
General Industry
standard does not apply
Prevent alm
ost 800 serious injuries
1926.21(b)(6)
1926.21(b)(6)(i)All employees required to enter into confined or enclosed spaces shall be
instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas.
1926.21(b)(6)(ii)For purposes of paragraph (b)(6)(i) of this section, "confined or enclosed
space" means any space having a limited means of egress, which is subject to the accumulation of toxic or flammable contaminants or has an oxygen deficient atmosphere. Confined or enclosed spaces include, but are not limited to, storage tanks, process vessels, bins, boilers, ventilation or exhaust ducts, sewers, underground utility vaults, tunnels, pipelines, and open top spaces more than 4 feet in depth such as pits, tubs, vaults, and vessels.
General Industry1910.146(a)S
cope and application. T
his section contains requirem
ents for practices and procedures to protect em
ployees in general industry from
the hazards of entry into perm
it-required confined spaces. T
his section does not apply to agriculture, to construction, or to shipyard em
ployment
(Parts 1928, 1926, and
1915 of this chapter, respectively).
Review of confined spaces
Confined space Bodily enter
Limited or restricted means for entry and exit
Not designed for continuous employee occupancy
Permit-required confined space
A confined space
with a hazard
◦Hazardous
atmosphere
◦Engulfm
ent
◦Entrapm
ent
◦Any other serious
safety/health hazard
GI requirements Identify spaces
Inform employees
Restrict entry if not entering
Develop program if entering
Entry options Full PRCS Program
Alternate entry
Reclassify
New requirements of Subpart AA
Dr. Michaels statement
“This rule
emphasizes
training, continuous w
orksite evaluation and com
munication
requirements to
further protect w
orkers’ safety and health.”
Confined Space in Construction
If the employer is following the construction standard, he or she is in compliance with the general industry standard
Requirements Permits may be “suspended” instead of “cancelled”,
provided the employer conducts a full evaluation prior to re-entry
Employers must develop a plan for summoning local emergency services, and to contact them before starting work if relying on them for entry rescue
During alternate procedures entry, employers may control/isolate physical hazards instead of eliminating them
Effective date August 3, 2015
◦ Postponing full enforcement for 60 daysOctober 2, 2015
◦ No citation for “good faith efforts to comply”
1926.1202 Definitions
Controlling
contractor
Early-w
arning system
Entry em
ployer
Entry rescue
Host em
ployer
1926.1203Basic requirementsSpace evaluation must be done by a competent person
Continuous atmospheric monitoring when technology is available
Continuous monitoring for engulfment hazards if in a continuous system (sewers)
1926.1203(e)Alternate procedures
Eliminate or isolate all physical hazards
Demonstrate continuous forced air ventilation is sufficient
Develop monitoring and inspection data
If entry is required to get data the full permit is followed
Provide data to employees
Alternate procedures entry Remove cover safely
Install railing, cover or barrier
Test atmosphere
Ventilate
Continuously monitor
Safe entrance and exit
Certify space for safe entry
1926.1203(g)Reclassification
No atmospheric hazard
Eliminate all physical hazards without entry
Certify elimination of hazards
1926.1203 (h)Communication and coordination Before entry◦Host Employer - give controlling contractor
information if available
◦Controlling Contractor - must give information to entry employers
◦Entry Employer - must inform controlling contractor of their procedures
Communication and coordinationEntry and controlling employers must coordinate work during entry if:
◦More than one entity is in the space at the same time
◦Other activities could result in a hazard within the space
Communication and coordinationPost-entry information transfer
◦Entry Employer - Must give controlling contractor information about the space
◦Controlling Contractor - Must give information to host employer
1926.1207Training
Ensure the employee possesses the understanding, knowledge and skills necessary
In both a language and vocabulary that the employee can understand
1926.1211Rescue and emergency services
Time frame
Equipped and proficient
Agrees to notify the employer in the event the service becomes unavailable
Resources
Resources
OS
HA
http://ww
w.osha.gov/confineds
paces/index.html
◦C
onstruction C
onfined Spaces
topics pageS
tandard and Federal
Register
3 Fact S
heets
Fatal F
acts #12-2015
Case S
tudy
OTI Education Center Confined Space CoursesOSHA #2264 ◦Permit-Required Confined Space Entry
OSHA #7300 ◦Understanding OSHA’s Permit-Required
Confined Space Standard
DTE is updating the learning objectives to include the new rule. Tentative – Quarter 4, FY 2015
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