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

For further assistance◦Call your Agent◦Contact ACUITY Loss Control at 1.800.242.7666◦Send an email to ACUITYEducation@acuity.com

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