Lessons from a Deep, Dark Confined Space: A Case Study and ... miller aiha... · Confined Spaces in...

September 17, 2015

Lessons from a Deep, Dark Confined Space: A Case Study and A Brief on the New Construction Standard

Presented by Sally K. Miller, CIH

and Patrick Walz, PE

AECOM

Confined Spaces in Construction:

OSHA’s Final Rule

• History and Timeline of the Final Standard

• Construction Standard Overview

• Main Differences between the General

Industry and Construction Standards

• Effect on Other OSHA Standards

• Minor Differences, Subtle Effects and Nuanced

Interpretations

History and Timeline

29 CFR 1926, Subpart AA:

Confined Spaces in Construction

1979:

Const. CSE

Training

Provision

issued

1993: Gen.

Ind. CSE

Std.

1910.146

issued

OSHA

agreed to

propose

Const. CSE

Std.

2003: Draft

Const. Std.

developed

2007:

Proposed

Const. CSE

Rule

published

May 4,

2015: Final

Rule

published

Aug. 3,

2015: Rule

effective,

but

extension

granted

Oct. 3,

2015:

Const. CSE

Std.

EFFECTIVE


29 CFR 1926, Subpart AA • 1926.1201 Scope

• 1926.1202 Definitions

• 1926.1203 General Requirements

• 1926.1204 Permit Required Confined Space Program

• 1926.1205 Permitting Process

• 1926.1206 Entry Permit

• 1926.1207 Training

• 1926.1208 Entrants

• 1926.1209 Attendants

• 1926.1210 Entry Supervisors

• 1926.1211 Rescue

• 1926.1212 Employee Participation

• 1926.1213 Provision of Documents

General Industry vs. Construction?

Final Construction Confined Space Standard =

General Industry Confined Space Standard

“Plus”

Construction CS Standard: Overview

• What is a confined space?

– Large enough to enter

– Limited or restricted means for entry and exit

– Not designed for continuous employee occupancy

• Examples in Construction: Tanks, bins, boilers,

vaults, sewers, elevator pits, manholes, crawl

spaces, attics…


• What is a Permit Space?

A confined space with one or more of the

following:

• Contains or has potential to contain hazardous

atmosphere

• Contains engulfment hazard

• Configured so as to pose entrapment or asphyxiation

risk

• Contains any other recognized serious hazard


What does the Employer need to do?

• Competent person must identify CS and evaluate

– Are they Permit Spaces?

• Decide if your employees will enter permit spaces

• If no, must take steps to prevent your employees from entering

• If yes, employer becomes Entry Employer

• Post DANGER signs to inform all on site

• Develop and post permits for entrants


• Entry Employer must develop Permit Space

Program

– Plans for training for exposed employees, attendants,

entrants & entry supervisors; also rescuers

– Plans for elimination or isolation of physical hazards

– Plans for testing, monitoring and ventilating

– Determination of required PPE

– Plans for rescue and summoning emergency help

– Annual program review


What’s Different?

• Continuous monitoring of

atmospheric required

• Early-warning system for engulfment hazards

required

• Emergency responders required to agree to

notify employer if they are unavailable


Multi-Employer Worksites

• Specific information exchange for multi-

employer worksites required

– Host Employer

• Owns or manages property

– Controlling Contractor

• Has overall responsibility for construction at site

– Entry Employer

• One who decides that an employee it directs will enter

a permit space


Information Exchange

Host Employer

Controlling Contractor

Entry Employer Subcontractor

Pre-Entry Post-Entry

Coordinate

during entry

Pre-EntryPre-EntryPost-Entry

Post-Entry


What’s Different?

• Alternate Procedures: It’s now allowable to

prevent exposure to physical hazards through

isolation (not just elimination)

• Permits may be suspended (instead of

cancelled) in response to temporary changes

• If you’re doing both construction and

maintenance, follow Construction Standard


Effect on Other Standards

• Rule does replace any other construction

standard (except old CS standard)

• Subpart V- Power Transmission, Generation &

Distribution

– Now requires compliance with Subpart AA

– “Enclosed Space”- one designed for periodic

employee entry under normal conditions

• Do hazards interfere with escape?

• What is a “normal” atmosphere in the space?


Effect on Other Standards

• Explicitly excluded from the rule:

– Subpart Y - Diving

– Subpart P - Excavation

– Subpart S - Underground Construction, Caissons, Cofferdams

• OSHA “taking this opportunity” to clarify scope of Subparts P and S

– Key question is: Excavation vs. non-excavation work?

Other Exemptions?

• Home construction is NOT

exempted

– Crawl spaces, basements,

cabinets, etc., are not inherently

free of atmospheric or physical

hazards

– But, in new construction,

employers should organize work

practices to avoid placing

workers in confined spaces

Clarifications in Subpart AA

• Controlling a hazard

– An action that reduces the hazard level in the space

• Isolating a hazard

– Process used to completely protect entrants from the release of energy or other hazard into the space

• Eliminating the hazard

– Removing the hazard from the space completely


• Limited or restricted means for entry or exit

– Applies when an entrant’s ability to escape in an

emergency would be hindered

– Includes trip hazards, poor lighting, slippery floors,

inclining surfaces, ladders and even stairs - if they

impede egress


• Noise is a physical hazard

– Will only trigger permit space procedures if it

reaches a level at which it can cause death or

serious physical damage

• In other words, if it is loud enough to interfere with

critical communication

– Can address in permit program by using non-

auditory cues (flashing lights)


• Training must be in the language and

vocabulary that employees can understand


OSHA’s Final Rule: Summary

• Numerous clarifications plus 5 key differences:

– Employers on site must coordinate activities

– Competent person must evaluate site

– Employers must conduct continuous air

monitoring

– Employers must conduct continuous monitoring

of engulfment hazards

– Employers can suspend a permit for temporary

changes

September 17, 2015

Lessons from a Deep, Dark Confined

Space: Amistad Dam Case Study

• Background

• Scope: Penstock Inspection

• Pre-Task Planning

– Hazard Identification

– Hazard Mitigation

• Implementation and Change Management

• Lessons Learned

September 17, 2015

Amistad Dam: Background

• Constructed by International Boundary Water

Commission (Joint US/Mexico agency that controls

the Rio Grande) in 1969

– Located 12 miles northwest of Del Rio, Texas

MS14

MS14 Shoulde this say "via vertical gate shafts"? Miller, Sally, 9/13/2015

September 17, 2015

Amistad Dam: Background

• Penstock connects reservoir to power generating stations– ~12-foot diameter circular tunnel

– Located 200 feet below dam deck, 150 feet below reservoir level

– Significant side slope – 15-20 degrees

• Only access points from downstream (requires SCUBA) or vertically via gate shafts

MS13

MS13 Shoulde this say "via vertical gate shafts"? Miller, Sally, 9/13/2015

September 17, 2015

Insert dam surface photos

September 17, 2015

Scope: Penstock Inspection

• Damage to penstock rendered it ineffective;

IBWC desired design to permanently plug the

penstock

• Required personnel to enter in order to inspect

and document current conditions of steel and

concrete

• Use instruments (electrodes and other sensors)

and collect chip samples of concrete and steel

Sounds simple, right?

September 17, 2015

September 17, 2015

Pre-Task Planning: Hazard

Identification & Evaluation

• Lockout/Tagout of gate

• Unsophisticated safety protocols

on-site

September 17, 2015

Hazard

Identification

• Confined-Space entry

– Engulfment (from upstream)

– Drowning (if slide

downstream)

– Very slow retrieval from

space

• Isolated work site

September 17, 2015

Pre-Task Planning: Hazard Mitigation

• Developing Lockout/Tagout protocols

• Designing back-up engineering control for steel gate

suspension by structural engineer (use of I-Beams)

Beams secured via

webbing to handrail and

column. Tied with a

‘clover’ knot.

Below each beam

is two 2”x12”

boards (8 ft long)

September 17, 2015

Pre-Task Planning: Hazard Mitigation

• Hiring qualified subcontractor

to design fall protection system

and confined space rescue

protocol

September 17, 2015

Pre-Task Planning: Hazard Mitigation• Developing a comprehensive Entry Permit, HASP &

Contingency/Rescue Plan, reviewed at highest levels of organization’s Safety management team

• Performing safety inspection and practice run prior to actual entry

September 17, 2015

HASP Development/Review took HASP Development/Review took HASP Development/Review took HASP Development/Review took approximately 100 personapproximately 100 personapproximately 100 personapproximately 100 person----hours, hours, hours, hours,

compared to approximately compared to approximately compared to approximately compared to approximately 45 person45 person45 person45 person----hours hours hours hours for the actual inspection.for the actual inspection.for the actual inspection.for the actual inspection.

September 17, 2015

Implementation & Change

Management

• LOTO procedures implemented.

• Engineering controls (beams) required modification; required

concurrence from structural engineer before proceeding.

September 17, 2015


Management

• Fall protection/rescue zone establishment

• Practice run indicates extraction is too slow for comfort –

AECOM personnel trained to assist with lift (pulling ropes)

during rescue

September 17, 2015


Management• Air quality checks (probe dropped from surface) find

conditions in penstock ideal.

• Safety inspection finds no odors, relatively good traction, comfortable temperature, little mud, good setup by subcontractor.

September 17, 2015


Management• Scaffold tie-offs insufficient and improved prior to inspection.

• Inspection completed 8 hours without incident.

• Project scope successful.

• AECOM awarded additional work.

September 17, 2015

Lessons Learned• Pre-Task Planning crucial; short-duration

projects are no exception

• Client procedures – Trust, but Verify!

• Staff projects for safety:

– Employee expertise, experience & comfort level

(fear of heights, claustrophobia)

– Subcontractor expertise and flexibility

• Teamwork!

Thank you!

Sally K. Miller, CIH

AECOM

Denver, CO

720-483-3976

[email protected]

Patrick Walz, PE

AECOM

Austin, TX

512-221-3195

[email protected]

September 17, 2015

Questions?

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