Confined Spaces in Construction: Applicable Standards
Stan Liang, CIH, CSP, CETKTA-Tator, Inc.
Webinar Objectives
Brief overview of the following: OSHA Construction Standards Applicability of OSHA General
Industry Standards
Resources for additional information
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
Permit Required Confined Space Standard
Compliance can be required by:•Contract specifications•Prime contractor’s safety program
Permit Required Confined Space Program Requirements
• Hazard identification• Hazard control• Entry permit• Specialized equipment• Employee designation
Permit Required Confined Space Program Requirements
• Testing and monitoring• Outside contractors• Emergency procedures
Construction Regulations
• Construction Standard requirements can be similar to that found in the General Industry Permit Required Confined Space Standard
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
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)
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
Safety Training and Education29 CFR 1926.21
• OSHA does not provide specific guidance on training requirements
• General requirement for compliance with applicable standards
Emergency Action Plans29 CFR 1926.35
• Plan must be in writing • Response procedure in the event of a fire or
other emergency
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
Emergency Action PlanElements
• Means of reporting fires and other emergencies
• Contacts for further information
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
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
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
Medical Services and First Aid29 CFR 1926.50
• Checked prior to the start of the job and weekly
• Must be easily accessible
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
Respiratory Protection29 CFR 1926.103
• Use feasible engineering controls
• Respiratory hazard evaluations
• Respirator selection and rescue procedures for IDLH atmospheres
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
Respiratory Protection29 CFR 1910.103
• Oxygen levels must be determined
• Instrumentation required for determination
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
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%
Respiratory Protection29 CFR 1926.103
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
Fall Protection29 CFR 1926 – Subpart M
• Employers relying on personal fall arrest systems must have pre-planned rescue procedures
Fall Protection29 CFR 1926 – Subpart M
• Criteria for “prompt” rescue in Suspension Trauma/Orthostatic Intolerance OSHA information bulletin
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
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
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
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
Questions