1926 Subpart AA Confined Spaces in Construction Lee McKinney, CIH Consultative Services Occupational Safety and Health Division
What are we doing today 1926.1201(a) What we are talking about PRCS - Decision Tree Not training Today
Objectives Identify Confined Spaces in Construction work Follow the decision tree Activity!
Subpart AA Background General Industry Standard published 1993 United Steelworkers settlement 1994 Proposal for Confined Spaces in Construction held in 2007 Final Rule published May 4, 2015; effective August 3, 2015 Enforcement began on October 2, 2105.
Clarifications Subpart P still covers work in excavations If there is a confined space within an excavation, such as a sewer pipe, and a worker enters the pipe to perform work, that is covered by Subpart AA Subpart S still covers underground construction Work done in an underground space that does not involve altering the *structure* of the space is covered by Subpart AA (such as equipment installs)
Differences between GI and Subpart AA A competent person must conduct worksite evaluation alternate procedures for permit space entry must prevent physical hazard exposures through elimination or isolation through methods such as LOTO Permits may be suspended instead of cancelled, provided the space is returned to permit conditions prior to re-entry
Continued differences Continuous monitoring of atmospheric and engulfment hazards Employers relying on local emergency services for rescue must arrange for responders to notify in advance if responders will be unavailable Specific information exchange requirements for multiemployer work sites
Information Exchange Host Employer Controlling Contractor Sub Contractor Sub Contractor
WHERE ARE THE PROBLEMS?
Identifying confined spaces 1) Large enough for a person to enter 2) Difficult to exit in the event of an emergency 3) Is not intended for regular human occupancy
Permit-Required Confined Space Contains or has a potential to contain a hazardous atmosphere; Contains a material that has the potential for engulfing an entrant; Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section
Permit Confined Space Hazards Atmospheric hazards H2S, CH4,CO, low O2, high O2, toxic gases, particulates, Corrosives, Acids Acute Exposure Hazards
Continued Explosive Hazards flammable gases in concentrations above 10% LEL, combustible dusts Physical Hazards fall, struck-by, electrical, temperature, ergonomics, noise
Creating Hazardous Environments Cleaning with chlorinated solvents in areas that contain hot surfaces like heating pipes Welding on a surface with residual chlorinated solvent Degreasing operations
Competent Person New Capable of identifying existing and probable hazards Authority to take corrective actions Must Identify all confined spaces On a multi-employer jobsite who is responsible then?
Competent Person Identify all confined spaces Identify all permit confined spaces Post and identify the spaces for everyone else Identify specifically which spaces the company s employees will enter
Competent Person Employer and CP must ensure their permit space program complies with requirements in section 1204 of the standard If no one is entering Prevent all unauthorized access
What is a permit space program? A permit space program is a plan that includes: Identification and evaluation of the hazards in the permit space 1204(b) Measures that will be used to prevent unauthorized entry 1204(a) Means, procedures, and practices needed for safe entry, including: 1204(c)
Training Each Affected Employee In a language and vocabulary the employee can understand 1207(b)(1) Before assigned duties Anytime there is a change to Assigned duties Permit space entry Deviation from permit safety procedures
Training Questions Where s your paperwork! Employee s name Trainer s name Dates of training
Rescue Non-entry rescue must be provided A mechanical device must be available if entrants are more than 5 feet deep
Designating Rescue Evaluate rescuer s ability to respond For example, 1926.103 (Respiratory protection) requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres. Agrees to notify employer immediately in the even of a rescue service becomes unavailable
Rescue The employer must inform the rescue service of the hazards they may confront Should have been identified by competent person Someone should have a list. The employer must provide the rescue service with access to all permit spaces from which rescue may be necessary
IMIS Data
Citations Inspections Penalty Industry Classification 596 223 $1,522,017 Total for All Industries 51 15 $96,960 3273 / Cement and Concrete Product Manufacturing 28 4 $49,549 3331 / Agriculture, Construction, and Mining Machinery Manufacturing 22 8 $64,405 2382 / Building Equipment Contractors 19 1 $16,769 3353 / Electrical Equipment Manufacturing 18 9 $26,230 2131 / Support Activities for Mining 17 2 $16,800 8111 / Automotive Repair and Maintenance 16 3 $13,800 5629 / Remediation and Other Waste Management Services 14 3 $445,930 4882 / Support Activities for Rail Transportation
On December 8, 2010, Employees #1, #2, #3 and #4 were working at a multi-employer worksite. Employees #1 and #2 worked for one employer, and Employees #3 and #4 worked for another employer. Employee #1 was assigned the task of demolishing an abandoned septic tank. Employee #1 entered the tank and attempted to break the floor of the tank. An explosion occurred, and Employee #1 was injured in the blast. Employees #2, #3 and #4 were also injured by the blast.
September 2013 Richard C. "Rick" Whitney Jr., 58, an employee of Joy Process Mechanical, was welding a pipe inside a methane gas dome at the plant when the explosion occurred. He suffered third-degree burns to most of his body and died three days later at a burn center in Boston
The employer did not furnish employment and a place of employment which was free from recognized hazards that were causing or likely to cause death or serious physical harm to employees in that employees were exposed to hazardous atmospheres while working in a permit required confined space: a) On or about 9/11/2013, Canastota Waste Water Treatment Facility: Employee performing welding and cutting operations inside of a "Methane Collection Dome" was exposed to a hazardous atmosphere caused by Methane gas.
On January 23, 2014 Employee #1, hired by a septic service contractor, and Coworkers #1, #2, and #3, also working for the contractor, were assigned to clean out a building's septic tank. They were suctioning out the septic tank. Employee #1 entered the tank to shovel the excess waste to the suction hose. He worked inside the tank for approximately 30 minutes. Employee #1 then called for the ladder to exit the tank. When he did not exit, Coworker #1, who was working outside the tank, looked into the tank and saw Employee #1 lying on the tank floor.
Coworker #1 entered the tank, wrapped a water hose around Employee #1, and with the help of Coworkers #2 and #3 pulled Employee #1 out of the tank. Emergency services were called, and emergency responders pronounced Employee #1 dead at 2:58 p.m. on January 23, 2014. Washington State OSHA investigated and determined that Employee #1 was not a regular employee of the septic service contractor;
On September 21, 2011 Employee #1 and Employee #2 of Stevens Electric & Pump Service, Inc., were found dead inside a sewer tank, a confined space. They died from exposure to hydrogen sulfide. The space had been improperly isolated, no air monitoring had been performed, no air supplied to the space and no retrieval system used by the person entering into the confine space.
SN67 NC Interpretation of Concrete Is it a confined space? Mixing Trucks
Mechanical / Health Hazards Rotation of drum Silica exposure Chemical exposures What are the created hazards?
Permit-Required Confined Space standard was the most frequently cited standard in federal fiscal year 2014 for SIC code 3273: Ready-mixed concrete. 51 citations over 15 inspections for $96,960
Consultative Services Pamphlets and information up front Free General Schedule Inspection Deferral Assist with safety and health programs Answer questions about compliance Assist in qualifying for recognition/exemption programs like SHARP
Lee McKinney, CIH OSH Division/Consultation Charlotte Field Office 704-665-6801