Confined Space Safety in Construction

You have likely been following the General Industry guideline as a best practice if your business is in the construction industry and you work in tight places. Up until now, the sole prerequisite for restricted space construction was that the workers were involved in getting training. Despite the lack of restrictions, many businesses willingly go above and above what is expected of them since they understand the inherent hazard in tight places. The recently issued Final Rule for Confined Spaces in Construction (29 CFR 1926 Subpart AA) will take effect on August 3, 2015, eliminating the need for a decision.

Although this may seem difficult for some, the new laws do not completely replace the General Industry norm. If you were following the GI rule, to begin with, it shouldn't be too difficult to follow the new one as it just differs slightly and makes a few clarifications.

Construction or general industry

Identifying whether you must adhere to the construction rule or the general industry rule should be your top focus. Avoid making this choice any more challenging than it needs to be. You must abide by the construction regulation if you are undertaking any type of construction, demolition, remodeling, etc. If you are performing maintenance, engaging in routine business operations, or any other work that is not related to construction, you must abide by the usual industry practice.

Once you've decided you must adhere to the construction rule, you may use this page as a comparison chart to make sure you comply. The following modifications should be reflected in your organization's health and safety policy as well as staff training. Keep in mind that you are already familiar with the majority of the standards because you have been adhering to the general industry regulation (however, if you have not been following the general industry rule, stop now and get confined space training for your employees before proceeding with any confined space work).

Coordination of Efforts

When several contractors are operating in/around limited locations, the new guideline calls for more collaboration. If you're a construction manager or general contractor, pay heed because, according to the wording used in the multi-employer workplace policy, the "Controlling Contractor" will be your primary source of information on restricted spaces. The controlling contractor is in charge of relaying information in both directions, from the host employer to the contractors about the presence and nature of confined spaces on the premises to the contractors' confined space policies and any hazards they encounter when entering to the host employer. There is also a requirement for lateral communication: it is the Controlling Contractor's duty to advise other entry employers of any hazards or other problems that might not have been anticipated by one entry employer. It is now expressly the Controlling Contractor's duty to make sure that neither contractors operating inside the space nor those working outside it endanger other entry employers.

Competent Person

In case you "forgot," an OSHA-defined Competent Person is someone who possesses both the knowledge to identify a hazard and the power to address it (not just one or the other...both). The new regulation defines this term for restricted spaces and mandates that an assessment of the worksite and identification of all confined spaces be made by a Competent Person.

Monitoring of the Atmosphere Continuously

I like to imagine that with the development of smaller, quicker, real-time devices with longer battery lives, continuous air monitoring became more commonplace but was not always necessary. It is now needed whenever possible in the building regulation.

Ongoing evaluation of Risks

The new regulation mandates continual monitoring upstream when engulfment by water or other flowable material is a possibility to safeguard participants from an unanticipated danger. OSHA used the example of employees in a storm sewer who may be submerged in water in the case of a storm's flash flood. Mechanical or human monitoring, with direct access to the participants or attendees, may be used to keep an eye on the environment.

Suspension of Permit

In the past, the permit had to be rescinded and reapplied for whenever there was a change in the circumstances influencing the restricted area. The permission may be suspended under the new regulation. In essence, the same thing is happening — work is stopped, but this permits the workers to return and resume working without requiring the issuance of new permission.

Program for Working Without a Permit

By saying that an employer who enters a confined area without a comprehensive permit program is required to safeguard the employees by removing the danger or utilizing isolation techniques like lockout/Tagout, the construction rule explains a part of the general industry regulation.

Emergency assistance

If you are relying on local emergency services to act as your rescue team, hopefully, you have already contacted them to let them know that you are depending on them, checked to make sure they are trained in confined space entry rescue, and have the right equipment to help you, invited them to your site so they can become familiar with your confined spaces, and decided that their response time is adequate for your needs. Additionally, the new regulation mandates that you make arrangements for those emergency services to get in touch with you in case they are delayed in responding for whatever reason (such as their rescue team getting called away to perform a rescue on a different site). This is significant since it is very plausible that in many previous situations, there was no contact. An entry-level employer could have been operating in a small area, believing they were fully prepared, only to learn that an emergency prevented their response team from arriving.

Language

According to the new regulation, firms must provide employees with training in a language they can comprehend. Sad to say, this had to be written at all. It goes without saying that if an employee struggles to comprehend the instruction, they have not learned anything and have not received any training.

Exemptions

Any work covered by Subpart P (Excavations), Subpart S (Underground Construction, Caissons, Cofferdams, and Compressed Air), or Subpart Y is exempt from the new regulation (Diving). That is not to imply that there is nothing that needs to be done for those kinds of tasks; rather, it is to say that the tasks are outlined in those subparts and not in Subpart AA (Confined Spaces in Construction).

A few definitions have been added, but no new criteria have been introduced other than those. To guarantee compliance with OSHA, read the confined spaces document, comprehend it, identify the sections that pertain to you, revise your policy, and train your staff. And above all, always work safely. Confined Spaces may be extremely hazardous environments.