MIOSHA Part 35 Confined Space in Construction - Awareness - PowerPoint Presentation

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MIOSHA Part 35 Confined Space in Construction - Awareness(OSHA 1926.1201 SubPart AA)

Presented byMIOSHA Consultation Education and Training517-284-7720Slide2

AgendaProvide overview of the existing and new standardsDescribe roles of controlling owner/employer and individuals

Review training requirementsProvide resources and additional informationReview compliance policiesQuestion and Answer

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Part 35 Scope and ApplicationTo protect employees engaged in construction activities at a worksite with 1 or more confined space

Does not apply to the following:Excavation, Trenching and Shoring (Part 9)

Tunnels, Shafts, Caissons and Cofferdams (Parts

14 &

665)

Diving Operations (Part 504)

When Part 35 and another MIOSHA standard applies to confined spaces

(

except those listed above), employer must comply with both.Examples: Part 1 – General Rules and Part 7 – Welding and Cutting

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What is a confined space?Is large enough and so configured that an employee can bodily enter it;

Has limited or restricted means for entry and exit; and,Is not designed for continuous employee occupancy Must have all three to be a confined space!

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Examples of a Confined spaceBins, boilers, pits

ManholesTanksIncineratorsScrubbersConcrete pier columns

Sewers

Transformer vaults

HVAC ducts, Air receivers

Storm

drain, water

mains

Drilled shaftsEnclosed beamsVessels, digestersLift stationsCesspoolsSilosSludge gates

Air preheaters Step up

transformersTurbinesChillers Bag houses

Mixers/reactors

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What is a permit required confined space?

A confined space containing

one or more

of the following:

Hazardous atmosphere or potential to contain a hazardous atmosphere;

Material that has the potential for engulfing an entrant;

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; or

Any other recognized serious safety or health hazard

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Part 1 General RulesPart 7 Welding and CuttingRevised to reference Part 35 Confined Space in Construction

Revised Construction Safety Rules

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MIOSHA G.I. Part 90/490 & OSHA 1910.146

General Industry – Permit-required Confined Space Rules are similar to the new Construction Safety Part 35

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Is the Work Construction or Maintenance?

9

Construction

work would include:

construction

, alteration, and/or substantial repair (upgrades and improvements

)

painting

and decorating.The General Industry Standard would apply to “maintenance activities“Activities related to making or keeping a structure, fixture or foundation in proper condition, in a routine, scheduled, or anticipated fashion.

Maintenance involves "keeping equipment working in its existing

state, i.e., preventing its failure or decline.“Slide10

Overview of Differences: G.I. vs Construction Confined Space Rules

GI Standard, Plus:A competent person must conduct worksite evaluationEmployers using “alternate procedures” for permit space entry must prevent physical hazard exposures through elimination or isolation

(e.g. Lockout/Tag Out).

Permits may be suspended instead of cancelled, provided the space is returned to permit conditions prior to

re-entry

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Overview of Differences (continued)Continuous

monitoring of atmospheric and engulfment hazardsEmployers relying on local emergency services for rescue must arrange for responders to notify in advance if responders will be unavailableSpecific information exchange

requirements

for multi-employer

work sites

Image from: sewerhistory.org

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Confined Space in Construction:Who’s WhoHost EmployerControlling Contractor

Entry EmployerEntry SupervisorCompetent Person

Attendant

Authorized Entrant

Emergency Rescue Personnel

All have a specific jobs responsibilities outlined

in the Confined Space in Construction Standard

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1926.1203(a) general requirements: Before Work Begins

Each employer must ensure that a competent person identifies and evaluates all confined

and permit-required spaces.

Reprinted with permission: Waterhelp.org Project

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1926.1202/1203 Competent PersonDefinition: one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which

are:unsanitary,hazardous, or dangerous

to

employees

Has

the authorization to

promptly correct/eliminate hazards.

Identifies

all confined spaces in which employees it directs may workIdentifies each space that is a permit space. Evaluating all hazards. May included testing. Reevaluate and reclassify a space, if necessary

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1926.1203 general

requirements: Before Work Begins (continued)

If

the workplace contains one or more permit spaces

, the

employer must:

Inform

exposed

employees of the:Existence;Location; and,Danger posed by each permit space

Sign may be usedInform employees’ authorized representatives and

the controlling contractor:Timely

manner Manner other than

postingExistence, location of,

and danger

posed

by

each permit space

.

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Each employer must effectively prevent their unauthorized employees from entering the permit space.

1926.1203 general requirements - Prevent Entry or else…

Image Source: Brady Corporation

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1926.1203 general requirements – Written Program

Each entry employer must have a written permit space program implemented at the construction site. The written program must be made available prior to and during entry operations for inspection by employees and their authorized representatives

Accident Prevention Program and,

1926.1204 Permit Required Confined Space (PRCS) Program

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1926.1203 general requirements: Alternate Entry and Reclassification

Construction Part 35 CSC permits alternate entry:(e)(1) – Alternate Entry(g) - Reclassification

G.I. Part 490 PRCS

permits alternate entry:

(c)(5) – Alternate Entry

(c)(7)

- Reclassification

Image source: ehstoday.com

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1926.1203 general requirements: Alternate Entry Procedures - Overview

Eliminate or isolate physical hazardsEliminate unsafe conditions when opening the space cover and guard openingProvide forced air ventilationMonitor and inspect (pre-entry):

Oxygen

Flammable gasses/vapors

Potential toxic air contaminants

Make data available to employees or employee

representatives

Eliminate

hazardous atmosphereProvide continuous air monitoring during entry (some exceptions)Provide continuous forced air ventilation (during entry)Ensure a safe method of entering and exiting the space.

Maintain inspection, entry and monitoring recordsReevaluate space as

needed to protect employees

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What are Physical hazards?Physical hazard means an existing or potential hazard that can cause death or serious physical damage

Energy:MechanicalElectricalHydraulicPneumatic

Radiation

Noise

Physical hazard also includes chemicals that can cause death or serious physical damage through skin or eye contact (rather than through inhalation).

T

emperature

extremes

Explosives (see definition)EngulfmentOther hazards introducedInwardly converging

surfacesFalls

Examples

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Determined by a competent personSpace contains no actual or potential hazardous atmosphereElimination of hazard without enteringDocumentation of reclassification criteriaEmployee exit and return to permit

space classification if hazards arise1926.1203 general requirements:

Reclassification (e)(2

)(g) - Overview

HAZARDS

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Confined Space and PRCS Hazard and Procedures Information Exchange

Host Employer

Controlling Contractor

Sub Contractor

Sub Contractor

Pre entry

Pre entry:

Post entry debrief

Coordinate during entry

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Space:

-Location

-Hazards

-Precautions

Pre/post entry:

- Permit program

-Hazards present

or created

Controlling Contractor

Pre/post

entry:

-Permit program

-Hazards present

or created

Space:

-

Location

-Hazards

-PrecautionsSlide24

1926.1204 Permit Required Confined Space Program - OverviewEach Entry Employer Must:

Prevent unauthorized entryI.D. and evaluate hazards

Develop and implement safe entry: means, procedures and practices

Provide and ensure proper use of equipment

Evaluate permit space conditions for air contaminants

Provide attendant(s) outside space

Manage multiple spaces in an emergency

Assign duties to employees involved in permit space entry

Develop and implement procedures:Rescue and emergency servicesPrep, use and cancel entry permitsCoordinate entry with multiple employersConclude/close entry operationsReview entries and program; revise when needed

Annual review using cancelled permits

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Evaluate permit space conditions when entry operations are conducted: Before entry - test

conditions in the permit space before changing the space’s natural ventilation, Exceptions: If isolation of the space is infeasible because the space is large or is part of

a continuous

system (such as a sewer), the employer must

:

Perform

pre-entry

testing; and,

Continuously monitor entry conditions in the areas where authorized entrants are workingProvide an early-warning system that continuously monitors for non-isolated engulfment hazards.

1926.1204 Permit Required Confined Space Program (

e

):

Evaluation

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1926.1204 Permit Required Confined Space Program (e):Evaluation (continued)

Continuously monitor atmospheric hazards unless:Equipment is not

commercially available

OR

Periodic monitoring is sufficient to

ensure the

hazard at

are safe

levels. If continuous monitoring is not used, periodic monitoring is required with sufficient frequency to ensure acceptable entry conditions are maintained during the entry operations

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1926.1204 Permit Required Confined Space Program (e):Evaluation (continued)

Testing for atmospheric hazards:

Oxygen (Range = 19.5 to 23.5%)

Combustible

gases and

vapors

Measured by Lower Explosive Limit (LEL)

Toxic

gases and vapors:Permissible Exposure Limit (PEL)Test in that order!

O

2

CO

LEL

H

2

S

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Provide at least one attendant outside the permit space for the duration of entry operationsMay be assigned to more than one spaceMay be stationed at any location (outside)as long as duties can be performed If multiple spaces assigned to 1 attendant, document how emergencies will be managed without detracting from responsibilities for other spaces

Designate each person who has a role in entry operations:Identify their duties Provide training

1926.1204 Permit Required Confined Space Program (

f

)-(

h

)

Attendant:

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Summoning rescue and emergency servicesPreventing unauthorized personnel from attempting a rescue;

Preparing, issuing, using, and cancelling of entry permits Coordinating entry operations when employees of more than one employer

are working

simultaneously in a permit space or

where their activities may result

in a hazard within the confined

space

Concluding

the entry after entry operations have been completed

1926.1204 Permit Required Confined Space Program

(

i

)-(l)

develop and implement procedures:

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1926.1205 Permitting ProcessBefore entry each entry employer must:

Prepare an entry permit.Have entry supervisor sign the entry permit to authorize entry.

Make completed

permit

available to all entrants or their representatives

Posting at

the entry portal or

Other

equally effective meansThe duration of the permit may not exceed the time required to complete the task/job identified on the permit.

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1926.1206 Entry PermitThe entry permit

must identify:The permit space to be entered; The purpose of the entry;The

date and the authorized duration of the entry permit

;

The name/ID of authorized

entrants within the permit

space;

Means of detecting an increase in atmospheric hazard levels if ventilation system stops working;

Name of each person serving as an attendant;

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The entry permit must identify (continued):Name of the “on duty” entry supervisor and signature or initials of each entry supervisor who authorizes entry;

Hazards of the permit space to be entered;Measures used before entry to Isolate the permit

space

E

liminate or control hazards;

Acceptable

entry conditions;

Results

of tests and monitoring performed including:Names or initials of the testersNote when tests were performed;

1926.1206 Entry Permit

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1926.1206 Entry Permit

The entry permit must identify (continued):

Rescue

and emergency services that can be summoned and the means (such

as the

equipment to use and the numbers to

call);

C

ommunication procedures used by authorized entrants and attendants; Equipment to be provided (e.g. PPE, testing equipment, communications equipment, alarm systems, and rescue equipment);Other information

necessary to ensure employee safety; and

Additional permits (e.g. hot work) that have been issued to

authorize work in the permit space.

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1926.1207 TrainingThe employer must provide

training:At no cost to the employeeEnsures employee possesses understanding

, knowledge, and skills

to safely perform assigned duties

Results

in an understanding

of the hazards

and the methods used

to:Isolate, Control Protect employeesInstructs unauthorized employees in the dangers of attempting rescue.

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The employer must provide training (continued):In understandable language and vocabulary;

Before the employee is assigned duties; Before a change in assigned duties; Whenever

there is a change

that presents a new hazard

Whenever

there is any evidence of a deviation from the permit space entry

procedures or,

Whenever there

are inadequacies in the employee’s knowledge or use of the procedures1926.1207 Training

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The employer must provide training (continued):Establishes employee proficiency in the duties Introduce new or revised procedures, as necessary.

The employer must maintain training records including:Each employee’s name,

Name

of the trainers,

and

Dates

of training.

1926.1207 Training

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Duties and ResponsibilitiesAuthorized EntrantAttendantEntry Supervisor

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1926.1208 Duties: Authorized EntrantThe entry employer must ensure that all

authorized entrants:Familiar and understand the hazards

including exposure information

Properly use required equipment

Communicate

with the

attendant and

alert

the attendant whenever:There is any warning sign or symptom of exposure orThe entrant detects a prohibited condition

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1926.1208 Duties: Authorized Entrant (continued)

The entry employer must ensure that all authorized entrants (continued):Exit from the permit space as quickly as possible whenever:An

order to evacuate is given by the attendant or the entry supervisor

;

There

is any warning sign or symptom of exposure to a dangerous situation

;

The

entrant detects a prohibited condition; or An evacuation alarm is activated.

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1926.1209 Duties of Attendants

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1926.1209 Duties of AttendantsThe entry employer must ensure that each attendant:

Familiar and understand the hazards:Exposure modes, signs, symptoms Behavioral effects of hazard exposure in

entrants

Maintains

an accurate count

and identity of

authorized entrants in the permit

space

Remains outside the permit space during entry operations until relieved by another attendant; Communicates with entrants as necessary:Assess entrant status Alert entrants to

evacuate when necessaryAssesses

activities and conditions inside and outside the space to determine if it is safe for entrants to remain in the space

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1926.1209 Duties of AttendantsThe entry employer must ensure that each

attendant (continued):Orders entrants to evacuate immediately if any of the following occur:There is a prohibited

condition

T

he entrant exhibits behavioral

effects of hazard

exposure

There

is a situation outside the space that could endanger the authorized entrants If the attendant cannot effectively and safely perform all assigned dutiesSummons rescue and other emergency services if entrants need assistance to escape from permit space

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The entry employer must ensure that each attendant (continued):During entry, takes the following actions when unauthorized persons approach or enter a permit space:

Warn the unauthorized persons to stay away from the permit space;Advise

the unauthorized persons

to

exit immediately if they

have entered; and

Inform

the authorized entrants and the entry supervisor if unauthorized

persons have entered Performs non-entry rescues as specified by the employer’s rescue procedurePerforms no duties that might interfere with the attendant’s primary duties:Assess conditions during entryProtect the authorized entrants.

1926.1209 Duties of Attendants

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1926.1210 Duties of Entry SupervisorsThe entry employer must ensure that each entry supervisor:Familiar and understand the hazards including exposure information

Verifies by reviewing the entry permit:Any tests specified by the permit have been conductedProcedures and equipment are in place before endorsing

and allowing

entry to

begin

Terminates

the entry and cancels or suspends the

permit

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1926.1210 Duties of Entry SupervisorsThe entry employer must ensure that each entry

supervisor (continued):Verifies that rescue services:Are availableCan be summoned (system used is operable)Will notify the

employer

if services become unavailable

Removes

unauthorized individuals who enter or who attempt to enter the

permit space

during entry

operationsWhenever responsibility for a permit space entry operation is transferred:Determines that entry operations remain consistent with terms of the entry permitAcceptable entry conditions are maintained.

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1926.1211 Rescue and Emergency Services - EvaluateAn

employer who designates rescue and emergency services must evaluate: Rescuer’s ability to respond in a timely manner, considering the hazard(s) identified

;

Rescue

service’s

ability (proficiency) with rescue-related tasks

and

equipment, used to rescue entrants

from the each type of permit space identified

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Select a rescue team or service from those evaluated that: Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified

Is equipped for, and proficient in, performing the needed rescue servicesAgrees to notify the employer

immediately if rescue

service

becomes unavailable

1926.1211 Rescue and Emergency Services - Selection

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Inform each rescue team or service of the hazardsProvide the rescue team or service with

access to all permit spaces:From which rescue may be necessaryTo develop appropriate rescue

plans

To practice

rescue operations.

1926.1211 Rescue and Emergency Services – Information and Access

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Employees designated to provide permit space rescue:Training and PPE provided at no costTraining in use of PPE needed to conduct

rescues safelyTraining to perform assigned rescue duties and proficiency as authorized entrantsAt least

one member of

the rescue

team or service holding a current

certification in basic first aid and

CPR

is available

Practice (simulate) making permit space rescues before attempting an actual rescue at least once every 12 months.

1926.1211 Rescue and Emergency Services – Provided by Employee(s)

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Non-entry rescue is required unless the retrieval equipment would increase the overall risk of entry or would not contribute to

rescuing the entrant. Whenever non-entry rescue is selected, the entry employer must:

Ensure that retrieval

systems or methods are

used

Confirm

, prior to entry, that emergency assistance would

be available

in the event that non-entry rescue fails.If entry rescue is selected, the employer must designate an entry rescue serviceSDS or written information must be made available to the medical facility treating the exposed entrant

1926.1211 Rescue and Emergency Services –

Non-entry or Entry

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Retrieval systems requirements:

Chest or full body harnessGoal:Quick, safe removal and rescue in an emergency

Do not use:

Unsuitable retrieval equipment (

e,g

, entanglement or configuration of space

or other issues)

Retrieval line

- Attached center of back near shoulder and above head or other…and other end of line attached to:Mechanical device or fixed point outside the space (>5 ft deep)

1926.1211 Rescue and Emergency Services

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1926.1212 Employee ParticipationEmployers must:

Consult with affected employees and their authorized representatives on the development and implementation of all aspects of the permit space program.Make available to each affected employee and his/her authorized representatives all information required to be developed by this standard

.

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Additional InformationMIOSHA Confined Space in Construction webpageOSHA Small Entity Compliance guideOSHA Fact Sheets and FAQs

Standard InterpretationsGeneral Industry Standard – Permit-required Confined Space

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Questions?Michigan Occupational Safety & Health Administration

Michigan Department of Licensing and Regulatory Affairs www.michigan.gov/miosha

Consultation

Education & Training

Division

(

517)

284-7720

Construction Safety and Health Division(517) 284- 768054