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Confined Space Entry in Construction

Monday, June 29, 2015
Confined Space Entry in Construction
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OSHA recently published a final rule covering confined spaces in construction. The new standard becomes enforceable on August 3, 2015.

On the surface, it appears the new standard is directed only to the construction industry, but provisions in the new law also apply to facility owners, property managers, general contractors, and construction managers. These entities need to understand their specific compliance obligations under the new law.

The new standard for the construction industry is largely fashioned after a similar confined space entry standard for general industry was issued in 1993. Major provisions of the standard include:

  • Identification and communication of all confined spaces at jobsites
  • Development of a written confined space entry program
  • Classification of the confined space
  • Specific procedures for entry into confined spaces
  • Coordination with controlling employer and host employer
  • Development and use of a confined space permit and permit system
  • Rescue and emergency services
  • Training

Unfortunately, the majority of accidents in confined spaces result in the death of at least one worker. This is because the atmosphere in the confined space is incapable of supporting life, and death occurs very quickly. Statistically, there are more than two workers killed in confined spaces because one or more workers attempt to save the worker who becomes unconscious and become victims themselves.

To comply with the new standard, contractors who must enter and work in potentially dangerous confined spaces must:

  • Provide competent persons to identify potentially dangerous confined spaces
  • Provide training for all personnel involved in confined space entry operations
  • Acquire the equipment necessary to safely enter and work in confined spaces

 

Similar to the standard written decades ago for manufacturing and industry, the construction confined space entry standard can be confusing. We recommend contractors, and manufacturers and industries impacted by the new standard, attend and participate in informational workshops so they fully understand their compliance responsibilities and the steps necessary to develop and implement a compliant program.

Deaths in confined spaces are easily prevented, but contractors must first recognize, control, and prevent the unauthorized entry into potentially dangerous confined spaces.

An example of a confined space accident in which two employees were severely burned involved two elevator mechanics welding in the elevator pit of a building under construction. Plumbers working in the same building were using PVC primer and cement which is flammable and the vapors more than twice as heavy as air. The vapors migrated into the elevator pit and when the concentration reached the lower explosive limit, the vapors ignited burning the two workers severely.

The variability of construction operations, combined with unknown hazards present in a customer’s confined spaces, require the recognition of such conditions by competent persons employed by the contractor. The new law also recognizes the critical role of facility owners and managers in communicating the hazards associated with potentially dangerous confined spaces in the facilities they manage and operate.

Horton will be scheduling an informational workshop on this topic in the fall. Affected trade contractors, general contractors, facility owners and managers should attend. The agency will be closely evaluating compliance with this new standard including the obligations of facility owners and managers. Because the consequences of not having a confined space program are likely to result in death, the citations and penalties issued will likely be severe. The worst time to learn about this new standard is after an OSHA inspection or, worse yet, after an accident.

Interpretation of the standard can be somewhat confusing and complicated. If you have any questions concerning the new rule, please contact Horton Safety Consultants at 708-845-3662.

 

Material posted on this website is for informational purposes only and does not constitute a legal opinion or medical advice. Contact your legal representative or medical professional for information specific to your legal or medical needs.

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