The long-awaited confined spaces in construction standard, 1926 Subpart AA, is finally here.
OSHA published the new standard on 4 May 2015 with an initial implementation date of 3 August 2015. However, as with all new regulations, it takes time to gear up and train staff. As a result, OSHA recently issued a 60-day temporary enforcement policy to allow employers to train staff and fully comply with the new regulation. OSHA released the following statement on 9 July regarding the 60-day enforcement policy:
During this 60-day temporary enforcement period, OSHA will not issue citations to employers who make good faith efforts to comply with the new standard. Employers must be in compliance with either the training requirements of the new standard or the previous standard. Employers who fail to train their employees consistent with either of these two standards will be cited. (OSHA.gov)
Full enforcement of the new standard does not begin until 2 October 2015. Before this date, OSHA expects employers to establish all relevant compliance components and will continue to enforce the existing 1926.21(b)(6)(i) standard that states:
All employees required to enter into confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas.
Confined Space Defined
The new confined spaces in construction standard will use the same existing general industry definitions for confined spaces and permit-required confined spaces.
A confined space is any space that meets the following criteria:
- Is large enough and so configured that an employee can bodily enter it
- Has limited or restricted means for entry and exit
- Is not designed for continuous employee occupancy
Permit-Required Confined Space
A permit-required confined space* is a space that meets the definition of a confined space and it has one or more of the following characteristics:
- 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
- Contains any other recognized serious safety or health hazard
*In both general industry and construction, all permit-confined spaces must be labeled with a sign reading “Danger – Permit-Required Confined Space, Do Not Enter”.
Confined Space in Construction
The new confined space standard for the construction industry is considerably more extensive than the existing standard and is similar to the general industry confined space rule but with several enhancements for construction work including:
- A competent-person must evaluate the work site and identify confined spaces, including permit-required spaces
- When there are multiple companies at a worksite, the companies must have detailed provisions to ensure hazards are not introduced into a confined space while workers are inside spaces (e.g. one company running a generator near the entrance of a confined space while another company is working inside the space)
- While confined space is performed, continuous atmospheric monitoring of the space is required, whenever possible
- When engulfment hazards are present in the space, continuous monitoring for the engulfment hazards is required (e.g. when workers are performing work in a storm sewer and a storm upstream from the workers could cause flash flooding, an electronic sensor or observer should be posted upstream from the site to alert workers at the first sign of hazard)
- Allows a permit suspension rather than cancellation in the event of changes in the entry conditions listed on the permit or an unexpected event requiring evacuation of the space. However, the space must return to the entry condition listed on the permit before re-entry occurs
Written Confined Space Entry Plans and Confined Space Training
OSHA requires employers to develop written plans if any of their employees will enter a permit-required confined space. These programs must include a confined space inventory, measures necessary to prevent unauthorized entry, procedures to ensure safe entry, required equipment, rescue procedures and training.
Thorough training on confined space entry is not only required for every employee that is involved in any confined space entry, it is critical to ensure a safe workplace. Whether you are the entrant, attendant, supervisor, rescue personnel or the competent person involved in a confined space entry, training is required.
OSHA requires employee training before assignment to confined space duty, whenever there is a change in the confined space operations that present new hazards, whenever there are deviations from the entry procedures or there are inadequacies in an employee’s knowledge.
If your organization does not already have a confined space program, Anfeald can work with you to develop a program that meets these new standards. For organizations with existing plans, Anfeald can provide trustworthy review, auditing and supplementary recommendations to ensure your plan is compliant with all of OSHA’s standards.
Anfeald offers customized training courses for all personnel involved in a confined space entry and will ensure your team has the understanding, knowledge and skills necessary for safe performance of the duties assigned to each employee.
Even if you or your team have completed a confined space entry training, it may be time for a retraining. While OSHA has no annual retraining requirements, Anfeald recommends that employers retrain their employees on an annual basis.
So contact Anfeald to discuss how we can help train your staff for any Confined Space entry scenario!