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OSHA’s new Confined Spaces for Construction, 29 CFR 1926.1200

The new standard for confined spaces in construction became effective August 3, 2015.  Employers engaged in construction on job sites or facilities where confined spaces are located or will occur as a result of construction activities have obligations under this standard to perform certain activities and protect their workers.

Confined spaces may include areas such as bins, boilers, tanks, pits (such as those for elevators, escalators, valves or pumps), sewers (such as storm drains, those for electrical, communication or other utilities), transformer vaults, heating, ventilation and air-condition ducts (HVAC), water mains, precast concrete, enclosed beams, pre-formed manhole units and more.

At quick glance, the new construction confined space regulation includes five key differences from the general industry standard:  

  1. Impact of Multi-Employer Information Sharing, the
  2. The need for a Competent Person for Evaluation of Spaces
  3. Continuous Monitoring for Atmospheric Hazards
  4. Continuous Monitoring for Engulfment Hazards
  5. Permit Considerations and Suspension

Employers,now specifically identified include, host facilities, controlling contractors and entry employers, will need to participate in identifying and evaluating confined spaces and their associated hazards.

Hazards in confined spaces may include: atmospheric, health or physical hazards and other concerns like:  fall exposures, noise, vibration, illumination, temperature extremes, hazardous energy, slips, trips or biological concerns.

A written program encompassing the elements of the standard is required forall employers.  Procedures for safe entry, identifying appropriate equipment, properly training employees on the hazards, precautions, job descriptions and emergency procedures are highlights this requirement.

The intent of this standardis to protect employees from confined space hazards on construction sites where there may be a lack of history to such spaces, dynamic job-site conditions that change frequently or transient workers that may flow in and out of work place activity.  The new regulation assigned information exchange obligations to all employers at a location based on the multi-employer workplace policy.  Information on: location of spaces, hazards or potential hazards, previous precautions taken are examples of what has to be communicated up and down stream to and from various employers on site.

Lastly, emergency procedures must be appropriately planned.  Rescue personnel must be able to respond in a timely manner, ensure the capability to reach a victim, be proficient in rescue,and be able to notify the employer if they are not able to respond.
Dennis M. Dougherty
Med-Tex Services, Inc.
ddougherty@med-texservices.com

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