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NFPA Issues New Guide for Confined Spaces

Thursday, January 07, 2016
“Up until now, requesting or researching OSHA Letters of Interpretation or checking with other safety professionals was the means to get a clearer picture of ‘how’ to accomplish safe and compliant confined space entry. NFPA's Guide for Safe Confined Space Entry (NFPA350) helps to bridge that area from regulation to compliance. It is a ‘must have’ resource for safety professionals, confined space owners/workers and rescuers as well,”  states, Dennis O'Connell, Director of Training for Roco Rescue, who served as an alternate committee member for NFPA 350.

Here's more from NFPA on their new guide...

Every year, confined space incidents result in worker deaths, injuries, and serious illnesses. The danger is widespread because all facilities can have confined spaces - from commercial buildings and hospitals to public works, utilities, and chemical/industrial facilities. By U.S. law, employees must comply with applicable regulations such as OSHA's 29 CFR 1910.146 and 29 CFR 1926 Subpart AA to ensure personnel safety. However, these regulations tell you 'what' to do, not 'how' to identify, evaluate, and control confined space hazards or conduct rescue response.

NFPA has just introduced NFPA 350: Guide for Safe Confined Space Entry and Work. This all-new guide is essential for anyone who enters confined spaces, along with facility managers, code officials, and safety personnel. NFPA 350 explains how to protect workers who enter into confined spaces for inspection or testing, or to perform associated work. Provisions address the full range of special hazards, including those present in water treatment, petrochemical, and agricultural facilities. It provides information to assist companies that need to comply with OSHA's Permit-Rquired Confined Spaces (29 CFR 1910.146) among other standards. In addition, NFPA 350 helps fire service and emergency services personnel develop and evaluate plans for confined space rescue in conjunction with NFPA 1670: Standard on Operations and Training for Technical Search and Rescue Incidents.

This guide will help you be prepared to recognize, evaluate, and control confined space entry hazards. Follow practices developed by experts for: 

    • • Identification of Confined Spaces
    • • Evaluation of Hazards
    • • Atmospheric Monitoring
    • • Hazard Elimination and Control
    • • Ventilation
    • • Rescue and Rescue Planning
    • • Confined Space Personnel Duties, Responsibilities, and Competencies
    • • Pre-Entry Evaluation Forms and Permits
    • • Management of Change
    • • Prevention Through Design
    • • OSHA Alternate Entry Procedures and Reclassification (Annex C)

As an added note, NFPA 350 looks at all confined spaces from a different prospective- i.e., all spaces are treated as "permit required" until it is proven that entry is safe or the proper precautions have been taken. This guide's impact in confined space work and rescue will be significant in reducing risk and meeting compliance issues. For more information, visit NFPA.org.

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Worth the Wait...OSHA’s Confined Space Standard for Construction

Tuesday, December 15, 2015

In our opinion, the new OSHA regulation for Confined Spaces in Construction (Subpart AA of 1926) was worth the wait! This new standard is well thought out and includes some significant as well as subtle differences from the General Industry Permit Required Confined Space Standard 1910.146.

In this article, we will point out additional requirements for compliance for construction activities involving confined spaces. With the exception of residential construction, the final rule became fully enforceable as of October 2, 2015.   

These additional requirements instituted by OSHA are due to the dynamic nature of the construction environment. Dynamic in terms of the continuously evolving configuration of the workplace, and also in the diverse and ever-changing makeup of employers and employees depending on the phase of construction. We feel the most significant differences are not complete shifts in an administrative or operational approach to conducting safe permit required confined space operations, but more of an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.

“We believe the new standard offers an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.”

Please pay particular attention and review 1926 Subpart AA for requirements to ensure clear communication and coordination between the varied entities that work in or adjacent to the construction areas that have confined spaces. The lack of accurate communication and coordination continues to be a cause of confined space fatalities.

The need to communicate with the controlling contractor and entry employers regarding any operations that may have introduced a hazard into a confined space is of paramount importance. The failure to do so has repeatedly led to disaster for unsuspecting follow-on entrants into those confined spaces. Likewise, understanding and communicating the types of operations adjacent to, or in the proximity of confined spaces that may negatively affect that entry operation, must be coordinated and communicated.

Also, several new roles and responsibilities have been added to the confined space regulations. One of the most important new roles is that of the “competent person” for confined spaces.

Having a dedicated individual (Competent Person) who has the expertise and background to perform this critical function will undoubtedly result in lives saved.

OSHA has also added clarification to the need to ensure that the designated confined space rescue service is not only available at the time entry operations commence, but also that rescue service must now agree to notify the entry employer if a situation arises that renders them unable to respond to an emergency.


So let’s take a look at some of the particulars of these new requirements and clarifications.

1. Allows an Entry Permit to be suspended, instead of cancelled in the event of changes from the entry conditions list. Ref: 1926.1205(e)(2)

This differs from 1910.146(e)(5) which requires an employer to terminate entry and cancel the entry permit. This change has specific requirements and limits. Suspending a permit is only allowed when a condition that is not allowed under the entry permit arises in or near the permit space and that condition is: (a) temporary in nature; (b) does not change the configuration of the space; and/or, (c) does not create any new hazards within it.

The first action of the entry supervisor must be to terminate entry and ensure all authorized entrants have safely evacuated the space. At that point, the entry supervisor can suspend or cancel the entry permit. Prior to authorizing reentry, the entry supervisor must fully reassess the space before allowing reentry.

2. Includes more detailed provisions requiring coordinated activities when there are multiple employers at the worksite.

This is an important difference compared to the General Industry regulation. It is required due to the ever-changing makeup of the construction workforce and most especially when the need for workers from multiple employers must enter permit spaces at the same time, or perform work activities in the vicinity of the permit space – thus, the potential to introduce new hazards to the space that all employers on site must be aware of and prepare for.

This final provision differs from 1910.146(d)(11) by specifically addressing the need to coordinate work activities through the controlling contractor, as well as with employers working outside the permit space when their work could foreseeably affect conditions within a confined space. The new construction industry standard goes far beyond by outlining the need for coordinated activities between multiple employers by identifying specific roles – host employer, controlling contractor and the entry employer. (Refer to Chart.)

OSHA 1926.1203 General Requirements paragraph (h) includes specific communication and coordination requirements between the various employers and contractors. The host employer must provide certain information they may have about confined spaces to the controlling contractor.

Required information includes items such as:
(a) The location of known permit spaces;
(b) The nature of hazards in those identified permit spaces;
(c) The reason for classifying the space as permit required; and,
(d) Any additional precautions that the host employer, any other controlling contractor, or entry employer have previously employed to protect their employees must be provided.

It is also incumbent upon the controlling contractor to obtain information from the host employer regarding the hazards associated with the permit spaces and any information on previous entry operations into that permit space.

The controlling contractor is responsible for passing information to any entry employer that may authorize entry into that permit space as well to any other entity at the worksite that could foreseeably create a hazard that may affect that confined space.

The entry employer must obtain from the controlling contractor all the information regarding the particular permit space hazards and entry operation information. Additionally, the entry employer must inform the controlling contractor of the provisions of their permit required confined space program and any hazards they expect to confront or create during their entry operations.

It is also very important that the controlling contractor and all entry employers coordinate their activities when multiple entry employers have entrants in the same space, or when other activities around the permit space may create a hazard that affects the confined space entry operation.

At the completion of entry operations, it is equally important that all entities including entry employers and controlling contractors communicate information regarding the particulars of any given entry. This information must include the permit space program followed during the entry operation as well as any hazards confronted or created during entry. Of particular importance is to communicate any hazards created within the confined space that may still be in place. The controlling contractor in turn communicates all of this information to the host employer.

3. Requires a Competent Person to evaluate the work site and identify confined spaces, including permit spaces.

Along with the increased need for strong communications and coordination, the addition of the role of competent person for confined spaces may be one of the most important differences between the general industry standard and the construction standard.

It may seem to be a subtle difference in the two standards’ requirements, but now there is a specific role, or an identified position for conducting an evaluation of the worksite to determine the presence of confined spaces, a determination of the known or potential hazards associated with those confined spaces, and that has the authority to eliminate the identified hazards.

The competent person for confined spaces must have a high degree of expertise in identifying confined spaces and to make an accurate determination of the nature of any known or potential hazards associated with the confined space that would trigger it to be classified a permit space. In the event that the configuration or use of a non-permit required confined space changes, or a new hazard is introduced, the entry employer must have the competent person reevaluate that space to determine if it has become a permit required confined space. This is also true for any confined space that may not have initially been adequately evaluated to identify any known or potential hazards that would require that space to be classified a permit required confined space.

4. Designated rescue service must agree to notify the entry employer immediately if it becomes unavailable.

Although it has always been implied in the general industry standard that the entry supervisor would ensure the designated rescue service is available during entry operations, 1926.1211 explicitly requires an employer to designate a rescue service – in turn, the rescue service agrees to notify the entry employer immediately if they become unavailable to respond.

5. Provide an early warning system for non-isolated engulfment hazards.

This is primarily for sanitary and storm drain entry operations, but is equally important for any entry operations of a similar nature. The type of early warning systems can be as simple as posting an individual as an “upstream watch” to more complex systems such as electronic sensors or camera systems. Whatever system is used to detect an impending engulfment hazard, it must include a means of communications to provide advanced warning to the downstream entrants in time to safely evacuate the space.

We encourage our readers to spend time studying the new regulation, and in particular understanding the points we have highlighted in this article as well as in our downloadable Confined Spaces in Construction Safety Poster. If you have questions, or if we may be of service, please contact us at 800-647-7626.

 

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Protecting the Safety of Firefighters - Updated OSHA Publication

Thursday, November 05, 2015

WASHINGTON - Firefighting is urgent and stressful work, and decisions are often made without vital information on the hazards that exist. Recently, a Denver firefighter died after falling 25 feet through a skylight. OSHA's newly revised manual on "Fire Service Features of Buildings" addresses this and many other types of building-related hazards for emergency responders. 

"Structural fires present hazards that can result in serious injury or death for emergency personnel who respond to them," said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. "This revised manual offers practical and relevant information to help emergency responders stay safe while doing their jobs."

The revised manual explains how fire personnel can resolve an incident sooner and in a safer manner if a building design is tailored to meet their needs during an emergency. The manual includes: new chapters on water supply and integrating design elements to protect fire personnel during a building's construction, occupancy and demolition phases; new sections on energy conservation, emergency power, and room and floor numbering; and additional photos to help explain concepts.

The manual is aimed at helping emergency responders during fires and other emergencies such as hazardous material releases, emergency medical care, non-fire rescues and terrorist attacks.

To better protect emergency responders in these situations, the Occupational Safety and Health Administration has revised its manual, Fire Service Features of Buildings and Fire Protection Systems*.

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Rescue Challenge 2015 off to a great start

Wednesday, October 07, 2015

2015 CHALLENGE PHOTO GALLERY

A big Louisiana welcome to the six industrial rescue teams participating in this year's Challenge. Here are the "before" shots. Good luck and good learning!

Rescue Team Calumet – Superior, WI


Rescue Team Exxon Plastics – Baton Rouge, LA


Rescue Team Lion Oil – El Dorado, AR


Rescue Team Shell-Geismar – Geismar, LA


Rescue Team Valero – Wilmington, CA


Rescue Team Motiva-Convent – Convent, LA


Challenge Evaluators with Kay Goodwyn, Roco’s president

left to right: Jason Stubbs, Kenny Greene, Randy Crews, Jim Breen, Kenney Moore, Kay Goodwyn, Dominic Velasquez, Terrell Huber, Mike Adams, Randy Miller, Homero Garcia, Dwaynne Ardeneaux, Eddie Chapa, Chad Roberson, Troy Gardner, Bobby Kauer, Dennis O’Connell

Here's the photo gallery

Rescue Team Calumet – Superior, WI
Next


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OSHA Memorandum on Confined Spaces in Construction

Sunday, September 13, 2015

This memorandum provides guidance on the enforcement of the Confined Spaces in Construction standard published on May 4, 2015. The new standard goes into effect on August 3, 2015. Requests for an extension of the effective date have indicated a need for additional time for training and the acquisition of equipment necessary to comply with the new standard. OSHA will not delay the effective date, but instead will postpone full enforcement of the new standard for 60 days from the effective date of August 3, 2015 to October 2, 2015.

During this 60-day period, OSHA will not issue citations to an employer making good faith efforts to comply with the new standard, as long as the employer is in compliance with either the training requirements of the new standard, found at 29 CFR 1926.1207, or the training requirements found at former 29 CFR 1926.21(b)(6)(i), which is provided:

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.

Employers who fail to train their employees consistent with either 29 CFR 1926.1207 or 1926.21(b)(6)(i) would properly be cited for violation of 1926.1207(a). Factors OSHA will consider when evaluating whether an employer is engaged in good faith efforts to comply with the new standard include:

  • If the employer has not trained its employees as required under the new standard, whether the employer has scheduled such training,
  • If the employer does not have the equipment required for compliance with the new standard, including personal protective equipment, whether the employer has ordered or otherwise arranged to obtain such equipment required for compliance and is taking alternative measures to protect employees from confined space hazards, and
  • Whether the employer has engaged in any additional efforts to educate workers about confined space hazards and protect workers from those hazards.

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Delay on CS Construction Enforcement

Monday, July 13, 2015

Washington, D.C. – In response to requests from the construction industry, OSHA is delaying full enforcement of its recently promulgated Confined Spaces in Construction Standard to allow employers additional time to comply with the rule.

The final rule, issued May 4, has requirements similar to the Permit Required Confined Spaces Standard for general industry, including employee training and atmospheric monitoring.

The new construction rule is scheduled to go into effect Aug. 3. Between that date and Oct. 2, construction employers will not be cited for violating the new standard if they are making a "good faith" effort to comply and are in compliance with training requirements under the new or old standard.

According to OSHA, good faith efforts include scheduling training for employees, ordering necessary equipment to comply with the new standard, and taking alternative measures to protect employees from confined spaces.

Nearly 800 annual serious injuries will be prevented under the new rule, OSHA estimates.

For more detailed information regarding this ruling see our previous post here.

Source: National Safety Council
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​Confined Space Rescue…Always Seeking a Better, Safer Way!

Monday, June 01, 2015

When a student returns to one of our classes after a few years, we’ll often hear, “Wow, things sure have changed! There are a lot of new techniques and equipment since the last time I attended.” So, why do we change our courses on a regular basis? If it worked back then, why change it?

The answer is simple really… if there’s a better way or safer way to do something, we'll take the opportunity to incorporate it into our programs.

When deciding what techniques or equipment may be candidates, we typically look at three primary objectives: 

1.  Does it perform a function that is needed in order to accomplish the type of rescue that is being addressed?

2.  Does it perform in a safe, or even a safer manner, than previous equipment or techniques?

Once these requirements are met, we'll ask... 

3.  Does it add efficiency to the rescue effort? And, is it efficient in terms of time, manpower and equipment needed?   

When evaluating a new piece of equipment for our programs, we will also consider how versatile the item may be. 

To have one piece of equipment that performs multiple functions is a huge benefit to rescuers in that it saves time, money, weight and bulk. 

One example of a product that performs multiple functions is the Petzl ID. The ID can be used as the foundation of MA systems, it can also be used for short ascents, and the manufacturer now allows it to be used as a belay device.

Compliance with legislated regulations is also a big consideration. For performance-based regulations like 1910.146 (Permit-Required Confined Spaces), it’s all about creating a competent rescuer who is capable of safely and effectively in permit spaces. Other relevant OSHA regulations include Fall Protection, Respiratory Protection, Lock Out/Tag Out, and HAZMAT, just to name a few. We also refer to many different nationally recognized consensus standards as we build our programs. Probably the most visited we draw from are NFPA 1006 and 1983, which offer guidance on professional qualifications for rescuers and equipment standards for manufacturers. We also rely on ANSI, NATE, SPRAT and IRATA, as well as other standards that provide appropriate guidance for the type of program we are delivering.

But, where do we come up with the leading edge techniques and equipment that we are continuously adding to our courses? Well, this is where we take a lot of pride in how we operate internally as a business. 

Roco’s leadership has always encouraged our instructors and rescue personnel to identify needs in the rescue world and think of a way to satisfy that need…yes, to build a better mousetrap! 

We want our people to constantly be on the lookout for opportunities to evaluate new equipment or come up with a new technique that meets the three primary objectives that we identified earlier.

As an added benefit, Roco instructors and rescue team members come from a wide variety of backgrounds. This includes the fire service, law enforcement, U.S. military and private sector industrial emergency response teams. What’s more, some of our personnel enjoy sport climbing and even expedition mountaineering on their off time. In other words, we have a very diverse way of putting ropes and associated hardware to the test. Everyone is encouraged to share their ideas. 

Oftentimes this "free thinking" among our personnel leads to a great step forward in efficiency and allows us to keep our courses leading the way to a better rescuer.

It’s also exciting to see some of the emerging technologies that have come to market as far as rescue equipment is concerned. By encouraging our personnel to get their hands on these new pieces of kit and “ride them hard,” we are able to determine if it is something that needs to be incorporated into our scheme. Every once in a while, we’ll even discover a new way to use the equipment that is beyond what the manufacturer envisioned. Our people have come up with some very unique ways to meet some very specific rescue needs. But, it all comes back to those same three primary objectives. We need a piece of gear (or a technique) that will do the job we need it to do, and do it safely and efficiently.

Here's a great example...who would have thought that a technique used on glacier crevasse rescue would be a skill that comes in handy in an industrial environment? Fortunately, someone in our think tank did, and now it is a staple of our curricula. So, if it’s been a while since you have attended a Roco class, maybe it’s time to come see what we have been up to lately.

For the ultimate rope rescue experience, click on Roco's Fast-Track 120™

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It's Final-Confined Spaces in Construction-Effective 8/3/15!

Monday, May 04, 2015

The Occupational Safety and Health Administration today issued a final rule to increase protections for construction workers in confined spaces. 

Confined spaces rule (29 CFR 1926 Subpart AA) could protect nearly 800 construction workers a year from serious injuries and reduce life-threatening hazards…Construction protections now match those in manufacturing and general industry. 

Manholes, crawl spaces, tanks and other confined spaces are not intended for continuous occupancy. They are also difficult to exit in an emergency. People working in confined spaces face life-threatening hazards including toxic substances, electrocutions, explosions and asphyxiation.

Last year, two workers were asphyxiated while repairing leaks in a manhole, the second when he went down to save the first – which is not uncommon in cases of asphyxiation in confined spaces.

“In the construction industry, entering confined spaces is often necessary, but fatalities like these don’t have to happen,” said Secretary of Labor Thomas E. Perez. “This new rule will significantly improve the safety of construction workers who enter confined spaces. In fact, we estimate that it will prevent about 780 serious injuries every year.”

The rule will provide construction workers with protections similar to those manufacturing and general industry workers have had for more than two decades, with some differences tailored to the construction industry. These include requirements to ensure that multiple employers share vital safety information and to continuously monitor hazards – a safety option made possible by technological advances after the manufacturing and general industry standards were created.

“This rule will save lives of construction workers,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Unlike most general industry work sites, construction sites are continually evolving, with the number and characteristics of confined spaces changing as work progresses. This rule emphasizes training, continuous work site evaluation and communication requirements to further protect workers’ safety and health.”

On OSHA's website, it also states than an employer whose workers are engaged in both construction and general industry work in confined spaces will meet OSHA requirements [for 1910.146] if that employer meets the requirements of 29 CFR 1926 Subpart AA - Confined Spaces in Construction.

Five (5) key differences in the construction rule, and several areas where OSHA has clarified existing requirements:

  1. More detailed provisions requiring coordinated activities when there are multiple employers at the work site. This will ensure hazards are not introduced into a confined space by workers performing tasks outside the space. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.
  2. Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces.
  3. Requiring continuous atmospheric monitoring whenever possible.
  4. Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a storm upstream from the workers could cause flash flooding. An electronic sensor or observer posted upstream from the work site could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely.
  5. Allowing for the suspension of a permit, instead of cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space. The space must be returned to the entry conditions listed on the permit before re-entry.

OSHA has added provisions to the new rule that clarifies existing requirements in the General Industry standard. These include:

  1. Requiring that employers who direct workers to enter a space without using a complete permit system prevent workers’ exposure to physical hazards through elimination of the hazard or isolation methods such as lockout/tag out.
  2. Requiring that employers who are relying on local emergency services for emergency services arrange for responders to give the employer advance notice if they will be unable to respond for a period of time (because they are responding to another emergency, attending department-wide training, etc.).
  3. Requiring employers to provide training in a language and vocabulary that the worker understands.

Finally, several terms have been added to the definitions for the construction rule, such as "entry employer" to describe the employer who directs workers to enter a space, and "entry rescue", added to clarify the differences in the types of rescue employers can use.

Host Employers, Controlling Contractors, and Entry Supervisors

The rule makes the controlling contractor, rather than the host employer, the primary point of contact for information about permit spaces at the work site. The host employer must provide information it has about permit spaces at the work site to the controlling contractor, who then passes it on to the employers whose employees will enter the spaces (entry employers). Likewise, entry employers must give the controlling contractor information about their entry program and hazards they encounter in the space, and the controlling contractor passes that information on to other entry employers and back to the host. As mentioned above, the controlling contractor is also responsible for making sure employers outside a space know not to create hazards in the space, and that entry employers working in a space at the same time do not create hazards for one another’s workers.

Click for an update on this ruling

Download 29 CFR 1926 Subpart AA Confined Space in Construction Ruling

Source: www.osha.gov

Frequently Asked Questions: https://www.osha.gov/confinedspaces/faq.html

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WH Completes Review of OSHA's Confined Spaces in Construction

Friday, April 10, 2015

Washington – On April 3, the Office of Information and Regulatory Affairs (OIRA) completed its review of OSHA's Confined Spaces in Construction Standard, paving the way for the final rule to move forward. The rule (29 CFR 1926.36) has been in the works for more than a decade. An OIRA review is one of the last steps a federal agency must take before it can publish a final rule. According to OSHA's timetable, the confined spaces final rule was originally scheduled for publication in March.

In 1993, OSHA issued a general industry rule to protect employees who enter confined spaces while engaged in general industry work (29 CFR 1910.146). This standard has not been extended to cover employees entering confined spaces while engaged in construction work because of unique characteristics of construction work sites. Pursuant to discussions with the United Steel Workers of America that led to a settlement agreement regarding the general industry standard, OSHA agreed to issue a proposed rule to protect construction workers in confined spaces.

Source: Membership News Alert from National Safety Council

UPDATE: Roco is hearing that a final ruling will be released within the next 6 weeks. As soon as the information is provided, we will be sure to post for you!

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