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New CS Types Chart & Compliance Guide

Wednesday, May 04, 2016

This helpful new guide provides information for evaluating your rescue team or prospective rescue service based on the requirements of OSHA 1910.146 and 1926 Subpart AA. It includes a Rescue Team Evaluation Checklist from Appendix F and illustrates Confined Space Types 1-6, which is based on criteria from OSHA 1910.146. Roco’s method of categorizing confined spaces by various types can be useful in establishing practice requirements for your rescue service.

Responding in a safe, effective and timely manner to the various types of permit-required confined spaces at your facility is required by OSHA regulations 1910.146 (PRCS) and 1926 Subpart AA Confined Spaces in Construction.
An effective response by your rescue service is crucial to the safety of workers who are tasked with entering confined spaces to perform their job duties.

In order to be prepared, rescue teams can use this chart to plan their practice drills to include all of the various types of confined spaces. Appendix F of 1910.146 states that rescuers may practice in representative spaces that are considered “worst case” or most restrictive with respect to internal configuration, elevation and portal size. This illustrated guide will serve as a reminder to be prepared for the unexpected when planning for confined space emergencies for the safety of the rescuers and the entrants.

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What is a Competent Person?

Wednesday, March 02, 2016

Many OSHA standards, especially in construction, require a “competent person” to be designated at the jobsite. Filling this role requires proper training, relevant experience to the work being performed and adequate knowledge of the associated regulations. 

The competent person should be able to recognize critical hazards as well as have the authority to take the action needed to mitigate hazards. It’s much more than just picking someone to fill a slot.

A previous article, "What is a Competent Person?" found in the National Safety Council's Safety+Health publication, talks about how the term is often taken too lightly. Again, it's much more than just selecting a body to fill a role or attending one 10-hour training class covering all the various standards. Competency must be considered and evaluated for this important role. 

At a minimum, your designated competent person should meet the following minimum qualifications:
(1)    A high level of understanding of the types of hazards typically encountered in that area of work;
(2)    A solid review of applicable standards relating to that type of work; and,
(3)    A thorough understanding of types of solutions to control or eliminate the hazards
.

To assist in preparing your competent person in fall protection, we encourage you to register for Roco's Fall Protection
Competent Person - April 4-5, 2016 course in Baton Rouge. This course will provide practical experience in recognizing fall hazards and developing appropriate measures for reducing or eliminating those hazards. 

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New World of Worker Safety: DOL & DOJ Reach Agreement

Monday, February 22, 2016

Source: Safety+Health Magazine February 2016

Washington – A recent agreement between the Departments of Labor and Justice will launch a “new world of worker safety” by holding managers and supervisors criminally accountable for violations of the law, agency officials announced Dec. 17.

The two departments signed a memorandum of understanding that pools their resources toward the prosecution of individuals who willfully disregard labor and environmental statutes, according to John Cruden, assistant attorney general for the DOJ’s Environment and Natural Resources Division, who spoke at a press conference moments after the memo was signed.

For the past several years, OSHA and DOJ have worked with each other on certain cases, but the new agreement formalizes that relationship.

This cooperation could lead to hefty fines and prison terms for employers and individuals convicted of violating a number of related laws. For example, a roofing contractor recently pleaded guilty to violating an OSHA law, lying to inspectors and attempting to cover up his crime; he could be sentenced up to 25 years in prison.

“Strong criminal sanctions are a powerful tool to ensure employers comply with the law and protect the lives, limbs and lungs of our nation’s workers,” OSHA administrator David Michaels told reporters at the press conference.

Deborah Harris, DOJ’s Environmental Crimes Section chief, said prosecutions would be open to “the ones making the decisions that lead to the deaths of others,” which could include people in the corporate office, as well as managers and supervisors.

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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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