New Standard Effective May 4, 2015
Until May 4, 2015 there wasn’t any rules specifically pertaining to construction workers performing work in confined spaces. On August 3, 2015 that all changed when OSHA began enforcing Subpart AA of 29 CFR 1926. A lot of us were already following the general industry standard but in the following I will try to explain what is different
There are 5 key differences and these requirements include:
- If there are more than 1 employer working in or near the confined space, there must be coordination between all involved employers. This is to assure that hazards are not introduced into the confined space either by employees doing something to introduce a hazard from outside (running a generator for example).
- A competent person is required to evaluate the work site and identify confined spaces, including permit spaces.
- Continuous atmospheric monitoring is required whenever possible.
- Continuous monitoring of engulfment hazards is required. 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.
- Permits can be “suspended” instead of canceling when an unexpected condition is presented and the confined space has to be evacuated. However, the space must be returned to the entry conditions listed on the permit before re-entry.
In addition, OSHA has added provisions to the new rule that clarifies existing requirements in the General Industry standard. These include:
- 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/tagout.
- 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.).