PERMIT REQUIRED CONFINED SPACE Opening Slide

Objectives When finished with this section, participants will be able to: List the three characteristics of a Confined Space List three hazards that define a Permit Required Confined Space State objectives

Examples of Confined Spaces Boilers Baggers Mixing vats Tanks Pipelines Electrical vaults Manholes Elevator pits Pipe chases Sumps These are but a few of the examples of confined spaces. Ask the participants to name others that are not on the list. Ask them to give examples from their work sites. There may be questions such as “Would this be considered a confined space?” This is a good lead in for the next slide.

Confined Space 29CFR1910.146(b) Limited or restricted access or egress Not designed for continuous employee occupancy Large enough to enter and do work For a space to be a Confined Space, it must meet all three parts of the definition. If it does not meet all three, it still may be a dangerous location. It would not be covered by the Confined Space standard. Tell the participants that this is the General Industry definition. This may generate some discussion as to why are they studying General Industry when they are construction workers. Any work that is not new or significantly altering a space is covered by the General Industry standard. This would include almost all work at Power Plants, Refineries, Chemical Plants, and any maintenance work. (See Letter of Interpretation on next page)

Letters of Interpretation Excerpt from a Letter of Interpretation BMW Constructors, Inc. 1740 West Michigan St. PO Box 2210 Indianapolis, Indiana 46222-0210 29 CFR 1910.12(b) defines construction work as "work for construction, alteration, and/or repair, including painting and decorating." Generally speaking reconfiguration of space or installation of substantially new equipment is usually considered construction, whereas refurbishing of existing equipment and space is considered maintenance. Maintenance operations are covered by general industry standards contained in 29 CFR 1910 and construction activities are covered by the construction standards contained in 29 CFR 1926. While paragraph (a), scope and application, of 29 CFR 1910.146 does not apply to construction activities, is does not exclude contractors from coverage when performing maintenance type operations in confined spaces. Thus, if you are a contractor performing maintenance type activities for a host employer, compliance with 29 CFR 1910.146 is required. Some examples of maintenance operations would be: The partial patching, total removal of existing lining and replacement, and installation of a new lining in a tank. The relining of a furnace with new refractory. Tuck pointing and individual brick replacement in a manhole. Relining of a sewer line using a sleeve which is pushed through a section of the existing system. Repainting, which is part of a scheduled program to maintain a system or prevent its deterioration. 29 CFR 1910.12(b) defines construction work as "work for construction, alteration, and/or repair, including painting and decorating." Generally speaking reconfiguration of space or installation of substantially new equipment is usually considered construction, whereas refurbishing of existing equipment and space is considered maintenance.

General Industry Standard applies when workers: Are doing maintenance work Are repairing existing facilities or process equipment Review of last slide

Permit-Required Confined Space 29CFR1910.146(b) Contains or has the potential for a hazardous atmosphere Potential for engulfment Configuration Any other serious safety or health hazard For a Confined Space to be considered a Permit Required Confined Space, it must contain, or in the case of a hazardous atmosphere or engulfment, have the potential to contain a hazard. Item 4 – Any other serious safety or health hazard – is a catch-all to force the employer to evaluate every space and be aware of the potential hazards. It would be impossible for OSHA to list all hazards.

Hazardous Atmosphere Greater than 23.5% Oxygen Less than 19.5% Oxygen Greater than 10% of the LEL Toxins greater than the PEL Greater than 23.5% Oxygen would be considered a flammable atmosphere Less than 19.5% Oxygen would be considered Oxygen Deficient Greater than 10% of the LEL would be considered flammable Toxins are irregardless of PPE

Objectives When finished with this section, participants will be able to: List the three characteristics of a Confined Space List three hazards that define a Permit Required Confined Space Restate objectives. Take any questions