1. New Standard 1926.1200: “Confined Spaces in Construction” presented by Tim Robson, NM Team Leader/Chief Instructor

2. DISCLAIMER This presentation is provided as a complimentary resource by Roco Rescue and that our logos shall remain intact. Also, Roco Rescue assumes no liability or responsibility for content, content delivery and/or omission of content from the presentation, associated materials or actions that may be taken as a result of or following exposure to this presentation. For questions regarding the presentation or information on Roco training programs, please contact Tim Robson at trobson@rocorescue.com.trobson@rocorescue.com

3. Confined Spaces in Construction February 18, 1994 – OSHA submitted a draft “proposed standard” for confined spaces in construction. August 3, 2015 – Final Rule was promulgated. NOTE: Full enforcement of the new standard postponed by OSHA for 60 days to October 2, 2015. Terms in the Final Rule are consistent with 29 CFR 1910.146 (General Industry PRCS Standard).

4. Due to high employee turnover and an ever-evolving worksite, OSHA has placed an emphasis on training, continual worksite evaluation and communication. More detailed provisions requiring “coordinated activities” when there are multiple employers at the worksite… to ensure that hazards are not introduced into a confined space by workers performing tasks outside the space. Example: Generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space. Requiring a “competent person” to evaluate the worksite and identify confined spaces, including permit spaces. Confined Spaces in Construction

5. Requiring “continuous atmospheric monitoring” whenever possible. Requiring continuous monitoring of engulfment hazards. Example: 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 worksite could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely. Allowing for the “suspension” of a permit vs. cancellation in the event of changes from the entry conditions listed on the permit or an unexpected event requiring evacuation of the space. NOTE: The space must be returned to the entry conditions listed on the permit before re-entry! Confined Spaces in Construction

6. OSHA estimates that 20,479 construction establishments have employees entering at least one confined space annually. Excluded job types regulated by other regulations: 1.§1926, subpart P - Excavations 2.§1926, subpart S - Underground Construction, Caissons, Cofferdams and Compressed Air 3.§1926, subpart Y - Diving Confined Spaces in Construction

7. Proposed Standard vs. Final Standard The final standard requires employers to determine: –What kinds of spaces their workers will be in –What hazards could exist in the confined space –How those hazards shall be made safe –What training the workers shall receive –How to rescue those workers in an emergency

8. New Definitions Competent Person – one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them. Controlling Contractor – the employer that has overall responsibility for construction at the worksite. NOTE: If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer.

9. New Definitions Entry Employer – any employer who decides that an employee it directs will enter a permit space. NOTE: An employer cannot avoid the duties of the standard merely by refusing to decide whether its employees will enter a permit space, and OSHA will consider the failure to so decide to be an implicit decision to allow employees to enter those spaces if they are working in the proximity of the space.

10. Hazardous Atmosphere – an atmosphere that may expose employees to the risk of death, incapacitation, impairment of ability to self-rescue, injury, or acute illness from one or more of the following causes: –Flammable gas, vapor, or mist in excess of 10 percent of its lower flammable limit (LFL); –Airborne combustible dust at a concentration that meets or exceeds its LFL; –Atmospheric oxygen concentration below 19.5 percent or above 23.5 percent; –Atmospheric concentration of any substance for which a dose or a permissible exposure limit is published in subpart D of this part (Occupational Health and Environmental Control), or in subpart Z of this part (Toxic and Hazardous Substances), and which could result in employee exposure in excess of its dose or permissible exposure limit; Note: An atmospheric concentration of any substance that is not capable of causing death, incapacitation, impairment of ability to self-rescue, injury, or acute illness due to its health effects is not covered by this definition. –Any other atmospheric condition that is immediately dangerous to life or health. New Definitions

11. Host Employer – the employer that owns or manages the property where the construction work is taking place. Note: If the owner of the property on which the construction activity occurs has contracted with an entity for the general management of that property, OSHA will treat the contracted management entity as the host employer for as long as that entity manages the property. Otherwise, OSHA will treat the owner of the property as the host employer. In no case will there be more than one host employer. Limited or Restricted Means for Entry or Exit – a condition that has a potential to impede an employee's movement into or out of a confined space. Such conditions include, but are not limited to, trip hazards, poor illumination, slippery floors, inclining surfaces and ladders. New Definitions

12. Physical Hazard – an existing or potential hazard that can cause death or serious physical damage. Examples include, but are not limited to: Explosives; mechanical, electrical, hydraulic and pneumatic energy; radiation; temperature extremes; engulfment; noise; and inwardly converging surfaces. Physical hazard also includes chemicals that can cause death or serious physical damage through skin or eye contact (rather than through inhalation). New Definitions

13. Silent Killer in a Newly Constructed Manhole

14. OSHA received notification of a construction site fatality on August 5, 2004, the day following the incident. Reported that the employee was found at the bottom of a manhole. New sewer system under construction - SIC Code 1623. Silent Killer in a Newly Constructed Manhole

15. Company was laying sewer pipe and manholes for a new housing development Six (6) employees onsite. Farm land; slightly hilly; slope of ground ~ 1 to 4. Manhole was adjacent to an entrance ramp to a highway. Silent Killer in a Newly Constructed Manhole

16. 2 ft. opening Riser was constructed of 4 ft. x 4 ft. concrete pipe sections 17 ft. deep outside; 16-1/2 ft. inside Two 8” PVC Pipes in the bottom Built on a 4” to 12” bed of limestone chat Silent Killer in a Newly Constructed Manhole

17. After vacuum test failure, employee reportedly was assigned the grouting task. Grouting is done by hand and takes about 1 hour. The employee was working alone. The employee was found at the bottom of the manhole unconscious. Silent Killer in a Newly Constructed Manhole

18. After recovery, the medical examiner requested sampling of manhole. Fire Department HazMat Division took some multi-gas readings about 3 hours after recovery. Results were 16.3 to 17% for oxygen and 0.0 to 4.5 % LEL. Zero readings for carbon monoxide and hydrogen sulfide. No readings taken for carbon dioxide. Manhole Conditions Silent Killer in a Newly Constructed Manhole

19. OSHA’s Salt Lake City Technical Center Health Response Team assisted with site analysis. Direct Reading Instruments results 9 days later revealed: – Oxygen: 16.0 to 18.2 % – CO2: 1.8 to 3.5 % or 18,000 to 35,000 PPM – LEL: 5 to 8 % Inspection Activity The employer did not have a confined space entry program. Silent Killer in a Newly Constructed Manhole

20. Grab or bulk air samples taken with a medium flow pump at 3 L/Min. Collected in aluminum bags Lab results as follows: –Oxygen: 12.5 to 14.1 % –CO2: 16,845 to 23,968 PPM –Methane: 776 to 1372 PPM Inspection Activity Silent Killer in a Newly Constructed Manhole

21. Rescue Requirements – 1926.1211 1.Ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. Note: What will be considered timely will vary according to the specific hazards involved in each entry. For example, 1926.103 Respiratory Protection requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres. 2.Proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified. The employer must EVALUATE a prospective rescuer’s…

22. i.Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified; ii.Is equipped for, and proficient in, performing the needed rescue services; Rescue Requirements – 1926.1211 The employer must SELECT a rescue team or service from those evaluated that: iii.Agrees to notify the employer immediately in the event the rescue service becomes unavailable;

23. The employer must: 4.Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and Rescue Requirements – 1926.1211 5.Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue team or service can develop appropriate rescue plans and practice rescue operations.

24. Provide all equipment and training at no cost to employees. Provide personal protective equipment (PPE) to conduct permit space rescues safety and train in its proper use. Train employees to perform assigned rescue duties and ensure that employees successfully complete the training required and establish proficiency as authorized entrants. Train employees in basic first aid and CPR with at least one member holding a current certification in first aid and CPR. In-House Rescue Teams – 1926.1211 An employer whose employees have been designated to provide permit space rescue must:

25. Ensure that employees practice making permit space rescues BEFORE attempting an actual rescue, and AT LEAST once every 12 months by means of simulated rescue operations from actual spaces or representative spaces. In-House Rescue Teams – 1926.1211 Note: Representative permit spaces must, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed. Exception: Practice is not required where the affected employees properly performed a rescue operation during the last 12 months in the same permit space the authorized entrant will enter, or in a similar permit space.

26. Non-entry rescue is required unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. The employer must designate an ENTRY RESCUE SERVICE whenever non-entry rescue is not selected. Whenever non-entry is selected, the entry employer must ensure that retrieval systems or methods are used – and must confirm, PRIOR TO ENTRY, that emergency assistance would be available in the event that non-entry rescue fails. Non-Entry Rescue: Key Points

27. New Standard: 1926.1200 “Confined Spaces in Construction” Tim Robson, NM Team Leader/Chief Instructor Email: trobson@RocoRescue.com