Confined Spaces in Construction Workbook (4-Hour)

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   4-hour Construction Industry Confined Space Hazard

   • Awareness Level Training
   • Workbook
   • First Edition
   • Rutgers School of P ublic H ealth
   • Copyright © 2017
   • Rutgers Biomedical and Health Sciences (RBHS)
   • School of Public Health
   • All rights reserved
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   Table of Contents

   • Controlling and Managing Dynamic Hazards associated with Confined Spaces in Construction
   • Workbook. Topics will include:
   • Section One: Introduction: Construction Industry Confined Space
   • The New Confined Space Standard for Construction
   • Planning, Coordination and Communication
   • Relationship and Responsibility Flow Chart
   • Exemptions to the Confined Space Construction Industry Standard
   • Quick Definitions
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   Federal Disclaimer

   • This material was produced under grant number SH29649SH6 from the Occupational Safety and Health Administration, U.S. Department of Labor. It does not necessarily reflect the views or policies of the U.S. Department of Labor, nor does mention of trade names, commercial products, or organizations imply endorsement by the U.S. Government.
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   Section One: Introduction: Construction Industry Confined Space

   • “The Confined spaces rule 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”
   • OSHA National News Release
   • U.S. Department of Labor, May 1, 2015
   • In May of 2015, OSHA issued a new Standard for construction work in confined spaces, which…
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   • information and monitor hazards. The sharing of responsibility between various entities to protect workers is not a new concept in the OSHA standards and in compliance. Precedent exists that requires multiple employers to multilaterally communicate and coordinate their respective activities and share information, concerning the safety and wellbeing, with associated employers. …
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   Relationship and Responsibility Flow Chart

   • Exceptions to the new Confined Space Rule
   • It should be noted that this new standard has three exemptions where the standard does not apply. In cases where the standard applies and there is a provision that addresses a confined
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   • space hazard in another applicable OSHA standard, the employer must comply with both that requirement and the applicable provisions of the following standards.
   • Construction work regulated by §1926 subpart P—Excavations.
   • Construction work regulated by §1926 subpart S—Underground Construction, Caissons, Cofferdams and Compressed Air.
   • Construction work regulated by §1926 subpart Y—Diving.
   • Some Quick Definitions
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   • 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—Occupational Health and Environmental Control, or in Subpart Z—Toxic and Hazardous…
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   • Line breaking means the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.
   • Lockout means the placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be…
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    • permanent or temporary and includes, but is not limited to, loss of consciousness, disorientation, or other immediate and substantial reduction in mental efficiency. Injuries involving such impairment would usually require treatment by a physician or other licensed health-care professional.
    • Note: The hazards that would trigger the permit-required confined space provisions: (1) contains or has the potential to contain a hazardous…
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    • 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.
    • Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces.
    • Requiring continuous atmospheric monitoring whenever possible.
    • Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a…
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    • The difference between construction and maintenance is the activity to be performed. "Maintenance" means keeping equipment or a structure in proper condition through routine, scheduled or anticipated measures without having to significantly alter the structure or equipment in the process. For equipment, this generally means keeping the equipment working properly by taking steps to prevent its failure or degradation. …
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    Section Two: Rights and Responsibilities

    • Responsibilities under the OSH Act: General Duty Clause
    • It is both wise and mandatory for an employer to start any undertaking with some reasonable anticipation of what hazards and obstacles you may likely encounter because it is essential that in each workplace an employer provides the means of assessing and identifying potential hazards and where applicable utilize measures that seek to…
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    Report an injury or illness, and receive copies of their medical records

    • See and examine copies of the workplace injury and illness log for the employer Review records of work-related injuries and illnesses
    • Get copies of test results done to find hazards in the workplace
    • Employer Responsibility
    • Under the OSH law, employers have a responsibility to provide a safe workplace. This is a short summary of key employer responsibilities:
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    • Post OSHA citations at or near the work area involved. Each citation must remain posted until the violation has been corrected, or for three working days, whichever is longer. Post abatement verification documents or tags.
    • Correct cited violations by the deadline set in the OSHA citation and submit required abatement verification documentation.
    • The Whistleblower Protection Programs: How to File a Discrimination Complaint
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    Right to Be Hard: Your Rights as a Whistleblower

    • OSHA’s Whistleblower Protection Program enforces the whistleblower provisions of more than twenty whistleblower statutes. Rights afforded by these whistleblower acts include, but are not limited to, worker participation in safety and health activities, reporting a work related injury. illness or fatality, or reporting a violation of the statutes.
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    How to File a Safety and Health Complaint

    • The Occupational Safety and Health Act of 1970 gives employees and their representatives the right to file a complaint and request an OSHA inspection of their workplace if they believe there is a serious hazard or their employer is not following OSHA standards. Workers do not have to know whether a specific OSHA standard has been violated in order to file a complaint. …
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    • Note: Complaints from workers or their representatives are taken seriously by OSHA. OSHA will keep your information confidential.
    • Section Three: Confined Space Safety Training Program
    • The following sample training modules are for workers to help them better understand what confined spaces are and the nature of hazards associated with these spaces.
    • This training should be provided to all employees who will be exposed to confined spaces…
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    YOUR COMPANY NAME HERE

    • Construction Industry Confined Space Training Program (SAMPLE)
    • Key Elements to Training Employees who will be exposed to Confined Spaces
    • General Awareness-level Confined Space Training Module Flammable Atmospheres Module
    • Oxygen Deficient and Enriched Atmospheres Module Vapor Density and Specific Gravity Module
    • The Control of Hazardous Energy Module
    • Oxidizing Agents Module
    • Rescue Module
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    • We should know that the host, controlling contractor (often referred to as the General Contractor) along with YOUR COMPANY NAME HERE competent person MUST make you aware of specific confined spaces at our worksites. They must brief you on the location of specific confined spaces and respective associated hazards in your work environment. …
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    • designed for continuous occupancy. Product storage areas, enclosed machinery, vessel tanks, ceiling plenums, attics and crawl spaces are NOT designed for continuous occupancy and hence fulfill this prohibiting design criterion. Other typical confined spaces are boilers, furnaces, ceilings, pipelines, ducts, pits, pumping stations, process vessels, septic tanks, trenches, excavations, silos, storage tanks, barges, sewers, utility vaults…
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    • 3. The space contains has a design that possess a configuration that could trap or asphyxiate an entrant. Such configuration may include internal walls or baffles, nooks, ducts or obstructions to egress that would make emergency extrication difficult or time consuming.
    • 4. The forth criteria is intentionally open-ended and includes any serious safety or health concern that may be within a space or can potentially come into existence in…
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    • the General Contractor.
    • If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer.
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    • The Host employer means the employer that owns or manages the property where you are working.
    • A Hazardous atmosphere means an atmosphere that may expose employees to the risk of death, incapacitation, impairment, injury, or illness from such hazards as flammable gases, combustible dusts, atmospheric oxygen concentration below 19.5 percent or above 23.5 percent and concentrations of recognized toxic and hazardous substance or any other…
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    2. Flammable Atmospheres Module

    • The fire tetrahedron include 4 necessary components
    • Fuel (something that will burn)
    • Heat (enough to make the fuel burn) Oxygen (enough to support combustion) Uninhibited chain reaction
    • Formerly the use of the fire triangle included on three components fuel, heat, oxygen. These three components must be present to have a fire but an uninhibited chain reaction must also be present. …
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    3. Oxygen Deficient and Enriched Atmospheres Module

    • An oxygen deficient atmosphere means an atmosphere containing less than 19.5 percent oxygen by volume and an oxygen enriched atmosphere means an atmosphere containing more than 23.5 percent oxygen by volume. These two states of concentration have pose different hazards to entrants inside of confined spaces. …
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    • Oxygen is essential to life. Its normal concentration in the air we breathe is approximately 21 % (20.9%)
    • OSHA 19.5 % to 23.5 %
    • We can breathe in a 50-60% oxygen enriched atmosphere for several hours under medical care (oxygen therapy)
    • Oxygen is not flammable but supports combustion.
    • Most materials burn fiercely sometimes explosively in oxygen.
    • As the oxygen concentration in air increases, the potential fire risk increases. …
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    • especially flammables, oxidizers or other highly reactive chemicals that can displace air, possibly presenting hazard to employees.
    • Vapor Density and Specific Gravity are subject to environmental condtions.
    • Helium
    • Molecular Weight 4g
    • Carbon Dioxide
    • Molecular Weight 44g
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    5. The Control of Hazardous Energy Module

    • Dr. William Haddon Jr. a physician with degrees from the Massachusetts Institute of Technology, Harvard Medical School and Harvard School of Public Health and the first director of the National Highway Traffic Safety Administration, proposed a general idea that accidents and injuries involve the transfer of energy. …
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    • Examples of Isolation Devices
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    6. Oxidizing Agents Module

    • An oxidizing agent is a chemical substance that reacts with another chemical called the reactant and results in the removal electrons. This reaction is referred to as a redox chemical reaction and can in some oxidizers release a great deal of chemical energy, which has the potential to cause injury, illness and damage.
    • Common Oxidizing Agents
    • Oxygen (O 2 )
    • Ozone (O 3 )
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    7. Rescue Module

    • There are three types of rescues for a PRCS. Let’s discuss the implications of rescue.
    • 1. Self-Rescue
    • 2. Non-Entry Rescue
    • 3. Entry Rescue
    • Vertical PRCS
    • Horizontal PRCS
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    Section Four: The Checklist

    • Using checklists has become standard Other critical industries have made aviation, healthcare, hospitals and other critical industries, managers have turned to utilizing checklists to ensure and hedge against human error. Sometimes there are just too many moving parts to remember so deliberate checklist help keep everyone on the right track.
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    Thing People Do: College student takes shortcut off the campus planned path.

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    Section Five: Confined Spaces in Construction Group Exercise

    • Exercise Option 1:
    • 1. Create your own permit required confined space. Congratulations! You just received a contract for the XYZ Company located in Queens, New York. Each group will act as a different entity in this exercise; the host employer, the controlling contractor, the entry employers, rescue team and others. …
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    Section Six Debriefing:

    • As is proper with any form of training or education, there should be a means of evaluating the experience and assessing its effectiveness. Let us take a few moments and talk about what this program has achieved and where it can be made better. Also, let’s take notes so we can look back on our notes say in the months to come and see if, at all, has this training and what we accomplished today had some longer-term…
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    Appendix A: Subpart AA Confined Spaces in Construction

    • 1926.1200
    • Reserved
    • 1926.1201
    • Scope
    • 1926.1202
    • Definitions
    • 1926.1203
    • General requirements
    • 1926.1204
    • Permit-required confined space program
    • 1926.1205
    • Permitting process
    • 1926.1206
    • Entry permit
    • 1926.1207
    • Training
    • 1926.1208
    • Duties of authorized entrants
    • 1926.1209
    • Duties of attendants
    • 1926.1210
    • Duties of entry supervisors
    • 1926.1211
    • Rescue and emergency services
    • 1926.1212
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    • cesspools; silos; air receivers; sludge gates; air preheaters; step up transformers; turbines; chillers; bag houses; and/or mixers/reactors.
    • (b)
    • Exceptions. This Standard does not apply to: (1) Construction work regulated by §1926 subpart P—Excavations. (2) Construction work regulated by §1926 subpart S—Underground Construction, Caissons, Cofferdams and Compressed Air. (3) Construction work regulated by §1926 subpart Y—Diving.
    • (c)
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    • Control means the action taken to reduce the level of any hazard inside a confined space using engineering methods (for example, by ventilation), and then using these methods to maintain the reduced hazard level. Control also refers to the engineering methods used for this purpose. Personal protective equipment is not a control.
    • Controlling Contractor is the employer that has overall responsibility for construction at the worksite.
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    • Entry permit (permit) means the written or printed document that is provided by the employer who designated the space a permit space to allow and control entry into a permit space and that contains the information specified in §1926.1206 of this Standard.
    • Entry rescue occurs when a rescue service enters a permit space to rescue one or more employees.
    • Entry supervisor means the qualified person (such as the employer, foreman, or crew…
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    • Communication Standard, §1926.59 of this part, published information, and internal documents can provide guidance in establishing acceptable atmospheric conditions.
    • Host employer means 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, and has…
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    • Line breaking means the intentional opening of a pipe, line, or duct that is or has been carrying flammable, corrosive, or toxic material, an inert gas, or any fluid at a volume, pressure, or temperature capable of causing injury.
    • Lockout means the placement of a lockout device on an energy isolating device, in accordance with an established procedure, ensuring that the energy isolating device and the equipment being controlled cannot be…
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    • Physical hazard also includes chemicals that can cause death or serious physical damage through skin or eye contact (rather than through inhalation).
    • Prohibited condition means any condition in a permit space that is not allowed by the permit during the period when entry is authorized. A hazardous atmosphere is a prohibited condition unless the employer can demonstrate that personal protective equipment (PPE) will provide effective…
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    • Note. Testing enables employers both to devise and implement adequate control measures for the protection of authorized entrants and to determine if acceptable entry conditions are present immediately prior to, and during, entry.
    • Ventilate or ventilation means controlling a hazardous atmosphere using continuous forced-air mechanical systems that meet the requirements of §1926.57—Ventilation.
    • §1926.1203 General requirements.
    • (a)
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    (i)

    • The employer can demonstrate that all physical hazards in the space are eliminated or isolated through engineering controls so that the only hazard posed by the permit space is an actual or potential hazardous atmosphere;
    • (ii)
    • The employer can demonstrate that continuous forced air ventilation alone is sufficient to maintain that permit space safe for entry, and that, in the event the ventilation system stops working, entrants can…
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    (iv)

    • No hazardous atmosphere is permitted within the space whenever any employee is inside the space.
    • (v)
    • Continuous forced air ventilation must be used, as follows:
    • (A)
    • An employee must not enter the space until the forced air ventilation has eliminated any hazardous atmosphere;
    • (B)
    • The forced air ventilation must be so directed as to ventilate the immediate areas where an employee is or will be present within the space and must continue…
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    • providing the certification. The certification must be made before entry and must be made available to each employee entering the space or to that employee’s authorized representative.
    • (f)
    • When there are changes in the use or configuration of a non-permit confined space that might increase the hazards to entrants, or some indication that the initial evaluation of the space may not have been adequate, each entry employer must have a…
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    • Before entry operations begin, the host employer must provide the following information, if it has it, to the controlling contractor:
    • (i)
    • The location of each known permit space;
    • (ii)
    • The hazards or potential hazards in each space or the reason it is a permit space; and
    • (iii)
    • Any precautions that the host employer or any previous controlling contractor or entry employer implemented for the protection of employees in the permit space.
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    (ii)

    • The entry employer must inform the controlling contractor in a timely manner of the permit space program followed and of any hazards confronted or created in the permit space(s) during entry operations; and
    • (iii)
    • The controlling contractor must apprise the host employer of the information exchanged with the entry entities pursuant to this subparagraph.
    • Note to paragraph §1926.1203(h). Unless a host employer or controlling contractor…
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    • Determining that, in the event the ventilation system stops working, the monitoring procedures will detect an increase in atmospheric hazard levels in sufficient time for the entrants to safely exit the permit space;
    • Providing pedestrian, vehicle, or other barriers as necessary to protect entrants from external hazards;
    • Verifying that conditions in the permit space are acceptable for entry throughout the duration of an authorized entry…
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    • Rescue and emergency equipment needed to comply with paragraph §1926.1204(i), except to the extent that the equipment is provided by rescue services; and
    • Any other equipment necessary for safe entry into, safe exit from, and rescue from, permit spaces.
    • (e)
    • Evaluate permit space conditions in accordance with the following paragraphs (e)(1) through (6) of this section when entry operations are conducted:
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    • Immediately provide each authorized entrant or that employee’s authorized representative with the results of any testing conducted in accordance with §1926.1204 of this Standard.
    • (f)
    • Provide at least one attendant outside the permit space into which entry is authorized for the duration of entry operations;
    • Attendants may be assigned to more than one permit space provided the duties described in §1926.1209 of this Standard can be…
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    (m)

    • Review entry operations when the measures taken under the permit space program may not protect employees and revise the program to correct deficiencies found to exist before subsequent entries are authorized; and the occurrence of an injury or near-miss during entry, a change in the use or configuration of a permit space, and employee complaints about the effectiveness of the program.
    • (n)
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    • and that condition is temporary in nature and does not change the configuration of the space or create any new hazards within it; and
    • Cancel the entry permit when a condition that is not allowed under the entry permit arises in or near the permit space and that condition is not covered by subparagraph (e)(2) of this section.
    • (f)
    • The entry employer must retain each canceled entry permit for at least 1 year to facilitate the review of the…
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    • Note to paragraph §1926.1206(i). Those measures can include, but are not limited to, the lockout or tagging of equipment and procedures for purging, inerting, ventilating, and flushing permit spaces.
    • (j)
    • The acceptable entry conditions;
    • (k)
    • The results of tests and monitoring performed under paragraph §1926.1204(e) of this Standard, accompanied by the names or initials of the testers and by an indication of when the tests were performed;
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    • Whenever there is a change in permit space entry operations that presents a hazard about which an employee has not previously been trained; and
    • Whenever there is any evidence of a deviation from the permit space entry procedures required by paragraph §1926.1204(c) of this Standard or there are inadequacies in the employee’s knowledge or use of these procedures.
    • (c)
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    The entry employer must ensure that each attendant:

    • (a)
    • Is familiar with and understands the hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of the exposure;
    • (b)
    • Is aware of possible behavioral effects of hazard exposure in authorized entrants;
    • (c)
    • Continuously maintains an accurate count of authorized entrants in the permit space and ensures that the means used to identify…
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    • Informs the authorized entrants and the entry supervisor if unauthorized persons have entered the permit space;
    • (i)
    • Performs non-entry rescues as specified by the employer’s rescue procedure; and
    • (j)
    • Performs no duties that might interfere with the attendant’s primary duty to assess and protect the authorized entrants.
    • §1926.1210 Duties of entry supervisors.
    • The entry employer must ensure that each entry supervisor:
    • (a)
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    • §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.
    • Evaluate a prospective rescue service’s ability, in terms of proficiency with rescuerelated tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit…
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    • spaces or from representative permit spaces, except practice rescue 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. 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.
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    (b)

    • Employers must make available to each affected employee and his/her authorized representatives all information required to be developed by this Standard.
    • §1926.1213 Provision of documents to Secretary.
    • For each document required to be retained in this Standard, the retaining employer must make the document available on request to the Secretary of Labor or the Secretary’s designee.
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    Appendix B: Sample SDS

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    Appendix C: Confined Space Basics

    • Question: What is a Confined Space?
    • Answer: A confined space means a space that:
    • Is large enough and so configured that an employee can bodily enter it; Has limited or restricted means for entry and exit; and
    • Is not designed for continuous employee occupancy.
    • Examples of typical Confined Spaces:
    • Pipes and pipelines Possible Hazards: Engulfment Atmospheric Configuration
    • Attics
    • Possible Hazards:
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    Vaults

    • Possible Hazards:
    • Engulfment
    • Atmospheric
    • Configuration
    • Electrical
    • Explosion
    • Stored Energy
    • Struck-by
    • Crawspaces and Ducts Possible Hazards:
    • Atmospheric
    • Electrical
    • Animals
    • Enfulgment
    • Pits and Shafts
    • Engulfment
    • Atmospheric
    • Struk-by Electrical
    • Explosion
    • Falls
    • Manholes
    • Atmospheric
    • Electrical
    • Enfulgment
    • Struck-by
    • Falls
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    Tanks Vesseal

    • Possible Hazards:
    • Engulfment
    • Atmospheric
    • Explosion
    • Stored Energy
    • Concrete Mixers Possible Hazards: Configuration Atmospheric Stored Energy Configuration
    • Question: In a permit required confined space, what is a hazard?
    • Answer: A hazard in permit required confined space means a physical hazard or hazardous atmosphere:
    • Question: What is a physical hazard?
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    • 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—Occupational Health and Environmental Control, or in Subpart Z—Toxic and Hazardous Substances, of this part and which could result in employee exposure in excess of its…
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    Physical: Hazards exposed electrical

    • Physical: Paint mixing/spray booths/chemials
    • Atmospheric: Hazards may include a toxic or flammable atmosphere or an atmosphere that is oxygen enriched or oxygen deficient.
    • Question: What is a permit required confined space?
    • Answer: A permit-required confined space (permit space) means a confined space that has one or more of the following characteristics:
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    • (2) Contains a material that has the potential for engulfing an entrant;
    • (3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
    • (4) Contains any other recognized serious safety or health hazard.
    • Physical hazard means an existing or potential hazard that can cause death or serious physical damage. …
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