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Safety
in confined spaces: More than a rope?
Working
in confined spaces requires more than rudimentary rescue equipment. Depending
on your job, it takes a full-blown plan.
The confined
space entry standard for general industry does not apply to
construction, or at least that’s what the wording in the beginning
of the 22 CFR 1910.146 standard states.
“A review of
the 22 CFR 1926.21 construction standard reveals that construction
work must follow many of the same standards set for general
industry,” says Todd Eastham of McCulley, Eastham and Associates
in Greenup, Kentucky.
Eastham works
closely with companies developing confined space entry programs and
serves as a member of ANSI committee developing the Z11717 standard
for confined spaces.
“It all
intertwines. 22 CFR 1926.21 B6i and ii set forth the parameters
construction sites must follow when working in confined spaces.
It’s similar to the general industry standard, but does not
require a confined space permitting process,” he says.
Eastham says an
effective confined space program is important on any site. That’s
because confined space emergencies are as deadly to rescuers as they
are to untrained or poorly trained workers in these hazardous
environments.
“Sixty to 70
percent of the victims in confined space accidents are rescuers. A
good confined space program can help reduce accidents, which in turn
reduces emergency rescues,” he says.
Just what is a
confined space?
“A confined
space is any work area that is large enough to enter, has limited
access but is not designed for continuous occupancy,” explains
Eastham.
“You don’t
have to go far in a building already built or under construction to
realize there are many areas that qualify as confined spaces. In
general industry situations, the space must then be identified as a
permit or non-permit confined space,” Eastham says.
Construction or
re-hab?
Construction
contractors can’t completely ignore the general industry standard
that requires the confined permit process. “If the work is rehab
or remodeling, the site definitely falls under maintenance which is
covered under the general industry standard,” says Eastham.
The standard
outlined in 22 CFR 1910.146 (c) (8) requires the host employer to
identify permitted confined space areas to contractors and require
them to follow the company’s established permit space entry
protocol.
The host
employer must tell why the space is considered a permit space entry
area, any background the company has on the confined space and what
the established procedures are to work in the permit area.
The contractor
must comply with the permit space requirements set forth by the host
employer. The contractor must also train or coordinate training with
the host employer so contractor employees working in or near the
permit space are aware of the danger and precautions needed to work
safely.
The contractor
employees must also inform the host employer of any hazards workers
confronted or created while working in the permit confined space.
Confined space
hazards
In
permit-required spaces, workers may encounter any or all of the
following hazards:
Asphyxiation/respiratory
hazards Atmospheres with less
that 16.5 percent oxygen can kill. Fumes, fluids and flowing solids
can displace breathing air, creating an oxygen-deficient
environment. Fumes from liquids stored or transported in the
confined space as well as gases from welding or internal combustion
engine exhaust can degrade air quality. Ventilation and respirators
may be needed.
Uncontrolled
release of energy Electricity,
high-pressure fluids and gases or mechanical energy may be
accidentally released in confined spaces.
Employers must
institute and workers must use lock-out tag-out procedures as
outlined in 29 CFR 1910.147, even if it is considered a construction
job.
Lack
of Personal Protection Equipment (PPE) Working in a confined space amplifies dangers. Head, hearing and eye
protection take on added importance. Hazards should be evaluated and
personal protection equipment identified and worn to reduce the
hazard.
Make a written
safety plan
“Contractors usually write very generic written plans for
working in confined spaces. They often don’t understand the
impact,” says Eastham.
A good written
plan includes a jobsite assessment process that identifies hazards.
It should be followed by a plan to eliminate the hazards and
appropriate training for anyone working around or in the confined
space.
The written plan
should also identify emergency procedures. Local emergency crews
trained in confined space rescue should be contacted and briefed
about the site and its various confined spaces.
Even with the
best written confined space plans, Eastham finds that the biggest
obstacle to this type of work is a company’s upper management
attitude toward safety.
“It is the
biggest key to safety. The resources are out there to help people
work safely, but if management isn’t willing to seek out those
resources, it puts workers at risk,” he says.
On-line help
Eastham
recommends contractors who work in confined spaces log on to this Web
site. “This will take you
directly to a hands-on site to help you identify confined space
hazards and what you should do about them.
"It
will even help you develop a permit entry space program,” he says.
The program can be downloaded and run in a Windows environment or
used online.
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New
confined space
rules on the way for construction?
OSHA is
gathering information to update its confined space standard
for construction. It plans on issuing a proposed rule for
confined space in construction in 2002.
Through
stakeholder meetings, OSHA is looking for information on the
following issues. Depending on its findings, these are likely
topics that will be covered in the revised standard:
Confined
spaces encountered in construction:
OSHA researchers are asking contractors to identify the types
of confined spaces they typically encounter, how contractors
define a confined space and what obstructions impair entering
or exiting these confined spaces.
Engulfment
hazards in construction: OSHA
wants to address engulfment hazards, such as sewers that can
not be effectively blocked off. It is considering requiring
contractors to use an early-warning system that would notify
workers of coming engulfment hazards.
Atmospheric
hazards and testing in construction:
Presently, the general industry standard requires only
periodic atmospheric monitoring. Because atmospheric testing
tools have advanced technologically and are now much less
expensive, OSHA is considering requiring continuous monitoring
on construction sites. OSHA wants to know: Does continuous
monitoring better protect employees than periodic monitoring?
Are there labor savings associated with continuous monitoring?
What do continuous monitors cost?
Considerations
for small businesses: OSHA wants
to find ways to make it easier for small businesses to protect
their employees from confined space hazards without
compromising safety.
Allow
attendants to monitor more than one permit-required confined
space (PRCS). Even though OSHA
officials are concerned about the risks involved with
combining the entry supervisor and attendant responsibilities,
they will consider it if can be done in a way that shows the
attendant can fully perform such duties and responsibilities.
It wants to identify how many PRCSs one attendant can
effectively monitor and the means and procedures needed to
allow the attendant to respond to an emergency affecting any
of the PRCSs. |
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Know your
site and be prepared to handle any event or emergency
L. Todd
Eastham of McCully, Eastham and Associates teaches confined
space permitting and rescue procedures to industrial and
construction customers across the country.
To be
well-prepared for confined space work and rescue, you need to
plan ahead. He suggests you consider the following areas:
Confined
space
Use
lock-out/tag-out devices on power or energy sources. That
includes all sources – electrical, steam, water, hydraulic,
chemical – whatever is in the confined space that could
release energy or material that could injure or kill.
Consider other
hazards. Check the air quality and ventilate and/or select the
appropriate respirator. Bleed off any valves or systems that
have been locked out. Consider any components in the confined
space that could act as booby-traps. Be prepared for animals
that may have made the confined space their home.
Confined space
opening guarding. Set up barricades around the perimeter; if
it is a permit-required confined space, make sure the
attendant is present and understands his or her duties.
Personal
protective equipment
PPE selection
depends of the job. Do you need:
• Gloves:
Rubber/surgical, leather?
• Helmet or
hard hat?
• Eye
protection: Goggles, safety glasses, side shields?
•
Respiratory protection: dust mask, cartridge respirator,
self-contained breathing apparatus, outside air supply and
hood?
• Turn-out
gear (what is this?)
• Fall
protection: Everyone should be tied off; lifelines should be
attached in almost all confined spaces.
Work
equipment
Rope: Match
the rope to the job. Make sure the ropes are part of a
maintenance program where they are inspected regularly for
damage. Make sure workers know a variety of knot styles that
can be used to handle material safely and easily.
Caribiners:
Select the appropriate caribiner for the job. Never load on
the gate or use them for three-way loading.
Webbing: Match
tensile strength to the job. Use padding to protect the
webbing from sharp corners or abrasive surfaces.
Anchor
straps:
Match tensile strength to job; 20,000 lbs. is most common.
Pulleys: Match
to job needs.
Haul
systems:
Short haul systems work well, but don’t rely on them for
rescue; tripod and winch systems can be used for rescue;
remember to make lifts so the weight stays in the center of
the tripod.
Rescue
equipment
Usually
trained rescue teams carry this equipment:
• Backboard
• C-Spine
immobilizer
• Stokes
Blanket
• Prusics
• Belays
Talk
with rescue teams before work starts to assure they are
familiar with the hazards and the confined space. It can save
valuable time in the case of an accident. |
Published
in the September/October 2001 issue of Contractor Tools and
Supplies
magazine.
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