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Beyond Compliance: Inspired by Confined Space Rules

TUESDAY, OCTOBER 20, 2015

By Robert Ikenberry


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In the works since 1980, federal OSHA recently published new construction-specific confined space safety regulations under rule 1926.1201-1213. 

iStock.com/vinzo
© iStock.com / vinzo

OSHA has just released its confined space safety regulations specifically for the construction industry. Published in May, enforcement will begin in October 2015.

Finally published on May 4, 2015, the regulations went into effect Aug. 3, while full enforcement was delayed until October 2015.

General Industry vs. Construction

Many industrial painters are familiar with, and have been following, confined space regulations under the General Industry Orders rule 1910.146, but these guidelines have generally been triggered by maintenance in industrial plants and were not specific to construction.

Most large or sophisticated owners required compliance with the confined space regulations, including permit-required confined spaces, for any maintenance work on their tanks, pipelines, sewers, pits or similar spaces that fit the definition of a confined space. Confined spaces are classified as work areas that:  

  1. Are large enough for a worker to enter;
  2. Are not designed for long-term occupancy;
  3. Have limited access and egress; and
  4. Pose a potential for hazardous atmospheres or engulfment or entrapment hazards.

Even now, most work that complied with 1910.146 will comply with the new construction standard. Similarly, if contractors follow the new 1926.1200 series sections on industrial owners’ property, they generally won’t run afoul of the General Industry regulations.

iStock.com/BanksPhotos
© iStock.com / BanksPhotos

Most large or sophisticated owners required compliance with the confined space regulations, including permit-required confined spaces, for any maintenance work on their tanks, pipelines, sewers, pits or similar spaces.

I hope everyone who works in confined spaces will carefully review and follow the new regulations. A thorough analysis of the new construction regulations is beyond the scope of this blog, but I have another thought.

I propose that we can save lives by going beyond them. The approach that permit-required confined space regulations take has real value and provides insights for other worksites.

Applying Confined Space Principles Elsewhere

Pretty much by definition, containments on painting project (bridges, enclosed exteriors, partitioned interiors, etc.) are not confined spaces—they are, after all, designed for worker occupancy.

However, they present many of the specific hazards that confined spaces can: limited access and egress, potential for hazardous atmospheres to accumulate, difficult rescues, limited visibility and communication, etc.

iStock.com/joshuaraineyphotography
© iStock.com / joshuaraineyphotography

Even projects that are not in a confined space per se present many of the same hazards: limited access and egress, potential for hazardous atmospheres to accumulate, difficult rescues, limited visibility and communication, etc.

So if we were to treat a blasting and painting containment like a confined space, we would:

  1. Designate an entry supervisor;
  2. Identify the hazards present and how to reduce or mitigate them;
  3. Ensure we know who is inside the space;
  4. Monitor the space to verify its safety and act when it’s no longer safe; and
  5. Arrange for a rescue team and have a plan for how to reach, treat and evacuate any injured worker.

I suggest that these types of plans and practices should be considered for every contained project, even if it isn’t officially a confined space.

Designating an ‘Entry Supervisor’

A knowledgeable, qualified and empowered person—such as the project manager, superintendent or safety representative—should be designated as the party responsible for all activities in the space.

That person needs to be aware of every process that occurs, from constructing access, erecting containment, cleaning or painting to containment/access removal. He or she needs to consider the entire process—the tools, equipment, products, and personnel introduced into the space, as well as the preexisting conditions and hazards (lead paint, traffic, weather extremes, fall risks, operating or energized equipment, etc.). 

istock.com/kozmoat98
© iStock.com / kozmoat98

Coordination with local fire, police or other emergency responders would ensure they know how to access the site, what materials are in use, and what skills and equipment they will need to respond to an emergency.

In this way, the “entry supervisor” can consider what training each participant needs, what safety or rescue equipment may need to be pre-staged in the space, and how the company can accurately account for everyone in the event of an emergency. 

Coordination with local fire, police or other emergency responders may also be appropriate. This would ensure they know how to access the site, what materials are in use, and what skills and equipment they will need to respond to any anticipated emergency.

Safety First

Permit-required confined spaces really are just a special instance among the kind of worksites we routinely encounter. The specific steps developed to keep them safe can be applied in our approaches to safety on other jobsites as well.

ABOUT THE BLOGGER

Robert Ikenberry

Robert Ikenberry, PCS, has been in industrial painting and construction since 1975. Now semi-retired as the Safety Director and Project Manager for California Engineering Contractors, Robert stays busy rehabbing, retrofitting and painting bridges. His documentary on the 1927 Carquinez Bridge was the pilot for National Geographic’s Break it Down and an episode of MegaStructures.

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Tagged categories: Air quality; Bridges; Chemical Plants; Confined space; Construction; hazardous materials; Hazards; Oil and Gas; OSHA; Petrochemical Plants; Pipelines; Pipes; Railcars; Regulations; Robert Ikenberry; Safety; Sewer systems; Shipyards; Tanks; Tanks and vessels; Tunnel; Wastewater Plants; Water Tanks; Wind Towers

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