Breaking Down OSHA's New Confined Space Standard For Construction

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Gary Lopez, CSP, has a long history of involvement in standards-development activities. He served for many years on ASSE Standards Development Committee, including 8 years as chair. In addition, he has served on several consensus standards committees, including the group responsible for the ANSI/ASSE Z117 standard on confined space entry. ASSE recently spoke with Lopez about OSHA’s new confined space standard for construction.

ASSE: What are the key differences with OSHA’s new confined spaces standard for construction (1926.1200) and how does it compare to the general industry standard and the Z117 consensus standard?
Gary: I think that you’re going to find after a long, laborious process that OSHA came around to understanding that it had to come pretty close to mimicking what is already used in practice, not just the general industry standard, but the ANSI/ASSE Z117 standard as well. The problem is if the terminology isn’t familiar, people aren’t going to recognize it, and the training is going to be insurmountable for those in the field. More to the point, where you start mixing the two spaces together, for example, a construction site that isn’t green sealed, you could have conflicting requirements going into the confined space.

Having experience in confined space entries in both the manufacturing industry--I spent most of my time in pharmaceuticals--and the construction industry, the key will be what I call the fluidness of the confined space. You will have a bigger challenge writing permits in the construction site then in a chemical plant confined space because it is more dangerous. On a construction site, the confined space can evolve from being a confined space and present a considerable challenge for people who make the determination of an entry permit. It won’t be a one-stop shop like you have on manufacturing sites. Once they identify it, they identify it, and it probably will never change from being a confined space. In the construction site, it’s going to be more difficult. You have to more on-site identification than you would in general industry.

The second great challenge is going to be rescue. At a manufacturing location, you have a known time by which on-site rescue teams can get to the confined space. Construction sites will not experience that luxury.

ASSE: What were some key changes?
Gary: The proposed version had four different categories of confined space that were extremely confusing. The final standard focuses on two types of confined space, almost like the Z117 standard, where you have a permit entry standard or non-permit standard if certain conditions are met.

ASSE: What are some key ways to identify confined spaces?
Gary: There’s a pretty clear definition in the standard regarding what constitutes a confined space. Typically, the first thing you start with is configuration. Many confined spaces are obvious--tanks, manholes and pits. But then you start hitting a borderline, for example a valve pit. Then you question it, so you have to make some further determination about what the hazards are.

Once we get past configuration, the next tripwire is whether there is a potential for hazards in the space. The leading hazard is atmospheric hazards, so it’s important to ask, Is there an oxygen deficiency or toxic materials in the confined space? Are there flammable levels of vapors in the confined space? There’s also the inundation hazard to consider. Could a person be inundated, like in a grain silo or working with water?

ASSE: What are the requirements of the employer and of the individual entering the confined space as a result of the standard?
Gary: This gets complex when you say “employer.” One of the great struggles OSHA has with many standards is who is in charge. Is it the general contractor? Is it the person who directly employs the workers entering the confined space? OSHA has struggled with the language, but ultimately, the employer is responsible for making sure it shares any information about confined spaces on a location, and identifies hazards that would impact entry into those spaces. On the other hand, the employee must understand and have been trained about and appreciate the hazards of a confined space; must know how to recognize those hazards and what to do if something goes wrong, such as an atmospheric alarm sounding. If an employee is in the role of a safety watch or attendant, s/he must know the responsibilities of that role and what the limitations are with regard to rescue efforts.

In essence, confined space entry is a team sport. You never do it alone, and you always make sure that everybody knows their role and has been trained properly before they jump into it.

ASSE: What are some of the key elements of the permit system?
Gary: A permit system is like a pilot’s checklist. If you look at the various permit systems out there, they are similar and they lead you down the path of conducting a risk assessment before you enter a confined space. So, they will always start out with background information about the confined space and the reasons for entry.

Then, the permit asks the user to identify potential hazards of the confined space. The next step is precautions, which more or less is the counter balance to the hazards section. For every hazard identified, you must list a precaution that addresses how you will counteract that hazard. All these must be in place before you enter the confined space.

Then there’s the section that apply to atmospheric readings taken in the confined space, who entered and what authority signed off on it. Permits are a risk assessment tool as much as an approval and communication tool. They are similar no matter who is doing the permit.

ASSE: Rescue has been a problem. What are successful strategies for preventing multiple fatalities?
Gary: Let’s talk about it from two angles. One is the manufacturing angle. Manufacturing sites have a bit of an advantage in that with a defined site area, they can actually train internal rescue teams to be available to respond to any type of emergency situations that may occur in confined spaces.

The construction side is more difficult. Construction personnel have to take one of two approaches. They either take their rescue team and equipment with them when they enter a confined space in the field. Or they depend on some type of local authority, usually a county or municipality emergency response organization, to perform the rescue.

If they decide to do the latter, I advise them to make sure before a rescue is needed or a rescue attempt takes place. The last thing you want is to be planning the best strategy for rescue during an actual emergency. This is a difficult thing to get through because the temptation is to worry about it when the time comes.

Most multiple fatalities in confined space entries do not turn out to be multiple entrants, but the initial entrant and the attendants. It is a natural reaction among people to want to help a coworker in distress, but this is the last thing you want an attendant to do.

During confined space entry training, I stress to future attendants that their job, no matter the circumstance, is to never enter the confined space. That is the job of the rescue team. The attendants’ job is to stand outside and communicate key details to rescue personnel so they can expedite the rescue.

Another way to reduce confined space fatalities is to ensure that entrants take atmospheric reading equipment into the space with them. Today’s equipment features technology that provides continuous readings and can warn workers before things really get bad.

ASSE: What resources can OSH professionals turn to for more information?
Gary: Most of my experience has learned in the field. One thing you can do that will prove educational is to read the preamble to the construction confined space standard. OSHA explains its logic and what led to the standard.

Gary Lopez, CSP, area vice president with AJ Gallagher Risk Management Services in Weston, FL, will present a general session on the confined space standard during ASSE’s Construction Symposium, which will be held Nov. 12-13 in New Orleans, LA. Learn more.