Transcript Standards Development in Fall Protection

STANDARDS UPDATE:
US Federal OSHA
Proposed Rule for Confined
Spaces in Construction
MSA WebCast
July 17, 2008
Presented by:
Joseph Feldstein
Manager Technical Services
Mine Safety Appliances Company
1
© MSA 2008
Today’s WebCast Topic
 Background on the history
and need for new
rulemaking
 Review of Requirements
 Safety Equipment for
Confined Spaces
 Costs and Implications for
Industry
 Question and Answer
Session
©MSA 2008
2
Background on the OSHA
Proposed Confined Spaces Rule
 New requirements
 Training, hazard analysis, classification
 Entering, working, exiting and rescue
 History
 Litigation
 Role of the ACCSH
 Need for new rulemaking
 Annual average of 6.44 deaths and 967
injuries
©MSA 2008
3
Summary of the Proposed Standard
 What is a Confined
Space?



Space large enough and
arranged so an
employee can enter
Limited or restricted
means of entry/exit
Is not designed for
permanent occupancy
 Examples of Confined
Spaces in Construction





©MSA 2008
pits
tanks
sewers
silos
turbines
4
Worksite Evaluation and Coordination
 Controlling Contractors and Host
Employers
 Information to be shared:




Location of confined spaces
Hazardous conditions
Precautions taken to address hazards
Classifications of the confined spaces
©MSA 2008
5
Atmospheric Testing
 Test or monitor for:
 Oxygen deficiency
 Combustible gases and
vapors
 Toxic gases and vapors
 As necessary, based on
 Results of tests
 Regularity of entry
 Effectiveness of
monitoring
 Provide information like
MSDS
©MSA 2008
6
Classifications of Confined Spaces
 Continuous System Permit Required
Confined Space (CS-PCRS)
 Permit Required Confined Space
(PCRS)
 Controlled Atmosphere Confined
Space (CACS)
 Isolated Hazard Confined Space
(IHCS)
©MSA 2008
7
Continuous System Permit
Required Confined Space
 Definition
 Confined space that is part
of, and contiguous with a
larger confined space
 Subject to release from the
larger space that would
overwhelm protective
equipment
 High risk category
 Example
 Space contiguous to a
sewer system
©MSA 2008
8
Permit Required Confined Space
 A confined space that has:



A hazardous atmosphere
Inwardly-converging,
sloping surfaces
An engulfment hazard or
other physical hazard
 Physical Hazards






©MSA 2008
explosives
mechanical, electrical,
hydraulic and pneumatic
energy
radiation
temperature extremes
falls
noise
9
Controlled Atmosphere
Confined Space
 A confined space
where ventilation
alone will control
its atmospheric
hazard
 Cannot be a CACS
if it has a physical
hazard (unless that
hazard is isolated)
©MSA 2008
10
Isolated Hazard Confined Space
 A confined space in
which all physical and
atmospheric hazards
have been isolated
 Isolation includes:






©MSA 2008
Blanking and binding
Misaligning or removing
section of lines
A double-lock-and-bleed
system
Machine guarding
Blocking or
disconnecting all
mechanical linkages
Installing guardrails,
stairs or platforms
11
Classification Options
 Employers can classify a confined
space in any classification, so long as
all of the characteristics and
requirements for that classification
are met
 Exception is that a space with the
characteristics of a CS-PRCS cannot
be given a different classification
©MSA 2008
12
Reassessment
 Whenever conditions
change, the space
must be reassessed
 Prior to reassessment,
entrants must exit the
space
 No one may re-enter
until hazards have
been evaluated and
protection has been
provided
©MSA 2008
13
Permit Required Confined Spaces
 Identification of Hazards
 Isolation or other protective
measures must be provided
 If isolation is not feasible, then PPE may
be required
 Monitoring procedures are required
 Detect atmospheric hazards in time for
entrants to safely exit the space
©MSA 2008
14
Continuous System
Permit Required Confined Space
 For a CS-PRCS, employers must
complete all requirements for PRCS,
as well as:
 Monitor continuously for atmospheric
hazards
 Monitor continuously for non-isolated
engulfment hazard using an early
warning system
©MSA 2008
15
Controlled Atmosphere
Confined Spaces
 For each physical hazard, determine
and implement an isolation method
 Test the atmosphere while using
ventilation equipment to verify that
ventilation alone can control at safe
levels
 Monitoring procedures must include
an early warning system in the event
of a ventilation failure
©MSA 2008
16
Isolated Hazard Confined Spaces
 Determine and implement an isolation
method for each physical and
atmospheric hazard
 Isolate the hazards without entering
the space
 Verify in writing that all physical and
atmospheric hazards in the space hav
been isolated
©MSA 2008
17
Training
 Training would be
required for all hazard
classifications
 Employees to be
trained:




Entry supervisors
Attendants
Authorized entrants
Rescue Service
Employees
 Exit procedures
 Records
 Retraining
©MSA 2008
18
Rescue from Confined Spaces
 Non Entry Rescue
 Requires a retrieval
system
 Harness and retrieval
line
 Rescue anchor point
 Structural anchor
 Heavy equipment
(locked out or tagged
out)
 For retrievals involving a
vertical distance over 5
ft, a mechanical retrieval
device would be required
©MSA 2008
19
Rescue from Confined Spaces
 Entry Rescue
 Respond to a rescue
summons in a timely
manner
 Have appropriate
rescue plans and
practice rescue
operations
 Entry rescue services
must be provided with
adequate training and
equipment for the task
©MSA 2008
20
Safety Equipment
for Confined Spaces

Equipment required in proposed
rule:






Atmospheric testing and
monitoring equipment
Forced-air mechanical ventilation
equipment
Personal protective equipment,
such as respirators
Any other equipment necessary for
safe confined space operations
PPE must meet applicable OSHA
regulations
Equipment must be maintained
and calibrated according to
applicable OSHA requirements and
manufacturers’ instructions
©MSA 2008
21
Safety Equipment
for Confined Spaces
 Portable gas monitoring
instruments



Oxygen
Flammable vapors
Toxic gases



Tripods and anchorages
Personnel hoists
3-way rescuers
 Continuous air
monitoring instruments
 Air purifying respirators
and SCBA
 Confined space entry and
retreival equipment
©MSA 2008
22
Cost Impact of the Proposed Rule
 640,000 confined spaces per year
 20,000 construction companies with
employees working in confined spaces
 Estimated annual cost of compliance is
$76.8M




$11.7M
$10.0M
$9.6M
$8.1M
atmospheric monitoring
respiratory protection
rescue capabilities
training
©MSA 2008
23
Public Comment
 OSHA will hold public hearing on the
proposed rule in Washington DC on July 22,
2008. For further information, contact
Garvin Branch, Directorate of Construction,
U.S. Department of Labor, 200 Constitution
Avenue, NW, Washington, DC 20210.
 Copies of the proposed rule are available
online at the OSHA website
(http://ww.osha.gov), select "Federal
Register," and "Date of Publication,"
(November 28, 2007).
©MSA 2008
24
Schedule for Publication
of the Final Rule
 OMB advises OSHA no new
regulations after July 2008
 Second quarter 2009 is earliest
expected publication of final rule
 OSHA usually gives at least 90 days
before rule takes effect
 Much depends on comments received
by OSHA on the proposed rule
©MSA 2008
25
Conclusions
 New requirements
would be placed on
construction
companies for
evaluating, planning,
training and
monitoring confined
spaces
 New knowledge and
skills required for
construction personnel
 Proposed requirements
for prompt rescue will
favor on-site rescue
teams
©MSA 2008
26
Thank you for your
participation!
To Contact the Presenter:
Joseph Feldstein
MSA Fall Protection
2250 South Tejon Street
Englewood, CO 80110
ph: (303) 975-2304
fax: (303) 934-9960
email: [email protected]
website: www.msanet.com
27
© MSA 2008