Monday, August 17, 2015

OSHA Updates Confined Space Safety Rules

Contractors who work in crawl spaces and attics may find the latest confined space regulations ... confining! Until recently, residential contractors rarely had to worry about confined space regulations. Now they will need to address confined space regulations on most jobs - both installation and service. OSHA just made changes to the confined spaces rules which will affect everyone that works in residential attics and crawl spaces. Considering that a large amount of residential HVAC equipment is installed in an attic or crawl space, these changes will affect residential HVAC contractors. A confined space is now defined as

  1.         Large enough to get your body in
  2.         Limited means for getting in and out
  3.         Not designed for continuous occupancy

The employer is responsible for providing a competent person to inspect all confined spaces before work begins. This person is looking for any other hazards which can make the confined space more dangerous, such as toxic fumes, low oxygen, electrical hazard, fall hazard, or extreme temperature. (Note this is only a partial list.) If the confined space has any additional hazards it becomes a permitted confined space. Workers can only enter a permitted confined space for the purposes listed on the permit under the conditions and restrictions listed on the permit. A hazard warning must be posted at the entry to a permitted confined space and a permit issued that lists all the details regarding work in that particular confined space. There must be an attendant posted outside a permitted confined space any time a worker is in the space. There are many more regulations. This is honestly only the tip of the iceberg. Suffice it to say, you want to avoid having to declare the confined space a permit required confined space. 

You are allowed to remove hazards to accomplish this. For example, a typical attic with no floor is a permitted confined space based on the fall hazard. If you put boards down for the workers to walk on you remove that hazard, and it no longer requires a permit. Similarly, an electrical hazard can be removed by turning off all power to the confined space. If a confined space has no additional hazards, then you can use what OSHA refers to as an alternate procedure. For this, the competent person must determine that no additional hazards exist, or that they have been removed. The space needs continual positive ventilation while work is being performed. However, the permit and the attendant are not required. Note that this still requires a competent person to inspect the pace BEFORE work begins.

Some logical questions come to mind, such as

Who is the competent person?
The competent person can be one or more of your employees who have been trained to recognize hazards in confined spaces and can use test equipment to test for oxygen level, combustible gasses, or toxic gasses. In the event of an incident, they will be asked to clearly tell OSHA what procedures they used identifying the risks involved with the space. 

Where do I get the permit?
For confined spaces requiring a permit, your company generates the permit – not some government agency. The purpose of the permit is to clearly communicate the conditions under which the space may be entered and who may enter.

When does this go into effect?
The new rules will start being enforced on October 2, 2015.

Where can I read more about this? (Trust me, you NEED to even if you don’t WANT to)