Industrial Hygiene in Construction

There is a lot of confusion over confined spaces in construction. OSHA is enforcing these rules since Aug 3, 2015, but has given a 60 day postponement (effective Oct 2, 2015). Right now you need to make “good faith efforts” to comply. For those in construction, you need to get up to speed, and even more importantly, get confident. Unfortunately, this information isn’t going to get you 100% there.

The reason confined spaces (and the rules) are so complicated is because every space is different. It’s not a minimum height guard rail, or fall arrest system. There are just too many factors, including: 

• the size (or smallness)
• the ventilation (or lack of)
• access (or lack of)
• the work activity (what you introduce)
• the hazards (before you enter, and what you introduce)
• the people inside (people are different, and work different)

To begin getting educated, here are my suggestions:

• Know the definition of (and when it’s) a confined space (hint: 3 things)
• Know the location(s) of your confined spaces (AND mark them as such)
• Train your employees and yourself
• Buy a multi-gas meter
  • And, know how to use it, bump it, and calibrate it
  • And, train others
• Know: host employer, controlling contractor, sub contractor, mobile worker. It may not be obvious.
• Know: ventilation. When you can use it,  what changes, and how much you need
• Understand “rescue”.  And, the answer is not calling 911.

When an accident happens in a confined space, there’s a high likelihood it’s a fatality.

If you have confidence in the rules, and, more importantly, in the hazards & controls, confined spaces can be safe.

If you haven’t already heard, it is worth while to mention,OSHA now has jurisdiction over confined spaces in construction (in force on August 3, 2015). Hopefully those working in construction have already realized this hazard and have taken steps to prevent injury.

Here are some of my thoughts:

• **although there are many factors, and we should not compare hazards** OSHA estimates an “injury saving” of 780 serious injuries, and 5 lives spared with the confined space rule.  Compare this with the estimated injury saving from the proposed silica: prevent 1,600 cases of silicosis and save 700 lives.  (and, I do realize these cost employers different amounts of $)
• Oregon OSHA – confined spaces already has a (new) construction confined space standard, which is very much different. It will be interesting to see if this; meets/exceeds/or needs to be changed, to comply with the federal rule.
• Since this rule was dropped without much warning, we will wait to see if anyone calls “foul”. Other than political reasons, it is hard to imagine a reason why construction should be exempt from these rules.
• There are some differences in the construction rule and the general industry:
  • Multi-employer work sites are covered
  • Continuous monitoring – when possible engulfment
  • Upstream early warning- when possible
  • Suspension (not cancellation) of a permit

I’m easily impressed with welding and welders. Welding looks so simple, yet hard, dangerous and permanent.

When interviewing your welder, here are some questions to ask:

• What type of welding are you doing?
• What type of metal do you weld on? (mild steel, stainless, galvanized)
• Is there any coating on the metal?
• What type of flux is used?
• Where do you weld?, and then, “Where else?”
• Is there any ventilation in the area you weld?
• Are there any flammables in the area?
• Do you wear any PPE when welding? (ear plugs, respirator, leather)
• When do you use fall protection?
• Do you have & use welding shields?

What makes welding so difficult is the number of variables involved. The welding variables can change by the minute. Educate your employees on these dangers.

After the above questions, if the employee is agreeable, I ask some additional questions. These are the ones that provoke the best stories:

• What is the strangest things you’ve welded?
• Have you ever welding in a really small (confined) area?
• Have you ever welded with exotic metals? fluxes?
• What’s the worst thing you’ve welded on?
• Have you ever gotten sick from welding?

There are many, many more questions to be asked depending on the answers. The authority on this subject, Michael Harris, has written an excellent book on this subject, “Welding Health and Safety“(ISBN 978-1-931504-28-7). It is available from AIHA. It is VERY detailed, and money well spent if you do welding. I have taken his short course (all day) and I learned more than I ever thought possible, and I still can’t even weld!

If you operate a ready-mix plant and have concrete trucks, you are aware of this process. Once a year (hopefully, only once) a person must climb into the drum of the ready-mix truck and chip off excess concrete. What happen during regular use, is that some concrete hardens, which usually sets-up over and around the blades. Access into the drum is by either the 3×4 hole in the side, or down the chute.

Yes, it is a confined space (def’n: 1. large enough to enter, 2. not designed for occupancy, and 3. limited entry/egress).

Here are a list of the possible hazards:

• silica dust (from chipping concrete)
• noise exposure
• hazardous atmosphere (curing concrete uses up oxygen, which we DO need BTW)
• slipping hazard (drum is round inside)
• heat stress (if you’re trying to do this activity in the summer)
• eye hazard (chipping)
• electrical hazard (if you’re using water & have an electric hammer)
• lock out / tag out (if the truck drives away, or if the barrel starts turning)

There are many resources available (see below). Some things to keep in mind; ventilation (fans, etc) to control the airborne silica dust are usually not effective (too much dust versus exhaust). Water controls are best, but you must limit the amount of water and the direction of the sprayer. I suggest looking at what others have done.

Keep in mind, if you perform this activity you will need (as a company):

• respiratory program (medical, fit test, written plan)
• confined space program (multi gas meter, written program, attendant?)
• lock out /tag out policy or procedures
• training (for each of the above, and for this specific activity)

At this point I know what my contractor-friends are thinking…I will subcontract this out!   ha. If you do, please make sure your sub is doing it right.

Resources:

Georgia Tech – good presentation & guidance

Georgia Tech/OSHA – Safe Work Practices (in Spanish too!)

Teamsters H&S hazards & controls

Illinois DCEO – Consultation on ready mix cleaning

If you weren’t aware, OSHA is in the process  of establishing a ‘new’ rule (could be years) for confined spaces in construction (here).

In the meantime, if you plan on entering a space that is confined, below is my “standard” answer: Get help!

What I mean by this is; obtain some assistance as early as you can. Ideally this might even be before you bid the job. I often suggest to  send a superintendent or project manager to a 1/2 day training. Do not rely on the owner, or your general contractor to “safely approve” your employees entering this space. It is your job!

Although confined spaces are simple by definition (restricted opening, large enough to be in, and not meant to be occupied) , they can get  complicated easily. The first thing to consider is what is/was in the space. Secondly, what are you bringing into it? If those two questions are answered completely, the dangers are usually identified.

When reviewing, consider: electrical, oxygen, engulfment, entrapment, access (ingress & egress), coatings, noise, slips, temperature and emergency response (this is NOT an exhaustive list).

There are many other items and steps to have a well-run confined space program. Take a class, know the space, and train your employees. There are many resources at Federal OSHA and at your state OSHA, like Washington here, or like this one from Oregon.

There are many distinct, separate, and important issues when entering a confined space. The point I would like to make is, as a manager of “safety” , Do you allow your employees to enter a confined space?

Most employers do (with consent, acquiesce ). Below are some questions to consider.

• Do employees know what a confined space is? (see OSHA definition)
• Do they know if it is a permit required space?
• Have they been trained? (this is a separate question)
• Do you control the space? What about the space around it? (what about the space where the air/water comes from?)
• Would you allow any employee to enter?
• Who would you NOT allow? (subcontractors? safety personnel? inspectors?)
• What paperwork/training would you want to see if you did allow these people to enter?

The management of confined spaces is by far the most critical piece. The space could be as innocent as a treehouse, or as dangerous as sewer hole immediately dangerous to life and health.