June 2015

In this months G&G New Letter I wanted to inform you of OSHA’s proposed final rule on confined space for construction as the August 3, 2015, deadline is quickly approaching. I have attached the link for you https://www.osha.gov/confinedspaces/index.html

In a nutshell, the rule requires every construction employer that has employees who may enter into a confined space to have a written Permit-Required Confined Space Program that meets the requirements of the standard. The program must be designed to control and protect employees on the jobsite from permit-space hazards and to regulate entry into permit regulated confined space

The standard does not apply to construction work that is cover by Subpart P — Excavations 

In addition construction work covered by Subpart S – Underground Construction, Caissons, Cofferdams and Compressed Air which applies to tunneling is also not covered.


General Industry verses Construction


In addition to classifying the type of each permit-required confined space that employees will enter into there have been some changes to the general industry standard which are applicable to construction operations. Some of the aspects of the construction industry standard that are not included in the general industry standard include requirements for having a competent person evaluate all confined spaces before work begins and having a qualified person as a entry supervisor. 

The standard includes information exchange requirements for host employers, controlling contractors and entry employers to ensure multiple employers on a jobsite share important confined space safety information. Additionally, requirements have been added for providing and posting warnings for workers at jobsites with confined spaces.


OSHA also adjusted the construction rule to account for advances in technology and equipment that allow for continuous monitoring of atmospheric hazards and early-warning systems to prevent engulfment.


Other differences between the regulatory text of the general industry rule and this standard reflects improvements in clarity of the regulatory language. OSHA has also determined that construction employers who are in compliance with this new standard will also be considered to be in compliance with the general industry standard when need be. A rescue plan must be included in the PRCS program but OSHA has clarified the implementation of non-entry rescue and what must be done to ensure the availability of an entry rescue service as needed.


In addition to the Definitions and General Requirements OSHA has included sections within the standard to address and clarify the Permit-Required Confined Space Program; Permitting Process; Entry Permit; Training; Duties of Authorized Entrants, Attendants, and Entry Supervisors; Rescue; and Employee Participation.