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Spray Foam Safety: Confined Space Safety Regulation Update

By Jennifer Coon, CHMM, CET, Safety Director, Tank Industry Consultants

In May of 2015, the U.S. Occupational Safety and Health Administration (OSHA) published the Final Rule for Confined Spaces in Construction (29 CFR 1926 Part AA). The standard refined the parameters for working in confined spaces – creating additional requirements for construction industry confined spaces and encompassing residential construction – meaning that OSHA’s ruling has direct ramifications for those who work in the spray foam industry. Enforcement of the ruling took effect October 2, 2015; however, official enforcement of the residential regulations were delayed until March 8, 2016.

WHAT ARE THESE REGULATIONS? AND WHAT DO THEY MEAN?

OSHA describes the differences between the new final rule and the previous in the following manner: “The rule requires employers to determine what kinds of spaces their workers are in, what hazards could be there, how those hazards should be made safe, what training workers should receive, and how to rescue those workers if anything goes wrong.” (OSHA FAQ. www.osha.gov/confinedspaces/faq.html)

Employers are charged with recognizing and addressing the atmospheric and physical dangers that might exist in the confined space. They are also responsible for establishing warning and monitoring systems while their crews are performing work in confined spaces with hazardous conditions. Finally, employers may also be responsible for establishing a rescue plan.

OSHA defines a confined space as a space that is large enough to enter; has limited or restricted means of access (entry and / or exit points); and is not designed for continuous occupancy. In industrial projects, tanks, pipes, tunnels, and pits all fall under this definition. In residential projects, this includes attics and crawlspaces. It can also include enclosed beams such as the scissor trusses that form cathedral ceilings; the areas below stair landings; heating, ventilation, and air conditioning ducts (HVAC); as well as basements (lacking outside exits) prior to the installation of staircases.

CONFINED SPACE, PERMIT-REQUIRED

  1. A confined space may be a permit-required confined space if it contains, among other things, a hazardous atmosphere. OSHA defines a hazardous atmosphere as meeting one of four criteria:
  2. The atmosphere is oxygen deficient (O2 concentrations less than 19.5 percent) or oxygen rich (O2 concentrations greater than 23.5 percent).
  3. If any flammable gas, vapor, or mist exists in excess of 10 percent of its lowest explosive limit (LEL), then OSHA considers that a hazardous atmosphere.
  4. If airborne combustible dust particles are present at a concentration that is equal to or greater than their LEL, this too is a hazardous atmosphere, according to OSHA.
  5. Further, if there is the presence of an atmospheric concentration of any substance that can cause acute illness, injury, impairment of ability to self-rescue, incapacitation, or death then this also is an OSHA-defined hazardous atmosphere.

It is important to note that if the atmospheric hazard can be reduced by continuous forced air ventilation, then employers may follow alternative procedures instead of full permit space procedures, although the space will still be classified as a permit space.

If the confined space contains materials that could engulf entrants, and / or is designed in such a manner as to entrap or asphyxiate entrants, it is not necessarily a hazardous atmosphere; but it is a permit-required confined space. Also included in this permit-required confined space category are confined spaces containing “other recognized safety or health hazards” such as snakes, insects, fragile floors, etc.

Again, it must be noted, if the permit-requiring condition (e.g. insects) can be exterminated and removed from the work area, the space may be reclassified as a non-permit confined space.

If any of these permit-necessitating hazards exist, and cannot be addressed, they must be assessed. A hazard management plan must be developed, and an entry permit must be obtained.

The entry permit for confined spaces includes the following information:

  • Permit space,
  • Purpose of entry,
  • Date and duration of permit,
  • Authorized entrants,
  • Attendants,
  • Entry supervisor,
  • Hazards of the space,
  • Hazard control procedures,
  • Acceptable entry conditions,
  • Atmospheric test results,
  • Emergency procedures, and
  • Equipment.

The permit must be posted at the entry point of the confined space.

REAL WORLD COMPLIANCE

As an employer, how do you comply with the standard?

If you work in the construction industry – regardless of commercial, residential, or industrial focus – confined space safety needs to be a key part of your safety plan. Prior to beginning any project, as an employer it is your responsibility to:

  1. Identify any confined spaces in which your crew will be working,
  2. Determine whether or not those spaces are permit-required, and
  3. Implement an action plan. In some cases, the hazards can be remediated (for example with insect / pest control) and the space reclassified. If the space cannot be reclassified, then a program must be developed.

In general, employers are required to maintain a written confined space safety program that includes documentation of all entry procedures, permits, the roles and responsibilities of workers, training, gas monitoring, potential hazardous situations, rescue procedures, and documentation.

Employers are required to train their employees. Your crew must be able to identify the confined-space and permit-space warning signs. They must know and understand what each means. Employees must be provided with, be trained to operate, and must use, personal protective equipment (PPE), including atmospheric monitors and two-way communication devices.

Employers are also required to identify an attendant who will remain outside the confined space and monitor the crew inside the confined space. Employers are also responsible for identifying an entry supervisor who is responsible for overseeing the entire confined space safety program.

REAL WORLD RESOURCES

Valuable links and information can be found at the OSHA website (www.osha.gov), including a “Confined Space Advisor,” which can help employers create new or refine existing confined space programs. OSHA consulting is always available as well, it is free, confidential, and will not result in citations or penalties. To find an OSHA consultant near you visit www.osha.gov/dcsp/smallbusiness/consult_directory.html. The Spray Polyurethane Foam Association (SPFA) also provides written safety guidelines on their website, www.sprayfoam.org. Both organizations provide excellent resources for SPF employers.

It is always best to err on the side of caution when it comes to safety. Visit the provided links, use the guidelines, but remember, confined spaces do not fit into a “one size fits all” category. As an employer, evaluate the programs and guidelines that fit your specific situation.  •

ABOUT THE AUTHOR: JENNIFER COON, CHMM, CET, has a Masters of Science degree in Environmental Science from Indiana University, with a concentration in Hazardous Materials Management. Her Bachelor’s degree, also from Indiana University, is in Public Affairs, with a concentration in Environmental Science. She is a Certified Environmental Trainer and a Certified Hazardous Materials Manager. Jennifer is the Safety Director for Tank Industry Consultants (TIC), where she is responsible for developing, communicating, and monitoring TIC’s extensive Health and Safety program. Jennifer authors, updates, and enforces all aspects of TIC’s construction safety program, which includes Lead in Construction, Hazard Communication, Personal Protective Equipment, Confined Space, and Lockout/Tagout components.