safety and health

DISCUSSION

Review the following proposed rule document – Confined Spaces in Construction. The general industry standard specifies a limited exce3ption from some of the permit-required confined-space requirements when the only hazard in a confined space is an atmospheric hazard and ventilation equipment will control the atmospheric hazard at safe levels. However, the general industry standard does not apply to construction employers, and as such, does not specify the appropriate level of employee protection based on the hazards created by construction activities performed in confined spaces

General industry standard Proposed construction standard
Organization of the Standard
The standard begins with requirements for entering PRCSs The proposed standard takes a step-by-step approach, explaining how to assess hazards, determine the classification for the space, and how to safely enter it.
Information Exchange
The standard requires a host employer to coordinate entry operations with a contractor when the host employer and the contractor both have employees working in or near a permit space The proposed standard requires the controlling contractor to coordinate entry operations among contractors who have employees in a confined space regardless of whether or not the controlling contractor has employees in the confined space.
Confined Space with Hazards Isolated
Does not address working in confined spaces in which the hazard has been isolated Allows employers to establish an Isolated-Hazard Confined Space by isolating or eliminating all physical and atmospheric hazards in a confined space.
Controlled-Atmosphere Permit-Required Confined Space
Monitoring required as necessary Continuous monitoring required unless the employer demonstrates that periodic monitoring is sufficient.
Permit-Required Confined Spaces (PRCS)
No explicit requirement for entry supervisor to monitor PRCS conditions during entry Explicit requirement for entry supervisor to monitor PRCS conditions during entry.
Requires a written PRCS plan No written plan required when employer maintains a copy of the standard at the worksite.
No specific early-warning requirements for up-stream hazards Early-warning requirement for up-stream hazards in sewer-type spaces.

In the discussion, choose one area in the comparison between the general industry standard, and the proposed construction standard and write appropriate comments to help convince shareholders that the standard is needed. Topics to be discussed would include: (1) Typical confined spaces encountered in construction; (2) whether an early-warning system should be required for spaces in which an engulfment hazard cannot be isolated (such as in some sewer situations); (3) the need for, and cost of, continuous monitoring for atmospheric hazards; (4) how a confined-spaces standard for construction could accommodate the needs of small businesses; and (5) whether an attendant should be permitted to monitor more than one confined space at a time..