Construction Safety

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Course Learning Outcomes for Unit VII

Upon completion of this unit, students should be able to:

2. Apply Occupational Safety and Health Administration standards and related practices to construction. 2.1 Discuss the requirements for working safely in confined spaces.

4. Examine methods used to control common construction hazards. 4.1 Analyze hazards that contribute to construction accidents.

8. Examine training and hazard communication strategies. 8.1 Examine hazard communication strategies.

Course/Unit Learning Outcomes

Learning Activity

2.1 Unit VII Lesson Required Readings Unit VII Assessment

4.1 Unit VII Lesson Required Readings Unit VII Research Paper

8.1 Unit VII Lesson Required Readings Unit VII Assessment

Reading Assignment

Occupational Safety & Health Administration. (2015). Subpart AA, confined spaces in construction [Brochure]. Retrieved from https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

Occupational Safety & Health Administration. (2015). Confined spaces in construction: Pits [Brochure]. Retrieved from https://www.osha.gov/Publications/OSHA3788.pdf

Occupational Safety & Health Administration. (2015). Confined spaces in construction: Sewer systems [Brochure]. Retrieved from https://www.osha.gov/Publications/OSHA3789.pdf

Occupational Safety & Health Administration. (2014). Hazard communication: Small entity compliance guide for employers that use hazardous chemicals [Brochure], pp. 1-29. Retrieved from https://www.osha.gov/Publications/OSHA3695.pdf

Occupational Safety & Health Administration. (n.d.) Steps to an effective hazard communication program for employers that use hazardous chemicals [Brochure]. Retrieved from https://www.osha.gov/Publications/OSHA3696.pdf

UNIT VII STUDY GUIDE

Confined Space Entry and Hazard Communication

https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

https://www.osha.gov/Publications/OSHA3788.pdf

https://www.osha.gov/Publications/OSHA3789.pdf

https://www.osha.gov/Publications/OSHA3695.pdf

https://www.osha.gov/Publications/OSHA3696.pdf

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Title Unit Lesson

Confined Space Entry

On August 3, 2015, a new Occupational Safety & Health Administration (OSHA) standard regulating confined space entry in construction became effective, nearly eight years after the proposed rule was first published in the Federal Register. The standard was needed to protect workers from exposure to serious hazards while working in confined spaces on construction sites. Workers in other industries have been protected by a confined space standard for decades, and OSHA recognized that a separate standard was needed for construction due to the ever-changing nature of construction confined spaces and the type of work done in them. The standard emphasizes training, monitoring, and communication between contractors and subcontractors (Cordado, 2015).

By definition, a confined space has three specific characteristics:

 is large enough and so configured that an employee can bodily enter it;

 has limited or restricted means for entry and exit, and

 is not designed for continuous employee occupancy (Occupational Safety & Health Administration [OSHA], 2015).

It is important to note that “restricted for entry/exit” does not mean “one way in—one way out.” Restricted means that it may be difficult to exit in an emergency or it may be difficult for rescue workers to enter the space. Time is a critical factor in confined space emergencies

On construction sites, confined spaces often include pits, trenches, manholes, tanks, sewers, ducts, and drains. Not all confined spaces need controlled entry. OSHA further defines a permit-required space as one that has one or more additional characteristics:

 contains or has a potential to contain a hazardous atmosphere,

 contains a material that has the potential for engulfing an entrant,

 has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section, or

 contains any other recognized serious safety or health hazard (OSHA, 2015).

Determinations of permit-required spaces must be made by a competent person. If hazards are identified, control measures that allow safe entry must be implemented, including continuous monitoring of existing

(Almeida, n.d.)

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Title

hazards. Employees authorized to enter permit-required spaces must be trained on safe entry procedures, and employers must ensure that non-authorized employees are not allowed to enter the confined spaces. Provisions must be in place for emergency egress from the space as well as provisions for emergency rescue (OSHA, 2015).

Safety professionals familiar with the confined space requirements of OSHA’s General Industry Standards will recognize many similarities in the Construction Standard. However, some sections of the 29 CFR 1926 version include new or revised requirements based on advances in technology and lessons learned since the implementation of the 29 CFR 1910 standard. It is important that the standard be read in its entirety before developing any confined space entry program.

Hazard Communication

In 1983, OSHA published its first Hazard Communication (Hazcom) Standard at 29 CFR 1910.1200 (Haight, 2013). The goal of this standard was to ensure workers were provided information and resources necessary to identify hazardous chemicals in the workplace and protect themselves from exposure to these chemicals. The term “Right to Know Law” is often used to describe the Hazcom Standard. More than 30 years later, the Hazcom Standard remains the second most frequently cited OSHA standard (OSHA, n.d.-a). The reasons for the number of citations could include that the standard is complex or that the standard was not clear in its requirements. OSHA originally chose to write a performance standard that provided general guidelines rather than a specification standard that provided more detail. For example, the old standard did not specify the formatting of labels used on hazardous material containers, but simply stated that the labels must include identity of the hazardous chemicals, appropriate hazard warnings, and the name and address of the chemical manufacturer, importer, or other responsible party (OSHA, 2012). Numerous labeling systems could be found in a single workplace, creating confusion for both workers and employers. In 2012, OSHA revised the Hazcom Standard to align with the United Nations Globally Harmonized System of Classification and Labeling of Chemicals (GHS). The revision resulted in standardized label formatting, the use of pictograms on labels, standardized wording of precautionary statements, and standardized information required on safety data sheets. Workers see the same information in the same format regardless of the chemical manufacturer or the industry in which they work. In OSHA’s own words, “The standard that gave workers the right to know, now gives them the right to understand” (OSHA, n.d.-b, p.1).

The OSHA construction standard for Hazard Communication (29 CFR 1926.59) states, “The requirements applicable to construction work under this section are identical to those set forth at 1910.1200 of this chapter” (OSHA, 1996, p.1). The construction industry must comply with the Hazcom requirements in the General Industry Standards. The requirements of the standard are summarized in the image below.

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Title

The challenge to implementing an effective Hazcom program is, once again, the constant changes that occur on a typical construction site. The adoption of GHS will improve the understanding of labels and hazard warnings, but the employer must still ensure all hazardous chemicals are inventoried and the safety information is communicated effectively to employees.

References

Almeida, A. (n.d.). “Who taught the new guy…” [Cartoon]. Retrieved from http://www.almeidacartoons.com/Safe_toons1.html

Cordado, T. L. (2015). OSHA issues new construction confined space standard. Retrieved from http://www.oshalawblog.com/2015/05/articles/confined-spaces

Haight, Joel M. (Ed.). (2013). Hazardous material management and hazard communication. Des Plaines, IL: American Society of Safety Engineers.

Occupational Safety & Health Administration. (n.d.-a). Commonly used statistics. Retrieved from https://www.osha.gov/oshstats/commonstats.html

(OSHA, 2014)

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Title Occupational Safety & Health Administration. (n.d.-b). Hazard communication. Retrieved from

https://www.osha.gov/dsg/hazcom/index.html

Occupational Safety & Health Administration. Regulations (Standards – 29 CRF): Hazard communication. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_id=10633&p_table=STANDARDS

Occupational Safety & Health Administration. (2012). Side-by-side comparison of OSHA's existing Hazard Communication Standard (HCS 1994) vs. the revised Hazard Communication Standard (HCS 2012). Retrieved from https://www.osha.gov/dsg/hazcom/side-by-side.html

Occupational Safety & Health Administration. (2014). Hazard communication: Small entity compliance guide for employers that use hazardous chemicals [Brochure] Retrieved from https://www.osha.gov/Publications/OSHA3695.pdf

Occupational Safety & Health Administration. (2015). Subpart AA, confined spaces in construction [Brochure]. Retrieved from https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf