mischelle vanreusel michael penn
TRANSCRIPT
Mischelle Vanreusel
&
Michael Penn
2011 MdQI ConferenceSustainable Transportation - A Multi-Modal Approach
MOSH
Confined Space
Michael Penn, Chief of Compliance
Confined Spaces
• Brief overview of the confined space laws in Maryland.
• Review two accidents that involved confined spaces.
Confined Space Standards
• 29 CFR 1910.146 - Permit Required Confined Spaces
• COMAR 09.12.35 - MOSH Standard for Confined Spaces
• Labor & Employment Article Section 5-602 - Work in Confined Spaces
29 CFR 1910.146
• Scope: Covers general industry and not construction.
– Became effective in 1993
Confined space is defined as a space that is:
• Large enough and so configured that an employee can bodily enter and perform assigned work;
• Has limited or restricted means for entry or exit; and,
• Is not designed for continuous employee occupancy.
Permit–required confined space has one or more of the following 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 smaller cross section; or
• Contains any other recognized serious safety or health hazards.
Requirements
• Evaluate and identify the spaces.
• Develop a permit system.
• Fill out entry permit prior to entering.
• Test atmosphere prior to entry.
• Train employees in confined space entry.
• Develop rescue procedures.
• Have authorized entrants oversee the entry.
COMAR 09.12.35
• Covers construction activities:
– Storage tanks
– Open-topped space more than 4 feet deep (bin, silo or pit)
– Manholes, sewer, tunnel pipeline and similar structure.
• Became effective in 1978.
Confined Space is defined as a space:
• Having limited means of entry or egress.
• So enclosed that adequate dilution ventilation is not obtained by the following:
– Natural air movement
– Mechanically induced movement
• Subjected to:
– The accumulation of toxic or combustible agents
– An oxygen deficiency
Case Study
Two cases that involved accidents in confined spaces in construction
Background: Case #1
• Paving company had a contract to pave the roadway and raise the manhole covers up a few inches.
• Sewer lines and manholes were completed a year ago and covered over.
Paving Operation
• At end of shift employee was parging a manhole dropped his cement trowel into the manhole.
• Manhole is 24 feet deep.
• Active sewer line.
Employee entered the manhole to get trowel
Employee passed out at the bottom
Rescue Attempt
• Foreman’s son entered the manhole to try to save the employee by carrying him out on his shoulder.
• Foreman called his son out of the manhole and he then entered to try and rescue the employee.
Consequences
• Both the worker and foreman died at the bottom of the manhole for an $8 trowel.
• Cause of death: Lack of oxygen.
Background: Case #2
• A new sewer line was being installed in a new housing development.
• The sewer pipes were not active, and the line was sealed from the main county sewer line.
• Sewer vault involved was 15 to 20 feet deep.
• A section of the line had been plugged and pressure tested for leakage.
Accident: Case #2
• Utility company finished a pressure test on the line and needed to remove the plug.
• Water had leaked into the pipe over the weekend and the pipe was filled with about 6 inches of water.
• The Vice President of the company, who was on-site, sent employee #1 into the manhole to pull out the plug to drain the water.
• Employee #1 entered and passed out with his face in the water.
• Employee #2 entered the manhole to try to retrieve employee #1
• Employee #2 collapsed at the bottom of the sewer vault with employee #1.
• Employee #3 attempted to provide assistance to employee #1 and #2.
• Employee #3 became ill half way down and climbed back out
of the manhole.
• Co-workers then attached a hose to an air compressor and used it to blow air into the sewer vault.
• Employee #2 regained consciousness and was able to assist in rescuing Employee #1 and himself from the sewer vault.
Rescue Attempt
• Employee #1, who was a laborer, died in hospital later that day.
• Employee #2 and #3 were taken to the hospital and released the following day.
• Cause of death: Lack of oxygen.
Consequences
Possible Cause of Accident
• A week before the accident a lawn care company hydro seeded and fertilized the site.
• The heavy equipment on-site cracked a pipe which allowed surface water rich with nitrogen to enter the sewer.
• With the sewer pipe plugged the water was trapped in the pipe.
• Over the weekend there was an algae boom that caused carbon dioxide to built up and displaced the oxygen.
• Employees enter into an oxygen deficient space.
Citations
• COMAR 09.12.35.03(b)(4)
– When neither adequate natural air movement nor adequate continuous forced ventilation is provided, test the following:
• Atmosphere in the confined space for oxygen deficiency;
• Combustible gas in excess of 10% of lower explosive limit (LEL); and,
• Air contaminants in excess of levels specified in Sub Part Z of 29 CFR 1910.
Citations Cont’d.
• COMAR 09.12.35.03(b)(7)
– Ensure that each employee working inside and outside the confined space has been adequately trained in rescue and cardiac pulmonary resuscitation procedures.
– Ensure that an employee entering a confined space for rescue complies with B(6):
• Involved use of respiratory protection.
Findings
• COMAR 09.12.35.03(d)
– Employer did not establish a written procedure covering confined space entry under emergency conditions.
Overall Consequences
• Loss of three workers - could have been three more.
• The company in Case #1 was fined $56,600.
• The company in Case #2 was fined $106,250 with willful citations.
• Possible loss of insurance carriers.
• Both companies have this on their record for future job bids.
Most Difficult Consequence
Telling the family members about the death of their loved ones.
Prevention
Do I need this?
Do you use, contract, or work around cranes?
New Crane Regulations
Mischelle Vanreusel Program Manager
42
Objective / Agenda:•Background & History
•Purpose & Scope of the Rule
• Training Concepts & Terms
•Coverage of Specific Provisions
•Training Requirements•Discussion Forum
Crane Safety Regulation• OSHA Construction Standards – ASME -1968
• Cranes & Derricks Negotiated Rulemaking Advisory Committee (C-DAC) – July 2002
• February-2006 – Ron DeJuliis – DLI Commissioner
• Bringing the Industry Together
• First Joint Effort of it’s Kind (Merit / Union Shops)
• Fast Track (two public hearings)
• Regulatory Process (Legislative Action)
• OSHA (CFR Subpart “CC”)– August -2010
• This effort will save Lives & Reduce Injuries
Maryland’s New Crane Regulation
Regulatory & Safety Update
The Integration and Adoption
of the federal OSHA Crane
rule.
Maryland Crane Safety Requirements Summary
Insert Craig’s slide here!!
Scope of Coverage:
• This regulation applies to all powered operated equipment including cranes and crane operators, signal persons, riggers, and crane operator trainees, and to the erection, operation, and dismantling of cranes and powered equipment used in construction and demolition.
QUALIFICATION OR
CERTIFICATION IS
REQUIRED!
•Employer Qualification Training: Conducted by employer using competent individual who can accurately assess whether an individual meets the qualification standards.
•Independent Qualification Training: Conducted by an entity that is independent of the employer and is competent to accurately assess whether an individual meets the qualification standards.
•Independent Certification : Provided through an accredited organization meeting specific criteria.
1926.1428
Signal Person Requirements.
• Drug and alcohol free. (pre-susp-random)
• Trained, proficient, and successfully demonstrates knowledge ~Written Test -1926.1419 thru 1422 & 1428
Qualification Requirements
A qualified signal person must;
• Know and understand signals
• Be competent in using signals
• Have a basic understanding of crane operation
• Pass a verbal or written test and a practical test
Rigger Requirements. • Drug and alcohol free. (pre-susp-random)
• Trained, proficient and successfully demonstrates knowledge. (Re-training
requirement)
–Employer established audited program
–Third party NCCA/ANSI certification
–Approved Apprenticeship (Rigger I)
Rigger II Experience
Rigger Proficiency Levels • Level I – Basic – Signal Person Proficiency
• Level II – Full Performance
• Master/Lead Rigger – Special Skill / Suprv.
Persons can not perform work that
exceeds their level of training or
experience.
The controlling entity must: • Ensure that ground preparations
necessary to meet the requirements of this
section are provided.
§ 1926.1413 Wire rope - inspection
• Shift inspection. • A competent person must begin a visual
inspection prior to each shift the equipment is used, which must be completed before or during that shift. The inspection must consist of observation of wire ropes (running and standing) that are likely to be in use during the shift for apparent deficiencies, including those listed
• Untwisting (opening) of wire rope or booming down is not required as part of this inspection.
Employer must comply with all applicable manufacturer prohibitions
•1. Manufacturer Proceduresor
•2. Employer Procedures
Note: Employer must follow manufacturer procedures when using synthetic slings during A/D rigging( See 1926.1404(r)).
Resources
• Training and Education
• Consultation
• Website
• Hunt Valley Office
• Alliance
Thank you!!
Things to Know…
• Penalties
• Legislation
• Posting Time