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Building or remodeling? OSHA helps employers with confined spaces in residential construction

New fact sheet identifies when attics may be permit-required confined spaces

Posted July 3, 2017

An OSHA fact sheet describes how the Confined Spaces in Construction standard applies to residential construction. The new guidance was developed with help from the National Association of Home Builders to help clarify provisions in the standard and their application to residential construction work.

The confined spaces in construction standard at 29 CFR 1926 Subpart AA applies to any space that meets the following criteria:

  • Is large enough for a worker to enter it;
  • Has limited or restricted means of entry or exit; and
  • Is not designed for continuous occupancy.

Certain confined spaces require a permit for employees to enter them. A permit-required confined space (PRCS) means a confined space that has one or more of the following characteristics:

  • Contains or has the 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.

The fact sheet points out that spaces in residential homes may be considered confined spaces or PRCSs during the construction or remodeling process. However, OSHA says that most of the standard’s requirements only apply to PRCSs. Common spaces in residential homes such as attics, basements, and crawl spaces will not typically trigger these requirements.

While attics do not usually fall into the PRCS category, OSHA warns that extreme heat in an attic can be a serious physical threat and could make the attic a PRCS. The Agency has not quantified how hot it must be to trigger the permit-required confined spaces requirements. However, heat that is extreme enough to cause heat exhaustion (e.g., dizziness, headaches, severe sweating, cramps) may impede an entrant’s ability to exit the attic without assistance and would make a confined space permit-required.

As for basements, OSHA says if they are configured as designed (i.e., they have permanent stairs, a walk-out entry or exit, or an egress window installed), they are not PCRSs.

The same goes for crawl spaces. Crawl spaces in residential homes will not typically trigger the majority of the requirements of the standard unless they also contain a physical hazard such as an exposed electric wire.

Employer responsibilities

The fact sheet also details the various responsibilities employers have in identifying hazards and communicating them with employees and other employers on the work site.

OSHA points out that employers’ obligations under the standard depend in large part upon the employer’s “type.” Most of the obligations in the standard apply to the “entry” employer. This is the employer who decides that an employee it directs will enter the PCRS.

The fact sheet explains that the standard makes the controlling contractor the primary point of contact for information about PCRSs at the site. The controlling contractor passes this information on to the employers whose workers will enter the confined spaces.

Conversely, entry employers must share information about their entry program with the controlling contractor, especially about the hazards they encounter in the space. The controlling contractor, in turn, passes that information on to other entry employers. The controlling contractor is also responsible for making sure that employers outside a space know not to create hazards in the space, and that workers from different entry employers working in a space at the same time do not create hazards for each other.

Other entry employer obligations include informing employees of hazards present in the confined space; providing the appropriate personal protective equipment; training employees; complying with the requirements for a written PRCS entry program; and ensuring properly trained rescue and emergency services are available.

J. J. Keller's Confined Space SignsJ. J. Keller's confined space signs inform your employees of the danger posed by permit-required confined spaces.


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