IKECA continues our mission to inform and educate our members about important changes in standards relating to occupational hazards. The Occupational Safety and Health Administration (OSHA) has just released a new construction standard 29 CFR 1926 Subpart AA. This subpart is specifically designed to protect construction workers from confined space hazards that are not covered in Subpart P Excavations.
Here is the information you need to know:
What are confined spaces?
Confined space means a space that:
(1) Is large enough and so configured that an employee can bodily enter it
(2) Has limited or restricted means for entry and exit; and
(3) Is not designed for continuous employee occupancy.
Confined spaces include: HVAC ducts, bins, boilers, sewers, storm drains, electrical vaults, tanks, manholes, digesters, GREASE ducts, etc.
How does this apply to the Kitchen Exhaust Cleaning industry?
Kitchen Exhaust Cleaning often involves access to confined spaces for proper cleaning.
Many people who die in confined spaces simply aren’t aware of the potential hazards, therefore all hazards must be addressed before entering a space to perform work, and eliminated whenever possible. The first step in confined space awareness is performing a confined space assessment to identify all permit-required confined spaces.
• Can an employee be trapped or asphyxiated?
• Is the atmosphere hazardous or is the air contaminated?
• Is there a need for testing?
• Is the work environment susceptible to really hot or cold conditions?
• Do we have a need to isolate energy sources?
Once evaluations are performed, employees need to receive awareness training on the potential hazards of confined spaces, confined space entry requirements, entrant and attendant training. A rescue plan must also be developed.
This is a starting point for finding information about these spaces, the hazards they may present, and ways to safely work in them. This can be a big deal and add significant cost to a project, as an employer it is our duty to provide a safe and healthy work environment. There are several resources available at OSHA’s Frequently Asked Questions.
The full Subpart AA can be found here