Key Differences Between OSHA 1910146 And 1910146AA

February 20, 2023 |

The Occupational Safety and Health Administration (OSHA) section 1910.146 contains requirements for practices and procedures to protect employees in general industry from the hazards of entry into permit-required confined spaces. When it comes to the Construction Confined Space Regulations (26 CFR 1926 Subpart AA), there are several vital variances that employers and safety experts should be aware of.

These regulations require employers to take adequate precautions to prevent their employees from entering the space, even if they don’t expect their employees to enter confined spaces. This article provides an overview of the differences between OSHA 1910146 and 1910146AA.

Multi-Employer Worksites

Construction sites typically have a frenzy of activity. It’s not unusual that any employer will be the sole contractor or subcontractor working on a site at any given moment unless scheduled. Depending on the project’s size, scope, and complexity, there are typically at least a few different contractors on the job site at any time.

According to the new standard, the host employer has sole accountability. The host employer must provide information on the locations, risks that may arise in the future, and any past safety measures or entry controls.

Additionally, where coordination is necessary between numerous parties entering the same confined location, the host employer, controlling contractor, and entry employer have duties. To ensure the controlling contractor and host employer know of any new or changing risks discovered or produced in the confined space, this also necessitates an information exchange following the closure of the entrance permit and confined space operations.

An effective consensus standard for multiple employer projects and permit-required confined spaces is ANSI/ASSE A.10-2011 Safety & Health Program Requirements for Multi-Employer Projects.

Evaluation of the Worksite and Confined Spaces, Including Permit Spaces by a Competent Individual

There are requirements for competent persons under other rules, such as the General Industry Fall Protection rule. Adopting this requirement emphasizes the importance of having skilled workers on the project. Identification of current and potential (predictable) confined space dangers will fall under the purview of one individual.

The competent person must participate in entry planning as a subject matter expert. Even though they are not obligated to participate in the follow-up, the competent person should try to acquire knowledge of any new or evolving risks in the area. Knowing these risks helps future entrants. It’s also imperative to ensure that your worksite has the best emergency response team you can get.

Continuous Atmosphere Monitoring

Even if the law doesn’t mandate it, monitoring seems like a given. The environment or atmosphere in a confined space often fluctuates, as anyone who has worked in one can attest to. Work-related risks, dangers that employees are aware of, and risks not taken into account during the risk assessment can all contribute to the need for constant monitoring.

Even after ventilation and other measures are in place, ongoing atmospheric monitoring should continue. As a refresher, the initial atmospheric test should be performed without controls to establish a baseline for the confined space’s conditions.

Continuous Engulfment Hazards Monitoring

The fact that dangers might and often do change makes managing them on a construction site challenging. These frequently happen without warning, and mishaps and fatalities have been linked to shifts in the conditions within confined spaces. For the safety of the users, monitoring offers an extra layer of defense against environmental changes in the area.

To refresh your memory, oxygen, flammability, and hazardous gases are monitored in that order during atmospheric monitoring. The ideal oxygen content is 19.5%–23.5%. Flammable gases should not exceed 10% of the lower flammable limit (LFL) for gases, mists, vapors, or combustible dust. The permissible exposure limit (PEL), threshold limit value (TLV), or time-weighted average (TWA) of a substance should not be exceeded by toxic gases.

Permit Suspensions

The construction rule offers a little more flexibility than the general industry rule regarding permit-required confined spaces. For general industries, the permit must be revoked if the dangers or environment of the area change and they are not stated on the confined space permit.

The permit may be put on hold during construction as long as the conditions can be reverted to what is stated on the permit before re-entry. Employers who are required to comply with the general industry clause and the 1910 and 1926 standards should choose the more restrictive of the two to maintain consistency and avoid the possibility of field interpretations.

Not Sure Where to Start?

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