FTI Update on Confined Space Standard

As the International Union of Painters and Allied Trades endeavors to build new partnerships in our communities, one of the keys to successfully do so is maintaining a reputation of being the best of the best, on and off the job.  If we are going to grow by maintaining that the “union way” is the way for men and women to enter our industries, then we must continue to build state-of-the-art training programs.

The IUPAT Finishing Trades Institute is on the job every day to provide those programs through working with government experts, studying new regulations and building its own community of trainers and experts online.

Why did the industry need its own confined space standard?

Although much of the work our building crafts men and women perform is done outdoors and within view of the public eye, many construction workers are hidden within confined spaces such as the restricted interior of a manhole, pipe, tank or other crawl spaces that provide limited ventilation and entrance/exit holes that are not so easy to get in, or out of, quickly. Inside these confined spaces, workers weld, strip, paint, seal and glue to coat surfaces, linings and valves, and perform other jobs necessary to maintain the infrastructure of the systems on which they work.

If the proper precautions are not communicated and understood prior to, during, and after completing a job, some of the concealed hazards the workers encounter, while performing their jobs, are exposure to toxic hazards, electrocution risks, explosions and asphyxiation. OSHA’s new rule, Confined Spaces in Construction Subpart AA 1926.12XX (1200-1213), intends to protect the worker who may enter one or more confined spaces while engaged in construction activities at a worksite. The rule outlines more detailed provisions for the coordination of activities on a job site where there are multiple employers. This is intended to eliminate hazards introduced in a confined space by workers performing tasks outside of the space, such as the buildup of carbon monoxide within the space due to a generator running near the entry. Previously, the only requirement for working in confined spaces was training which did not take into account the unique environment of an active construction site in which injuries and fatalities resulted.

In its simplest form, the rule requires employers to determine what kinds of spaces their workers are in, what hazards could be there, how those hazards should be made safe, what training workers should receive, and how to safely rescue those workers if anything goes wrong. The key players identified by OSHA to enforce the rules include a Competent Person, a Qualified Person, the Host Employer, the Controlling Contractor, and the Entry Employer; each plays a role in ensuring the safety of any employee who may enter a permit space.


Confined Spaces in Construction Subpart AA 1926.12XX went into effect on August 3, 2015, with enforcement postponed until October 2, 2015. Enforcement of the rule is expected without penalty by OSHA for those employers who are making a “good-faith” effort to comply. A good-faith effort includes:

  • Scheduling training for employees as required by the standard
  • Ordering necessary equipment
  • Taking alternative measure to educate and protect employees from confined space hazards

More information on confined spaces and the full regulation OSHA 1926.12XX can be found on the OSHA website. Other useful references include:

ANSI A10.43 – Confined Spaces for Construction

  1. Under development
  2. Latest comments/vote on most recent changes 6/19/15

OSHA 1910.146 – Permit Required Confined Spaces

  1. Available on the OSHA.gov website

ANSI Z117.1 – 2009 – Safety Requirements for Confined Spaces

  1. Currently being revised
  2. Possible release in 2015

Requirements in the new rule that differ from those in the general industry rule include:

  • A competent person must conduct the initial job site evaluation
  • Information exchange requirements to inform employers what discussions must be conducted and, when, during confined space entry
  • Air contaminant and engulfment monitoring must be done continuously, as the technology is readily available for most hazards
  • For substances where continuous monitoring technology is not available, periodic monitoring is required
  • The rule explicitly requires employers to coordinate emergency services before workers enter the confined space
  • During controlled atmosphere entry, employers must isolate physical hazards rather than eliminate all of them, such as using lockout/tagout, blocking off access to struck-by hazards