Comment Submitted by: Thomas Van Hooser for Ras Gas

Confined Spacess in Construction: Proposed additions: 1) Ventilation: Include specific ventilation criteria and clear guidelines on how ventilation testing protocols are determined. How many minimum air changes are required in a non permitted confined space? 2) Lighting of confined spaces: Make it clear the requirements for illumination of confined spaces with respect to allowable voltage, when low voltage lights are reqired, Seperate circuits for lighting systems, hazards of double insulated tools (tools with no grounding conductor) in confined spaces, precautions for emergency backup illumination (flashlights), GFCI requirements, 3) Risk Assessments/JHA: Include need to prepare a detailed risk assessment and/or JHA for all Confined Space Entry Work and provide sample JHA. 4) Welding: Include clear precautions for welding in confined spaces with respect to welders work positioning, welders insulation from ground, fire resistive attire, and the like. 5) Excavations: Make it clear when excavations are considered confined spaces. Radon gas exposure in trenching and excavations should be discussed and addressed. 6) Identification of Confined spaces: Make it clear that Construction Contractors need to formally identify all confined spaces early in the project before confined space work commences with the listing made part of the Contractors Confined Sapce Entry Program. 7) Rescue: Make it clear that Contractors must have in place a trained first responder program to respond to basic confined space emergency situations until arrival of professional crews. Make it clear that trained first responder crews must be formed if professional emergencies crews are not available to respond with 3 to 4 minutes following an emergency assistance call. Make it clear that resuce equipment must be made available on the construction site and specify miminum resuce equipment to be provided. Thomas Van Hooser, Ras Gas