2.6        Requirements for Identification and Reporting of Confined Spaces during the Design Process

MDOT MAA requires that the creation of confined spaces resulting from the design of new facilities be minimized. The Consultant shall identify and report all possible new confined spaces during the design process, so that informed consent can be obtained from MDOT MAA. This MDOT MAA Design Standard provides guidance to Consultants related to potential new confined spaces.  These requirements may vary for tenant projects.

The Consultant shall be familiar with the MDOT MAA Confined Space Entry Program, and requirements of 29 CFR 1910.146, Occupational Safety and Health Administration (OSHA) Standard for Permit-Required Confined Spaces, with the intent of minimizing the creation of new confined spaces, and especially permit-required confined spaces, during the design process. The Consultant shall consider how the definitions for confined space and permit-required confined space apply to the components and systems developed in the design process. If a confined space is anticipated to be created by the design, then the Consultant shall present possible alternatives to its creation and identify possible design features that can be incorporated to minimize permit required confined spaces.

Any new confined spaces, including those which are necessary as a course of the design (e.g. telecommunication manholes, , ejector pits, return air duct, sewer manholes) shall be identified by the Consultant in the 30% design submittal/design report. The Consultant shall include a section in the report dedicated to confined spaces. This section will identify each potential confined space and discuss the anticipated hazards associated with the confined space, including an evaluation of alternatives which resulted in the selection. For example, a confined space such as the dry well of a wet well/dry well sewage pump station could be anticipated to have hazards of hydrogen sulfide and methane gases which would make the dry well a permitted confined space.

However, the design could, at some additional cost to the project, include mechanical ventilation to reduce the classification to a non-permit confined space, in contrast, the confined space classification of the wet well would likely not benefit from any type of improvement investment. In this example, the design report would indicate both the wet well and dry well as permit controlled confined spaces. The consultant would then provide narrative regarding the pros, cons and cost of designing the dry well to comply with the requirements of a non-permit confined space by the addition of adequate ventilation and instrumentation etc. and a statement that the wet well will not benefit from any investment. The Consultant would then make a recommendation as to whether or not the improvements are warranted on a case by case basis.

The design shall include all necessary signs for confined spaces as applicable and practical. Whenever the design includes new permit controlled spaces, the Consultant shall include in the design documents adequate signage for confined space notification in accordance with OSHA requirements.

As the design is developed through the 60% and 100% submittals, the Consultant shall record in these submittals, specific details and an evaluation of alternatives based on development of the findings presented in the 30% design submittal/report. Confined Space CAD standards, including Confined Space Structure IDs, are documented in Volume 1, Chapter 3.3.3 Confined Space/Non-Confined Space/No-EntryDrawings. Confined Space GIS data standards are documented in Volume 1, Chapter 4.3 Attributes & Domains.

As part of the Consultant Phase 3 Services, the Consultant shall identify all confined spaces and signage requirements for confined spaces created during the course of the design and include this information on the record drawings. All permit controlled confined spaces shall be clearly designated as such on the record drawings.

The Consultant shall also document all new confined spaces and provide the MDOT MAA Office of Safety & Risk Management and MDOT MAA Project Manager with a completed Confined Space Entry Evaluation Form for each new confined space.