Six critical confined space safety requirements

Ontario’s Green Book is the cornerstone of the province’s health and safety practices – every safety officer understands its importance. But regulations can be difficult to navigate and guidance is always appreciated on some of the thornier topics.

Confined space safety is a cross-industry issue, from mining to utilities. Most sectors in Ontario have the need to understand the intricacies of confined space safety. COS spoke with Douglas Legg, Service and Training Manager at Rubicon Safety, who has years of experience conducting confined space training, to gain his insights into key aspects of Ontario’s regulations. While not exhaustive by any means, here are six key things to keep in mind when covering confined space safety.

1. Planning saves lives. “I can break it down really simply, planning properly saves lives,” says Legg. He says that his previous experience as a volunteer firefighter has given his valuable insights into confined space safety, and what he has found is that planning is the most important thing that you can do.

And this is not just best practice; this is a key part of Ontario’s confined space regulations. The Occupational Health and Safety Act (OHSA) states that “if a workplace includes a confined space that workers may enter to perform work, the employer shall ensure that a written program for the confined space is developed and maintained in accordance with this Regulation before a worker enters the confined space.”

You need to have a proper program, and to create this program you need to do all mandated hazard assessments and come up with a safety plan. “If you plan properly, you can get in and out of a confined space with little to no hiccups. If things do go wrong, you’re prepared for those ‘what if’ scenarios,” says Legg. Plans should include proper means of entry and egress, how to navigate multi-employer involvement, and PPE requirements.

2. Don’t scrimp on the paperwork. To be able to enter a confined space, employers need to ensure that a separate entry permit is issued each and every time work is to be performed in a confined space. There are at least nine things that have to be found on an entry permit, says Legg, which are listed in the regulations:

• The location of the confined space.
• A description of the work to be performed there.
• A description of the hazards and the corresponding control measures.
• The time period for which the entry permit applies.
• The name of the attendant described in section 15.
• A record of each worker’s entries and exits.
• A list of the equipment required for entry and rescue, and verification that the equipment is in good working order.
• Results obtained in atmospheric testing under section 18.
• If the work to be performed in the confined space includes hot work, adequate provisions for the hot work and corresponding control measures.

The Act states that “before each shift, a competent person shall verify that the entry permit complies with the relevant plan” and “the employer shall ensure that the entry permit, during the time period for which it applies, is readily available to every person who enters the confined space and to every person who performs related work with respect to the confined space".

3. Training is key – and there are different levels. The Act also states that all workers that enter a confined space, or perform related work, need to be given adequate training on safe work practices – this includes training in the recognition of hazards associated with confined spaces.

Most people have never actually had to do a rescue, says Legg. And that is why training – including simulated training – is beneficial to the workforce, because they may never get experience from a real life event. “We have to do our best as instructors to simulate those conditions, so that workers can walk away from that experience to at least be able to walk through those steps and apply the skills that we’re talking about,” says Legg.

There are multiple levels of training ranging from basic hazard awareness to more complex matters. And not only do workers have to be confined space trained, but they also have to be trained on the specific equipment that is referenced in the organization’s confined space safety plan. Legg also says that training may be different depending on non-entry or entry level rescue training. Which leads us to the next point…

4. Understand the different between non-entry and entry level rescue. Non-entry level rescue is a rescue that can be completed by an attendant standing on the outside of the space that can safely retrieve at the entrance in the event of an emergency, says Legg. Attendants in this case must remain attached to the rescue system at all times, which has already been set up.

“On the flip side of that, an entry level rescue would be defined as when you have a worker or multiple workers now working inside of the space. And in the event of an emergency, you have to send personnel into the space to extract them,” he says. 

Training for each is different, and ultimately Legg says that training on entry-level rescue could be the best option because it leads to better preparation on the employer side – notably if equipment such as self-contained breathing apparatuses (SCBAs) or cascading airline systems are needed. If a non-entry level rescue fails, then at least the employer is better prepared for an entry level rescue.

It all comes back to planning, he says. “If we plan properly for entries, if we plan properly for rescue and we go through with that procedure, it should all just iron out in the wash.”

5. Pick the right attendant, and give them the right tools. OHSA says that “whenever a worker is to enter a confined space, the employer shall ensure that an attendant is assigned". It is the employer’s responsibility to determine who the attendant is (or multiple attendants if necessary) and make sure that one is assigned and stationed outside and near the entrance to the confined space.

Legg says that attendants have to be competent in confined space entry, and in specific training necessary to ensure rescue if one needs to be done. This includes being rescue trained as well as first aid and CPR training, and training on the use of the rescue equipment.

Attendants have to be in constant communication with all workers in the confined space, using a means of communication established in the relevant plan. “It’s really all about the attendants staying at the space and being close enough to that space so that they can monitor the safety of the worker or workers inside,” says Legg, and provide assistance to the worker and the adequate rescue response should that be required.

The Act doesn’t specifically define what “near” entails, though Legg says that “the best thing you can do is have the attendant just right on top of the space at all times".

6. Atmospheric hazards are more than just gas. Most people typically assume that the atmospheric hazards referenced by the Act simply cover gas. This could be because they are provided with a standard gas monitor which would cover things like oxygen, explosives, carbon monoxide, etc.

But, says Legg, if you look at the Act, atmospheric hazards include so much more such as dusts, fumes and vapours which could result in acute health effects or interfere with a person’s ability to escape should that be necessary. In addition, if these atmospheric hazards are likely to exist in a confined space, they should be purged and/or ventilated before any worker ventilation.

Purging and ventilation are two different things. Purging is the act of removing contaminants from a space. This could simply be removing dust from the space. With ventilation, you have to introduce equipment that can continuously ventilate out the space while workers are conducting their tasks. Employers and workers also need to be aware of the health effects that these contaminants and cleaning products, to do this they can read the product manual or get in touch with the manufacturer.