- The area is not normally occupied.
Work is not normally performed in the area. The area could be used as part of a process or it could be functioning as housing around another structure/device. The bottom line, however, is that the work you have planned (usually inspection, cleaning or maintenance) is different from what is normally going on inside the confined space.
- The area was not designed for continuous human occupancy. This means that the area and building design would not meet building code standards for light, heat, ventilation, ceiling height, door size, etc.
- There is a hazard inside that, if not controlled, may hurt the worker going in. Some jurisdictions will specify the type of hazard (e.g. hazardous atmosphere).
Determining whether a space is confined is a necessary part of determining what rules apply to the job being done. Work performed in a live sewer, for example, will need to follow the confined space regulations. Depending on the atmospheric readings this could mean that workers must be on supplied air, hot work be restricted, and/or ventilation be implemented. Alternatively, some regulations take precedence over the confined space legislation. For example, if you are working in a trench the trenching regulations act as the primary statute.
Check out the documents below to help you determine whether a space is confined and what rules you might need to follow:
Still unsure? Feel free to contact us with your questions.
- Egress Facilities:
- The space has a doorway greater than 21 5/8’’ x 35’’.
- The distance to a doorway is greater than 75’’.
- The space has a permanent elevator installed if it is more 33’ above or below grade.
- The work area is greater than 23 5/8’’ x 23 5/8’’ to 2’11’’.
- The floor has more than 2” of thick, smooth asphalt/concrete flooring or 10 mil poly tarps covering the entire floor. If multiple tarps are used, each tarp must overlap the others by 4’’ with the overlapped areas being weighted down.
- The space has a permanently installed lighting system consisting of electrical outlets and fixtures controlled by a wall switch or panel that supplies more than 50 lx (4.6’ candles) at floor or tread level or 5 Watts/m2 (.46 watts/ft2).
- The space has a permanently installed system to supply at least 7.5L/s (15.9 cfm) of outside air to the area or natural venting of .1 m/50 m2 (1.1 ft2/538 ft2).
To ensure we are following best practices, our courses have derived from two primary standards. The Canadian Standards Association published the CSA Z1006 in April 2010. This document outlines course objectives for confined space training programs. In addition, the National Fire Protection Association published the NFPA 1006, an accredited standard which outlines the qualifications required by professional rescuers. Confined space rescue skills are also covered in this document. Two further standards, the CSA 1001-13 and ANSI Z490.1 outline the requirements for Health and Safety Training.
- Develop a written inventory.
- Define the roles and responsibilities of the senior management member responsible for the confined space, as well as all supervisory personnel, workers, and contractors working inside the space.
- Install signs at entry points of all spaces and/or erect barriers around the space to prevent entry.
- Have a competent person complete a hazard assessment.
- Establish written work procedures, develop appropriate forms and documents as required, and identify & acquire the protective equipment necessary to carry out work.
- Determine the Entry and Rescue Personnel skills, Fitness to Work criteria, as well as develop and deliver training required.
- Just prior to entry, have a competent person identify the hazards due to changes in the environment or work activities that are planned. Develop and implement any additional controls to mitigate any new hazards found in or around the space.
- Set up the required protective and rescue equipment at the entry point.
- Periodically audit tasks/paperwork to ensure work procedures are being followed and that the protective and emergency response equipment are there as required.
- Conduct a periodic assessment of peoples’ skills and conduct semi-annual rescue practices.
- After task, ensure protective and emergency response equipment is clean, work as required, and is stored properly.
- Maintain equipment (e.g. monitors, fall arrest devices, and respirators) as required and keep a log of all activities.
- Maintain a file for all completed documents (time duration is usually determined by the AHJ).
- Review inventory, assessments, procedures, work fitness records, and training as changes occur, enhancement opportunities are found, or at regular intervals of no more than 3 years.
- Conduct retraining sessions at least every 3 years.
- Improve your system as required.
Due to the amount of work required to operate a confined space program, the Z1006 requires an individual within a management position be tasked with the above responsibilities. Lastly, because confined spaces come in a variety of configurations, contain different hazards, and are entered for different reasons, the procedures developed should be space specific. Although this is a lot of work, it ensures uniformity in approach and a higher degree of compliance.
- Supervisor – hazard assessment, selecting appropriate protective equipment, developing procedures, enforcing rules
- Attendant – proper PPE donning and use, incident notification, gas monitoring and/or other hazard detection controls, protective equipment set up and operation
- Entrant – proper PPE donning and use, the recognition of hazard exposure
- Rescue – patient handling, mechanical advantage system deployment, proper PPE donning and use, supplied air respirator donning and use, medical treatment etc.
Note that unless program instructors are bringing confined space gear, most often, you will only be getting awareness training. This training is for the entrant. For all other levels, additional time and equipment are needed to develop adequate skills. Seek courses that focus on the skills required and the specific equipment utilized in the field.
Our Confined Space Training sheet will help determine the type of training you require.
The Equivalency Clause is designed to provide businesses with some flexibility in their endeavors. Most clauses ask that the same level of protection be provided if you wish to deviate from the regulation. This is calculated through understanding the intent of the legislative clause you wish to deviate from as well as the particular hazards you might face. Far too many organizations do not do a proper/exhaustive hazard assessment which will increase the cost of the confined space work.
Common deviances include:
- Not calling a space confined in order to avoid the issue completely. This approach is never recommended as it does not put worker safety first. A good hazard assessment performed by a competent person is recommended instead as it points out the problems that need fixing. Efforts are then spent fixing the problems as opposed to covering them up.
- Not doing the work with your own personnel. Many people hire contractors to do the actual job thinking that the contractors hired will provide all of the confined space safety/rescue. But were they ever asked whether this was the case? If they do provide rescue, are they knowledgeable? Efficient? Skilled? It is recommended that contractors be pre-qualified to ensure they meet the requirements for the job. Communicate your requirements clearly and give them time to get it organized. Put a note in your calendar to remind yourself annually to re-obtain the information and analyze what is received.
- Eliminating the permit when it starts to feel redundant (typically when numerous confined space jobs are occurring per day). A onetime investment in a computer or smart phone with an app for permits saves time while not cutting corners.
- Cutting man hours and/or training. Reducing personnel required can be accomplished by scheduling the work better so one individual can look after more than one job. Another option is to invest in training. One Attendant can do Supervisory, Attendant, as well as Rescuer tasks. If an entry rescue might be required, invest some time with one of the workers located outside the space so that he/she can “hold the fort” until further assistance arrives. To help your “rescue assistance” team, invest in some instructional aids that assist with memory recall on how to operate your retrieval system or air supply.
Using the Equivalency Clause can create efficiencies that will save you money and ensure compliance.
For instance, the Attendant can perform the hazard assessment, complete all necessary forms and documents, operate the protective equipment, and in some instances, operate the rescue gear as well. The Attendant can also assist by being able to communicate directly with the supervisor when the work party is not able to. With a little thought, an employer can maximize the role of the attendant from sitting idly outside a confined space to being a vital part of the work progression.
Lastly, a helpful analogy is viewing the Attendant like a lifeguard at a swimming pool. The number of lifeguards would only have to increase if the single lifeguard could not adequately keep track of those inside pool. The same applies for Attendants and those working inside a confined space. That said, an emergency may increase the need for additional people. Those additional people, however, would be compromised of your Rescue Team (see next question for additional information on that topic).
Still got questions?
The Confined Space Attendant Information Sheet will help determine the type of work your Attendant might be able to do for you.
Operationally, the injuries and configuration that you’re responding to determines how you will stage the team, how many people are required, and what gear is mandatory. Hazards that cause respiratory arrest will require your team to be close by the entry point and fully geared to make an immediate retrieval. If your space is configured in such a way as to cause entry/egress routes to be blocked, a rescue team with specialized training will be necessary for the entry rescue. Alternatively, if the hazards could only cause minor issues and the path is both straight up and less than 20’, your Attendant could perform the rescue with some training.
Your plan is exactly like an insurance policy…it’s used only IF something happens. What’s important then is that the policy selected is both suitable and comprehensive.
Check out The Confined Space Rescue Information Sheet for help selecting what type of rescue plan will be the best “insurance” for you.
The first step in an evaluation is to look at the contractor’s documentation:
- Is there a policy statement present indicating what a confined space is, what constitutes entry into the confined space, and what the consequences are of non-compliance?
- Are there specific instructions regarding how to complete a hazard assessment; select, deploy and operate protective systems; select and use PPE; as well as what to do in an emergency?
- Does the permit contain a section for hazard evaluation?
- What training does the contractor cover (do they have a copy of their course curriculum)?
- Are equipment maintenance records kept on file?
There should also be a performance evaluation which would include asking:
- Have workers been made aware of the hazards involved in the work?
- Have procedures been fully explained to the workers entering the space?
- Is all equipment required for the operation as listed in their procedure present at the site?
- Are equipment operating instructions available to the workers?
- Have workers been provided with instructions on the retrieval of entrants?
- Do workers have documentation of training?
- Is there a suitable system to remove injured workers inside the space that will not aggravate a possible injury?
Finally, if you are contracting a Rescuer or Rescue Team, you should also verify:
- Does the prospective rescue service have the technical knowledge to perform a rescue?
- Have all members of the service been trained in the potential hazards of the confined spaces from which a rescue might be needed?
- Can team members recognize the signs, symptoms, and consequences of exposure to any hazardous atmosphere that may be present in spaces?
- If necessary, can the rescue service properly test the atmosphere to determine if it is IDLH?
- Can the rescue personnel identify information pertinent to the rescue from the entry permits, hot work permits, and MSDS sheets?
- Is every team member provided with, and properly trained in, the use and need for PPE (for instance, the SCBA or fall arrest equipment) which may be required to perform permit space rescues in the facility?
- Is every team member properly trained to perform his or her functions including carrying out rescues and utilizing rescue equipment such as ropes, backboards, extrication devices etc., that might be needed during a rescue?
- Are team members trained in the first aid and medical skills needed to treat victims overcome or injured by the types of hazards that may be encountered in the permit spaces at the facility?
- Does the rescue service have the equipment required to properly package and retrieve victims from a permit space that has an opening of less than 610 mm (24 inches) in diameter, limited internal space, or internal obstacles or hazards?
- Does the rescue service have the equipment to perform an elevated (high angle) rescue?
- Are there adequate methods for communication between the entry point and the rescuer available?
- For entry rescues into spaces that may pose significant atmospheric hazards, is a suitable respirator and air supply available (approximately 60 minutes/person) for the rescuers as well as the casualty?
- Does the rescue service have the necessary skills and equipment for a full medical evaluation and packaging?
- Does the rescue service practice rescues at least once every 6 months?
- Does the rescue service have an objective evaluation standard of the practice rescues and the corrections made to correct any deficiencies identified?
The Contractor Evaluation Information Sheet will help determine if your contractor is able to adequately provide what is necessary for your confined space projects.