If confined spaces have been around for so long, why is it some of us still have difficulty identifying them?
To figure out whether something is a confined space, we have to first determine if the area is intended for continuous human occupancy. Builders and manufacturers by law have to construct buildings and equipment in such a way as to enable people to work safely. Machines are guarded, lighting and ventilation systems ensure good air quality and egress systems are designed to evacuate people in an emergency. The main criteria needed for occupancy are:
1) Floor – Has less than 2″ thick smooth asphalt/concrete floor or 10 mil poly covering that overlaps each sheet by 4″ with all seems weighted down.
2) Lighting – The space does not have permanently installed lighting systems consisting of electrical outlets and fixtures controlled by a wall switch or panel that supplies more than 50 lx (4.6 foot candles) at floor or tread level or 5 Watts/m2 (.46 watts/ft2)
3) Heating – The space does not have a permanently installed system to ensure the temperature in the area remains above 150 C or 590 F.
4) Ventilation – The space does not have a permanently installed system to supply at least 7.5 L/s or 15.9 cfm of outside air to the area or natural venting of .1 m/50 m2 or 1.1 ft2 /538 ft2
5) Egress – The space has a doorway less than 21 5/8″ x 35″
Or
Has crawl way less than 23 5/8″ x 23 5/8″ to 2′ 11″ beyond work area.
Or
Has no permanent elevator installed if the space is more than 10 m (33′) above or below grade.
However, some worksites such as construction sites or roadway repair operations would not meet the all the Building Code requirements, but are not confined spaces. Therefore, there are other criteria that must be considered. These are:
1) Fully or partially Enclosed – Partially enclosed means a 1 metre or higher wall or hill/slope that goes at least 50% around the parameter.
2) Work/Task – The task being performed will either be done:
- periodically during a shift, or
- only when the regular process is not in operation, or
- for a purpose other than the regularly intended operation of the area
3) Isolated – When a worker or a group of workers are segregated in a way they are not visible to other workers or other people due to a barrier of either distance, time or a physical design.
4) Restricted Egress – The opening(s) hinder the provision of emergency aid. This difficulty is measured based on door size. Will a stretcher fit? This will determine whether or not local emergency response services could easily provide aid and extraction should an incident occur.
The Ontario Confined Space Regulations only apply if the spaces have a potential or actual hazardous atmosphere. However, by using our Confined Space definition, you could also have a variety of areas that are confined spaces that don’t fall under the regulation. This sets up 2 classes under our definition – Regulated and Non Regulated Confined Spaces. For some, this enables them to focus on one class and leave the rest for later. The regulations provide a framework for everyone to follow for specific confined spaces. But that won’t work for us. We also get the non regulated ones or the ones that are not quite “textbook”. The spaces that are not clearly under the regulation should not phase us.
These are opportunities to demonstrate how good we actually are. By helping our clients sort out the approach to non regulated spaces we differentiate ourselves from the competition. To do this we need to broaden our search for applicable legislation to guide us in ensuring the safety of those in non regulated confined spaces. You can search for the legislation based on the hazard, or potentially save yourself time and look for guidance with regards to your chosen hazard control system. For instance:
- In the Occupational Health and Safety Act, for any work area, you must complete a hazard assessment (Section 25(2)(d)),
- hazard control systems must be implemented (OHS Act Section 25(1)(a),(b),(c), & (d)),
- one must “take every precaution reasonable” (OHS Act Section 25(2)(h),
- and according to OHS Act Section 26(1)(d) monitoring and records of exposure to hazardous materials must be completed.
- The Ontario Fire Code (Section 2.8) as well as the construction regulations (Section 17 and 18) require the development of an Emergency Response System (Rescue) Plan in case something does happen.
My point here is that there are options for Non Regulated Confined Spaces. Don’t worry whether you have the backing of the Confined Space Regulations. No matter where you are working, there are legislated activities that provide direction on how to protect the workers that face specific hazards. Assistance can also be identified in a standard (eg. CSA Z1006) or through industry best practice. Don’t worry if it is or is not a confined space because the confined space regulations may not always be helpful. Spend your time evaluating the work area for hazards and then implementing interim systems (using Processes, Technology and Skills) to prevent injury. Our bottom line is that ANY area lacking “safe design” must have guards put in place to protect the occupants from harm.
In future blogs I will attempt to shed some light on how to deal with these non regulated types of spaces.
