The terms “unsafe” has come up a few times in the last few weeks and I’d like to take the opportunity to speak to this. When someone says they believe a situation is “unsafe and wants to shutdown the job”, I become very nervous. I’m nervous because I’m hearing (right or wrong) “you’re afraid”. I can understand the fear. You may have never seen the job before or you may not agree with the safeguards being taken. Fear is OK. However, the Occupational Health and Safety Act requires that competent people plan and organize the work as well as acquaint you with the hazards and the controls. So, my questions are, did we get the right people planning and organizing the job? Secondly, did they do their job?
A previous blog listed 30 hazards we should look for on a job. Once you identify potential or actual hazards, the Occupational Health and Safety Act requires planning and organizing the work to ensure the hazards are minimized. You must choose hazard control systems and/or equipment to minimize the impact of the hazard. Confined spaces, because of their unique nature will require more planning than normal to develop the necessary safeguards. Often we improvise or omit these systems because we haven’t adequately planned the job. The temporary nature of the work often requires extra thought be given to the selection of safeguards. Selecting any confined space safeguard must balance:
◆ size – being able to fit the job,
◆ portability – being able to easily move in and out,
◆ capability – being able to do the job required, and
◆ price – being able to afford it.
The following systems and gear may need to be deployed to control any hazard identified. Controls include:
|Atmospheric Monitoring||Testing equipment used to determine the air quality inside the space (e.g. oxygen, toxic gases, temperature, humidity, noise etc.).|
|Attendant||An individual whose primary task is to initiate the emergency response system. They can also evaluate and monitor hazards, operate hazard control equipment (fans, testers, etc.), complete paperwork, as well as assist the emergency response team (e.g. provide first aid, be the Attendant during a rescue, or perform non entry rescue operations).|
|Chemical Management||The efforts used to control exposure to a hazardous substance (e.g. purging, proper storage, etc.).|
|Communication System||Equipment that allows the Attendant to talk to the Entrant, the job Supervisor, and summon a Rescuer(s).|
|Decontamination||A cleaning system to prevent the spread of any material from the space by the Entrant and/or tools that were used in the space.|
|Electrical Safety||Devices and knowledge that prevent injury due to exposure with uncontrolled electricity.|
|Fall Protection||Systems to prevent people or objects moving unexpectedly from one level to another.|
|Guarding||The physical devices or systems added to equipment to prevent possible injury during their use.|
|Housekeeping||The act of cleaning and organizing any debris, tools or materials at the site.|
|Hot Work Controls||The system, devices and work processes designed to prevent fires.|
|Lighting||Portable lights that provides 5 watts/m2 or .46 watts/ft2 in the work area and the travel path.|
|Lockout||Locks and attachment devices that ensure switches, valve handles and doors remains in specific position. (e.g. off).|
|PPE||Personal protective equipment that a worker wears to minimize the impact of a hazard.|
|Procedures||Written instructions for equipment operation or how to operate a system.|
|Performance Auditing||A formalized system of measuring compliance to a standard.|
|Signage||Warning, directional, or informational signs posted at a site.|
|Shoring/Framing||Barriers deployed to prevent engulfment of workers from the movement by any free flowing solid into an area.|
|Temperature Management||Actions and tools to increase or decrease core body temperature as required.|
|Traffic Protection||Actions and tools required to redirect traffic around the worksite.|
|Training||Classroom, practical or on the job instruction to enable someone to complete a task.|
|Ventilation||Natural drafts or the use of fans, ductwork and filters that either supply fresh air into the space or that exhaust gases, smoke, dust, fumes and/or mists from the space.|
Unfortunately confined space work may need a vast array of equipment and skills. This requires an investment of time and money to do it properly. I believe this is what hinders that competency I mentioned earlier.
A further hindrance is created when these temporary safeguards don’t get set up properly. Most of our confined space work happens infrequently. The set up and operation of these temporary safeguards needs to be documented to assist the memory of your workers as it might have been a while since the last time they worked in the confined space. In other words “written instructions” are needed to guide the worker in the set up and operation of these temporary hazard control systems. Written instructions must be provided for each piece of equipment used. If the equipment is part of a system, the system’s operating instructions must also be supplied. The instructions should detail:
- the equipment and tools necessary,
- details on where/how to set up the system,
- operating parameters (what should happen), and
- troubleshooting information.
Photos and drawings should be included where possible. In addition, the information provided must be concise, understandable and detailed. Good procedures provide enough information that will eliminate guessing or “free lancing” by the workers.
Again, there isn’t a fast and easy way of doing this. However, doing it right is not just about minimizing the potential of a incident. In my opinion, it’s about doing this work better, faster and at less cost than the guy who wants to cut corners.