Lost in confined space: Roundtable on confined space management

Managing work in confined spaceWhat do Toronto’s Skydome, a farm and an ocean vessel have in common? Confined space.

Perhaps the biggest problems involving work in confined space is the failure on both the employer and the worker to identify a particular work environment as such. As far as occupational safety is concerned, confined space varies in different industries. Whether it’s a 200-sq.ft. boiler room or the basement of the 11-acre Rogers Centre in Toronto, confined spaces come in different shapes and sizes, and it’s important to be able to identify and assess each of them before any work is performed.

Without proper identification and determination of all hazards associated with a confined space, working in it could be an accident waiting to happen.

Canadian Occupational Safety recently hosted a roundtable forum on confined space, attended by occupational health and safety experts from across Canada: Lisa Bolton, lawyer at Sherrard Kuzz LLP; Ron O’Neil, director at Fall Protection Group Inc. in Calgary; Wagish Yajaman, a consultant and occupational hygiene specialist with the Industrial Accident Prevention Association; Tim Morrison, president of Safety Scope Inc. based in Vaughan, Ont.; Peter Gilmour, regional prevention manager for WorkSafeBC in Kamloops, B.C.; Stan Rodriguez, director of health, safety and environment at IPEX Management Inc. in Toronto; and Gabriel Mansour, a provincial coordinator with the Ontario Ministry of Labour.

The seven-member panel agreed that identification of a work area as confined space is vital in ensuring the safety of the workers.

“StatsCan says there are about 65 to 75,000 companies in Canada that are affected by confined space, and that ranges from cement plant, bakeries, pharmacies and telecommunications,” says Safety Scope’s Tim Morrison, whose company provides confined space safety and rescue training. Some of these workplaces are fully aware that they are dealing with confined space hazards and have control policies and programs in place to deal with those hazards.

But it’s those companies that do face confined space risks, but are unaware of them, that are worrisome, the panel agrees.

“With those stats that you mentioned, sometimes the core that know they are dealing with confined spaces and that know what to do with the means and measures, that’s great. But you mentioned the bakeries, etc., that are not used to them and do not know how to deal with them, they don’t recognize some of the vaults that they use as a confined space,” Ron O’Neil of Fall Protection Group Inc. says.

For example, manure pits found in farms pose confined space hazards, but people working in the farm may not necessarily know these risks nor have the knowledge required to work safely in or around manure pits.  An all-too-common scenario in a number of manure pit fatalities usually involves multiple victims, where one goes in and gets injured and a co-worker or family member would climb in the pit in a rescue attempt, only to be subjected to the same hazard as the original victim.

Another issue of concern is the increasingly mobile workforce, says lawyer Lisa Bolton. “As legal counsel, I see fairly frequently situations where employers really don’t appreciate that a workplace can move around where the workers are. So if they may have a plant or a facility that they in their own mind consider to be the workplace, but they forget that they may have service workers going around and they may be in confined spaces that aren’t necessarily physically on the employer’s property.”

What constitutes a “confined space” in the occupational safety sense? The Ministry of Labour’s Gabriel Mansour says the phrase connotes high risk, meaning an area that is “confining because of the physical characteristics, the contents inside, and the content that must have generated the work activity.”

Mansour adds the complexity of managing work in confined spaces led the labour ministry to revamp its confined space regulations to include all the various components associated with confined spaces, including risk assessment, training, rescue and entry permits. “So I think, hopefully, the new regulation has covered a lot more ground with the guide of consult, Ministry of Labour and other partners, and will help larger and smaller employers to be able to comply with the regulation.”

Confined space applies to so many different workplaces and industries that it’s a challenge to nail down one common definition, says Morrison. And the difficulty only increases for companies that have a mobile workforce that moves across different provinces. “It’s like military intelligence. It’s an oxymoron; the two words don’t go together.”

Even with the recent development and launch of the first Canada-wide standard on the management of work in confined space (CSA Z1006), the technical working committee spent many days just discussing the definition, he recalls. “I think this is a struggle to most companies who are used to a stationary workplace … everyone’s got examples of the moving, roving workplace and people don’t recognize the danger.”

Morrison, along with four other members of the roundtable panel — Wagish Yajaman, Stan Rodriguez, Gabriel Mansour and Peter Gilmour — were part of CSA’s technical working committee that developed the Z1006 standard. The standard defines confined space as a workspace that: is fully or partially enclosed; is not designed or intended for continuous human occupancy; and, has limited or restricted access or egress, or an internal configuration, that can complicate first aid, evacuation, rescue or other emergency response services.

Failure to recognize a confined space also leads to failure to conduct comprehensive risk assessments, which is an essential element in managing work in confined space. Without risk assessment, companies cannot implement effective controls to address confined space hazards, says WorkSafe BC’s Peter Gilmour.

“I think it’s important to note that confined spaces include a full spectrum of hazards, and all of them seem to be amplified because of the spaces,” Gilmour said. “Some of the hazards are a bit more obvious than others . . . but sometimes they are not so obvious, which I believe leads to a failure to classify a place as a confined space.”

There is one common characteristic of a confined space that is easy to recognize, however, and that is restricted access and egress that tend to complicate rescue, he adds.

Identifying whether an area is a confined space should be done by a competent individual, says IAPA’s Wagish Yajaman. Z1006 offers guidance on choosing the appropriate person for the job.

“The standard actually takes a closer look at who should actually be doing that (risk assessment) and addressing it appropriately, instead of looking at a narrow perspective of, ‘Is it just atmospheric hazard or is there more potential hazards that need to be looked at as well?’,” says Yajaman.

Common ground
Legal requirements pertaining to confined spaces also vary from jurisdiction to jurisdiction. This is especially challenging for companies that have operations in multiple provinces. This is why a comprehensive standard makes a lot of sense.

In developing the standard, the Z1006 technical committee held meetings across Canada to look at the various legal and regulatory components each jurisdiction has on confined space, in an effort to make a standard that is as comprehensive as possible. Morrison says the diversity and differences among these jurisdictions is a real challenge.

“I don’t think they are really going to solve those differences, but what we (have got to) look at is what are the commonalities. And the commonalities are the definition, to recognize that your are going to get into trouble. And secondly, what the standard really focuses on is the risk assessment,” Morrison says.

Differences are also evident in provincial and federal legislation, says Yajaman. “I think this is where the standard comes in with respect to trying to transcend what the legislative requirements are and put it into best practices when somebody goes in (a confined space) so that they come out safely at the end of the day.”

Gilmour says the intent is for all jurisdictions in Canada to “harmonize” legislation on confined space based on one standard. “Whether that happens in the next five or 10 years, I’m not prepared to prognosticate, but that would be very nice.”

It’s important to recognize, however, that regulations always take precedence over standards and companies are required to comply with regulatory changes in various jurisdictions.

“I think we need to caution people that just because it complies with the standard doesn’t mean you’re going to comply with regulations in every province. Certainly, there are some in Ontario and Quebece and in B.C. where the bar is a little bit higher,” says Rodriguez whose company, IPEX Group, designs and manufactures piping systems. IPEX operates various plants across the country and is therefore subject to different legislative requirements. Rodriguez says his firm is “pleased to see the development” of the Z1006 standard.

As in any other occupational health and safety hazards, training is key to preventing confined space accidents.  And just as it was a challenge dealing with differences in the legal requirements in jurisdictions across Canada, training seems to be “all over the map” when it comes to confined space training services, says Morrison.

“A lot of people don’t do competent-person training, they don’t get to play with the toys. Some go for gas monitor training and some people don’t even see a gas monitor, which is appalling that it could happen that way, but it’s true,” he says.

Standardizing the approach to training on confined space is another objective of Z1006. Morrison says the ultimate goal is to develop a certified training program for confined space that will be implemented nationally. Whether it happens sooner rather than later, is a another question.

O’Neil agrees noting that occupational health and safety in Canada is largely governed provincially, which makes standardization a challenging feat.

“Currently, our nation truly allows for any kind of training delivered by anyone, under any circumstance, to anyone, with any standard. And the (Z1006) standard notwithstanding, we will continue in our lifetime to have this problem,” explains O’Neil. “Any of the good initiatives that we might see with one province, their neighbouring province might not even be on the radar.”

Some provinces are moving towards consolidation, though. In Alberta, for instance, O’Neil says there is a provincial database that keeps track of all safety trainings that workers in the province have undergone. The recent amalgamation of safety associations in Ontario, as well as the trend of consolidation among construction associations in B.C. may be a step in that direction as well, he adds.

“There is no question, training is a real core element and as Gabe (Mansour) was saying, the maintenance of it is just as crucial. I think that people in Peter’s (Gilmour) shoes should really convince the provinces to have some harmonization. CSA can be a vehicle but it can’t be the exclusive vehicle,” O’Neil says.

As of this writing, Z1006 is pending approval as a National Standard of Canada. 

Panelists note that while training is absolutely essential to prevention, confined space accidents have, in the past, occurred among trained personnel as well.

Yajaman says this is because in a confined space, one is always dealing with dynamics. “When you create a policy or a procedure, it’s a dynamic document because the spaces can change, a number of spaces can change. And a lot of people figure that once you create a policy, they don’t realize that it needs to be updated — same with training — with the individuals who are going into these spaces, to keep it fresh in their minds.”

To make such policies and programs work, however, there needs to be commitment, confidence and culture in the workplace, says our panelists.

“The other important element is the commitment of the workplace and the confidence of the workplace,” Mansour says. “You can have the best procedures, you can have all the mechanical stuff in place, but you have to have the confidence to be able to have the procedures go really effective and you have to have the commitment by the workers and the employer to go through with it if it happens.”

Another factor is culture, Rodriguez adds. People may often know what the right thing to do is, but they don’t always do the right thing for various reasons. Some of the reason could be behaviour-modeling, where leaders are not exhibiting good examples for workers to emulate, and some may have to do with conditions in the workplace. These factors affect people’s decision-making process, particularly with regards to health and safety.

“I think we all know we need better standards and more consistency, but an important message for organizations who are having people who do these things, they need to remember in the meantime it’s their obligation to be duly diligent in how they make decisions on who will be doing the training and how you are going to validate confidence,” Rodriguez says.

Z1006 requires an assessment of the training needs of workers and external service providers involved in confined space work including the competencies required for each role (i.e. entry supervisor, entry worker and trainer), review of previous training and experience, and the need for refresher training.

The various types of confined space skills training outlined in the CSA standard include entry supervisor, attendant training, air supply system attendant, entrant, emergency response team leader, dispatcher, rescue system operator/helper, rescuer, and first aid/CPR responder.

The standard also covers guidelines for establishing competence of the instructors.

In far too many instances, confined space accidents usually involve multiple victims. In fact, more than 60 per cent of confined space-related fatalities involve would-be rescuers or colleagues of the victims who would go in and try to help out, without the necessary training and appropriate rescue plan.

This why having a rescue or emergency response plan is an essential component of a comprehensive confined space risk management program, panelists agree.

As Gilmour puts it: “The time to find out whether your breathing apparatus doesn’t fit through the manhole is not the time of the rescue.”

Practicing your rescue plan is vital, Morrison adds. This can be accomplished through regular drills. Try simulating a confined space incident by putting a mannequin inside the hazard area and pulling them out based on the emergency response plan. Practicing the plan twice a year is what Z1006 prescribes.

Yajaman relates a previous experience with a client: “I will see companies who will have the policies and equipment, but they never do the drills or they don’t practice. In their policy it said they had a gas monitor. Well, that policy was from another company and they didn’t change it . . . and when I asked to see their monitor, they looked around to see if they had one. Having something good on paper is one thing, but actually how it works and making sure it work in real life is another matter altogether.”

One more reason to practice, says Gilmour, is the fact that there is no generic rescue when it comes to confined space. Every rescue is very specific to a particular confined space.

Developments in and the declining cost of technology have also helped in managing risks in confined spaces, says O’Neil. “You can have some really strong enforcement of great plans on the prevention side and rescue side, and there are some amazing advancements with thermal imaging, wireless, etc. . . . and with awareness, we can have some strong prevention safeguards with technologies.”

Technology can also be used to replace human intervention as much as possible, Bolton says. The ability to perform work in a confined space using technology without the need for a worker to actually get into the confined space and be exposed to the hazards goes a long way in preventing accidents.