Oxymoron
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.