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Look before you enter

By Michelle Morra-Carlisle
| www.cos-mag.com

It’s time for the annual cleaning of a storage drum. The worker enters the drum, having been briefed on what chemicals were previously stored inside and having been told it is safe. What the worker doesn’t know is

that the cleaning agent he is about to use could trigger a dangerous chemical reaction with those other lingering substances.

If only the employer’s confined space entry procedures had been written by a competent person, the worker would be aware of the danger and of the need for ventilation and appropriate personal protective equipment (PPE).

“But wait,” the employer might say. “I did hire a competent person to assess the hazards and write the procedures. Didn’t I?”

There lies a common problem: It’s not enough to look at a self-professed expert’s resumé and hope for the best. The law expects an employer to be certain of the person’s competency. Occupational health and safety legislation refers to a confined space safety expert as a “competent” or “qualified” person. Regulations in jurisdictions across Canada point to the need for this person to conduct a hazard assessment before anyone enters the confined space.

“You need a competent person to assess the hazards of a confined space and make a determination whether or not it is hazardous. You would always need a competent person to look at the confined space first,” says Chris Budzich, president of Proactive Consulting Services in Regina.

The competent person also must be trusted with writing the confined space entry procedures.

“We have to have a plan developed in consultation with our health and safety committee to make sure that the worker going into that confined space will be looked after,” says Budzich. “The competent person that looks at these confined spaces has to tell us what kind of PPE do we wear, what are the procedures we need to follow when we work on this confined space, what are the results of the gas testing.”

Although the law doesn’t get too specific about the necessary competencies or qualifications, enforcement officers take the requirement to have a “competent” or “qualified” person very seriously.

For example, the WorkSafeBC guideline G9.11 Confined Spaces – Qualified Persons requires a hazard assessment and written confined space entry procedures be prepared by a “qualified person who has adequate training and experience in the recognition, evaluation and control of confined space hazards.”

While many workers are well aware of the associated hazards of confined space entry and how to completely remove or mitigate them to an acceptable level, a competent person factors in more than that, says Michael Cadotte, president and CEO of Firewise Training and Consulting in Barrie, Ont.

“They look at safety factors for time inside the space, workload performed and ensure that there are stoppers and redundant safeties in place to additionally protect the worker,” he says. “A qualified worker is not just somebody who has entered confined spaces many times. It is also someone who understands that a confined space, by its very definition, always has the potential to kill.”

Much as a human resources manager is diligent in getting to know a job applicant, due diligence in selecting a competent person for confined spaces includes a review of the person’s experience as well as his credentials.

The WorkSafeBC guideline lists the following qualifications that are acceptable as evidence of adequate training and experience:

• A Certified Industrial Hygienist (CIH) or Registered Occupational Hygienist (ROH) with experience in confined space entry.

• A Certified Safety Professional (CSP), Canadian Registered Safety Professional (CRSP) or professional engineer (P.Eng.) with experience in the practice of occupational hygiene as it relates to confined space entry.

• Other combination of education, training and experience acceptable to the Workers’ Compensation Board.

The individual should have previous experience conducting confined space hazard assessments and writing procedures as well as proficiency with applying exposure limits.

Besides the person’s education

and training, it’s also important to know if she has experience with specific confined space elements, says Nancy Harwood, a Vancouver-based lawyer and principal of the Harwood Safety Group.

“Are they familiar with items such as lockout, isolation, air monitoring, ventilation, rescue techniques and drills? Don’t just hire a company. Make inquiries about the person’s experience and knowledge,” she says.

The employer should also evaluate the extent of experience with confined space entry relevant to the industry or type of space the person will encounter. For example, the hazards workers encounter in a refinery are very different from those encountered in a steel mill. In a refinery, workers are in confined spaces that have zero per cent oxygen, so the competent person hired for this situation should have experience working in oxygen-deficient atmospheres and with breathing apparatuses, says Budzich. In a steel mill, workers go inside pipes and pits with cutting torches, so the qualified person would need to know about filtration systems, for example.

“It’s not just finding out whether they are qualified in confined space work, but taking into consideration the circumstances. They may have worked in a manufacturing or marine environment but do they have experience with confined space entry relevant to the oil and gas sector?” says Harwood, who previously worked for WorkSafeBC as director of regulatory practices. “Also consider the kinds of substances, spaces, kind of rescue that would be involved. Some situations are much more complex than others.”

The following are among the questions to ask a prospective competent person. Does he have:

• a fluent understanding of the scope of work to be completed?

• comprehension of the applicable rules and regulations?

• knowledge of the purpose or function of the confined space to be entered?

• knowledge and experience to recognize and mitigate potential serious safety issues before they arise?

• an understanding of the workings and contents of the confined space to be entered?

• hazard mitigation skills?

• communication skills? 

• experience in health and safety?

• an understanding of rescue techniques and what may be required in an emergency?

• a commitment to making worker safety a priority?

In many cases, a company’s safety manager would be considered a competent person in regards to confined spaces. If he does not fit the bill, the employer should look at other in-house safety professionals and engineers. It’s possible someone is an expert in confined spaces enough to be seen as “qualified” in the eyes of the law. If not, an external consultant will need to be hired.

An employer’s responsibility doesn’t end with recruiting. Once the competent person has conducted the hazard assessment and written the procedures, the employer is accountable for the quality and contents of those documents.

“There is some positive obligation to not only look for a qualified person to conduct a hazard assessment and write the procedures, but also to review the procedures yourself to ensure that the assessment contains the required elements and the written procedures have been developed based on the assessment,” Harwood says.

If there is an incident, investigating officers will assess to what degree the employer should have known better. They will want to know what steps the employer took to ensure the hazard assessment and entry procedures were done right.

So why is the issue of competency important to employers? Because at the end of the day, if something goes wrong, the employer is accountable.

“If one of the elements of the confined space program is missing or not implemented properly, the employer may be held responsible and could receive compliance orders or be subject to penalties or other enforcement action,” says Harwood. “The employer holds the ultimate responsibility for the safety of workers pertaining to confined space entry.”

[em]Michelle Morra-Carlisle is a freelance writer based in Toronto. She can be reached at morramich@gmail.com[a href="mailto:morramich@gmail.com."].

[/a]This article originally appeared in the June/July 2016 issue of COS.

[/em]

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