According to CCOHS, an estimated 60% of the workers killed in confined spaces were would-be rescuers. For example, of the four workers killed in a BC barge, three entered the confined space as rescuers. So it’s hardly a surprise that OHS confined space regulations require measures to ensure the safety of not only the workers who enter the confined space to perform work operations but also the ones who might have to go in to rescue them. Having an effective emergency plan for confined spaces is the key to protecting both of these groups.
We’ll explain the confined space emergency plan requirements under the OHS laws as well as the new confined space standard from the Canadian Standards Association (CSA). And we’ll tell you how to create an effective plan, including what the plan should cover and training workers on the plan. There’s also a chart that spells out the confined space emergency plan requirements under the OHS law in each jurisdiction as well as a Checklist of areas your emergency plan should cover.
What the Law Says
Every jurisdiction’s OHS laws have specific confined space requirements. These requirements address emergency plans for confined spaces in five different ways:
As part of overall confined space program. Nine jurisdictions require employers to develop emergency plans or procedures as part of their overall confined space programs (although such programs have different names depending on the jurisdiction). Four jurisdictions—BC, NS, ON and YT—require employers to have confined space entry programs that include procedures for emergencies in or near confined spaces, such as on-site rescue procedures. MB and QC require employers to have safe work procedures or measures for confined spaces that include rescue procedures. NT and NU require employers to develop codes of practice for confined spaces that include rescue procedures. And in SK, employers must develop a hazardous confined space plan that contains rescue procedures.
In a separate plan. Federally regulated employers may have to create confined space entry permit systems that specify the equipment to be used in emergencies. But these systems don’t need to include emergency plans. Instead, federally regulated employers must have separate emergency procedures for incidents or emergencies in or near confined spaces.
As part of a report by competent person. In New Brunswick, employers must have a “competent person” evaluate and test a confined space and then set out in a written report the procedures to be used in the event of an emergency in or near that confined space.
As part of general emergency procedures. In AB and NL, employers must have general emergency response and rescue plans for the workplace as a whole. These general plans must include procedures for emergencies involving confined spaces.
As an implied requirement. Prince Edward Island is the only jurisdiction whose OHS law doesn’t specifically state that employers must develop emergency procedures or plans for confined spaces. But this requirement is clearly implied by the language used in the other confined space requirements. For example, the OHS regulations say that employers must ensure that:
- Workers only enter confined spaces where training in emergency procedures is provided for workers assigned to a confined space entry job;
- Workers only enter hazardous confined spaces when suitable arrangements have been made to remove the worker from the confined space should it be required; and
- A worker posted outside a confined space must be knowledgeable in the correct use of the emergency retrieval system procedures.
CSA Confined Space Standard
On March 31, 2010, the CSA released a new confined space standard, CSA Z1006 Management of Work in Confined Spaces. CSA Z1006 contains requirements and guidelines for managing work in confined spaces, including emergency plans for rescuing workers. Approval of the new standard as a national Standard of Canada is still pending.
CSA Z1006 requires companies to establish and maintain procedures to prepare for and respond to confined space emergencies. These procedures must include:
- A plan for responding to emergencies and preventing or mitigating any illness or injury;
- Identification of the necessary resources to implement the plan effectively;
- Testing of the plan at specified intervals;
- Communication with and training of affected parties so that they can fulfill their duties and responsibilities with respect to the plan and procedures; and
- Communication with external service providers, visitors, emergency response services, government authorities and the local community, as appropriate.
Because standards like the CSA’s are voluntary, companies don’t have to comply with them unless the jurisdiction specifically incorporates the standard into its OHS regulation. CSA Z1006 is so new that no OHS regulation has adopted it yet. But it’s wise to consider complying the standard anyway, especially in a jurisdiction that doesn’t provide a lot of guidance (either in its OHS laws or in supplementary guidelines) on confined spaces and emergency plans. First, CSA Z1006 was specifically developed to ensure that it doesn’t conflict with existing OHS regulations on confined space. In addition, courts may eventually view the standard as a best practice and consider a company’s compliance with the standard a factor in determining if it showed due diligence.
How To Comply
To ensure that your company complies with the emergency plan requirements for confined spaces, you should take the following steps:
Step #1: Develop Written Emergency Plan
The OHS regulations typically say very little about what confined space emergency plans should include, often only requiring plans to spell out rescue procedures, PPE and emergency equipment to be used by rescuers. Fed, AB, NB and NS do specify that emergency plans must include evacuation procedures for certain circumstances, such as when:
- An alarm is activated;
- The oxygen level within the confined space changes; or
- The concentration or percentage of hazardous substances in the confined space changes significantly.
In Saskatchewan, rescue procedures must include the number and duties of personnel and the availability, location and proper use of equipment. And Québec requires the rescue procedures to cover the rescue team, evacuation plan, alarms and communications, PPE, safety harnesses and lifelines, first aid and recovery equipment.
So how do you know exactly what your confined space emergency plans should cover? BC’s confined space reference manual provides guidelines that are useful to safety coordinators in all jurisdictions. It says that emergency procedures should consider:
- All hazards in the confined space previously identified in a risk assessment;
- Dimensions of the space;
- Location of entry and exit points;
- Obstacles to removing an injured worker;
- Rescue equipment required;
- PPE for rescuers, including appropriate respirators;
- Communication between workers, rescuers, the supervisor and people on standby;
- Procedures to follow immediately after an incident;
- Possible hazards that may arise during rescue, appropriate evaluation of these hazards and control methods for them; and
- Rescue methods for a worker who’s unconscious, unresponsive or distressed.
- CSA Z1006 says that a written emergency response plan for rescuing entrants from a confined space should be developed before work in that confined space begins and should cover:
- The situations in which the type or types of rescue identified by the plan as options, such as self-rescue, external rescue or entry rescue, will be used;
- How the entry team and emergency response members will effectively communicate with each other;
- When emergency team members performing specific roles will be deployed;
- How the equipment needed to rescue entrants will be brought to the site, set up and operated;
- The procedures to be followed during a rescue; and
- The emergency medical care and materials that will be available to treat the injured on site.
This article includes a Checklist based on information from CSA Z1006 that you can use to ensure that your company’s confined space emergency plan covers all the necessary areas.
OHSInsider: At www.OHSInsider.com, members can download Model Confined Space Emergency Plans to adapt and use in their workplaces.
Step #2: Provide Equipment Required by the Plan
Your confined space emergency plan will likely require the use of specific PPE and/or rescue equipment during an emergency, such as respirators, lifelines, harnesses, stretchers and lifting equipment. It’s essential that you ensure that the company actually provides such equipment. In fact, the OHS laws in Fed, AB, BC, MB, NB, NT, NS, NU, ON, SK and YT specifically require employers to provide the equipment identified in the emergency or rescue plan.
Such equipment should generally be readily available to workers near the confined space. In addition, CSA Z1006 recommends that all equipment used for rescues—including PPE—be:
- Inspected prior to use to ensure that it’s operable in accordance with the manufacturer’s recommendations and applicable standards;
- Certified or recertified in accordance with the manufacturer’s recommendations and applicable standards; and
- Used in accordance with the manufacturer’s recommendations and applicable standards.
Step #3: Train Workers on Plan
As with all other safety procedures, you must train workers on the confined space emergency procedures. Who should get such training? Workers who actually work in the confined space should be trained as should any workers who are part of the rescue team or may be called upon to rescue co-workers from the confined space. In addition, train any supervisors who supervise work in the confined space. And if the OHS law requires the use of a sentinel, attendant or “standby” worker who stays outside of the confined space and in communication with workers inside the space, that worker should be trained, too. CSA Z1006 spells out the emergency plan training requirements for specific groups, including workers who work in confined spaces; confined space entry supervisors; attendants; emergency response team leaders; and rescuers.
Insider Says: Members of the rescue team may need additional training. For example, Ontario requires members of the on-site rescue team to be trained in not only the rescue plan and use of the rescue equipment spelled out in the plan but also first aid and CPR. In addition, CSA Z1006 suggests that companies have a documented process to ensure that all workers, attendants and rescuers involved in confined space work have the necessary physiological and psychological capability to safely perform their assigned duties.
Step #4: Conduct Practice Drills
Some jurisdictions, such as BC and YT, specifically require employers to conduct annual practice drills on the confined space emergency plans. Québec simply requires rescue procedures to be tested. And CSA Z1006 requires rescues to be practiced at least twice a year or prior to entry into a confined space. But drills or test runs are advisable even if they aren’t required in your jurisdiction. After all, it’s better to work out any kinks in your emergency plan when lives aren’t actually at stake. According to CSA Z1006, a drill should consist of a simulated rescue from a simulated or actual confined space from which rescuers could be called upon to remove workers. If you discover any problems during a drill, make sure you change the emergency plan accordingly and retrain workers on the updated plan.
Taking steps to protect workers while they work in confined spaces is a good—and necessary—first step. But we all know that safety incidents can occur despite our best efforts. And when a worker gets hurt or an emergency arises in a confined space, having an effective emergency plan can mean the difference between life and death for both the worker and members of the rescue team who come to his aid. By following the steps outlined in this article, you can ensure that your company does what’s needed to effect a safe rescue of workers from confined spaces without endangering the rescue team in the process.