Two workers employed by a telecom company were killed by a toxic atmosphere while laying fibre optic cable at the bottom of a manhole. A federal OHS officer issued an order to the company, requiring it to take specific steps as to confined space rescues and emergencies for “designated” or “special” manholes. The company appealed the order. The OHS Tribunal upheld the order. The company’s manholes qualified as confined spaces under the OHS law. The company didn’t train workers who work in manholes on rescue procedures, instead preferring to rely on emergency service providers in an emergency. It also didn’t specify protection and emergency equipment as required. The Tribunal found that this approach violated OHS law. So the Tribunal upheld the order but expanded it to apply to any confined space [Bell Canada v. Communications, Energy and Paperworkers Union of Canada,  OHSTC 17, Sept. 10, 2014].