Conducting work in confined spaces can be hazardous to your and other workers’ health and safety. However, are all so-called confined spaces actually considered confined under the WorkSafeBC Regulations? With several changes to the Guidelines and WorkSafeBC expectations in the past few years, Employers and Contractors alike are confused as to what makes a space confined (or not).
Do you have suspect confined spaces at your building or workplace that requires entry and work by individuals? If so, then you and those workers may be exposed to unintended risks and consequences, such as:
Do you understand your regulatory duties to properly identify your confined spaces, excluded spaces, and assess the hazards/risks of both, through a “Qualified Person,” and do you know how to manage these risks to minimize your liabilities and maintain your due diligence?
First, it is important to understand and know the criteria, under WorkSafeBC, that defines a space as confined. Per Section 9.1 of the Part 9 Regulations a confined space is an area, other than an underground working that:
It is important to note that excluded confined spaces are confined by definition, but may not have certain hazards/ risks associated with them that “traditional” confined spaces do. It is therefore imperative to really understand and know the types of spaces that WorkSafeBC has determined to be not confined, the criteria companies must use to assess the possibility of excluding a space, and when a “Qualified Person” needs to be engaged to assist with this determination.
Let’s de-mystify excluded confined spaces (typically called “enclosed spaces”) and review the nine exclusion criteria that must be met.
Per Column A in Guideline G9.1-1, WorkSafeBC has indicated the following, select spaces that could be possibly excluded from being confined:
|SPACES THAT MAY BE EXCLUDED (FROM PART 9)|
However, there are very specific “exclusion criteria” that all must be met in order to be able to deem a space “not confined.”
There a nine specific questions that must be asked by your qualified representatives or a “Qualified Person” (as defined by WorkSafeBC under Section 9.11):
When all the above criteria are met, Employers can make, through proper consultation with a worker, worker health and safety representative, or joint health and safety committee member, a determination that the space is not confined. This decisions must be documented and be available for review by a WorkSafeBC Officer. However, WorkSafeBC does expect that individuals involved in the process have suitable knowledge and expertise in confined space identification and assessment, otherwise a “Qualified Person” must be engaged.
Should your company not have a well educated, trained, knowledgeable and/or experienced “Qualified Person,” then WorkSafeBC expects you to engage one. What is the definition of a Qualified Person under WorkSafeBC? We can look at Section 9.11 of the Regulations which states the following criteria:
However, it is important to note that WorkSafeBC does expect those who conduct confined space assessments and those with the above qualifications have experience in the recognition, evaluation and control of confined space hazards.
OHS Global is here to help! We are an industry leader in the provision of professional, quality, timely and practical confined space consulting and training services. We have nearly 50 combined years of experience in assisting hundreds of clients from various industry sectors in identifying their confined and excluded space risks, and designing effective strategies and solutions to manage those risks. Our services include, but are not limited to:
Developing compliant, detailed, but easy to use:
In addition, we offer comprehensive, engaging and dynamic confined space training courses:
Contact us for further information about how we can help you meet and overcome your specific confined space challenges.
Craig Yee is an Industrial Hygienist and Principal of OHS Global Risk Solutions. He earned his Masters Degree in Occupational and Environmental Hygiene at the University of British Columbia. He has over 12 years of direct experience in the hygiene, health and safety industry in both public and private sectors. You can connect with him on Google+.
Risk Identified. Risk Managed.