What is a confined space? The legal definition of a confined space changes from one regulator to another. In general, these spaces will have the following features: they are large enough for humans to enter and perform work, they are fully or partially enclosed, they have not been designed or intended for continuous human occupancy, and they have a limited or restricted means for entry and exit. But are these physical features alone enough to classify a space as “confined”? This depends on who the regulator is. Here in BC, the only conditions needed for a space to be considered “confined”, are the physical properties of it. Conversely, in Alberta they require these physical properties AND whether the space is or may become harmful to the occupants due to hazards present or a potential hazardous atmosphere. Federally, they differentiate between a “confined space” which meets the physical requirements and a “hazardous confined space” that physically is confined and presents hazards that are likely to cause injury, illness or other adverse health effects to someone who enters, occupies, or exits the space. Not only is this method used by other regulators, but this is the approach that is recommended by the Canadian Standards Association (CSA) in their standard Z1006 Management of Work in Confined Spaces.
Differentiating between these spaces can have a huge impact on the regulations and requirements. For example, federally there are more requirements that are very prescriptive for a “hazardous confined space” compared to a “confined space”. Or in Alberta, there are more regulations around a “confined space” than a “restricted space”. Whereas in BC, only the physical aspects of a space are considered when determining if is confined or not, and all spaces that are “confined” must meet the WorkSafeBC OHSR Part 9 regulations on Confined Spaces. The only exception to this are spaces that meet the exclusion criteria in G9.1-1.
If BC were to change the way they regulate these spaces, the effects would be felt throughout many workplaces and industries who deal with confined spaces on a regular basis. What is the “correct” definition of a confined space? Do you think that BC should follow the direction of other regulators and the CSA standard and take into consideration whether hazards are present or may arise? Or is using the physical criteria a more conservative approach that can better protect workers accessing these spaces?
Prior to performing work inside of a confined space ensure that a qualified safety professional assesses the space to identify potential hazards and develop safe work procedures. Arcose Consulting Ltd. is a leader in occupational health and safety serving commercial, industrial and institutional clients in British Columbia. If you wish to contact us regarding this post or to inquire about our services, please do so at [email protected] or 604.372.2502.
