6 Processes & Paperwork for Confined Space Entries

Hazard Identification

Every hazard that can exist in a confined space in the absence of controls must be identified. Every confined space shall be considered hazardous unless a competent person has determined it not to be hazardous after performing a hazard identification/risk assessment.

A hazard identification process considers:

• routine and non-routine activities of all personnel having access to the workplace (including external service providers and visitors)
• facilities at the workplace that could affect the health or safety of a worker in or near the confined space, such as electrical installations, piping containing hazardous substances, mechanical equipment, mechanical ventilation, lighting, etc.

A hazard identification process includes the following:

• the current and past uses of the confined space that present or presented hazards to workers and others entering or near the confined space
• the work activities planned to take place inside near the confined space
• the potential for a hazardous atmosphere to be present or develop in or near a confined space before or during an entry
• the conditions that could be present prior to entry or develop during entry, including the potential for unplanned or unintentional conditions that might present hazards in or near the confined space
• the physical characteristics, including configuration and location of the confined space
• hazardous substances or energy requiring lockout, isolation, or other controls
• the potential for engulfment or entrapment by materials inside or near the confined space
• the potential for fire or explosion inside or near the confined space
• biological hazards
• physical hazards, including, but not limited to, temperature extremes, humidity, lighting, noise, vibration
• any other known or potential hazard

Risk Assessment

A risk assessment includes an examination of the following with respect to each hazard:

• the potential magnitude, frequency, and duration of exposure to the hazard
• the potential number of persons exposed
• the probability of occurrence
• the consequences of an occurrence and their severity
• the potential for changes in conditions in or near the confined space to increase or diminish risk
• current and planned strategies for controlling the hazard (based on the Hierarchy of Control)
• the impact of controls on overall risk
• the need for emergency response
• the impact that hazards, risks, and controls could have on emergency response.

A risk assessment includes recommendations for the elimination of hazards and control of risks to ensure the safety of workers. It specifies which conditions and precautions need to be in place to allow for safe entry and what constitutes a change in conditions that requires a reassessment of the confined space.

Risk assessments need to be documented and include the date of the risk assessment, the name of the person conducting the assessment, and a description of the assessed spaces.

Risk assessments must be reviewed by one or more competent persons:

• as part of the planning process prior to entry into a confined space;
• when there is a change in the physical characteristics of, environment inside or near, or activities inside the confined space that could adversely affect workers inside or near the confined space
• when risks not previously identified are discovered; and
• at regular intervals of three years or less. The intervals shall be shortened if deemed appropriate by a management review

Hazard identification/risk assessment shall be carried out before and after any modification to or introduction of work methods, materials, processes, machinery, or equipment affecting a confined space.

The hazard identification/risk and assessment process should consider information provided by:

• workplace inspections
• workplace health and safety committee recommendations
• worker or worker representative concerns or complaints
• investigations of incidents and near-misses
• worker illness or injury records
• documentation related to legal and other requirements
• material safety data sheets
• equipment manufacturers’ specifications and instructions
• hazard alerts and bulletins

Written Procedures

Written testing, entry and work procedures are required. The procedures need to be developed by a competent person and must be based on the hazard identification/risk assessment. Procedures need to include the controls necessary for ensuring the safety of persons entering and working inside the confined space.

Entry Permit

Before initial entry, a permit must be completed and signed by the entry supervisor or other competent person designated for this task, and the contents of the permit communicated to the entrants and attendants.

A permit shall be immediately revoked if:

• activities outside the scope of work specified on the permit are performed in the confined space
• changing work conditions or work activities introduce new hazards into the confined space
• atmospheric monitoring results are outside acceptable limits
• safety precautions (e.g. respiratory protective controls) have failed

A new permit may be issued or the original permit re-issued if it addresses the new conditions.

Legislation usually states specific requirements for entry permits. In addition, ©CSA Z1006-10 – Management of work in confined spaces contains valuable recommendations.

Emergency Response Plan

A written emergency response plan for rescuing entrants from a confined space is required to be developed before work in that confined space begins. The plan needs to cover at least the following issues:

• the situations in which the type or types of rescue identified by the plan will be used
• how the entry team and emergency response members will achieve a fail- safe method of communication 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 that will be followed during a rescue
• the emergency medical care and materials that will be available to treat injured entrants on site.

If the emergency response plan is developed before the day that work is performed, any adjustment, deviation, or change on the day that work is performed shall be recorded on the plan.

Prior to entrants entering a confined space, it must be assured that the members of the emergency response team are ready and able to respond to an emergency in the confined space.