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LEGISLATIVE INTERPRETATIONS

OCCUPATIONAL HEALTH AND SAFETY ACT

Confined space – Restricted access or egress

Topic: Confined space – Restricted access or egress Issued By: Director, Compliance and Regulatory Review
Statute: General Regulation 91-191 Date Issued: November 13, 2019
Section: 262 Date Revised:

Definition

262 In this Part “confined space” means an enclosed or partially enclosed space not designed or intended for continuous human occupancy with restricted access or egress and which is or may become hazardous to a person entering it because of its design, construction, location, atmosphere or the materials or substances in it or other conditions.

Question

How can I determine if a space has “restricted access or egress”?

Answer

For a space to be considered a confined space, it must meet the following four components within the definition:

  1. Enclosed or partially enclosed space.
  2. Not designed or intended for continuous human occupancy.
  3. With restricted access or egress.
  4. Is or may become hazardous to a person entering it because of its:

    • Design
    • Construction
    • Location
    • Atmosphere or the materials or substances in it or other conditions.

While all components of the definition must be addressed, to answer this question the focus is on determining whether or not a work space is considered to have restricted access or egress.

A space is considered to have restricted access or egress if a person’s ability to escape in an emergency would be hindered and/or the means of entry or exit “may complicate” emergency response. Therefore, “access and egress” does not only include how to get into and out of the confined space, but also includes the routes inside the confined space for gaining access to the work area, or returning from it.

Different types of emergency responses must be considered, such as first aid, rescue, and escape. Some factors to consider for the different situations follow:

First aid and rescue: First aid and rescue are often closely related. First aid includes both injury treatment and preparation of an injured worker for transport on a device such as a spine board or stretcher. Rescue involves removal of a worker from danger, for example, by use of a transport device, or other means such as a lifeline and harness. Note that the rescued worker may or may not be capable of assisting the rescue, and you must consider both scenarios. When carrying a worker on a transport device the normal practice is to carry it at about hip level with the bearer’s arms extended downward.

Following are some examples of situations where the means of entry or exit are typically considered to complicate first aid or rescue:

  • A space for which the means of exit prevents the use of a first aid transport device, and requires a worker to be removed from the space by other means such as a harness, lifeline, or lifting device.
  • A space in which circumstances impede the ability to transport an injured worker. For example:

    • The exit port of the space is narrower than the width of the transport device.
    • The exit port is constructed so that a person carrying the device has no alternative but to put it down to get through the port or pass it to another person through the port.
    • The transport device needs to be lifted at any time to shoulder height or higher when exiting the space with the injured worker in it.
    • The transport device needs to be inclined at any time to 45° or more above horizontal.
  • Specialized equipment such as a block and tackle or other equipment is necessary during the exit scenario to lift or direct the transport device.
  • A space with a potentially dangerous atmosphere and a means of entry or exit constructed so that first aid or rescue workers wearing self-contained breathing apparatus (SCBA) must remove tanks from their backs at any point when entering or exiting.

Escape: Whether or not the means of exit may complicate the escape or evacuation of workers from a space will typically depend on factors such as the potential of immediate danger, the number of workers in the space, and the obstacles they may encounter when exiting.

If there is the potential for immediate danger, for example release of a flammable or toxic atmosphere into the space, exits must be sufficiently accessible so that workers can exit the space quickly, regardless of the number of workers. If the impediments to evacuation would result in any delay, then the means of exit will be considered to have complicated the capability to escape the space.

In summary: For any space that does not allow easy walk-in to and from the work area, emergency response scenarios such as first aid, rescue, and escape must be considered. If any of these scenarios is complicated by the means of entry and exit, the space is considered to have “restricted access and egress”.

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