New Regulation Compliance

 

Compliance 101 for the
New Ontario Confined Space Regulations

The following, although not all inclusive, provides some ideas on how to achieve compliance.

Step #1 - Determine what are confined spaces on your property

• Define when entry occurs
• Understand the new confined space definition or create your own (e.g. continuous human occupancy - any place not designed to meet the standards set out in the Ontario Building Code with regards to doorways, aisles, lighting, ventilation, etc.)

Step #2 -Tour your property looking for confined spaces

• Develop a written inventory of the confined spaces

Step #3 - Identify the hazards that are in each confined space

• Determine what hazard(s) are in the space all the time
• Figure out what jobs would occur in the space and the hazards these tasks create
• Determine the hazards that could develop from nearby unrelated work and/or work areas
• Understand when “entry” occurs to determine the severity of the risks faced (the more the probability and the greater the injury - the more you need to do something about it.)

Step #4 - Select the protective systems needed to control the hazards for the job

• Obtain all the protective equipment available for the job
• Ensure operating instructions for each protective device is available
• Develop a procedure to follow outlining when each piece of equipment is used and how it is to be used (Hazard Control Plan)
• Develop an inspection and maintenance system for the equipment
•                

Step #5 - Create a permit and other documentation

• Use checks boxes, cross offs, etc to keep writing to a minimum
• High tech (data logging capability on your gas detector or PDA’s) may work better
• Ensure there is written instructions on how to complete the documents properly (what goes in what box including N/A if the box doesn’t apply)
• Make sure the paperwork goes somewhere that completes the continuous improvement process

Step #6 - Create a Rescue Plan

• Identify the possible injuries that may occur if someone follows the system
• Identify the possible injuries if someone DOESN’T follow the procedures
• Determine how you would remove each type of injury, where possible minimize the number of procedures needed.
• Working with the various parties involved (in house personnel, fire, ambulance or contractors) assign who is to do what in an emergency

Step #7 - Select personnel to work on the confined space team

• Provide everyone training on how to identify a confined space (definition, signs, etc.)
• Identify who will operate what devices in the system and ensure they have training on these devices
• Test the procedures(including the retrieval plan) to make they work

Step #8 - Auditing

• Have supervisors and JHSC members watch the entries to ensure the procedures work
• Review the permits and other documents to find problems
• Adjust the procedures and retrain as required