Confined space – Restricted access or egress Legislative Interpretations

Definition

262 The following definitions apply in this Part.

“confined space” means, other than a development heading in an underground mine and excavations, heating, ventilation and air conditioning (HVAC) plenums and related ventilation ductwork, crawl and attic spaces with openings to outside allowing for continuous passive ventilation and other similar structures provided that there are no factors that could lead to the presence of an atmospheric or other hazard, an area that
(a) is enclosed or partially enclosed,
(b) is not designed or intended for continuous human occupancy, and
(c) has limited or restricted means for entry or exit that may complicate the provision of first aid, evacuation, rescue or any other emergency response.

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 criteria;

(a) is enclosed or partially enclosed,

(b) is not designed or intended for continuous human occupancy, and

(c) has limited or restricted means for entry or exit that may complicate the provision of first aid, evacuation, rescue or any other emergency response.

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”.