Understanding the role of confined space attendants in worker health and safety

What the Regulation for Confined Spaces tells Ontario employers about the safety requirements for confined space work.

Ontario employers must comply with provincial legislation. When it comes to safely performing work in confined spaces, the law requires employers to use in-person attendants—rather than a technological alternative, such as confined space remote monitoring systems.

The Regulation for Confined Spaces (O. Reg. 632/05) defines a confined space as “a fully or partially enclosed space, (a) that is not both designed and constructed for continuous human occupancy, and (b) in which atmospheric hazards may occur because of its construction, location, or contents, or because of work that is done in it.”

Tanks, vaults, vats, vessels, hoppers, bins, and maintenance holes are examples of confined spaces in the workplace. For utility workers, confined spaces may also include cable chambers, hydro vaults, sewer systems, water towers, and storage tanks.

The legal requirement for in-person confined space attendants

“The Regulation for Confined Spaces is very prescriptive,” says Blair Allin, Canadian Health and Safety Representative for the International Brotherhood of Boilermakers and a member of IHSA’s Board of Directors. “Having an attendant at the entrance is the expectation.”

According to Section 15(1) of the regulation, the employer must station one attendant outside and near the entrance of each confined space whenever a worker is inside. That attendant must also be in constant communication with the worker inside and have a device that allows them to call for a rescue response.

Confined spaces can contain many physical hazards. These hazards may include:

• Noise and vibration
• Temperature extremes
• Cramped workspaces
• Limited entry and exit
• Rotating or moving equipment
• Electrical hazards
• Uncontrolled movement of liquids and solids
• Reactive or corrosive residues
• Slick or wet surfaces
• Poor lighting

Dangerous atmospheric conditions can also exist in a confined space; its very air may be combustible, explosive, toxic, oxygen-deficient, or oxygen-enriched.

While any workers are inside, the attendant should monitor their safety, provide help as needed, and prepare to call for rescue in case of an emergency. Because attendants are stationed near the entrance of the confined space, they can keep the work activity in their line of sight and hear the noise that it generates.

“When you weld, the attendant can notice the noise and the by-products of the work,” Allin says. “When somebody is welding in a confined space, I can see the reflection of the light. When they stop, I can then see that they’re not welding anymore. When they’re chipping their weld, I can hear the clicking sound.”

He adds that attendants who are familiar with the type of work that’s being done inside the confined space offer an additional level of safety because they are more capable of interpreting the situation. Their knowledge and expertise allow them to make more timely decisions when help is needed.

“It has to do with the comfort of the people on the inside of the confined space.”

At the same time, attendants can identify other work happening in the area that might affect the activities and atmosphere inside of the confined space. Nearby equipment and vehicles might produce carbon monoxide, for example, or an item at the workplace might block ventilation or affect purging activities.

The hazards of using remote monitoring systems

Confined space remote monitoring systems use cameras, sensors, and other technology to monitor confined space work. They collect information about the work environment and use it to identify hazards as well as track conditions and incidents.

They also allow one worker to monitor multiple confined spaces at the same time from a single location. This is often promoted as a benefit, but the practice does not meet the requirements of the Regulation for Confined Spaces. To remain compliant, employers can only use remote monitoring as an extra part of their confined space safety program. It can’t replace a trained human attendant.

There are also hazards associated with introducing a remote monitoring system. Unlike attendants, who are available near the entrance to the confined space and can react immediately—to changing conditions outside of the confined space that may affect the workers inside it, as well as to emergency situations—remote monitoring happens away from the confined space. The distance could create a delay if an emergency response is needed. Additionally, the technology cannot replicate the attention of an attendant, who is assigned to just one confined space and is trained to detect small changes in the work, the environment, and worker behaviour.

Remote monitoring systems also provide less situational awareness than human attendants. A person viewing a remote system’s monitor is not able to see or hear other nearby work activities that are happening outside of the camera’s view—and so cannot anticipate if those activities will have an effect on the confined space. They also can’t smell fumes.

The possibility of technological failure is another hazard: noise, dust, and other changes to work conditions—not to mention technical issues and power outages—can cause a remote monitoring system to malfunction.

Canadian health and safety standards concur

Other influential Canadian health and safety organizations support the use of an in-person attendant. The Canadian Standards Association (CSA) is one example. “If I were to go to any jobsite, they’re not going to let me wear a pair of work boots unless they’re CSA approved,” Allin says. “Why do they do that? Because CSA approval is a gold standard of proven reliability and protection.”

CSA Z1006:23: Management of Work in Confined Spaces provides guidance on managing health and safety in confined spaces.

Section 9.2 is specific about what’s expected of remote monitoring systems: they must provide an equal level of safety as an in-person attendant. This means employers need to consider the hazards of confined space remote monitoring systems—such as the possibilities of decreased attention to the work environment, uncontrolled and identified hazards entering the workspace, delayed emergency response, and technological failure—that may reduce the level of protection for workers.

In Section 9.3: Limitations, the standard additionally states that employers should not use remote monitoring to replace the attendant at the entrance to the confined space when the work will be completed in the following types of confined spaces:

• Confined spaces with non-atmospheric hazards that present a risk that could cause major injuries.
• Confined spaces with atmospheric hazards alone or in combination with hazards that present a risk that could cause injuries.

The CSA standard also states that employers must not use a remote monitoring system for any activity that would disrupt the system’s video or audio streams, such as work that creates loud noise or generates a lot of dust.

Beyond these limitations, Section 11.1.5.2 of the standard says there must be an attendant present at any confined space that requires an entry permit. Combined with the fact that every confined space in Ontario requires an entry permit (O. Reg. 632/05, s. 10(1)) and every confined space attendant must be stationed outside or near the space’s entrance, the standards and regulations make the case that a human attendant is essential to all confined space entry teams.

Employer and worker roles in confined space safety

Workplace safety is a shared responsibility. The internal responsibility system (IRS) gives each workplace party duties for maintaining a safe work environment. The IRS is the foundation of health and safety legislation in Ontario.

Under the IRS, employers have the most responsibility for health and safety. When a company engages in confined space work, the employer must comply with provincial laws and take all reasonable precautions to protect workers from harm. When making safety-related decisions, Allin says employers should keep in mind that the companies developing new technologies, like confined space remote monitoring systems, may not take Ontario legislation into account when designing or selling their product.

If an employer doesn’t provide an in-person confined space attendant, the worker should report the hazard to their supervisor or the workplace’s joint health and safety committee (JHSC). The JHSC can investigate the report and make recommendations to the employer on how they can control the hazard.

Ultimately, Ontario workers also have the right to refuse work that they believe endangers their health and safety or the health and safety of others. In this case, workers should follow their workplace procedure for work refusal.