On July 25, 2023, a regulatory amendment to the Quebec Occupational Health and Safety Regulation came into force, incorporating changes to those performing work in confined spaces who fall under provincial jurisdiction, with the exception of those working under the Safety Code for the Construction Industry, which remains unchanged.
The legislator’s objective was to replace the definition of a confined space by targeting the main causes of confined-space fatalities and injuries that have occurred in recent years. It also aims to reduce workers’ exposure to confined-space hazards at their source, by requiring new and renovated confined spaces to be designed so that, when possible, the work can be performed from outside the confined space.
Here are the main changes:
The new definition now states that a confined space is any space that is totally or partially Confined and involves one or more of the following three hazards:
The inclusion of the notion of a partially-confined space is important given the history of injuries and fatalities in confined spaces in recent years. For example, a manure pit, although completely open at its highest point, will still be considered a confined space under the new definition.
The notion that the space is not intended to be occupied by people and that access or egress is by a restricted route have been eliminated from the new definition.
Reducing a risk at its source is one of the most effective ways of preventing accidents. The regulatory amendment now requires that new confined spaces, as well as those to be renovated, must allow work normally performed inside the confined space to be carried out without the worker having to enter the confined space when reasonably possible.
For example : Laurent City Public Works is replacing all of the water pumps that carry water to citizens throughout the city. Currently, the pumps are located inside the pump housings which are located underground inside of the large water pipes that run under the city. When the pump or motor needs to be repaired, maintenance personnel must climb down into the pipe to perform the repair inside of a very confined space. This opens the worker up to various risks related to confined space work, along with added costs to the city.
In an effort to meet the new confined spaces regulations for Quebec, Laurent City Public Works positions the pumps above ground with a pump shaft that goes down and connects into the main pipe, rather than positioning the entire pump underground. This enables workers to repair and maintain the pumps without needing to enter the confined space, effectively eliminating hazards faced by workers with respect to confined spaces.
Controlling the risks present around the confined space should also be part of the work procedures to be drawn up before the confined space is put into service.
If it is impossible to carry out all the work to be done in the confined space from outside it, the layout of the confined space must enable safe work to be carried out inside it, by controlling the risks associated with atmospheric hazards, burial and drowning. Fixed ladders or walkways can be used to meet this requirement.
Another requirement of the regulatory amendment is the provision of access points sized to allow access and egress without physical constraints, as well as the installation of fall protection devices where applicable. We can think of the installation of permanent anchorage points at locations where access and/or rescue equipment will be installed on an ad hoc basis.
The regulatory change now requires any worker required to work in a confined space to be 18 years of age or older.
As pre-work characterizations are an effective means of identifying the hazards and controls applicable to work in a specific confined space, changes have been made to the information they must contain.
Atmospheric hazards must now include those that may be introduced by the nature of the work to be performed in the confined space. Potential thermal stresses must also be identified and controlled.
Risks associated with worker evacuation must be identified, including means of entry and exit, lighting conditions and means of communication.
To emphasize the leading cause of injury and death in confined spaces, the thresholds for certain atmospheric values have been modified.
As a result, the minimum threshold for oxygen in the air has been raised from 19.5% to 20.5%. This is one of the biggest changes in the regulations. Issues have already been raised regarding the ability of certain detection devices to be programmed at this value.
The same applies to flammable and combustible gases, for which the maximum threshold is reduced from 10% of the lower explosive limit to 5%.
As rescue planning is the key to a successful operation, the requirements for rescue plans have been significantly modified.
Plans must now stipulate that rescue equipment must be selected to suit potential conditions of use, must be inspected and maintained in good condition, and must be present and easily accessible in the vicinity of the confined space in order to reduce response time.
Rescue plans must include a person whose function is to take charge of the execution of the rescue plan in order to ensure proper coordination of operations and maximize their effectiveness.
In the future, rescue workers will have to be trained by a qualified person in confined space rescue techniques, with the primary aim of ensuring their own safety.
Finally, rescue plans must be tested through exercises involving rescue workers, so that they are familiar with rescue procedures and equipment, and that they have undergone the appropriate practice in a safe and controlled environment.
Work in confined spaces where solid or liquid materials are stored will also have new parameters.
In addition to the energy control procedures already in place under the old regulations, additional checks will be required to detect any risk of material movement due to the presence of cavities in the material, material agglomeration or any other potential reasons. It will also be forbidden to gain access over a vault formed by solidified materials in an confined space.
For liquids, a procedure for isolating liquids at the work site will now be mandatory. The procedure must enable control over the liquid level, so that it does not rise while workers are inside the confined space. This control can be achieved by draining the liquid, bypassing, plugging pipes or closing and locking valves.
Regulatory change is the ideal time to validate and update your confined space work procedures so that they meet the new requirements. Don’t hesitate to contact one of our specialists, who can support you every step of the way.
For aid in confined space rescue plans, characterization of confined spaces, standby rescue, or training, contact Nouvelle Hauteur for more information.
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