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Confined Space, Common Sense


By Michael Halliwell

As I write this, it’s October, which means that the new OSHA confined space standard, published back in May 2015, is now in force.

© / shotbydave

Most confined space regulations have come to the same point...the rules are catching up with common sense.

In looking over the legislation, there are some differences in definitions between the jurisdiction where I live and what OSHA has laid out. Even so, I think most confined space regulations have come to the same point. Whether it is a confined space (called a “restricted space” in my area) or a permit-required confined space/permit space (“confined space” in my local jargon), the rules are catching up with common sense.

So in looking at the new standard, were there any surprises? In my opinion, no, not really. It looks like the standard has caught up with the times: you assess the hazard, control the hazard as best as possible and protect the workers who have to go in to get the job done.

This is pretty much what the folks responsibly undertaking permit-required confined space entry have been doing for quite some time, and what other jurisdictions have had on the books for a few years.

Doing Things Right…

About this time last year my blog asked a question about confined spaces: “Have We Learned Our Lesson Yet?

© / ultrapro

The guidelines are pretty clear and a lot of this stuff is common sense, so why do we keep reading about our fellow workers losing their lives in confined spaces?

The guidelines are pretty clear and a lot of this stuff is common sense, so why do we keep reading about our fellow workers losing their lives in confined spaces?  

Well, as cliché as it sounds, it’s because common sense isn’t as common as one would think.

As an example, about five years ago, an environmental investigation I was working on led me to an underground tank. This tank contained some form of fuel and had been installed in what had formerly been the concrete coal bunker of a small power plant.

We weren’t sure what was in the tank, how big it was, what was used as fill around the tank or what other surprises might have been present in the bunker—but we needed to find out so that a proper clean-up could be conducted.

We treated it like the permit-required confined space it was: going in on air (SABA with escape bottles), using lifelines and monitors, wearing impermeable and flame-resistant coveralls due to the potential conditions, and having both a man-watch and a properly equipped rescue team there for emergencies.

© / andrej67

Where is the breakdown in the system and how do we prevent confined space tragedies?

We got out safely, having found a second tank and having collected samples of the fuel (Bunker C), backfill (fly ash containing significant heavy metals) and overhead pipe wrap materials (85 percent chrysotile asbestos). Good job, done professionally and, most importantly, done safely.

…and Wrong

Contrast that with the plethora of examples of confined space jobs gone wrong from the news: workers burned in confined spaces when the solvents they were using ignited, workers perishing in a confined space when overcome by vapours from the chemicals they are working with, “rescuers” and victims succumbing to asphyxiation in an oxygen-deficient atmosphere confined space, entrapments and deaths from trenches collapse….

The list goes on and on, and far too many of them would have been readily preventable if the confined space was handled correctly.

So where is the breakdown in the system and how do we prevent confined space tragedies?

Well, I think we all know that there are “bad apple” companies out there for whom safety is not a priority. For them, the “almighty dollar” is the only thing that matters, and injuries and deaths are just a cost of doing business.

© / wolv

Realistically, it comes down to us. We need to be informed about the regulations and our rights.

Sometimes, even the “good” companies can be lax, either from complacency or from ignorance. Sure, OSHA and their inspectors are out there doing what they can, but there are a lot more jobsites and companies than there are inspectors.

Taking Responsibility for All

Realistically, it comes down to us. We need to be informed about the regulations and our rights.

We need to have the training to do our jobs correctly and safely; we need to be looking out for ourselves and for our fellow workers.

We need to be willing to speak up for ourselves and for our coworkers when things aren’t safe, and we need to be backstopped by good whistleblower legislation if we need to get the authorities involved to prevent a tragedy.

I understand that a vast majority of you reading this entry know and do these things already—but we also need to reach out to the others around us who don’t know, weren’t trained and are putting their lives at risk when it comes to confined spaces.

We can’t afford to get complacent or to ignore the unsafe acts performed by others; otherwise the results for us, them and all involved can be tragic.

Stay safe out there, boys and girls.


Michael Halliwell

Michael Halliwell, M.Eng., CESA, EP, P.Eng., is an Associate and Environmental Engineer for Thurber Engineering Ltd. in Edmonton, Alberta, Canada. During his 17-plus years with the company, he has been involved with environmental site assessment, remediation, construction inspection and supervision, and project management. He also performs hazardous building material assessments for asbestos and lead paint.



Tagged categories: Engineers; Environmental Controls; Environmental Protection; Project Management; Thurber Engineering Ltd.; Confined space; Health & Safety; Manholes; North America; OSHA; Regulations; Tanks and vessels

Comment from Bob Walnut, (3/30/2021, 7:13 AM)

It is important to always practice OSHA when it comes to this kind of industry. The hazards on this job is a lot, just like on the concrete construction industry.

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