Entering Confined Space

[HousePlant]

Greetings,
Working on a problem around a potential confined space; what constitutes entry? In the USA the OSHA Regulation 1910.146 states the following:

"Entry includes ensuing work activities in that space and is considered to have occurred as soon as any part of the entrant's body breaks the plane of an opening into the space. " (emphasis added)

Meanwhile in the WorkSafe BC website they state the following:

“A worker should be considered to have entered a confined space when the breathing zone of the worker crosses the plane of the confined space access.” "

Any ideas for Ontario? We have a series of valves inside an enclosure that may contain a hazardous atmosphere (still working on that) but if a worker can put their hand inside without it being considered "entering" the confined space it will make things easier. We are also looking at having the valve handles extended outside of the enclosure but that may not be feasible so I wanted the group's opinion. Please include any reference to codes, standards or regulations.

Cheers,
Dan
Plasco LG
Cornwall/Ottawa Ontario

[Owen]

If you look at the new CSA Standard...it says as soon as a part of the body breaks the plane of the space it is an entry. Have to make them realise that if the atmosphere in the space can be hazardous, then the atmospehre near the entrance can be hazardous as well.

Owen

[EGordon]

Hi there ... just want to add my two cents as well on this.

I work for a municipality and our planners/inspectors sometimes have to check manholes after a assumed road is done in a site on municipal property. I found out (since 2008 or earlier before I started) that the contractors do not sniff prior to lifting the manholes (checking to see if the road grading affected them).

Our planners and the contractors are just merely looking in the manhole, lifting it to make sure it was not shifted or breached during the road work and construction but to date still do not sniff prior to an entry.

I took this on as a cause/crusade only to get reamed by management as they noted the risk is minimal.

I noted that it is still deemed a Confined Space Entry and documented the same to them and copied an e-mail to myself for CYA noting that this is part of Section 25 2(h) - take every reasonable precaution. The sniffer was cheap, there was free training and some that I could facilitate as well and still ... this was shot down in flames.

I cautioned my director as although the risk is low, all it takes is one opening to go wrong (as in fatal or critical).

The standards due say that breaking the plane is deemed to be a Confined Space Entry and have advised our planners/inspectors that if they do not have the capacity to do a confined space entry of this or more invasive, to let the contractors handle it and report them for non-compliance if they do not sniff before lifting.

I am curious to see who else also shares similar woes in this sometimes thankless profession of Occupational Health and Safety.

Thanks in Advance,

Ed G