Safety in Confinement

It could be a claim for fire, mould or water damage to a house. Perhaps an industrial accident caused an explosion in a warehouse. Whatever the cause, you’re on site by yourself and someone has to go into that crawl space, attic or storage tank and check for damage. You want to get this resolved now so you can start processing the claim — but if you go in, can you get back out safely?

Spaces such as these can cause more harm than just claustrophobia — there can be a risk of explosion, collapse, asphyxiation or poisoning, or even an angry raccoon that does not like its territory being invaded. Entering a mould-infested space can be a hazard for anyone with asthma; even someone who does not have asthma may develop it through repeated exposure on the job.

Underwriters and other insurance-sector personnel need to understand the legal and safety implications of confined space entry. There have been many instances of injury or death involving people who did not consider the risks. What they thought would be a quick in-and-out inspection tragically became one-way.

Insurance sector workers need to understand the risks so they can protect themselves, and insurance companies, adjusting firms and other corporate members of the insurance sector need to provide a safe environment for their employees. This includes making sure employees have the training and equipment needed for confined space entry; it also means knowing when it is necessary to call in specialists with the appropriate personal protective equipment (PPE), air quality assessment and other specialized equipment.

WHAT IS A “CONFINED SPACE”?

To begin with, recognize that not every “space” one would consider “confined” is actually a “confined space” according to regulations. Regulations are sometime subtly different for each province and territory, and they occasionally change, so it is important to stay current with the applicable laws. For example, in Ontario a confined space is any partially or fully enclosed space that is both not designed and intended for continuous human occupancy and is one in which atmospheric hazards may exist.

This description illustrates two of the main risks associated with confined spaces: the tight fit, and the potential for atmospheric hazards.

Generally, confined spaces are considered to be large enough for someone to enter, but have limited access, pose a risk of engulfment and have internal configurations likely to entrap and cause suffocation. They might have other hazards as well: risk of illness caused by excessive heat or cold, moving equipment, exposed electrical equipment/contacts and fall hazards.

Atmospheric hazards are defined just as broadly. Levels of oxygen deficiency or excess are defined in precise numerical (percentage) terms, and more activity consumes oxygen faster. Flammability on the other hand depends on several criteria including the (percentage) amount of flammable material, the type of activity undertaken by the person entering the space and, of course, jurisdiction.

In some jurisdictions, an enclosed space is not considered a “confined space” if there is cross-ventilation within the space. This generally means functioning vents on opposite sides, so that a cross-breeze will reduce the accumulation of hazards inside. However, anyone carrying out an on-site investigation would need to confirm that the vents are working and not obstructed — which is generally done by pushing through a metal rod or ruler from the outside — before they accepted the ‘not-a-confined-space’ designation or description.

RECOGNIZING THE HAZARDS

Determining whether a space is a “confined space” under the applicable legislation may seem arcane, but it is important for two reasons.

One is that all employers — such as members of the insurance sector — must provide a safe environment for their employees. Asking employees to enter a hazardous area without appropriate training, PPE and other necessities is dangerous for the worker, and it will ultimately leave the company exposed to sanction and its officers to criminal liability. At the same time, insurance adjusters are often called upon to investigate events that may require entry into what might be considered confined spaces.

So it is important for insurance-sector companies to teach their employees to recognize a confined space when they see it, enter it only when hazards have been appropriately controlled and/or eliminated and to make sure employees know it is their right and obligation to refuse unsafe working conditions.

A second important reason to recognize a confined space is that any space that meets the definition is almost certainly hazardous; those hazards may come from unexpected sources.

Consider the case a few years ago at a chemical plant in which there was need to enter a tank made of mild steel to decontaminate it prior to repairs. After a few days, the tank had been successfully and safely cleaned and decontaminated, and considered safe for re-entry. Two welders subsequently entered the tank to conduct the repair and were asphyxiated. Analysis conducted after the fact indicated the water used to rinse the tank at the end of the cleaning had caused rusting of the mild steel of the tank; given insufficient natural air exchange, the oxygen levels were depleted to levels that resulted in rapid asphyxiation.

Consider also a 2007 incident in which two workers entered, unprepared, a utility vault that was subsequently found to be seriously oxygen-deficient from unknown causes. They were quickly overcome, and died of asphyxiation.

Some gases have an odour that warns a person of the danger (natural gas has the odour added for this reason). Other atmospheric hazards, such as carbon monoxide, are undetectable. Oxygen deprivation can cause irreversible brain damage — and death — within seconds.

As a result, employees need to have the right equipment for their job. A respirator or mask that protects an employee against mould spores and asbestos fibres will still leave the person vulnerable to reduced oxygen levels, the presence of carbon dioxide or other hazards. A powerful flashlight, used from outside the space, can sometimes allow the employee to conduct inspection-type work without a need to enter.

Companies also need to make sure they have access to the appropriate professional advice, either in-house or outsourced. This would include a consultant specializing in health and safety who also has confined-space training and experience. There is also a need for a relationship with a firm able to supply remediation specialists with the appropriate PPE, training and other qualifications to enter the space, if necessary, to do the assessment.

Confined spaces are an inevitable part of many insurance industry members’ lives. Managing the work correctly also manages the risks involved, resulting in a safer workplace and workforce.