Ontario Regulation 632/05 (O.Reg 632/05) governs how organisations should identify and safely manage access to confined spaces in Ontario.
O.Reg 632/05 has significant legal implications for a very large number of businesses in the province, however in our experience many businesses are also either unaware of the various operational and legal implications associated with O.Reg 632/05 or do not completely understand their responsibilities in relation to this regulation.
This is not necessarily a matter of neglience, for example Tundra Rescue frequently meets and assists program, project and health and safety managers who both realise they need to and also want to do something about confined space safety issues in their operations, but are not clear about exactly either what they should be doing or how they should implement O.Reg 632/05 compliance within their own specific business context.
In some cases this starts from just being able to define what is and also what is not a “confined space”.
What is a Confined Space?
According to the regulation, O.Reg 632/05, a “confined space” means:
A fully or partially enclosed space,
- That is not both designed and constructed for continuous human occupancy, and,
- In which atmospheric hazards may occur because of its construction, location or contents, or because of work that is done in it.
This is a broad definition and there will be a vast number of different types of spaces, vessels and containers in Ontario that could fall underthe regulations requirements across the workplaces of almost every industry. Tundra Rescue’s client base also reflects this diversity.
What does “continuous human occupancy” mean exactly? And how can we tell if the “location” of a space might introduce an atmospheric hazard?
The Ministry of Labour Guidelines on this topic which are designed to assist the risk holders comply with O.Reg 632/05 provide more clarity about the regulation, but finding the time to properly interpret and apply these regulations and guidelines can be difficult while juggling the various pressures of a busy workplace. This is, after all, just one issue out of dozens of others that a busy manager may be required to address.
Given that the operational, moral and legal penalties for getting confined space safety wrong are potentially so high in Ontario, some businesses will choose to bring in a specialist like Tundra Rescue to assist them assess, plan and deliver their approach to confined space safety, including the provision of confined space rescue teams.
What can go wrong and how we can help?
Let’s take a quick look at a case study to show how this work in practice.
In mid-2021, Tundra Rescue received a request from a new customer to help them with the following:
- Identify (or confirm) any confined spaces in their facility, and,
- Clarify their requirements to ensure safety and compliance
Following a consultation process where we provided a confined space safety assessment and procedural advice, this customer also via opted to use Tundra Rescue’s confined space standby rescue services, and during one of our first field deployments to that customer’s facility, an entry took place into a newly identified confined space which the customer had not previously recognised.
During normal operations, the space held only inert (edible) materials. It was made of stainless steel, was was cleaned thoroughly and regularly, and had no obvious sources of atmospheric hazard. However, when our technicians tested the atmosphere before that first entry they discovered a dangerous amount of carbon monoxide was contained within it.
The business might easily have made the mistake of determining that this was not a confined space, based on an inexperienced interpretation of the regulation. Thankfully though they performed necessary due diligence by bringing in an expert to be sure, and in doing so successfully controlled a significant hazard.
If you have doubts about whether O.Reg 632/05 applies to your business, or aren’t sure how to apply the regulation to your unique confined spaces or operational processes please do contact us, and we will assist you build and maintain your confined space compliance in the most appropriate way to suit your specific operations and projects.