Confined Space Entry & Rescue Procedures

Table of Contents

1. Purpose & Scope
2. Legal Requirements
3. What Is a Confined Space?
4. Confined Space Hazards
5. Atmospheric Testing
6. Entry Team Roles
7. Entry Permit System
8. Ventilation & Controls
9. Communication Protocols
10. Rescue Planning
11. HCMI Confined Space Policy
12. Pre-Entry Checklist

1. Purpose & Scope

This guide establishes the procedures every HCMI employee must follow before entering, working within, or performing rescue operations in a confined space on any construction project. Confined space incidents are among the most lethal hazards in the construction industry; the majority of fatalities involve would-be rescuers who enter without proper preparation. Every worker who may encounter a confined space must understand these procedures thoroughly.

This training applies to all HCMI field staff, sub-trade supervisors working under HCMI direction, and any visitor who may need to enter a confined space on an HCMI-managed site. Common confined spaces encountered during church construction include mechanical rooms, cisterns, below-grade vaults, storm water chambers, elevator shafts, and large ductwork.

2. Legal Requirements

Confined space entry on Ontario construction projects is governed by several overlapping regulations:

• O. Reg. 632/05 — Confined Spaces: This is the primary regulation under the Occupational Health and Safety Act (OHSA). It requires employers to establish a confined space program, conduct hazard assessments, develop entry plans, provide atmospheric testing equipment, and ensure rescue procedures are in place before any entry.
• OHSA s.25(2)(h): Employers must take every precaution reasonable in the circumstances for the protection of a worker.
• OHSA s.27(2)(c): Supervisors must ensure that workers comply with confined space procedures and use required protective equipment.
• O. Reg. 213/91 — Construction Projects, s.221: Additional requirements specific to construction activities involving excavations and below-grade work that may constitute confined spaces.

3. What Is a Confined Space?

Under O. Reg. 632/05 s.1, a confined space is an enclosed or partially enclosed space that meets all three of the following criteria:

1. Not designed or intended for continuous human occupancy. The space was built for a purpose other than regular work — for example, a catch basin, a mechanical chase, or a water tank.
2. Has limited or restricted means of entry or exit. Access is constrained by location, size, or configuration — think of a hatch, a narrow opening, or a ladder-only access point.
3. May pose a hazard to a worker who enters due to its design, construction, location, atmosphere, the materials or substances in it, or other conditions.

On HCMI church construction projects, examples include: below-grade baptistry vaults, storm water management tanks, elevator pits, large HVAC plenums, sanitary manholes, and mechanical rooms accessible only through hatches or restricted openings.

4. Confined Space Hazards

Confined space hazards fall into two broad categories:

Atmospheric Hazards

• Oxygen deficiency: Normal atmospheric oxygen is 20.9%. Below 19.5% is oxygen-deficient and immediately dangerous. Biological decomposition, chemical reactions, or displacement by other gases can deplete oxygen.
• Oxygen enrichment: Above 23.0% creates severe fire and explosion risk. Leaking oxygen lines or cylinders can cause enrichment.
• Flammable gases and vapours: Methane from decomposition, natural gas leaks, or solvent vapours can reach explosive concentrations. The Lower Explosive Limit (LEL) is the threshold of concern.
• Toxic gases: Hydrogen sulphide (H2S) from sewage or stagnant water, carbon monoxide (CO) from combustion engines or propane heaters, and other toxic substances can accumulate to lethal levels in minutes.

Physical Hazards

• Engulfment by water, soil, or granular materials
• Entrapment due to converging walls or floors
• Electrical shock from uncontrolled energy sources
• Mechanical hazards from moving parts (pumps, augers, mixers)
• Thermal hazards (extreme heat or cold)
• Falls from internal ledges, ladders, or uneven surfaces
• Noise amplification in enclosed metal or concrete spaces

5. Atmospheric Testing

Atmospheric testing is mandatory before entry and must be continuous during occupancy. O. Reg. 632/05 s.18 requires testing before any worker enters and as often as necessary to ensure safety while workers are inside.

Required Tests & Acceptable Limits

• Oxygen (O2): 19.5% – 23.0%. Test first, as other sensor readings are unreliable in oxygen-deficient atmospheres.
• Lower Explosive Limit (LEL): Must be below 10% of LEL for entry. No hot work if above 5% LEL.
• Hydrogen Sulphide (H2S): Must be below 10 ppm (Ontario OEL). IDLH is 100 ppm. Even low concentrations deaden the sense of smell.
• Carbon Monoxide (CO): Must be below 25 ppm (Ontario 8-hour TWA OEL). IDLH is 1,200 ppm.

Testing Procedures

1. Calibrate the four-gas monitor at the start of each shift per manufacturer instructions.
2. Bump-test the unit before each use to confirm sensor response.
3. Test at multiple levels within the space — top, middle, and bottom — as gases stratify by density.
4. Allow adequate sample draw time (minimum 3 minutes for remote sampling with tubing).
5. Record all readings on the entry permit before any worker enters.
6. Maintain continuous monitoring while any worker is inside. Set audible alarms on the monitor.

6. Entry Team Roles

O. Reg. 632/05 s.11-15 requires specific roles to be assigned and filled before any confined space entry:

Entry Supervisor

• Authorizes entry by signing the permit after verifying all preconditions are met
• Ensures hazard assessment is current and all controls are in place
• Verifies atmospheric testing results are within acceptable limits
• Confirms rescue procedures and equipment are ready
• Has authority to cancel the entry or order evacuation at any time
• Must be a competent person as defined by the OHSA

Attendant (Hole Watch)

• Remains outside the confined space at all times — never enters under any circumstances
• Maintains continuous communication with entrants (visual, voice, radio, or hardwired)
• Monitors atmospheric conditions from outside if remote monitoring is in use
• Keeps an accurate log of who is in the space and their entry/exit times
• Initiates the emergency response and rescue procedure if needed
• Controls access to the space — no unauthorized entry

Entrant

• Must be trained in confined space hazards, entry procedures, and emergency response
• Uses all required PPE including a full-body harness with retrieval line when feasible
• Maintains communication with the attendant at all times
• Exits immediately upon any alarm, order to evacuate, or if they detect a hazard
• Reports any changes in conditions to the attendant immediately

7. Entry Permit System

O. Reg. 632/05 s.19 requires a written entry permit for every confined space entry. The HCMI Confined Space Entry Permit includes:

1. Location and description of the confined space
2. Date and authorized entry/exit times
3. Purpose of entry and planned work activities
4. Identified hazards and control measures
5. Atmospheric test results (pre-entry and continuous monitoring plan)
6. Names and signatures of the entry supervisor, attendant(s), and entrant(s)
7. Ventilation equipment in use and airflow verification
8. Communication methods and emergency contact numbers
9. Rescue equipment available and rescue plan summary
10. Lockout/tagout verification for all energy sources
11. Hot work permit reference (if applicable)
12. Entry supervisor signature authorizing entry

The permit is valid for one shift only. A new permit is required for each shift, each new space, or whenever conditions change significantly. Completed permits must be retained on-site for the duration of the project and archived at the HCMI office for a minimum of one year.

8. Ventilation & Controls

Mechanical ventilation is the primary engineering control for atmospheric hazards in confined spaces:

• Forced-air ventilation: Use a blower with flexible ducting to supply fresh air to the lowest point of the space. The air supply must be drawn from a clean-air source — away from vehicle exhaust, generators, and chemical storage.
• Airflow rate: Provide a minimum of 20 air changes per hour. Calculate the space volume and select an appropriately sized blower.
• Pre-ventilation: Ventilate the space for a minimum of 15 minutes before entry. Test the atmosphere after ventilation to confirm acceptable levels.
• Continuous ventilation: Maintain forced-air ventilation throughout the entire entry. Never shut off ventilation while workers are inside.
• Exhaust ventilation: Where toxic or flammable contaminants are generated by the work (welding, painting, adhesives), provide local exhaust ventilation in addition to supply ventilation.

9. Communication Protocols

Reliable communication between entrants and the attendant is required at all times under O. Reg. 632/05 s.14:

• Voice communication is preferred when the space geometry allows clear line of hearing.
• Two-way radios must be intrinsically safe (IS) rated for use in potentially flammable atmospheres.
• A hardwired communication system may be used for extended entries or noisy environments.
• Establish a check-in schedule — HCMI policy requires the attendant to confirm status with each entrant at minimum every 5 minutes.
• Agree on emergency signals before entry: three sharp tugs on the retrieval line means "emergency — initiate retrieval."

10. Rescue Planning

O. Reg. 632/05 s.22-25 requires that adequate rescue procedures be in place before any entry. The most critical rule: never attempt an unplanned rescue entry. The majority of confined space fatalities are rescuers.

Non-Entry Rescue (Preferred)

• Use a mechanical retrieval system (tripod and winch) to extract an incapacitated entrant without anyone entering the space.
• Entrants wear a full-body harness with a D-ring between the shoulder blades, connected to the retrieval line.
• The attendant activates the retrieval winch and calls 911 simultaneously.

Entry Rescue (Last Resort)

• Only trained and equipped rescue personnel may enter for rescue purposes.
• Rescue entrants must use supplied-air respirators (SCBA or airline with escape bottle).
• A second attendant must be assigned to monitor the rescue entrant.
• HCMI does not maintain an internal rescue team. For entry rescue, call 911 and request the local fire department confined space rescue team.

Rescue Equipment On-Site

The following rescue equipment must be staged at the confined space opening before any entry begins:

• Tripod or davit arm with mechanical winch and retrieval line
• Full-body harness for each entrant (with dorsal D-ring)
• First aid kit with pocket mask and AED
• Extra four-gas monitor for rescue personnel
• Communication device for contacting emergency services
• Supplied-air breathing apparatus (if entry rescue is part of the rescue plan)

11. HCMI Confined Space Policy

In addition to the regulatory requirements, HCMI enforces the following company-specific policies:

1. Competent Person Designation: Only HCMI site superintendents or project managers who have completed confined space entry supervisor training may authorize entry permits.
2. Training Requirements: All workers who may act as entrants or attendants must complete an approved confined space awareness and entry course before their first entry. Refresher training is required every three years.
3. Equipment Maintenance: Four-gas monitors are calibrated monthly and bump-tested before each use. Retrieval systems are inspected annually by a qualified technician. Records are maintained at the HCMI head office.
4. Sub-Trade Coordination: Sub-trades performing work in confined spaces on HCMI projects must provide proof of their own confined space program, training records, and equipment calibration records before being permitted to enter.
5. Incident Reporting: Any confined space near-miss, alarm activation, or entry cancellation due to hazardous conditions must be reported to the HCMI Safety Coordinator within 24 hours using the HCMI Incident Report Form.
6. Permit Posting: The active entry permit must be posted at the entrance to the confined space where it is visible to all workers throughout the entry.

12. Pre-Entry Checklist

Complete all items before any worker enters the confined space:

• Hazard assessment completed and documented by a competent person
• Entry plan developed based on the hazard assessment
• Entry permit filled out with all required information
• Entry supervisor has reviewed and signed the permit
• Atmospheric testing completed — all readings within acceptable limits
• Four-gas monitor calibrated and bump-tested — records available on-site
• Mechanical ventilation operating and verified — minimum 15 minutes pre-ventilation
• Lockout/tagout completed on all energy sources affecting the space
• Attendant stationed at the entry point with communication equipment
• Rescue equipment staged and functional — tripod, winch, harness, retrieval line
• Rescue plan reviewed with all team members — 911 procedure confirmed
• Entrants wearing full-body harness connected to retrieval line
• Continuous atmospheric monitoring activated with audible alarms set
• Entry area barricaded to prevent unauthorized access
• Emergency services pre-notified if required by the rescue plan