As many of you are already aware, there are amendments to OH&S Regulation Part 9 (Confined Spaces) coming into effect on Tuesday February 1st.
Currently, section 9.22 (1) states that if isolation using the measures specified in section 9.18 (double block and bleed) is not practicable, the employer may implement alternate measures acceptable to WorkSafeBC. Employers must obtain approval from WorkSafeBC before implementing alternate measures.
The new Regulation clarifies that acceptable isolation methods do not require approval from WorkSafeBC. This includes some confined spaces found in the public water supply systems where it may be necessary to control the hazards by a single flow control device, such as a valve or a gate.
The explanatory note accompanying the notice of the February 1st change states:
“Piping associated with dams and their isolation present a unique situation for the utilities that operate them when considering the appropriateness of isolation measures before permitting entry of workers to the confined space such as the water passageways associated with a dam. In most cases, engineering and occupational health & safety staff employed by the utility have a high level of expertise to develop safe measures of isolation for confined spaces within these workplaces. Hence, it is not necessary for these utilities to seek approval from WorkSafeBC for isolating adjacent piping for section 9.18.1 exempted confined spaces. The section mandates that the employer obtain engineering certification for the isolation of adjacent piping to ensure the isolation method is effective for workers to safely enter the part of the dam water passageway that is a confined space. A similar situation exists for entry into a part of the public water supply systems that is a confined space such as valve and meter stations.” (underline added)
In other words: IF your water system utilizes a single flow control device, AND an Engineer has certified that the device affords protection to the worker from the anticipated hazard, your municipality does not need to request a variance to the new Part 9.18 (3).
A professional engineer must certify, by means of a signed, sealed and dated document, that the toal means used to control the hazards during the confined space entry, ensures equivalent protection to all workers exposed to the hazard. The means used to control the hazard includes an evaluation of the physical integrity of the system, as well as monitoring of workers, system components and discharges. The professional engineer is not only certifying the physical components, but is also certifying the complete procedures related to the confined space entry.
Many Municipal water systems utilize AWWA-Certified Valves, or other Certified devices, which are certified to a particular Standard, and do not have a history of catastrophic failure. The Engineer may state that because the system uses AWWA-Certified Valves, the means used to control the hazards ensures equivalent protection to all workers exposed to the hazard.