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7. The Plan | Confined Spaces Guideline

  • Issued: September 2006
  • Revised: July 2011
  • Content last reviewed: July 2011

Disclaimer: This resource has been prepared to help the workplace parties understand some of their obligations under the Occupational Health and Safety Act (OHSA) and regulations. It is not legal advice. It is not intended to replace the OHSA or the regulations. For further information please see full disclaimer.

Section 7 - Confined Spaces Regulation (O. Reg. 632/05)

  • 7 (1)  Before any worker enters a confined space, the employer shall ensure that an adequate written plan, including procedures for the control of hazards identified in the assessment, has been developed and implemented by a competent person for the confined space.
  • (2)  The plan may be incorporated into an entry permit under section 10.
  • (3)  The plan shall contain provisions for,
    • (a)  the duties of workers;
    • (b)  co-ordination in accordance with section 4, if applicable;
    • (c)  on-site rescue procedures, in accordance with section 11;
    • (d)  rescue equipment and methods of communication, in accordance with section 12;
    • (e)  personal protective equipment, clothing and devices, in accordance with section 13;
    • (f)  isolation of energy and control of materials movement, in accordance with section 14
    • (g)  attendants, in accordance with section 15;
    • (h)  adequate means for entering and exiting, in accordance with section 16;
    • (i)   atmospheric testing, in accordance with section 18;
    • (j)  adequate procedures for working in the presence of explosive or flammable substances, in accordance with section 19; and
    • (k)  ventilation and purging, in accordance with section 20.
  • (4)  One plan may deal with two or more confined spaces that are of similar construction and present the same hazards as identified by the assessment.
  • (5)  The employer shall ensure that the plan is reviewed as often as is necessary to ensure that it remains adequate.

What is the difference between a program and a plan?

A program sets out the methods by which an employer intends to comply with the regulation, such as how to recognize confined spaces, how assessments will be carried out, how plans will be developed, how training will be delivered and what the entry permit system will be.

A plan is a specific set of measures and procedures to control hazards identified by the assessment for that confined space to allow workers to enter and work in a specific confined space safely. The plan must include, among other things, provisions for on-site rescue procedures, rescue equipment and methods of communication (see subsection 7(3) above for all required provisions).

Can my program replace the plan?

No. The program sets out the methods and processes by which the employer intends to comply with the Regulation whereas the plan, which may deal with two or more confined spaces of similar construction and same hazards, includes duties of workers, equipment and procedures for the control of hazards identified in the assessment. The plan for a confined space must be flexible to respond to the hazard assessment carried out for a specific entry; a program may not be as readily revised or extensive enough to deal with different situations.

Are my standard operating procedures good enough to constitute a plan?

It depends on the situation, since standard operating procedures may differ from one employer to the next. Some may include provisions for compliance with the program, while others may be measures and procedures to enter and would be more consistent with a plan. The plan for a specific confined space must be flexible to respond to the hazard assessment carried out for a specific entry; standard operating procedures often are not as readily revised or extensive enough to deal with different situations.

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Disclaimer: This web resource has been prepared to assist the workplace parties in understanding some of their obligations under the Occupational Health and Safety Act (OHSA) and the regulations. It is not intended to replace the OHSA or the regulations and reference should always be made to the official version of the legislation.

It is the responsibility of the workplace parties to ensure compliance with the legislation. This web resource does not constitute legal advice. If you require assistance with respect to the interpretation of the legislation and its potential application in specific circumstances, please contact your legal counsel.

While this web resource will also be available to Ministry of Labour inspectors, they will apply and enforce the OHSA and its regulations based on the facts as they may find them in the workplace. This web resource does not affect their enforcement discretion in any way.