Confined Space Program

Confined spaces kill the people who go in to help. More than half of confined space deaths are would-be rescuers (CSA Group, in the material published with CSA Z1006:23), and the fire service is the rescuer of last resort for every manure pit, sewer, tank, silo, vault and lift station in its district. This program is working when the department knows every regulated confined space in its own stations and shops and never enters one without a permit; when it has declared, in writing, the level of confined space rescue it provides and can deliver that level with the people, air, monitoring and retrieval equipment on the apparatus; when no member ever enters an unknown atmosphere without monitoring, supplied air and a retrieval line, and no attendant ever enters; when every industrial client that names the department as its rescue service has a signed agreement and the department has drilled in that client’s spaces; and when every entry, training or real, leaves a record.

This module is Required where the department is a designated rescue service for any employer, or where members enter confined spaces in stations, shops, training props or vessels; otherwise Conditional at the awareness level. It answers Profile Worksheet question 15 (01 Program Profile Worksheet). Even a department that provides no entry rescue has confined spaces in its facilities (pits, tanks, crawl spaces, cisterns, dry hydrant chambers) and responds to confined space emergencies at the awareness level, so sections 5.1, 5.2, 5.5 and 5.6 apply to every department.

Consistent with 06 Glossary and Acronyms.

• Attendant. The competent person stationed outside the space who keeps count, maintains communication, monitors conditions and activates rescue, and who never enters.
• Atmospheric hazard. Oxygen deficiency or enrichment, a flammable or explosive atmosphere, or a toxic contaminant above its occupational exposure limit.
• Bump test. A functional check that exposes a gas detector to known gas to confirm the sensors and alarms respond; not a calibration.
• Confined space. An enclosed or partly enclosed space not designed or intended for regular human occupancy, with restricted access or exit, that is or may become hazardous because of its design, construction, location, atmosphere, contents or other conditions (the definition most provinces use; CSA Z1006:23).
• Designated rescue service. An outside rescue capability an employer relies on for its own confined space entries, named in that employer’s entry program.
• Entry. Any part of the body passing through the opening of a confined space.
• Entry permit (certification). The written, time-limited record by a competent person that the space has been assessed and the conditions for entry are met, posted at the entrance.
• IDLH. Immediately dangerous to life or health; any unknown atmosphere is treated as IDLH.
• Lower explosive limit (LEL). The lowest concentration of a flammable gas or vapour in air that will burn; readings are expressed as a percentage of the LEL.
• Non-entry rescue. Retrieval of an entrant by a line and retrieval device operated from outside the space.
• Psychological safety. The shared belief within a crew that it is safe to speak up, ask, admit error and challenge (Edmondson, 1999)DOI.
• Retrieval system. The harness, line, and tripod, davit or winch that allows non-entry rescue.

The core is generic. Atmospheric limits, retraining intervals, certification validity, permit retention and the firefighter exemption differ by province and territory; they are set out on J17 Confined Space, and every topic this program relies on is listed under Jurisdiction requirements.

Deltas from 01 Roles and Responsibilities: the rescue team lead is the operational lead for entry rescue; facilities staff share the station inventory; the program manager is the Technical Rescue program manager (06 Program Improvement Teams).

Requirement. The department states in writing which of the three levels it provides (NFPA 2500, 2022): awareness (recognize, isolate, deny entry, call for resources, non-entry retrieval of a lightly injured person already on a line); operations (non-entry retrieval, support of an entry team, entry into spaces with no atmospheric or engulfment hazard that cannot be controlled); technician (entry rescue in any space the department has the equipment and training for). It also lists the mutual aid or contracted capability for any level it does not provide, with call-out contacts. Minimum method. The declaration is approved by the fire chief, consulted with the JOHSC, and reviewed with the annual program appraisal. Evidence. The signed declaration; the capability matrix in section 17.6. Stage. S1.

Requirement. Every confined space in a department workplace is identified, classified, signed and entered only under the entry procedure (CSA Z1006:23, cl. 6.2.1).

Minimum method. Walk every station, shop, training ground and vessel with facilities staff and the JOHSC. Typical spaces: oil and water separators and sumps in apparatus bays; underground and above-ground fuel and water tanks; cisterns and dry hydrant chambers; crawl spaces and attics with restricted access; HVAC plenums and ducts large enough to enter; training props built as confined spaces (culverts, tanks, mazes); vessel bilges, voids and tanks; elevator pits; manholes and vaults on department property. Record each in the inventory (section 17.1) with its hazards, classification (atmospheric, engulfment, configuration, mechanical, other), who may enter, and the entry method. Sign every space at its opening. Spaces no member needs to enter are locked or barricaded and marked “no entry; confined space”. Evidence. The inventory; signage; the annual review. Stage. S1.

Requirement. Every planned entry by a member, including training entries into props and real spaces, follows the full regulated entry process; no emergency exemption applies to it (MLITSD, n.d., GN 6-5). Check how your jurisdiction words any exemption (J17 Confined Space).

Minimum method. The elements, in order:

1. Hazard assessment of the specific space and the specific entry by a competent person, ignoring the protection that PPE and ventilation would give (so the hazard is recorded as it is, not as controlled). Atmospheric hazards, engulfment, configuration (sloping floors, converging walls), mechanical and electrical energy, temperature, biological hazards, access and egress size with PPE and rescue equipment.
2. Isolation and lockout of every energy source and every line that could introduce a product or a hazard, confirmed by test, with the lockout record attached to the permit (SWP - Lockout and Shop Safety).
3. Purging and ventilation of the atmosphere, with the space purged at least twice where practicable and retested, and continuous mechanical ventilation during the entry where the assessment calls for it; ventilation does not replace monitoring.
4. Atmospheric testing before entry and continuously during it, at the top, middle and bottom of the space, with a calibrated and bump-tested instrument, by a trained person, with results recorded on the permit. Entry only within the jurisdiction’s limits for oxygen, flammables and contaminants (J17 Confined Space). The department’s action levels, which are never looser than the jurisdiction’s limits: no entry at or above 10 percent of the LEL (lower it where the jurisdiction’s limit is lower); oxygen within the legal range; every contaminant below its occupational exposure limit; any alarm during entry means everyone out.
5. Attendant at the opening for the whole entry, in continuous voice, radio or line communication with every entrant, keeping the entry log, with the authority and the means to order evacuation and to start rescue, and never entering.
6. Entry permit (certification) completed by the competent person, valid for no longer than the maximum the jurisdiction sets, posted at the entrance for the duration, and retained for the period the jurisdiction sets (J17 Confined Space; Form - Confined Space Entry Permit).
7. Rescue plan specific to the space, with the retrieval system rigged and the rescue team or non-entry method ready before anyone enters; the rescue plan is written on the permit.
8. Communication method named and tested before entry; a back-up method; the signal for evacuation.
9. Respiratory protection: positive-pressure SCBA or supplied-air respirator with escape cylinder where oxygen is deficient, the atmosphere is unknown, or a contaminant could exceed its limit; air-purifying respirators only where the assessment proves the atmosphere is known, stable and within their limits.
10. Harness and retrieval line on every entrant where practicable, attached at the dorsal or overhead D-ring, running to a rated tripod, davit or winch outside.
11. Electrical and ignition control: battery, double-insulated or low-voltage tools and lighting; intrinsically safe equipment wherever flammables are possible; no ignition sources where the LEL reads above zero.
12. Traffic and public control: signs and barricades around openings on roads and in public areas.

Evidence. The permit file; lockout records; instrument records; attendant logs. Stage. S1.

Requirement. The department can perform the rescue it has declared, with a written procedure (SWP - Confined Space Entry and Rescue), the equipment in section 7, and pre-plans for the high-risk spaces in its district.

Minimum method.

• Size-up and classification before any approach: what the space is, who is inside and for how long, what put them down, what the atmosphere is doing now, what energy and product sources exist, who on site knows the space.
• Monitoring from outside first; readings at the opening and at depth with a pump and tubing (allow for tubing delay); continuous monitoring throughout.
• Non-entry first. If the patient is on a retrieval line, retrieve. If a reach or a line can be passed without entry, do that.
• Entry rescue only by a trained entry team of two on supplied air with retrieval lines, with a back-up team of two dressed and at the portal, an attendant, a rescue group supervisor, an incident safety officer, and medical standing by. Nobody enters without monitoring, supplied air and a retrieval line; the attendant never enters; nobody enters alone.
• Atmosphere: treat every unknown atmosphere as IDLH. Where a flammable reading is between the no-entry level and the department’s action level, ventilate before entry; where it cannot be brought below the action level, do not enter (the rescue becomes a recovery conducted by a different plan).
• Lockout of every energy source the site can identify before entry; where the site cannot isolate, the incident commander decides whether the risk to the entry team is acceptable and records the decision.
• Charged hoseline at the opening where flammables are possible; explosion-proof lighting; intrinsically safe radios.
• Medical: patient packaging for vertical or horizontal extraction; oxygen and monitoring for rescuers after exit; rehab per Firefighter Rehabilitation Program.
• Pre-plans for the lift stations, water and wastewater plants, grain and feed facilities, marine terminals, tank farms and industrial spaces in the district, built with the owners (section 17.4).

Evidence. The procedure; pre-plans; drill records; post-incident reviews. Stage. S1 at the declared level.

Requirement. The department understands exactly what its jurisdiction’s exemption, if there is one, does and does not cover, and writes that into the procedure.

The position. Most provinces relieve a firefighter engaged in structural firefighting or rescue from some or all of the entry provisions, and some make the relief conditional on the firefighter having received adequate training for confined space entry and rescue; the wording and conditions differ by jurisdiction (J17 Confined Space). This program applies the following limits whatever the local wording:

• It applies to emergency rescue and structural firefighting, not to training entries, maintenance entries, inspections, pre-planned standby entries for an industrial client, or any entry the department has time to plan.
• It is conditional on training in this program, as it is in law in some jurisdictions. A department that cannot show the training does not rely on any exemption, and its entries are judged against the full regulation.
• It does not relieve the employer’s general duty to take every reasonable precaution, the respiratory protection rules, the harness and SCBA rules for rescue entries, or the duty to have written rescue procedures.
• It does not relieve the standards the department has adopted: the NFPA organizational level, the two-in and back-up-team rule, continuous monitoring, and the attendant.

Evidence. The procedure text; the training records that make the exemption real. Stage. S1.

Requirement. Before the department lets any employer name it as that employer’s confined space rescue service, the two sign an agreement and the department proves it can perform.

Minimum method. The agreement (template in section 17.5) states: the spaces covered, with the employer’s hazard assessment for each; the department’s declared level and what it will not do; the realistic response time from dispatch to a rescue-ready team at the portal, measured, not estimated; what the employer must have in place before every entry (its own entry program, permit, attendant, retrieval line on the entrant, isolation, atmospheric data at the portal, a site contact who knows the space); notification to the department before entries begin where that is practicable; the department’s right to drill in the actual spaces at least annually and to decline any space it cannot rescue from; and the rule that if the department is unavailable, the employer’s entry does not proceed on the assumption the department will come. The performance test is the one regulators use for rescue service evaluation: timely response, the equipment and training for the specific space, and practice in representative spaces at least annually (OSHA, n.d.-c, 29 C.F.R. § 1910.146(k)). Contracted standby: where the department provides a standby rescue team at an employer’s site for a fee or by agreement, that work is fully regulated non-emergency work: the entry program in 5.3 applies, the department’s team is at the portal before the entry begins, and the crew is relieved from response unless the agreement says otherwise. Evidence. Signed agreements; drill records in client spaces; response time measurements. Stage. S2; S1 if the department already holds that status for anyone.

Requirement. Every instrument used to decide whether a person enters is bump tested before use, calibrated at the manufacturer’s interval, and its records kept.

Minimum method. Instruments matched to the hazards of the district (oxygen, LEL, carbon monoxide, hydrogen sulphide as the four-gas minimum; hydrogen cyanide, ammonia, chlorine, volatile organics where pre-plans call for them); bump test before every use and at least daily when in service; calibration at the manufacturer’s interval, commonly not exceeding 30 days (MLITSD, n.d., GN 6-51); sensor life tracked and sensors replaced on failure or expiry; calibration gas in date; records of every bump and calibration (section 17.3); instruments that fail a bump test tagged out. Members who test atmospheres are trained on the specific instrument, its lag time, pump and tubing delay, and sensor cross-sensitivities. Evidence. The monitoring log; calibration records; training records. Stage. S1.

Requirement. Every entrant can talk to the attendant and the attendant to the rescue team and command at all times. Minimum method. Primary and back-up methods named on the permit (voice, hard-line intercom, intrinsically safe radio, line signals); tested before entry; the evacuation signal known to everyone; radio channels assigned by command; a communications failure is an evacuation trigger. Stage. S1.

(a) Work-as-done. Before the entry or rescue procedure is written or changed, the learning team describes: how crews actually size up a confined space call with a civilian down and a family member shouting; what information is really available at the portal in the first five minutes; how long it really takes to rig a tripod and dress an entry team on supplied air, with the crew that normally arrives; how training entries at the station are done now (and whether a permit has ever been written for one); which spaces in the district have been entered before and how; how instruments are bumped on a busy morning; and what the crew does when the on-site people say “we tested it, it’s fine”.

(b) Capacity and margins. This work goes right because crews have been drilled to stop at the portal, because the attendant role is respected, because instruments are maintained, and because the rescue team arrives with air and retrieval. The margin erodes with a patient visibly alive and pleading, bystanders already inside, a short crew that cannot staff entry, back-up, attendant and supervisor at once, instruments with dead sensors, long tubing runs that hide a bad reading, and daytime volunteer response that puts the first-arriving members far from the rescue unit. The program protects the margin by making non-entry the default, by requiring the back-up team before entry, by naming the attendant first at every drill, by staffing the gas detection program, and by writing pre-plans that tell the first crew what the space is before they arrive.

(c) Just culture. A member who moved toward the portal too early, or who relied on a reading taken by someone else, is not the problem; the pull of a live patient and the gaps in information are. Those moments are described in the AAR and go to the learning team. The learning firewall applies to every debrief, learning team, near-miss report and review; none of it is used for discipline. Conduct concerns go to a separate process run by different people (Incident Investigation and Learning Program; The Human Factor, 2026a).

(d) Psychological safety. Anyone at a confined space incident or a training entry can say the hazard and the action: “Stop, nobody goes in, the meter is in alarm.” The rescue group supervisor and the incident commander acknowledge, hold, and review it later. Members are expected to question a reading, a lockout, or an order to enter, and officers answer with the reason or change the plan. Leaders show it is safe by rehearsing the stop call in every drill, by thanking the member who held the portal in the hot debrief, and by reporting their own near misses. A member’s concern about this program (an instrument, a space nobody listed, a client agreement that feels unsafe) goes to the company officer, the rescue team lead, the JOHSC consultant or the near-miss system and gets an answer within 15 days (section 11).

(e) Learning link. Every confined space response and every training entry gets a Tier 1 After-Action Review. Any entry made without a complete permit, any instrument alarm during entry, any entry rescue, and any near miss with potential for death goes to Tier 2 Post-Incident Analysis. A death or critical injury is Tier 3 Independent Learning Review (The Human Factor, 2026a). Crew AAR questions: What did we know about the atmosphere when the first member reached the portal, and how did we know it? Who was the attendant, and when was that decided? What nearly pulled someone inside before we were ready? Full method: Incident Investigation and Learning Program and Manual 02 - The Three Tiers and Event Triage.

Sign-off template in section 17.7.

• SWP - Confined Space Entry and Rescue
• SWP - Lockout and Shop Safety (shared with Facilities and Station Safety Program; the isolation step)
• SWP - SCBA Donning, Use and Air Management (owned by Respiratory Protection Program; the supplied-air rules)
• SWP - Rope Rescue Systems Rigging and Inspection (owned by Rope Rescue Program; vertical entries)

• Form - Confined Space Entry Permit
• Confined space inventory (17.1); entry log (17.2); atmospheric monitoring log (17.3); rescue pre-plan template (17.4); designated rescue service agreement template (17.5); capability matrix (17.6); training tracker (17.7); quarterly indicator worksheet (17.8)
• Retention: permits for the period the jurisdiction sets (J17 Confined Space; commonly 12 months) and longer for any entry with an incident; instrument records for two years; training records for the member’s service plus the period in 05 Document Control and Records; agreements for their term plus seven years.

Loop test. A firefighter reports on Monday that the four-gas meter on the rescue unit failed its bump test twice last week and was put back in service anyway. By the end of that shift the meter is tagged out and replaced from spares, the item is in the register as a P1 with the rescue team lead as owner, and the fire chief and JOHSC co-chairs have been told. By Friday the bump record of every meter has been checked, the P1 item is closed with evidence, and the firefighter has heard back; a P3 item stays open for the workflow. Within 30 days the learning team has met the crews who use the meters, the bump-test workflow is redesigned (station, calibration gas, spare meters, who signs), the change notice goes to every station, and the quarterly update reports it closed with the bump-compliance indicator attached.

Checklist: Checklist - Confined Space, Trench and Rope Rescue. The five questions first:

1. Show me the written service level and the roster that proves you can staff it at 2 p.m. on a Tuesday.
2. Show me the confined space inventory for this station and the permit for the last entry into any of those spaces.
3. Pick a rescue team member: show me their last retraining date and the last timed drill.
4. Show me this meter’s bump record for the last week and its last calibration.
5. Show me the signed agreement with the last employer that named you as its rescue service, and the drill in their space. And when did a member last refuse to enter, and what happened to them?

Accreditation crosswalk. The service level declaration, capability matrix and annual program appraisal are the evidence for the technical rescue criterion (deployment objectives by risk type and level, partner aid for gaps, annual appraisal), and the hazard reporting, inventory and corrective action records serve the occupational health and safety criterion (CPSE, 2019, criteria 5G.1, 5G.2, 11A.1, 11A.2, 11A.3).

Generic patterns from confined space fatality investigations (CSA Z1006:23; NIOSH, n.d.-b) this program answers:

• Multiple-fatality would-be-rescuer events in manure pits, sewers and tanks: co-workers and family enter first; responders enter without monitoring or supplied air. Controlled by 5.4 (non-entry first, nobody enters without air, monitoring and a line) and the awareness training of every member.
• Atmosphere tested once and then changed; no continuous monitoring; instrument not bumped. Controlled by 5.3 step 4, 5.7.
• Non-intrinsically-safe equipment in flammable atmospheres. Controlled by 5.3 step 11.
• Retrieval line fouled on obstructions; tripod not rated; harness attached at the wrong point. Controlled by 5.3 step 10 and the drill program.
• Department accepts designated rescue service status without drills in the actual spaces or a realistic response time. Controlled by 5.6.
• Task outside trained scope (the recurring Canadian theme in 05 Design Principles and Lessons Learned). Controlled by 5.1 and the service-level-matched-to-capacity indicator.

Stage 1 minimum. The service level declaration (5.1); the station and shop inventory with signage (5.2); the entry procedure and permit for every non-emergency entry (5.3); the rescue procedure at the declared level (5.4); the exemption position in writing (5.5); any existing client agreement brought under 5.6; a working gas detection program (5.7); awareness training for every member and rescuer retraining on the provincial interval (6); one learning-team session on the first five minutes at the portal; the accountability loop (11).

Cost note. People: program manager and team about four hours a month; rescue team drills (quarterly, half a day); instrument custodian (two hours a week). Money: four-gas detectors with pumps for every rescue unit and first-due engine in districts with pre-planned spaces, calibration gas and docking stations; one rated tripod or davit with winch per rescue unit; supplied-air respirators with escape cylinders for the entry and back-up teams if the department declares technician; intrinsically safe lighting and radios; the annual manufacturer inspection of retrieval devices. A department that declares awareness needs the inventory, the training, a meter on the first-due unit and the mutual aid agreement.

This chapter relies on the following legal requirements, which differ by province and territory. Check your jurisdiction’s section on each topic page before adopting it.

1. Parties, term, review date, termination.
2. Spaces covered (listed by site and ID) and the employer’s hazard assessment for each, attached.
3. The department’s declared level for each space and the spaces it declines.
4. Measured response time from dispatch to rescue-ready at the portal, by time of day, and the employer’s acknowledgement.
5. The employer’s obligations before every entry: its own compliant entry program and permit; an attendant; retrieval line on every entrant; isolation confirmed; atmospheric data available at the portal; site contact who knows the space; notification to the department where practicable.
6. The department’s right to drill in the actual spaces at least annually, to decline any space, and to be unavailable when committed to emergencies; the employer’s entries do not proceed on the assumption of availability.
7. Contracted standby (if any): staffing, fees, team at the portal before entry, relief from response.
8. Records each party keeps; incident review participation; learning firewall.
9. Signatures (roles only): fire chief; employer’s senior manager; JOHSC consulted (date).

National Institute for Occupational Safety and Health [NIOSH]. (n.d.-b). Fire Fighter Fatality Investigation and Prevention Program [Program website and investigation reports]. Centers for Disease Control and Prevention. https://www.cdc.gov/niosh/firefighters/fffipp/index.html

Occupational Safety and Health Administration [OSHA]. (n.d.-c). Permit-required confined spaces (29 C.F.R. § 1910.146). U.S. Department of Labor. https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.146

Ontario Ministry of Labour, Immigration, Training and Skills Development [MLITSD]. (n.d.). Firefighter guidance notes (Section 21 Advisory Committee; individual notes revised to 2026). https://www.ontario.ca/document/firefighter-guidance-notes