Policy - Confined Space

Format. Adopt as a policy approved by the fire chief (or the council or board where the municipality’s framework requires it), or restate as a standard operating guideline or directive. Keep the numbering either way, because the program, the procedure, the permit and the audit checklist refer to it.

Drafting conventions. Shall is mandatory. Should is expected unless a documented reason exists. May is permitted. Placeholders in double curly braces, such as {{Department}}, are completed by the department. Drafting notes sit in callouts and are removed before adoption.

Keep intact. The rule that the declared service level matches measured capacity (5.1.2); the full permit process for every planned entry, training included (5.3); the monitoring and action levels (5.3.4); the attendant-never-enters and nobody-enters-alone rules (5.3.5, 5.4.3); non-entry first (5.4.2); the limits on the firefighter exemption (5.5); the agreement-before-status rule for other employers (5.6); and the speak-up and learning firewall clauses (4(e) to 4(h), 5.10). Adapt the declared level, the instruments, the titles, the records system and the action levels, which may be made stricter and never looser.

1.1 To state {{Department}}’s commitment that no member enters a confined space without the assessment, isolation, atmospheric monitoring, air, retrieval, attendant and rescue capability the entry needs; that the department declares only the confined space rescue it can staff and equip at its weakest hour, and delivers it; and that every entry, real or training, leaves a record.

1.2 To assign accountability for that commitment to the line: the health and safety officer verifies it, and the joint occupational health and safety committee is consulted at each step.

2.1 This policy applies to every member of {{Department}}, career, volunteer and paid-on-call, including recruits and instructors, and to mutual aid members operating under the department’s command.

2.2 It applies to: (a) confined spaces in department workplaces, including stations, shops, training grounds and vessels; (b) every planned entry by a member, including training entries into props and real spaces, maintenance and inspection entries, and contracted standby; (c) emergency confined space rescue at the declared level; and (d) the department’s role as a designated rescue service for other employers.

2.3 Every member holds the awareness-level duties in 5.4.1, whatever level the department declares.

2.4 Exclusions: entries into trenches and excavations, which Trench and Structural Collapse Rescue Program governs, although the monitoring rules in 5.3.4 apply there too; hazardous materials entries, which Hazardous Materials, CBRN and Energy Hazards Program governs, except that a hazardous materials entry into a confined space meets both; and contractors entering confined spaces on department premises, who work under their own employer’s entry program, which must meet or exceed this policy (Policy - Contractors and Mutual Aid; Contractor and Mutual Aid Safety Program).

• Action level: an instrument reading at which a defined action is taken. The department’s action levels are stricter than the legal limits.
• Attendant: the competent person stationed outside the space who keeps the 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 a known gas to confirm that its sensors and alarms respond; it is not a calibration.
• Competent person: a person qualified by knowledge, training and experience to assess and certify a space, and familiar with the applicable law and the hazards.
• 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 (CSA Z1006:23).
• Designated rescue service: an outside rescue capability that an employer names in its own entry program.
• Entry: any part of the body passing through the opening of a confined space.
• Entry permit: the written, time-limited certification by a competent person that the space has been assessed and the conditions for entry are met, posted at the entrance (Form - Confined Space Entry Permit).
• IDLH: immediately dangerous to life or health. Every unknown atmosphere is treated as IDLH.
• Learning firewall: the rule that information gathered for learning is never used as the basis for discipline, and that conduct concerns are handled by a separate process run by different people (Incident Investigation and Learning Program; The Human Factor, 2026a).
• 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 a retrieval device operated from outside the space.
• Psychological safety: the shared belief that it is safe to speak up, ask, admit error and challenge (Edmondson, 1999)DOI.
• Service level: the written statement of which confined space rescue level the department provides: awareness, operations or technician (NFPA 2500, 2022).
• Standby rescue: a department rescue team placed at an employer’s space for a planned entry under an agreement.
• Work-as-done: how a task is actually performed under real conditions, as distinct from work-as-imagined (Hollnagel, 2014).

1. Non-entry first. The safest rescue is the one that needs nobody to go in. Many of the people who die in confined spaces went in to help someone else; CSA puts the share of would-be rescuers above half (CSA Z1006:23).

2. The atmosphere is unknown until it is measured, and it can change. Readings decide entry, monitoring continues during entry, and any alarm means everyone out.

3. Nobody enters alone, and the attendant never enters.

4. The department promises only what it can deliver at its weakest hour. A declared level that the weekday daytime roster cannot staff is a hazard to members and to the public.

5. People are the solution we build around, not the problem to fix. Members’ judgment, adaptations and reports are the program’s main source of safety; this policy supports that judgment rather than replacing it.

6. Procedures describe work as done, written with the people who do it. The entry and rescue procedures start from a learning-team description of how the work is really done and are revised with the crews who do it.

7. Learning comes before blame, and learning information is never used for discipline. Near-miss reports, after-action reviews, learning teams and post-incident analyses sit behind the learning firewall.

8. Psychological safety is a condition of safety, so speaking up is expected and protected. Any member may stop an entry or refuse to enter; the officer acknowledges, holds and reviews later; nobody is questioned for a concern raised in good faith.

5.1 Service level (S1). The department shall declare in writing, for each district, the confined space rescue level it provides (awareness, operations or technician) and the mutual aid, contracted or provincial capability it calls for any level it does not provide, with the call-out route recorded in dispatch. 5.1.1 The fire chief approves the declaration after consulting {{JOHSC}}, and it is reviewed with the annual program appraisal. 5.1.2 The declared level shall match measured capacity: where the department cannot field a full entry rescue team (entry team of two, back-up team of two, attendant and supervisor) within its response target at a given time of day, the declaration for those hours shall change. Accountable: the fire chief.

5.2 Department confined spaces (S1). Every confined space in a department workplace shall be identified, classified, entered in the inventory and signed at its opening, and spaces no member needs to enter shall be locked or barricaded and marked. 5.2.1 Members shall enter them only under 5.3. 5.2.2 The inventory is reviewed annually with facilities and {{JOHSC}}, and after any renovation or new building. Accountable: the health and safety officer with facilities; company officers for their stations.

5.3 Planned entries (S1). Every planned entry by a member, including every training entry, shall follow the full regulated entry process, and no emergency exemption applies to it. 5.3.1 A competent person shall assess the specific space and the specific entry, recording the hazards as they are, without the protection that PPE or ventilation would give. 5.3.2 Every energy source and every line that could introduce a product shall be isolated and locked out, and the isolation confirmed by test. 5.3.3 The space shall be purged and ventilated as the assessment requires. 5.3.4 The atmosphere shall be tested before entry at the top, middle and bottom of the space with a bump-tested, calibrated instrument and monitored continuously during the entry; no member shall enter unless oxygen is within the range the applicable regulation sets (J17 Confined Space), flammable gas is below 10 percent of the LEL and every contaminant is below its occupational exposure limit, and any alarm during an entry means everyone out. 5.3.5 An attendant shall be at the opening for the whole entry, in communication with every entrant, keeping the entry log, with the authority to order evacuation and start the rescue, and shall never enter. 5.3.6 A competent person shall complete the entry permit, valid for no longer than the regulated maximum, posted at the entrance and retained. 5.3.7 The rescue plan shall be written on the permit, and the retrieval system or the rescue team shall be ready before anyone enters. 5.3.8 Entrants shall wear a harness attached to a retrieval line wherever practicable, and positive-pressure SCBA or supplied air with an escape cylinder wherever oxygen is deficient, the atmosphere is unknown or a contaminant could exceed its limit. 5.3.9 Only battery, double-insulated or low-voltage tools and lighting shall be used, and intrinsically safe equipment wherever flammables are possible. Accountable: the officer or supervisor in charge of the entry; the competent person for 5.3.1 and 5.3.6.

5.4 Emergency rescue (S1 at the declared level). 5.4.1 Every member who arrives at a confined space emergency shall size up from outside, keep everyone, including the site’s workers, away from the opening, and call the resources the declaration names. 5.4.2 The atmosphere shall be monitored from outside first and treated as IDLH until readings show otherwise, and non-entry methods shall be used before any entry. 5.4.3 Entry rescue shall be made only by a trained entry team of two on supplied air with retrieval lines, with a back-up team of two dressed at the portal, an attendant, a rescue group supervisor, an incident safety officer and medical support in place. 5.4.4 Where flammable gas cannot be brought below the action level, members shall not enter; the incident becomes a recovery under a separate plan, and the incident commander records the decision and its time. Accountable: incident commanders; rescue group supervisors.

5.5 The firefighter exemption (S1). Where the applicable regulation relieves firefighters engaged in firefighting or rescue from the confined space entry provisions (J17 Confined Space), the department shall rely on that relief only for emergency rescue and structural firefighting, and only for members whose confined space entry and rescue training is current. 5.5.1 The department shall never rely on it for training, maintenance, inspection, planned or contracted standby entries, or any entry there is time to plan. 5.5.2 The relief does not relieve the general duty, the respiratory protection rules, the harness and SCBA rules for rescue entries, the written rescue procedures, or the standards the department has adopted. Accountable: the deputy chief, operations.

5.6 Designated rescue service and standby (S2; S1 where the department already holds that status). No employer shall name the department as its confined space rescue service until the two have signed an agreement. 5.6.1 The agreement shall state the spaces covered with the employer’s hazard assessment for each; the department’s declared level and the spaces it declines; the measured response time to a rescue-ready team at the portal; what the employer must have in place before every entry; the department’s right to drill in the actual spaces at least annually and to decline any space; and that the employer’s entries do not proceed on the assumption that the department is available. 5.6.2 Contracted standby is planned work under 5.3 in full, with the department’s team at the portal before the entry begins. 5.6.3 {{JOHSC}} is consulted on every agreement before it is signed. Accountable: the fire chief.

5.7 Gas detection and rescue equipment (S1). Every instrument used to decide whether a person enters shall be matched to the district’s hazards, bump tested before use and at least daily in service, calibrated at the manufacturer’s interval and recorded; an instrument that fails a bump test is tagged out. 5.7.1 Retrieval devices, rescue harnesses, rope and hardware, supplied-air equipment, ventilation fans and intrinsically safe lighting and radios shall be inspected before and after use and maintained on the manufacturer’s schedule, with rope and harnesses logged on Form - Rope and Rescue Equipment Log. Accountable: the program manager; the rescue team lead.

5.8 Pre-plans (S2). The department shall build rescue pre-plans with the owners of the high-risk confined spaces in its district (lift stations, water and wastewater plants, grain and feed facilities, marine terminals, tank farms and industrial spaces) and drill in those spaces. Accountable: the rescue team lead.

5.9 Training and competency (S1). Every operational member shall hold confined space awareness training. Entrants, attendants and rescuers shall be trained before their first entry and retrained on the intervals the applicable regulation sets; competent persons and atmospheric testers shall be assessed annually; rescue group supervisors and incident commanders shall be trained in confined space incident management; and the rescue team shall complete a timed drill in a representative space at least annually. A member whose training is not current does not enter. Accountable: the deputy chief responsible for training.

5.10 Reporting, learning and speaking up (S1). 5.10.1 Every confined space response and every training entry shall get an after-action review, and any entry without a complete permit, any instrument alarm during an entry, any entry rescue and any near miss with potential for death shall go to a post-incident analysis (Incident Investigation and Learning Program). 5.10.2 Any member may stop an entry by stating the hazard and the action; the officer or supervisor shall acknowledge, hold and review it later for learning. 5.10.3 Members are expected to question a reading, a lockout or an order to enter, and officers shall answer with the reason or change the plan. 5.10.4 Every member who raises a confined space concern shall receive an answer from the team lead within 15 days. 5.10.5 Learning information shall never be used as the basis for discipline; conduct concerns shall be handled by a separate process run by different people; and no member shall suffer reprisal for a report, a refusal to enter, a stop call or a concern raised in good faith. Accountable: the fire chief.

5.11 Program, consultation and review (S1; S3 for the independent review). The department shall maintain Confined Space Program as the written program this policy requires, review the written entry procedure at least annually, consult {{JOHSC}} on every safety-sensitive change before adoption, evaluate the program annually and have it independently reviewed every three years. Accountable: the fire chief.

Only the differences from 01 Roles and Responsibilities are stated here.

• Confined Space Program (FSSMS-PRG-15) with its implementation toolkit: inventory, entry log, monitoring log, pre-plan template, agreement clauses, capability matrix, training tracker and indicator worksheet.
• SWP - Confined Space Entry and Rescue; SWP - SCBA Donning, Use and Air Management for supplied-air rules; SWP - Rope Rescue Systems Rigging and Inspection for vertical entries; SWP - Mayday.
• The isolation step uses SWP - Lockout and Shop Safety, owned by Facilities and Station Safety Program.
• Forms: Form - Confined Space Entry Permit; Form - Rope and Rescue Equipment Log; Form - Fit Test Record.
• Audit: Checklist - Confined Space, Trench and Rope Rescue.

8.1 The records this policy creates are the service level declaration and capability matrix, the confined space inventory, permits and entry logs, atmospheric monitoring and calibration records, lockout records attached to permits, pre-plans, designated rescue service agreements, training records, drill records with times, incident and near-miss reports, the concern reply log, the quarterly updates and the annual appraisal. They are kept in {{Records system}} on the retention schedule in Confined Space Program section 10.

8.2 Permits are kept for at least the period the applicable regulation sets (J17 Confined Space) and longer for any entry involving an incident; agreements are kept for their term plus seven years.

8.3 Medical determinations for supplied-air use and for entry and rescue work are held by {{Occupational Health Provider}}; the department holds the outcome, the restriction and the dates, never a diagnosis.

8.4 Every record is written on the assumption that it may be disclosed under freedom-of-information legislation. Agreements with other employers may carry commercial terms; disclosure of those terms follows counsel’s advice. Near-miss reports, learning-team write-ups and post-incident analyses are de-identified before they are shared and are never placed in a personnel file.

9.1 To the fire chief: the quarterly indicator update; every entry rescue, every instrument alarm during an entry and every Tier 2 or Tier 3 event within 24 hours; the annual program appraisal; the corrective action register at management review.

9.2 To {{JOHSC}}: the quarterly update; the corrective action register monthly; every planned entry found without a complete permit; every proposed client agreement; every learning review outcome; the annual audit result.

9.3 To council or the governing board: confined space indicators and the service level declaration within the annual health and safety report (03 Accountability and Reporting).

9.4 To the regulator and the workers’ compensation board: as the applicable statute requires, including asphyxiation or poisoning of a member where the statute lists them (J08 Incident Reporting and Investigation).

11.1 The applicable occupational health and safety statute and regulations: the employer’s general duty (J02 Duties of Employers, Supervisors, Workers and Contractors); the confined space provisions (definition, written procedure, assessment, limits, certification, attendant, rescue equipment, respiratory and electrical rules, retraining intervals) and any firefighter exemption and its conditions (J17 Confined Space); the firefighter equipment rules for rescue entries (J12 Fire Service OHS Rules and Fireground Operations); fit testing (J14 Respiratory Protection, Fit Testing and Breathing Air); isolation and electrical safety (J19 Lockout, Machine Guarding and Electrical Safety); the duty to consult the committee (J05 Joint Committee and Health and Safety Representative; J06 Written Procedures and Committee Consultation); and reporting to the regulator (J08 Incident Reporting and Investigation).

11.2 CSA Z1006:23: the confined space management program, inventory, risk assessment of each space and entry, rescue plans and external service providers.

11.3 NFPA 2500 (2022): organizational levels for confined space search and rescue and hazard assessment of the response area. NFPA 1006 (2021, ch. 7): rescuer job performance requirements by level.

11.4 Respiratory protection: CSA Z94.4-18 through Respiratory Protection Program; SCBA to NFPA 1970 (2025). Technical rescue PPE to NFPA 1950 (2025).

11.5 NFPA 1550 (2024): the occupational safety and health program, incident management and the incident safety officer at rescue incidents.

11.6 The designated rescue service performance test (timely response, equipment and training for the specific space, annual practice in representative spaces) follows the rescue service evaluation criteria in the United States permit-space rule, used as a benchmark and not as law in Canada (OSHA, n.d.-c, 29 C.F.R. § 1910.146(k)).

11.7 Benchmarks adopted where the home jurisdiction is silent: written rescue procedures for confined spaces, which some jurisdictions’ firefighting rules require (J17 Confined Space); the limits of an emergency work exemption, and the full application of the confined space rules to contracted standby (MLITSD, n.d., GN 6-5); air monitoring practice (MLITSD, n.d., GN 6-51).

11.8 The duty of everyone who directs work to take reasonable steps to prevent bodily harm (Criminal Code [CA], 1985, s. 217.1) (01 Roles and Responsibilities).

11.9 Accreditation: technical rescue deployment objectives and annual appraisal, and the occupational health and safety program (CPSE, 2019, criteria CC 5G.1, CC 5G.2, 11A.1, 11A.2, 11A.3, CC 11A.5).

12.1 This policy is reviewed 12 months after adoption and every three years after that. The written entry procedure is reviewed at least annually under 5.11.

12.2 The policy is reviewed sooner after any confined space death, critical injury or Tier 2 event; after a change in the applicable regulation or a new edition of CSA Z1006, NFPA 2500 or NFPA 1006; on a written request of {{JOHSC}}; or when the annual audit or appraisal recommends it.

12.3 Every revision is consulted with {{JOHSC}}, {{Union}} and {{Volunteer Association}} before approval, and the consultation record is filed with the policy.

Consult early, before the policy is in final form, and put the outcome in writing. The committee and the bargaining agents will ask these questions; the honest answers follow.

Where the parties disagree, record the disagreement, adopt what can be adopted, and review at 12 months.

Disclaimer. This model policy is general information for the use of {{Department}} in building its own policy. It is not legal advice. The applicable statute, regulation and collective agreement govern on any conflict. Confirm every cited clause and section with counsel before adoption.

End of model policy.

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.

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