Building code requirement are mainly occupancy based. Some basic examples are smoke alarms required to awake sleeping occupants (Group C) and panic door hardware for larger crowds (Group A2). Occupancies less familiar with their space (Group A2) have more restrictive egress and exit requirements and there are some relaxations for occupants who are familiar with their suite (Groups C and D). Building code revisions always aim to improve safety for occupants…but one group that tends to get shortchanged are the maintenance and service workers. Service spaces, such as crawl spaces or attics, create unnecessary hazards for maintenance workers.
Service Spaces
Service spaces have specific code requirements for egress, exit, fire separations, fire alarms, sprinklers, exit signage and emergency lighting, however these are not always applied. The City of Regina has a great advisory highlighting the major code requirements that should be considered for crawl spaces and attic spaces here.
The egress and exit requirements of service spaces are similar to the less restrictive major occupancies such as low hazard industrial (Group F3) or business and personal services (Group D), but the logistics of physically leaving a service space are not as straightforward. Service spaces are meant for installing or maintaining building equipment and can contain gas and plumbing pipes, ventilation ducts, electrical conduits, air handlers, water tanks and unfortunately are often used incorrectly as storage spaces. All of this equipment can create cramped spaces for workers to navigate through, which is especially difficult if they are also poorly lit. Crawl spaces can also be so low in height that workers must crouch or be without a proper floor requiring balancing on cat walks. Service spaces are also permitted to have an access hatch instead of a typical door. Crawl spaces require at least one access opening not less than 550 mm by 900 mm (NBCC 3.6.4.6.). In short, leaving a service space is not as simple as just walking out.
Crawl Spaces Defined
Crawl space is not a defined term in the NBCC; however, many horizontal service spaces are considered a crawl space. A crawl space must be considered a basement if it is more than 1.8 m high, used for any occupancy, used for the passage of flue pipes or used as a plenum in combustible construction (NBCC 3.2.2.9.).
A confined space is defined by most Occupational Health and Safety (OH&S) regulations as “an enclosed or partially enclosed space that 1) is not primarily designed or intended for human occupancy, and 2) have restricted means of entrance and exit” (Ref 1). The design of many crawl spaces requires them to be considered as confined spaces.
Hazards in Crawl Spaces
Workers are exposed to a variety of hazards in crawl spaces including, but not limited to: falls (ladders), environmental (rodent poison control, mold, poor air quality), restricted access/egress, inadequate working space and inadequate lighting.
OH&S
OH&S legislation exists in each province and territory. This legislation is designed to keep workers healthy and safe while on the job. Countless accidents are reported for workers in crawl spaces ranging from falls off ladders to hazardous air quality (Ref 2). Fortunately, when OH&S procedures are followed, workers safely enter and exit crawl spaces every day. However, anyone who has entered a crawl space would agree that the restrictive working conditions make the job significantly harder and increases the risk of injury.
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Confined Space Entry
Confined space entry requires training and planning. Workers accessing the space are required to successfully complete confined space safety training. All hazards the workers may be exposed to in the space must be thoroughly assessed and a safe entry and work plan must be developed and documented. A rescue plan must be developed and documented and a rescue team must be trained and familiar with the specific crawl space. While in the space, communication and/or check-ins must be considered requiring additional staff to be present outside of the space. If a worker is injured in the space and cannot exit on their own, the rescue team will be required. Personal Protective Equipment (PPE) in a confined space typically consists of a rescue harness, steel toed boots, hard hat and air quality measuring equipment.
Mitigating Risk
The first method of reducing risk is to remove the hazard. Can a full basement, storey or service room with standard egress and exits be accommodated in place of a crawl space? If the crawl space hazard cannot be removed, such as in an existing building, can it be improved by better design during a renovation? Can lighting be added to the crawl space eliminating the requirements for headlamps/flashlights? Can permanent ventilation be installed to ensure air quality is safe and therefore testing equipment does not need to be carried? The main reason crawl spaces are considered confined space is the limited means of egress. If the crawl space already exists, can proper exits (doors) be created to remove the “restricted means of egress” (access hatch) component?
The Bottom Line
Small service spaces are cheaper to build than a basement or service rooms. This lower upfront cost results in increased maintenance costs over the lifespan of the building. Construction, maintenance and repair work in confined spaces takes significantly longer to complete and requires additional staff and specialized safety training compared to the same work in spaces not considered as confined spaces.
Consultation with building maintenance representatives and review of applicable OH&S requirements in pre-design helps to identify and understand the specific restrictions the design is creating for construction and maintenance workers.
Thoughtful design can eliminate unnecessary risk.
References
1. Government of Saskatchewan. The Occupational Health and Safety Regulations, 1996. April 30, 2003.
2. United States, Department of Labour. Occupational safety and Health Administration. Accident Report Details. Available at https://www.osha.gov/pls/imis/accidentsearch.accident_detail?id=200783926. Accessed February 20, 2020.
