A few years back I worked at an oil refinery, we were all (refinery wide training due to an accident that killed 4 and injured 1 maintenance workers) given classes in Confined Space Entry. During the training we were asked to give examples of a confined space, and I said "The waist water treatment ponds". I was told that those ponds were not confined space. Yet they are clearly areas of limited egress, a person could be completely engulfed, contained operating equipment and there was no MSDS for the fluid contained in the space (pond).
These ponds received all of the effluent from the refinery sewer system. It included fecal material and plant process runoff from leaks, overflows, wash downs and rain.
I tried for several months to argue that it was a confined space and that there should be a written procedure for electrical maintenance of the aerator motors (480V 3phase up to 5hp). Typical maintenance required an electrician to maneuver a dinghy out to the faulty motor by lifting the mooring cables of the other aerators over the boat and then after disconnecting the motor from its cord connection, and lashing the pontoon to his boat, make a return trip this time lifting the mooring cables over the boat and the aerator. (This required him to stand up in the boat and to come into physical contact with the fluid in the pond).
At the end of a very lengthy discussion it was decided that the current method was adequate and that it was not a confined space so no formal procedure was necessary.
Realizing that the safety culture would not change I decided to change employeers. But to this day I think about the accident and the reluctance of that plant to begin to take action concerning unsafe conditions.
