Confined Space Working
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IN THIS ISSUE |
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WELCOME |
You may be one of those people who cannot work in confined spaces, because you find the sense of claustrophobia overwhelming. On the other hand it may not trouble you at all.
Claustrophobia in confined spaces, however, is not the main concern of health and safety. It’s more to do with the hidden risks that lurk in places were there is a lack of adequate ventilation or where access and egress are difficult – things like reduced oxygen levels, build up of noxious gases, sudden and rapid flooding, build up of heat, presence of explosive gases and other things.
Part of the problem is that circumstances can change in unexpected ways between places that are superficially similar or in the same place over a period of time. It’s this ‘uncertainty’ aspect that is the subject of our current newsletter.
Perhaps you think that confined space working doesn’t affect you but then you may be wrong. You see a confined space doesn’t have to be physically small. An enclosed place of any size – even for example as big as a grain silo – may be a confined space if certain risks are present.
As demonstrated by this month’s example under Case Law, it’s easy to become complacent but that can prove very expensive in the long run. It’s much better to get the right advice now.
David Skews, (CEO)
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CONFINED SPACE WORKING |
What Exactly is Confined Space Working
Working in confined spaces isn’t everyone’s favourite topic but it’s one that needs to be aired from time to time (please forgive the poor pun).
When confined spaces are mentioned, most people imagine a space that is perhaps difficult to access or where, once you are in, it is difficult to manoeuvre. Such places may indeed be confined spaces in the sense of health and safety, but not necessarily so. The reverse may be true that a large roomy area could be designated as a confined space if certain types of risk are present.
The definition of “Confined Space” is more concerned with the level of risk to someone who is working there than its location or physical dimensions. A couple of examples may help to clarify:
- A large environmentally controlled room such as is used to house computer equipment, may be designated as a confined space if there is the possibility of asphyxiation due to flooding with an inert gas to extinguish a fire.
- On the other hand, a workman may need to squirm into the narrow space beneath a suspended floor but this would not be considered a confined space if there were no identifiable risks to health and safety.
A confined space, therefore, is one in which there is a reasonably foreseeable risk to someone by virtue of working there, or to quote the definition from the Confined Space Regulations:
"Confined Space means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk”.
It is worth noting that although this definition refers to an “enclosed space”, this does not mean that the space must be totally enclosed. Such examples as a “pit”, a “trench” and a “well” are included, all of which might be open to the sky.
What Are Your Responsibilities?
These examples demonstrate that people may be exposed to the risks of confined space working without ever realising it. Employers, however, have a duty to be aware and should have conducted risk assessments and put appropriate precautions in place.
Very briefly, those precautions should include:
- Ensuring there is no practical alternative for completing the work other than for a person to enter the confined space.
- Persons entering, leaving and working in the space must do so in accordance with a System of Work that is designed to render the work free of risk as far as is reasonably practicable
- Emergency arrangements must be in place to rescue and, if necessary, resuscitate workers who find themselves in difficulty. Such arrangements should not in themselves expose others to risk.
In practical terms, the precautions might take the form of training for those who are to carry out the work, equipment to monitor air quality, rescue and resuscitation equipment etc.
Tackling Complacency
One of the difficulties faced by employers who have the welfare of their workers at heart is that of complacency. The better the safety precautions, the less likely it is that something will go wrong and that can lead to the assumption that nothing ever will go wrong – a recipe for tempting fate if ever there was one.
Complacency can result in unrealistic ideas about one’s own invulnerability. It can lead to potentially dangerous shortcuts and being less rigorous about vital checks. In fact, the lack of accidents in the past can become a contributory factor to accidents in the future.
So what can be done to counter the problem of complacency? An actual accident is an effective stimulus but not one to be welcomed.
The alternative is a regular programme of training and exercises that is backed up by an enforcer who is ‘paranoid’ about safety. It is essential that every employee is fully conversant with the safety equipment – not only how to switch it on and off but they must also be completely familiar with the alarm signals from monitoring equipment, for example. Films or videos with visual shock tactics may also be used to drive home the horror of what could happen if proper precautions are ignored.
Equipment that may never have been used in anger must still be well maintained and thoroughly tested on a routine basis.
Procedures need to be tested to ensure they continue to operate as intended, even when changes have occurred to the environment in which they are designed to operate. Testing exercises should be as realistic as possible in the same way that we have regular fire drills.
“Learning the hard way” is not an option. Success should not be measured by how well the organisation responds to a real disaster. Instead, it should be measured by the less exciting statistic of having no incidents to report – ever!
Have you identified risks associated with confined space working in your organisation? If not, then now is the time to assess the risks and introduce appropriate precautions before you are faced with the consequences of a serious accident. EDP have specialists who are able to guide you on exactly what is required.
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CASE LAW |
Failure to take adequate precautions for confined space working resulted in a particularly tragic fatality for two employees of a marine and engineering company in Suffolk.
Two employees of the company – a man and his stepfather - were inspecting the construction of a disused admiralty submersible pontoon (ballast tank). Oxygen levels within the tank were depleted due to rusting that had been going on for years.
The elder man entered and was overcome by the poor air quality. It is believed that the younger man entered the tank in an attempted rescue bid but also lost his life.
No risk assessment had been carried out and neither of the men had been properly trained for confined space working. They just didn’t appreciate the risks they were running by entering the tank.
The engineering company and the owner of the tank were both found guilty and between them were fined a total of £125,000 with £60,000 in costs. That isn’t a lot for the loss of two men’s lives. However, with a little forethought, the company could have spent much less on the right precautions and avoided the needless loss of life.
You can read details of the case on the HSE website
If you have doubts about the safety of your business activities, you need to call us in, using the contact details at the end of this newsletter.
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LEGAL MONITOR |
October is one of the two months in the year favoured by the HSE for introducing new and amended legislation (the other being April).
Electricity Regulations
Next month, therefore, an amendment to the Electricity Safety, Quality and Continuity Regulations comes into force. Coverage of the regulations are to be extended to include tramways and other guided transport.
Fire Safety
You may not be affected by the electrical regulations but you will certainly be affected by the other big change which is the Regulatory Reform (Fire Safety) Order. The aim of this change is to move towards greater emphasis on fire prevention in all non-domestic premises. Fire certificates will be abolished and will cease to have any legal status.
We alerted our readers to these proposals as long ago as our July 2004 newsletter and wrote at greater length in July 2005. Now it is crunch time.
If you haven’t made any preparations for this significant change, then you have no time to lose. In most cases, if your fire safety precautions have been up to standard in the past then you probably don’t have much work to do.
However, if you are unsure about your compliance, it’s time to bring in some professional help. Give us a call on 08456 44 53 52.
View more anticipated legal changes. Then decide if they affect you and what changes you need to make by way of preparation.
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David Skews, (CEO)
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EDP Health Safety & Environment Consultants Ltd
Lakeside, Alexandra Park, Prescot Road, St. Helens, Merseyside, UK
Telephone: 08456 44 53 52
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