Working in a confined space is dangerous because of the presence of noxious fumes, reduced oxygen levels, fire, flooding or the risk of asphyxiation from some other source such as dust, grain or other contaminant.
Some confined spaces are easy to identify, such as sewers and closed tanks used to store chemicals. However, some are less straightforward. A confined space is not always enclosed on all sides – some may have open tops or sides (vats, silos and ships’ holds). Some may be small and/or difficult to work in, some can be very large or difficult to get in or out of. Some have several entrances/exits; others have quite large openings or are apparently easy to escape from. Some (such as those used for spray painting in car repair centres) are used regularly by people in the course of their work.
The regulations and an approved code of practice, L101, must also be considered before attempting to enter a confined space and emphasises the importance of understanding the environment as well as providing staff with an attainable method of completing the work in a safe way.
The regulations contain three key duties: avoid entry to confined spaces by doing the work from the outside, if entry to a confined space is unavoidable, follow a safe system of work; ensure adequate emergency arrangements are put in place before the work starts.
The ‘Management of Health and Safety at Work Regulations 1999’ requires employers and the self-employed to carry out a ‘suitable and sufficient’ assessment of the risks of work activities to decide what safety measures are necessary. For confined spaces, this means identifying any hazards that are present, assessing the risks and determining what precautions to take.
The first step would be to identify whether the space is hazardous before entry, and if there is a reasonably foreseeable risk of hazards that could arise during the completion of the work.
APPLYING THE RULES
The status of a space, as well as the risks, can alter depending on circumstances; for example, heavy rain may present a foreseeable risk of drowning in a space not usually considered confined. The space may be defined as confined because of the work being carried out in it, and may cease to be confined when the ‘specified risk’ is removed and the atmosphere tested as safe. For example, if the specified risk is due to fumes when cleaning with chemicals, the space may cease to be confined when the fumes have been removed by ventilation. Actions taken to mitigate a risk should be continuously monitored throughout the task to ensure they are effective.
A permit-to-work system is required where there is a reasonably foreseeable risk of serious injury in entering or working in a confined space. This is a formal recorded process used to control work which is identified as potentially hazardous. It provides certain people with the authority to carry out specific work within a time frame, describes what work needs to be undertaken and – based on a risk assessment – sets out the precautions required to complete the work safely.
Some employers may decide that where any identified risks can be easily controlled, or where the work system is very simple, they will not use a permit-to-work system. However, this decision should be taken by a competent, trained person. Other employers might make the decision that any and all work carried out in confined spaces presents a reasonably foreseeable risk of injury and so have a policy that a permit-to-work is always required for confined space work.
Permit-to-work systems are usually accompanied by a method statement describing how the work will be done. Method statements may take account of risks identified by the risk assessment and communicate the safe system of work to those carrying it out, especially for higher-risk complex or unusual work (for example, steel and formwork erection, demolition or the use of hazardous substances).
A method statement brings together the information compiled about the various hazards and the ways in which they are to be controlled for any job from the conclusions of the risk assessments. It takes account of a company’s health and safety organisation and training procedures, and may include arrangements to deal with serious or imminent danger. It effectively describes, in sequence, how a job should be carried out in a way that secures health and safety and includes all the control measures.
This will enable the job to be planned with appropriate health and safety resources. It can also provide information for other contractors working at the site.
As a formal record, it also requires declarations from those authorising the work, those carrying out the work, and those involved in shift handover or extensions to the work.
Serious consequences can occur for any business that fails to properly protect its workforce and ignores the regulations, especially with the introduction of tougher sentencing guidelines in 2016.
It is therefore crucial to follow the regulations, conduct a full risk assessment and consider all the potential hazards that workers may face – such as correct monitoring, ventilation, access to trained personnel and the correct maintained equipment – before taking action to ensure all safety precautions are in place before any entry.
BOX: CONFINED SPACE RISKS
Specified risks are categorised where the following may occur:
- serious injury to any person at work arising from a fire or explosion
- the loss of consciousness of any person at work arising from an increase in body temperature
- loss of consciousness or asphyxiation of any person at work arising from gas, fume, vapour, or the lack of oxygen
- drowning arising from an increase in the level of a liquid
- asphyxiation arising from a free flowing solid or the inability to reach a respirable environment due to entrapment by a free-flowing solid.
BOX: ESSENTIAL FEATURES OF PERMIT-TO-WORK SYSTEMS
While each organisation decides on its own formatting, essential features include:
- Clear identification of who may authorise particular jobs and who is responsible for specifying the precautions to be taken
- Training and instruction in the issue, use and closure of the permit
- Monitoring and auditing to ensure the system works as intended
- Clear identification of the types of work considered hazardous
- Clear identification of the work to be carried out
- Time limits on entry and permitted task duration
- Risk assessments
- Supplemental or simultaneous activity and control measures
- Supervision requirements
- The level of competency and training required by the entrant, topman and supervisor
- Specifying the communications system that will be used
- Rescue plan