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Arcoservices > Work and Rescue Journal > Work and Rescue Journal: Identifying your confined space

Work and Rescue Journal: Identifying your confined space

Some spaces that I see in my day to day job are blatantly confined spaces and need no investigation to ascertain this fact, where as some are very tricky to identify and require a great deal of enquiry. 

There are two questions that you need to ask yourself.

Question one: Is the space an enclosed space?

Question Two: Is there a specified risk within the enclosed space?

The following article will look in to these two questions in greater depth whilst also identifying problems with recognising specified risks and introducing the idea of thinking of Confined Spaces more as Hazardous Spaces.

Question One: Is the space an enclosed space?
As the Approved Code of Practice and Guidance for Safe Work in Confined Spaces explains a confined space is not necessarily:

  1. Enclosed on all sides- some may have open tops or sides; I have worked in 9m pits which were open topped but had a gas main, under repair, running through the space, other examples could be deep bunded areas around silos and vats.
  2. Be small and/or difficult to work in – such as grain silos and underground water reservoirs
  3. Difficult to get in or out of – I once worked in a chamber in Croydon, London which was at least 50m deep and accessed via a normal metal staircase.
  4. A place where people do not regularly work- Some Confined Spaces have people working in them regularly such as vessel cleaners in food manufacturing.

Question Two: Is there a specified risk within the enclosed space?

This article will discuss these certain hazards that are referred to as ‘specified risks’ as six specified risks for simplicity, they are:

  1. Serious Injury to a person as a result of fire or explosion; and/or
  2. The loss of consciousness of any person because of the increase in their body’s temperature; and/or
  3. The loss of consciousness or asphyxiation of any person arising from gas, fumes, vapours or the lack of oxygen; and/or
  4. The drowning of any person arising from the increase in the level of liquid; and/or
  5. The asphyxiation of any person arising from a free flowing solid; and/or
  6. The inability of a person to reach a respirable environment due to entrapment by a free flowing solid.

If any of the above specified risks are present in an enclosed space, even if the specified risk is controlled, then the enclosed space is a confined space

Figure 1 Confined Space Tunnel Shaft inspection using rope access techniques © Arco Professional Safety Services
 

Problems with identifying a Confined Space

One of the most common errors that I find with the way in which someone identifies confined spaces is that they simply look inside an enclosed space and ask themselves whether the space has one of the above specified risks. Although this method will identify a good deal of confined spaces it will also overlook other confined spaces.

With greater knowledge and training people are starting to truly understand confined spaces but there is still some distance to go, recently a customer proudly announced to me that they had re-evaluated their confined spaces around the site and had ‘de-classified’ some of their spaces as they didn’t possess a specified risk and as a result these spaces were now no longer controlled access parts of the site. Throughout the day it came up in discussion that although most people who would enter the space would not be exposed to a specified risk there would be some people who don’t regularly enter the space but for whom when they did enter they would be carrying out work such as welding within the enclosed space, using solvents to clean the enclosed space or using compressed air and spades to blow out and dig out a build-up of flour or sugar.

Lesson= don’t forget that a place which is not usually considered to be a confined space could be classified as a confined space because of the nature of a job, if the conditions within or near to the space change. For example, imagine a small metal silo which has a safe level of air and is free from substances, contaminants, free flowing solids and liquids. It could become a confined space if we are carrying out remedial repairs such as:

  • welding (this could introduce gases such as high oxygen levels or acetylene which are combustible, would consume some of the oxygen levels and may increase body temperatures)
  • spraying solvents or chemicals to clean (this could introduce contaminants which could be toxic, flammable or could affect a respirable atmosphere)
  • painting the inside of the silo or applying other chemicals (This could introduce contaminants and could be toxic or flammable)
  • Making a dusty atmosphere (could result in the rapid combustion of fine combustible particles)
  • Replacing valves (Could result in the inadvertent release of chemicals, gases, liquids or free flowing solids)

The Approved Code of Practice and Guidance 2014 as published by the Health and Safety Executive offers this useful decision-making tool to simplify the identification of Confined Spaces (see Appendix 1).

When a space is identified as a confined space the Confined Space Regulations 1997 apply in full even if there are control measures in place to manage the specified risks.

Should we think of them as hazardous spaces instead?

Hypothetically it would be more suitable to call them hazardous spaces than confined spaces, picture this scene: you show someone the work site and say, “this is the confined space that the work will be taking place within”, their natural reaction is to judge the size and say “ahh…that’s not too small, it is plenty big enough”. The risk with this scenario is that the true, potentially, dangerous nature of the space is overlooked and misunderstood for the duration of the work.

Instead if we were to show someone the ‘hazardous space’ that the work will be taking place within, their question should be “why is it hazardous? what is wrong with the space”. This starts the conversation that is needed to understand the nature of the space, thus keeping the awareness of the hazard in the minds of those involved in the work.

So why are hazardous spaces called confined spaces?

The answer to this is quite simple and lies within the first requirement for identifying confined spaces, “is the space an enclosed space?”. A petrol station has the risk of an explosive atmosphere, the reason it isn’t a confined space is simply because it doesn’t have any sides. Therefore, the specified risk is not confined to the area in which is resides. So, if petrol stations did have walls and you drove through a vehicle size opening, would it be a confined space?

 

Further Reading

“Under domestic law (the Health and Safety at Work etc Act 1974) employers are responsible for ensuring the safety of their employees and others. This responsibility is reinforced by regulations.

These regulations contain the following key duties:

  • avoid entry to confined spaces, e.g. by doing the work from the outside;
  • if entry to a confined space is unavoidable, follow a safe system of work; and
  • put in place adequate emergency arrangements before the work start

The Management of Health and Safety at Work Regulations 1999 [2]
Require employers and self-employed people to carry out a suitable and sufficient assessment of the risks for all work activities for the purpose of deciding what measures are necessary for safety. For work in confined spaces this means identifying the hazards present, assessing the risks and determining what precautions to take.” Health and Safety Executive http://www.hse.gov.uk/confinedspace/legislation.htm

Appendices

Appendix 1: HSE Decision-making tool