Safety Brief: Confined Spaces

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1 Safety Brief: Confined Spaces What is a Confined Space? It can be any space of an enclosed nature where there is a risk of death or serious injury from hazardous substances or dangerous conditions (e.g. lack of oxygen). Some confined spaces are fairly easy to identify, e.g. enclosures with limited openings: Storage tanks; Silos; Reaction vessels; Enclosed drains; Sewers. Others may be less obvious, but can be equally dangerous, for example: Open-topped chambers; Vats; Combustion chambers in furnaces etc; Ductwork; Unventilated or poorly ventilated rooms. It is not possible to provide a comprehensive list of confined spaces. Some places may become confined spaces when work is carried out, or during their construction, fabrication or subsequent modification

2 How does it affect me? Dangers can arise in confined spaces because of: A lack of oxygen. This can occur: Where there is a reaction between some soils and the oxygen in the atmosphere; Following the action of groundwater on chalk and limestone which can produce carbon dioxide and displace Normal air; In ships holds, freight containers, lorries etc as a result of the cargo reacting With oxygen inside the space; Inside steel tanks and vessels when rust forms. Poisonous gas, fume or vapour. These can: Build-up in sewers and manholes and in pits connected to the system; Enter tanks or vessels from connecting pipes; Leak into trenches and pits in contaminated land, such as old refuse tips and old gas works. Liquids and solids, which can suddenly fill the space, or release gases into it, when disturbed. Free flowing solids such as grain can also partially solidify or bridge in silos causing blockages, which can collapse unexpectedly. Fire and explosions (e.g. from flammable vapours, excess oxygen etc). Residues left in tanks, vessels etc, or remaining on internal surfaces which can Give off gas, fume or vapour. Dust may be present in high concentrations, e.g. in flour silos. Hot conditions leading to a dangerous increase in body temperature. Some of the above conditions may already be present in the confined space. However, some may arise through the work being carried out, or because of ineffective isolation of plant nearby, e.g. leakage from a pipe connected to the confined space. The enclosure and working space may increase other dangers arising through the work being carried out, for example: Machinery being used may require special precautions, such as provision of dust extraction for a portable grinder, or special precautions against electric shock; Gas, fume or vapour can arise from welding, or by use of volatile and often flammable solvents, adhesives etc; If access to the space is through a restricted entrance, such as a manhole, escape or rescue in an emergency will be more difficult (see Emergency procedures). What is the Legal Duty on you?

3 You must 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 (The Management of Health and Safety at Work Regulations 1999, regulation 3). For work in confined spaces this means identifying the hazards present, assessing the risks and determining what precautions to take. In most cases the assessment will include consideration of: The task; The working environment; Working materials and tools; The suitability of those carrying out the task; Arrangements for emergency rescue. HSE s free leaflet 'Five steps to risk assessment will help you further. You may need to appoint competent people to help manage the risks and ensure that employees are adequately trained and instructed (The Management of Health and Safety at Work Regulations 1999, regulation 7). Of course, you may be the best person to do this, however, you may need to train someone else or engage the services of a competent person for additional help. If your assessment identifies risks of serious injury from work in confined spaces, such as the dangers highlighted above, the Confined Spaces Regulations 1997 apply. These regulations contain the following key duties: Avoid entry to confined spaces, e.g. by doing the work from 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 starts. These duties, and what you need to do, are further described below.

4 How do we manage it? Avoid entering confined spaces You need to check if the work can be done another way so that entry or work in confined spaces is avoided. Better work planning or a different approach can reduce the need for confined space working. Ask yourself if the intended work is really necessary, or could you: Modify the confined space itself so that entry is not necessary; Have the work done from outside, for example: Blockages can be cleared in silos by use of remotely operated rotating flail devices, vibrators or air purgers; Inspection, sampling and cleaning operations can often be done from outside the space using appropriate equipment and tools; Remote cameras can be used for internal inspection of vessels. Safe systems of work If you cannot avoid entry into a confined space make sure you have a safe system for working inside the space. Use the results of your risk assessment to help identify the necessary precautions to reduce the risk of injury. These will depend on the nature of the confined space, the associated risk and the work involved. Make sure that the safe system of work, including the precautions identified, is developed and put into practice. Training Requirements Everyone involved will need to be properly trained and instructed to make sure they know what to do and how to do it safely. The level of training is rated in accordance with the type of confined spaces you may need to access on the level of risk you may be exposed to. These are identified as follows: Confined Spaces - Entry into Low Risk Confined Spaces (CS1L) This course is about entering and working in a low risk environment with adequate natural or mechanical ventilation, where the access may be simple and unobstructed and there is no likely risk of flooding (for example meter pits, valve chambers; stairwells). Low Risk confined spaces could be associated with lone working requiring the application of appropriate procedures. Confined Space - Entry into Medium Risk Confined Spaces (CS2M) This course is about working in confined space environments where there is a medium risk that a specified hazard may be present. It will require the use of escape breathing apparatus. It will involve the presence of one or more people - positioned outside the confined space - who have designated responsibilities for controlling the entry and dealing with emergencies. To ensure that work is properly managed and that safe systems of work are in place, suitable competence training for supervisors or Mangers is needed this is set out with the following training: Confined Space - Confined Space Awareness for Responsible Persons (CS02) This course is for managers, supervisors or other persons who will have responsibilities for personnel working in confined spaces. It will give them the background knowledge to be able to supervise or manage such operations and to ensure that personnel involved have appropriate levels of training. It will help them to appreciate the hazards and risks of confined space working and to ensure that the appropriate resources are available and being correctly used. Checklist for Working in Confined Spaces The following checklist indicated in the next section is not intended to be exhaustive but includes many of the essential elements to help prepare a safe system of work. Appointment of a supervisor

5 Supervisors should be given responsibility to ensure that the necessary precautions are taken, to check safety at each stage and may need to remain present while work is underway. Are persons suitable for the work? Do they have sufficient experience of the type of work to be carried out, and what training have they received? Where risk assessment highlights exceptional constraints as a result of the physical layout, are individuals of suitable build? The competent person may need to consider other factors, e.g. concerning claustrophobia or fitness to wear breathing apparatus, and medical advice on an individual s suitability may be needed. Isolation Mechanical and electrical isolation of equipment is essential if it could otherwise operate, or be operated, inadvertently. If gas, fume or vapour could enter the confined space, physical isolation of pipe work etc needs to be made. In all cases a check should be made to ensure isolation is effective. Cleaning before entry This may be necessary to ensure fumes do not develop from residues etc while the work is being done. Check the size of the entrance Is it big enough to allow workers wearing all the necessary equipment to climb in and out easily, and provide ready access and egress in an emergency? For example, the size of the opening may mean choosing airline-breathing apparatus in place of self-contained equipment that is more bulky and therefore likely to restrict ready passage. Provision of ventilation You may be able to increase the number of openings and therefore improve ventilation. Mechanical ventilation may be necessary to ensure an adequate supply of fresh air. This is essential where portable gas cylinders and diesel-fuelled equipment are used inside the space because of the dangers from build-up of engine exhaust. Warning: carbon monoxide in the exhaust from petrol-fuelled engines is so dangerous that use of such equipment in confined spaces should never be allowed. Testing the air This may be necessary to check that it is free from both toxic and flammable vapours and that it is fit to breathe. A competent person using a suitable gas detector that is correctly calibrated should carry out testing. Where the risk assessment indicates that conditions may change, or as a further precaution, continuous monitoring of the air may be necessary. Provision of special tools and lighting Non-sparking tools and specially protected lighting are essential where flammable or potentially explosive atmospheres are likely. In certain confined spaces (e.g. inside metal tanks) suitable precautions to prevent electric shock include use of extra low voltage equipment (typically less than 25 V) and, where necessary, residual current devices. Provision of breathing apparatus This is essential if the air inside the space cannot be made fit to breathe because of gas, fume or vapour present, or lack of oxygen. Never try to sweeten the air in a confined space with oxygen as this can greatly increase the risk of a fire or explosion. Preparation of emergency arrangements This will need to cover the necessary equipment, training and practice drills. Provision of rescue harnesses Lifelines attached to harnesses should run back to a point outside the confined space. Communications An adequate communications system is needed to enable communication between people inside and outside the confined space and to summon help in an emergency.

6 Check how the alarm is raised Is it necessary to station someone outside to keep watch and to communicate with anyone inside, raise the alarm quickly in an emergency, and take charge of the rescue procedures? Is a permit-to-work necessary? A permit-to-work ensures a formal check is undertaken to ensure all the elements of a safe system of work are in place before people are allowed to enter or work in the confined space. It is also a means of communication between site management, supervisors, and those carrying out the hazardous work. Essential features of a permit-to-work are: Clear identification of who may authorise particular jobs (and any limits to their authority) and who is responsible for specifying the necessary precautions (e.g. isolation, air testing, emergency arrangements etc); Provision for ensuring that contractors engaged to carry out work are included; Training and instruction in the issue of permits; Monitoring and auditing to ensure that the system works as intended. Emergency Arrangements When things go wrong, people may be exposed to serious and immediate danger. Effective arrangements for raising the alarm and carrying out rescue operations in an emergency are essential. Contingency plans will depend on the nature of the confined space, the risks identified and consequently the likely nature of an emergency rescue. Emergency arrangements will depend on the risks. You should consider: Communications How can an emergency be communicated from inside the confined space to people outside so that rescue procedures can start? Don t forget night and shift work, weekends and times when the premises are closed, e.g. holidays. Also, consider what might happen and how the alarm can be raised. Rescue and resuscitation equipment Provision of suitable rescue and resuscitation equipment will depend on the likely emergencies identified. Where such equipment is provided for use by rescuers, training in correct operation is essential. Capabilities of rescuers They need to be properly trained people, sufficiently fit to carry out their task, ready at hand, and capable of using any equipment provided for rescue, e.g. breathing apparatus, lifelines and fire-fighting equipment. Rescuers also need to be protected against the cause of the emergency.

7 Shut down It may be necessary to shut down adjacent plant before attempting emergency rescue. First-aid procedures Trained first aiders need to be available to make proper use of any necessary first aid equipment provided. Local emergency services How are the local emergency services (e.g., fire brigade) made aware of an incident? What information about the particular dangers in the confined space is given to them on their arrival? Legal Reference The Regulations applicable to Confined Spaces are listed as: The Confined Spaces Regulations 1997; The Management of Health and Safety at Work Regulations 1999; The Control of Substances Hazardous to Health Regulations 2002 (as amended); The Personal Protective Equipment at Work Regulations 1992 (as amended); The Provision and Use of Work Equipment Regulations 1998; Electricity at Work Regulations 1989; Workplace (Health, Safety and Welfare) Regulations Some of the above law is relevant because of the nature of the work to be carried out inside a confined space, e.g. where there are risks from machinery, electricity or from hazardous substances. Other Guidance /Useful Links: Safe work in confined spaces. Confined Spaces Regulations Approved Code of Practice, Regulations and guidance L101 HSE Books 1997 ISBN Health and Safety at Work etc Act 1974 (c.37) The Stationery Office 1974 ISBN Management of health and safety at work. Management of Health and Safety at Work Regulations Approved Code of Practice and guidance L21 (Second edition) HSE Books 2000 ISBN Successful health and safety management HSG65 (Second edition) HSE Books 1997 ISBN Guidance on permit-to-work systems: A guide for the petroleum, chemical and allied industries HSG250 HSE Books 2005 ISBN TH6052

8 Case Studies: BACKGROUND The deaths of workers in confined spaces constitute a recurring occupational tragedy; approximately 60% of these fatalities have involved would-be rescuers. If you are required to work in a: Septic Tank Silo Reaction Vessel Sewage Digester Vat Boiler Pumping/Lift Station Duct Pipeline Sewage Distribution Utility Vault Pit or Holding Tank or similar type of structure or enclosure, you are working in a CONFINED SPACE. Case 1 - Recognition And Rescue (Fatalities = 1 Worker + 1 Rescuer) A 54-year-old worker died inside a floating cover of a sewage digester while attempting to restart a propane heater that was being used to warm the outside of the sewage digester cover prior to painting it Workers had wired the safety valve open so that the flow of propane would be constant, even if the flame went out. The heater was located near an opening in the cover of the digester. When the worker attempted to restart the heater, an explosion occurred that vented through the opening. The worker crawled away from the heater into an area that was oxygen deficient and died. A co-worker attempted a rescue and also died. Case 2 - Recognition And Rescue (Fatalities = 1 Worker + 1 Rescuer) A 20-year-old construction worker died while attempting to refuel a gasoline engine powered pump used to remove wastewater from a 66-inch diameter sewer line that was under construction. The pump was approximately 3,000 feet from where the worker had entered the line. The worker was overcome by carbon monoxide. A co-worker, who had also entered the sewer line, escaped. A 28-year-old state inspector entered from another point along the sewer line and died in a rescue attempt. Both deaths were due to carbon monoxide intoxication. In addition to the fatalities, 30 fire fighters and 8 construction workers were treated for carbon monoxide exposure. Case 3 - Recognition And Rescue (Fatalities = 2 Rescuers) Two workers (26 and 27 years old) were overcome by gas vapours and drowned after rescuing a third worker from a fracturing tank at a natural gas well. The tank contained a mixture of mud, water, and natural gas. The first worker had been attempting to move a hose from the tank to another tank. A chain secured the hose and when the worker moved the hose, the chain fell into the tank. The worker entered the tank to retrieve the chain and was overcome. Case 4 - Recognition And Rescue (Fatalities = 1 Worker + 1 Rescuer) A 22-year-old worker died inside a toluene storage tank that was 10 feet in diameter and 20 feet high while attempting to clean the tank. The worker entered the tank through the 16-inch diameter top opening using a 1/2-inch rope for descent. Although a self-contained breathing apparatus was present, the worker was not wearing it when he entered the tank. The worker was overcome and collapsed onto the floor the tank. In an attempt to rescue the worker, fire department personnel began cutting an opening into the side of the tank. The tank exploded, killing a 32-year-old fire fighter and injuring 15 others. Case 5 - Recognition And Rescue (Fatalities = 1 Worker + 1 Rescuer) A 21-year-old worker died inside a wastewater holding tank that was four feet in diameter and eight feet deep while attempting to clean and repair a drain line. Sulphuric acid was used to unclog a floor drain leading into the holding tank. The worker collapsed and fell face down into six inches of water in the bottom of the tank. A second 21-year-old worker attempted a rescue and was also overcome and collapsed. The first worker was pronounced dead at the scene and the second worker died two weeks later. Cause of death was attributed to asphyxiation by methane gas. Sulphuric acid vapours may have also contributed to the cause of death. Case 6 - Recognition And Rescue (Fatality = 1 Rescuer) A 43-year-old father died while attempting to rescue his 28-year-old son from a tank used to store spent acids from a metal pickling process. The tank was out of service so that sludge could be removed from the bottom. The son collapsed in the tank. The father attempted a rescue and also collapsed. The two were removed from the tank; the son was revived, but the father died. The cause of death is unknown. Case 7 - Recognition (Fatality = 1 Worker) A crew foreman became ill and was hospitalized after using an epoxy coating, which contained 2-nitropropane and coal tar pitch, to coat a valve on an underground waterline. The valve was located in an enclosed service vault (12' x 15' x 15'). The worker was released from the hospital on July 3, 1985, but was readmitted on July 6, 1985; he lapsed into a coma and died on July 12, 1985, as a result of acute liver failure induced by inhalation of 2-nitropropane and coal tar pitch vapours. A co-worker was also hospitalized, but did not die.

9 Case 8 - Recognition And Rescue (Fatalities = 1 Worker + 3 Rescuers) A 27-year-old sewer worker entered an underground pumping station (8' x 8' x 7') via a fixed ladder inside a three-foot diameter shaft. Because the work crew was unaware of procedures to isolate the work area and ensure that the pump had been bypassed, the transfer line was still under pressure. Therefore, when the workers removed the bolts from an inspection plate that covered a check valve, the force of the wastewater blew the inspection plate off, allowing sewage to flood the chamber, and trapping one of the workers. A coworker, a supervisor, and a policeman attempted a rescue and died. The first two deaths appeared to be due to drowning and the latter two appeared to be due to asphyxiation as a result of inhalation of "sewer gas. Conclusions Based on the information derived from these case studies, NIOSH concluded that these fatalities occurred as a result of encountering one or more of the following potential hazards: Lack of natural ventilation, Oxygen deficient atmosphere, Flammable/explosive atmosphere, Unexpected release of hazardous energy, Limited entry and exit, Dangerous concentrations of air contaminants, Physical barriers or limitations to movement, or Instability of stored product.

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