Annex F to Loughborough University Facilities Management Health and Safety Policy Confined Spaces (Including Excavations). Ignorance of the dangers and hazards associated with confined spaces has led to the deaths of a number of construction and maintenance workers. In some cases, attempted rescues have ended in further tragedy with the death of poorly equipped rescuers as well. A confined space may be any space in which the work being undertaken makes the space dangerous, such as the use of solvents, some painting work and carbon monoxide producing operations or the space itself presents a hazard such as manholes, tunnels, some trenches, sewers and the like. Care must be taken to prevent the buildup of flammable gases, poisonous gases or oxygen depletion in any space in which a person needs to gain access to carry out any work or inspections. Specific precautions must be taken before anyone is allowed to access such spaces. 1. Commitment a. Senior management realises that work associated with Confined Spaces involves inherently greater risk than that occurring in other workplace environments. b. The term 'Confined Space' 1 applies to work spaces inside which one or more of the following hazardous conditions could be present or could possibly develop: i. Personal Confinement. ii. iii. iv. Unstable interior condition. Flowable solid materials or residual liquids or sludges. Release of energy through uncontrolled or unpredicted motion or action of equipment. v. Atmospheric confinement: vi. Toxic substances. Oxygen deficiency/enrichment. Flammable/combustible atmosphere. Fume cupboard and LEV plant extract including pressurised ductwork. Chemical, physical, biological, ergonomic, mechanical, process and safety hazards within the above. 1 Safety and Health in Confined Spaces 1999, N McManus, Lewis Publishers, London
vii. NB. Certain facets associated with sub-paragraph 'f' will also be covered by other permit systems, such as High Voltage Electrical Switch rooms, Pressure systems etc. c. Loughborough University Facilities Management will support all endeavours to reduce the risk when working within these workspaces to the minimum possible; accordingly a programme of continuous improvement of managing the hazards associated with confined spaces will be supported. d. In pursuit of this goal, all levels of management will conduct activities involving confined spaces in a manner that will minimise the risk to which employees will be subjected and take reasonable steps and support all initiatives to minimise such risk and management expects constructive and active participation at all levels. e. Work practices shall incorporate all elements necessary to ensure success of the stated policy. f. The satisfactory measure of the adopted approach to Confined Spaces is that associated operations are illness, injury and fatality free. 2. Inventory a. The development of a detailed inventory is a requisite of any ongoing confined spaces policy. However, the absence of such detail should not discourage active participation following the above guidelines as to the term 'Confined Space'. b. As a guide, the term confined space within Loughborough University Facilities Management will be deemed to include: An enclosed or partially enclosed workspace. (E.g. the internal spaces of a boiler). Subject to accumulation of toxic or flammable contaminants. (E.g. Boiler flue ways). May develop an oxygen deficiency. (E.g. foul drainage chambers). SeeAppendix 3 Not intended for continuous employee occupancy. (E.g. Service voids or risers with limited 2 access and egress). 2 Access to/egress from a location that might involve the use of specialist services or equipment, should the health and safety of anyone accessing the space to assist place those them in similar danger.
3. Identification a. Currently, four specific areas have been designated as confined spaces involving access by Facilities Management personnel and contractors, including the self-employed who undertake work on their behalf. These are: - East Site Voids Boiler watersides, combustion chambers and flue ways Foul, Grey and Surface water chambers Excavations where Flowable solids or oxygen deficiency may be experienced. The EHB Plantroom Void, all Manholes and drains, Storage tanks and Foul water pump wells are other examples of confined spaces that are present on the Campus. 4. Security a. Establishing the security of confined spaces against casual entry by unauthorised personnel is essential. To this end, once operatives enter a space that has been designated as a confined space, warning signs and where possible barriers should be utilised to prevent casual entry. b. Where the prevention of unauthorised entry to confined spaces is essential for operational reasons, but physical barriers may be breached, it will be necessary to post a watch during break periods where access cannot be prevented in any other way. c. A procedure for the control and management of access to West Site voids is given at Appendix 1. d. The Risk Management plan should state the communications methods and responsibilities of all those concerned with any rescue plan. 5. Hazard Assessment a. A Risk Assessment (RA) must be carried out prior to entry into any confined space, focussing on the anticipated hazards that might arise in the environment, predicting the possible severity, assessing the level of risk and its acceptability. (See Risk Assessment section). b. Such Risk Assessment should only be carried out by approved persons competent, through education, training and experience of the requirements associated with the particular situation at hand. Only staff (contractors and FM) who have received appropriate training shall be allowed to receive confined space permits. c. The Mechanical Services Service Manager in the case of boilers, and the
Buildings Service Manager in the case of drainage systems, having attended suitable training or their equivalent in status and/or knowledge would exemplify such competent persons within Loughborough University Facilities Management. It is feasible that specially trained personnel who undertake entry to confined spaces regularly could be appointed to undertake such risk assessments and issue permits to enter within a strictly controlled, documented regime. d. The Risk Assessment should be approached as indicated below: i. Inspection/appraisal of the undisturbed space. ii. Preparation prior to entry for pre-work inspection. iii. Pre-work inspection including identification of access and egress routes. iv. Work phase. (Including permits and safe systems of work) v. Emergency response plan. e. It is imperative that items 5a and 5b above are assessed and recorded prior to any entry, as hazardous conditions can occur at any stage during the cycle. 6. Site preparation, Entry and Work (Including Excavations). a. These phases must be consistent with the Risk Assessment. The Risk Assessment must be specific to the task at hand; generic Risk Assessment only being used where conditions remain the same from entry to entry. b. Work activities involving confined spaces are often time critical. Loughborough University Facilities Management managers will encourage safe practices at all times and shortcuts or non-compliance with Risk Assessment and this code of practice will not be tolerated. c. No person shall enter or allow others under their control to enter an excavation deeper than 1.2 meters (4 feet) unless the area being accessed has been suitably shored. Where access and egress to separate areas of an excavation is effected through the excavation, all the excavation shall be suitably shored. The risk assessment for the work may reduce the depth at which shoring is required depending on site and weather conditions. (E.g. during rain storms or following prolonged periods of wet weather). 7. Atmospheric and Environmental Testing a. Testing provides the basis for evaluating the environment within the workspace and gives warning not to enter, or when to leave under adverse conditions. The testing is for noxious gases and to ensure a breathable air supply. If acceptable conditions are not met, the work should be postponed until appropriate actions have been taken to remove or mitigate the risk posed.
b. Atmospheric testing must be appropriate to the contaminant of interest. Initial testing in new areas should be carried out in association with the University Health and Safety officers. However, operatives and those supervising the work must carry out subsequent testing during the work. 8. Ventilation a. Airborne contaminants can arise from residual contents and contaminants that arise from the work process itself. Ventilation to overcome such contaminants may utilise natural ventilation and convective air movement or portable ventilation equipment. b. The Risk Assessment should identify the requirement for and suitability of ventilation. Particular attention must be paid to the volumetric flow rates and pressure. c. Extreme care should be taken in the siting of generators and petrol or diesel driven pumps to ensure that exhaust gases do not enter the work area. Exhaust fumes are heavier than air and will settle in excavations causing a build up which could lead to asphyxiation and/or carbon monoxide poisoning. 9. Respiratory Protective and Personal Protective Equipment (RPE and PPE) a. Due to the possible impracticality of alternative control methods in an emergency situation, Respiratory Protective Equipment and Personal Protective Equipment may be required under certain conditions, with the need to rely on Respiratory Protective Equipment possibly greater than in normal working environments. b. It is imperative that great care is taken with the selection of suitable Respiratory Protective Equipment and Personal Protective Equipment to ensure that it is suitable protection against the contaminants, that it does not adversely hinder rapid egress should an emergency situation befall the occupants of the space and that an excessive burden is not placed on the individual by the equipment itself, such as claustrophobia, physiological and psychological stress and heat stress. c. No person shall use or rely on the use of Respiratory Protective Equipment without having undergone thorough training specific to the equipment being used. d. Respiratory Protective Equipment and Personal Protective Equipment are covered elsewhere within this policy. 10. Emergency Preparedness and Response a. The preparation of a suitable emergency plan will bridge the gap between what is supposed to happen during a job of work and what could happen. b. Determining what could happen is an integral part of the Risk Assessment. It is
a well-documented fact that the lack of a suitable emergency plan has been responsible for the inability of people to respond to unacceptable conditions. c. If the level of initial response to unacceptable conditions is less than that sufficient to alleviate a realistic (though theoretical) situation, then a reappraisal must be undertaken. Any response must be suitable and sufficient to ensure the safe removal of personnel from the work area in a timely manner. d. The Emergency Services should form an integral part of any proposed emergency plan. 11. Contractors a. Due to the nature and specialised expertise required for certain operations, contractors undertake various work within confined spaces. However, such contractors will seldom be as versed in the particular environment under consideration as Loughborough University Facilities Management staff and must be inducted into the fundamentals of this code of practice by the Facilities Management person in charge of the work, before being allowed to work in any confined space. b. Contractors shall be made to produce suitable and sufficient Risk Assessment and operating procedures or method statements prior to working in any confined space. c. The Facilities Management permit system shall be utilised at all times unless the Contractor has sole control of the workplace, as would be the case where a building site is formally handed to a building contractor. In such instances, the contractor shall be responsible for the management of anyone working within such spaces and shall impose suitable safe systems of work. d. FM staff requiring access to spaces under the control of a contractor shall accord to the requirements imposed by the contractor. Where such standards are considered inadequate, the matter should be referred to the FM manager responsible for the contract in question. 12. Permit to Enter Procedures a. Work should never be undertaken within a confined space without first obtaining a written permit to enter. b. Entering and Working in Ceiling Voids is strictly controlled by Loughborough University Facilities Management. The current procedure for entry into Ceiling voids is given at Appendix 1 to this Annex. c. A copy of a permit to enter confined spaces is given in Appendix 2 to this Annex. And its guidance should be utilised as an aide-memoir to offering
assistance to anyone wishing to enter a confined space. d. Where the information required on the permit is inapplicable, N/A shall be entered in each of the spaces provided. Appendixes: 1 Entering Ceiling Voids West Park 2 Example of a Permit to Enter a Confined Space 3 Procedure for entering into drains on campus Revision Revisions made Date 2 Revise policy highlighting the requirement for a Risk Assessment by competent persons before entering any confined space (5a and 5b) M. Commons 14 th July 2015 3 Clarification of Authorised person titles 26 th 4 Clarification of using RPE for emergencies only 26 th November 2015 November 2015 5 Examples of confined spaces present on campus. 28th January 2016