Working in Confined & Enclosed Space Policy Author: Alan Bryant Page 1 of 9
Table of Contents: 1. INTRODUCTION... 3 2. DOCUMENT HISTORY... 3 3. REFERENCES... 3 4. PURPOSE... 4 5. SCOPE... 4 6. IMPLEMENTATION... 5 6.1 SAFE WORKING CONDITION... 5 6.2 BREATHING APPARATUS... 5 6.3 EMERGENCY PLAN... 5 6.4 METHOD OF COMMUNICATION... 5 6.5 RISK ASSESSMENT... 6 6.6 PLANNING... 6 6.6.1 Lack of oxygen... 6 6.6.2 Poisonous gas, fume or vapour... 6 6.7 TRAINING & EQUIPMENT... 7 6.7.1 Training... 7 6.7.2 Equipment... 8 6.8 PERMIT TO WORK... 8 6.9 RESCUE TEAM... 9 6.10 ACCIDENT AND REPORTING... 9 Author: Alan Bryant Page 2 of 9
1. Introduction This document is in line with the Health & Safety Requirement of the Confined Spaces Regulation 1997. The document is aimed at Flint s employees and subcontractors who carry out work in confined spaces, and forms part of HSE s commitment to make simple and practical guidance available for small firms. What is confined space? - A confined space is defined as an enclosed or partially enclosed space that is not intended as place of work. It is liable to have an atmosphere that contains harmful contaminants or not contain a safe oxygen level. It may have contents that could cause engulfment. It may have restricted means for entry and exit. 2. Document History Issue Date Updated by Comments 1.0 23/9/2008 A Bryant Formal Release 3. References [1] Safe work in confined space HSE-INDG258 http://www.hse.gov.uk/pubns/indg258.pdf [2] Department of Labour Fact Sheet Confined Spaces: planning Entry and Working Safety in Confined Space [3] Confined Spaces - Self Certification Fitness Questionnaire Flint_0906-0069-SelfCertificationFitnessQuestionnaire-Issue1_0 [4] Confined Spaces Work Permit Flint_0906-0068-ConfinedSpacesWorkPermit-Issue1_0 [5] Working in Confined Spaces Checklist Flint_0906-0070-WorkinginConfinedSpacesCheckList-Issue1_0 Author: Alan Bryant Page 3 of 9
4. Purpose It is a requirement under the HSE Confined Spaces Regulations 1997 that employers must first try to avoid the need to enter a confined space. However, where this is not possible, the following must be carried out: Carry out an assessment of the risks associated with entering a confined space and draw up a plan of safe system of work; Limit entry to the confined space to employees who are competent for confined space work and who have received suitable training; Verify, prior to entry, that the atmosphere in the confined space is safe to breathe; provide any necessary ventilation; Make sure suitable rescue arrangements are in place before anyone goes in to the confined space. These rescue arrangements should not involve risks to the safety of the people intended to carry out the rescue. 5. Scope Under domestic law [the Health and Safety at Work Act 1974] employers are responsible for ensuring the safety of their employees and others. This is reiterated by the various Regulations: The confined Spaces Regulation 1997 and the Management of Health and Safety at Work regulations 1999. These regulations contain key points such as: Avoid entry to confined spaces where necessary, by carrying out the work from the outside; If entry to a confined space is unavoidable, then a safe system of work should be followed; Adequate emergency arrangement should be made before the start Confined spaces can be regarded as: Storage Tank Silos Reaction Vessels Enclosed drains Sewers Author: Alan Bryant Page 4 of 9
There are others, however, they may be less noticeable Open-topped chambers Vats Combustion Chambers in furnaces, such as ductwork Unventilated or poorly ventilated rooms 6. Implementation 6.1 Safe working Condition Carry out air testing to ensure the enclosed space is free from both toxic and flammable vapours and that it is fit to breathe. Testing should be carried out by a competent person using a suitable gas detector which is correctly calibrated. Where the risk assessment indicates that conditions may change, or as a further precaution, continuous monitoring of the air may be necessary. 6.2 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. 6.3 Emergency Plan An emergency plan should be formulated and discuss with all team members. The plan should cover the necessary equipment required, training and practice drills. The emergency process should be in place in case of emergency requirement. The process should consist of alarm rising, emergency contact names and numbers, and carrying out rescue operations. The emergency plans will depend on the nature of the confined space, the risks identified and consequently the likely nature of an emergency rescue. 6.4 Method of Communication There should be a proven and tested communication system between the operator and the supervisor outside of the confined enclosed space. The communication system should also be set up to the emergency services. Author: Alan Bryant Page 5 of 9
6.5 Risk Assessment The law requires that employees must carry out a Risk Assessment [The Management of Health and Safety at Work Regulation 1999, regulation 3]. For work in confined spaces this means identifying the hazards present, assessing the risk and determining what precautions to take. The assessment will include the following: The task Working environment Materials and Tools Suitability of those carrying out the task Arrangement for emergency rescue 6.6 Planning Dangers from confined spaces: 6.6.1 Lack of oxygen Which 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 act as a results of the cargo reacting with oxygen inside the space; Inside steel tanks and vessels when rust forms. 6.6.2 Poisonous gas, fume or vapour 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 Author: Alan Bryant Page 6 of 9
Fire and explosions [e.g. from flammable vapours, excess oxygen] Dust may be present in high concentrations, e.g. in flour silos can give off gas, fume or vapour Hot conditions leading to a dangerous increase in body temperature Residues left in tanks, vessels etc, or remaining on internal surfaces which can give off gas, fume or vapour Notable some of above may already exist in the confined space. However, some may arise through the work being undertaken, or due to ineffective isolation of plant within the area, such as leakage from pipe connection to the confined space. The confine and working space may increase other dangers falling out by work being conducted, such as the below: 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 for example; If access to the spaces is through a restricted entrance, such as a manhole escape or rescue in an emergency will be more difficult. 6.7 Training & Equipment 6.7.1 Training Employees who are about to work in a confined and Enclosed Spaces must have been PPE and adequately trained or have understanding in the following: ü Confined awareness ü Hazards in Confined Spaces and Controls the hazards during an entry by having a written Entry Plan, providing adequate ü Training for the workers and creating a Permit System for the entries ü Confined Spaces Entry with Escape Breathing Apparatus and Self Rescue Procedures Author: Alan Bryant Page 7 of 9
ü Safe Entry into NC2,3,4 Categories Confined Space Using Compressed Air Escape Breathing Apparatus as a Means of Self Rescue 6.7.2 Equipment The correct equipment such as the below should be use: 6.8 Permit to Work ü Gas detectors ü Escape breathing Apparatus ü Breathing apparatus for working duties ü Personal monitors ü Self rescue equipment ü Tripods and winches ü Ex, Exd and ATEX rated lighting and emergency lighting 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 operators are allowed to enter or work in the confined space. It is also a method of communicating between site management, supervisors, and those carrying out the hazardous work. Essential features of a permit-to-work are as follows: - 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. Author: Alan Bryant Page 8 of 9
6.9 Rescue Team The rescue team operative should have been properly trained to carry out their task, be ready at hand, and capable of using any equipment provided for rescue, such as breathing apparatus, lifelines and fire-fighting equipment. Rescuers also need to be protected against the cause of the emergency. Members of the team should also be first aid trained to carry out first aid requirement if deem necessary 6.10 Accident and Reporting Following an accident or incident employers should record details of all occurrences and subsequent investigations so if the accident becomes reportable under the Reporting of Incidents, Diseases, Dangerous Occurrences Regulations (RIDDOR) they have all the information required. Management with the assistance of the supervisor shall carry out the Investigations who should have knowledge of the workplace and systems as soon as is possible. They should be self critical where needed and implement corrective actions as soon as possible. Staff must be advised of the causes and new control measures established to prevent recurrence and where necessary re training carried if required. Author: Alan Bryant Page 9 of 9