MAGB HEALTH and SAFETY GROUP Working In Confined Spaces SCOPE: This document represents best practice advice available and considered pertinent after consultation within the membership and incorporating HSE guidance. It is intended to assist member companies to identify the hazards involved with working in confined spaces and offers guidance on measures that can be taken to prevent accidents/incidents from occurring. 1. INTRODUCTION A number of people are killed or seriously injured in confined spaces each year in the UK. This happens in a wide range of industries, from those involving complex plant to simple storage vessels. Those killed include not only people working in the confined space but those trying to rescue them without proper training and equipment. Source: HSE INDG258 Definition of a Confined Space Confined Space means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space, which by virtue of its enclosed nature, there arises a reasonably foreseeable specific risk. Specific Risks means a risk of a) Serious injury to any person at work arising from a fire or explosion. b) A loss of consciousness of any person at work arising from an increase of body temperature. c) A loss of consciousness or asphyxiation of any person at work arising from gas, fume, vapour, or lack of oxygen. d) The drowning of any person at work arising from an increase in the level of liquid. e) The asphyxiation of any person at work arising from a free flowing solid or the inability to reach a reparable environment due to entrapment by a free flowing solid. Free flowing solid means any substance consisting of solid particles and which is of, or is capable of being in, a flowing or running consistency, and includes flour, grain, sugar, sand or other similar materials. Source: Confined Spaces Regulations 1997 This document aims to provide some guidance on working in confined spaces. 2. LEGAL REQUIREMENTS The Health and Safety at Work Act 1974 requires employers to ensure the health and safety of all employees and visitors (including contractors) to their sites. This includes taking measures to control work in confined spaces. Employees must not endanger themselves or others and must use any safety equipment provided. The Management of Health and Safety at Work Regulations 1999 require employers to carry out a suitable and sufficient assessment of the risks for all work activities. This is designed to ensure that if it is not reasonably practicable to prevent work in a confined space that the employer will assess the risks connected with entering or working in the confined space. The assessment will need to identify not only Page 1 of 5
the risks to those entering the confined space but also any others, for example, other workers, contractors or the general public who could be affected by the work being undertaken. The Confined Space Regulations 1997 require employers to where it is not reasonably practicable to avoid entering a confined space to undertake work that a safe system of work is used. In designing a safe system of work priority should be given to eliminating the source of any danger before deciding what precautions are needed for entry. Furthermore that people are trained to work and enter confined spaces, that a permit to work system is in place to support the safe system of work, that emergency arrangements are in place. Rescuers 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. Other Legal Requirements The Control of Substances Hazardous to Health Regulations 2002 The Personal Protective Equipment at Work Regulations 1992 The Provision and Use of Work Equipment Regulations 1998 Electricity at Work Regulations 1989 Workplace (Health, Safety and Welfare)Regulations 1992 Example of HSE Enforcement www.hse.gov.uk/enforcement/example/director.htm 3. Confined Space Hazards The dangers that can arise from confined spaces within the malting industry will depend upon the type of plant and equipment i.e. Steeping/Germination Vessels, Silo s, Elevator pits etc, and also any ancillary equipment such as Burner Chambers, Air Receivers, Effluent Systems and Manholes. However listed below are some of the main dangers and where they are likely to be found: 1. Lack of Oxygen (oxygen deficient environments) In green malt & barley elevator pits In germination/steeping vessels Inside any steel tank or vessels where rust has formed 2. Poisonous Gas, Fumes, Vapour, these can build up in Sewers and manholes Underground tunnels Result of maintenance work, i.e. welding, adhesives Result of cleaning activities, i.e. use of volatile solvents 3. Liquids or Solids, which could suddenly fill the space or release gases into it, when disturbed Silos Steep Tanks Pits and effluent systems 4. Fire and Explosions, from flammable vapours, enriched oxygen environments or from excessive build up of dust Silos Burner Chambers Dust Plants Page 2 of 5
5. Hot Conditions leading to dangerous increases in body temperature Kiln Chambers Air Ducts Burner Chambers 6. Residues left in vessels, tanks and pits which may give off gas, vapour, fumes or lead to an oxygen deficient environment Effluent Tanks Effluent Pits 7. Diseases such as Leptospirosis (Weil s Disease) Effluent Systems Manholes 4. GUIDELINES TO PREVENT ACCIDENTS/INCIDENTS in CONFINED SPACES Identify Confined Spaces on Site a) All confined spaces on site should be identified, numbered and categorised. The National Classifications for Confined Spaces are; i) NC1 Low risk entries less than 1.5meters deep ii) NC2 Vertical entry attached to a line or winch iii) NC3 Work carried out away from point of entry, detached from line or winch iv) NC4 Non-standard entries requiring specific controls and rescue arrangements b) A confined space register should be compiled based on the above, and be available to all staff likely to be involved with work in confined spaces. It is recommended that confined space registers have the following information in them; i) Description & photograph of the space ii) Confined space identification number iii) Details of potential hazards iv) Safety equipment required for entry v) Safety procedures for entry vi) Isolation requirements vii) Rescue arrangements c) All confined spaces should be clearly labelled, displaying the following information; yellow/black warning triangle, permitting requirements, confined space number (to reference against confined space register) and the confined space category Page 3 of 5 Training and Equipment a) All staff likely to work in (or responsible) for confined spaces should be trained in confined space entry, confined space rescue and use of all confined space equipment. Regular refresher training should take place b) All staff likely to work in a confined space must be have the physical ability to carry out tasks assigned to them in the confined spaces. They should also be medically and mentally fit c) Depending upon the nature of the confined spaces on site, rescue equipment will be required. It is likely to consist of some/all of the following; tripod & winch, emergency stretcher, escape sets (RPE), rescue harness and rope rescue kit.(additional equipment is available)
d) PPE should be identified from the risk assessment and stated on the entry permit e) Multi-Gas detection system for pre-entry checks and ongoing measuring of the atmosphere f) Communication equipment/systems NOTE: All equipment should be regularly inspected and maintained, all electrical items should be intrinsically safe. (Atex rated) Risk Assessment, Safe Systems of Work (SSOW) & Permits to Work (PTW) a) A risk assessment should be carried out prior to any entry into a confined space. This will help to identify the necessary precautions to be included in the safe system of work. Factors to consider are residues, previous contents, contamination, oxygen deficiency or enrichment, ingress of materials, sources of ignition and emergency arrangements b) The safe system of work should remove any risks identified during the risk assessment. Some points to consider when developing the safe system of work; supervision, isolations, purging & ventilation, testing & monitoring the atmosphere, communications, access & egress, PPE & RPE, selection of suitable equipment for tasks being carried out in the space, emergency & rescue arrangements. (Note: this list is not exhaustive) c) A permit to work system is a formal written system used to control certain types of work that are potentially hazardous, it is a document which specifies the work to be done and the precautions to be taken. They form an essential part of Safe Systems of Work (SSOW) for many activities including confined space entry and work. They allow work to start only after safe procedures have been defined and they provide a clear record that all foreseeable hazards are considered Emergency Arrangements and Rescue Effective arrangements for raising the alarm and carrying out rescue operations in emergencies are essential. You cannot rely solely on the emergency services to affect a rescue in the event of an emergency. Contingency plans will depend upon the nature of the confined space, the risks identified and consequently the likely nature of an emergency rescue, you should consider the following; a) Communications how will the emergency be communicated from the confined space to people outside so that rescue procedures can start? b) Rescue and Resuscitation Equipment the provision of suitable rescue and resuscitation equipment will depend on the likely emergencies identified by the risk assessment. Rescue parties must be trained in the correct operation of all rescue equipment c) Capabilities of Rescuers they need to be properly trained, sufficiently fit to carry out the duty, ready at hand and capable of using the equipment provided. They also need to be protected from the cause of the emergency. d) Shutdown of Plant and Equipment it may be necessary to shutdown adjacent plant before attempting an emergency rescue e) First Aid trained first aiders should be available to make use of any necessary first aid equipment provided f) Local Emergency Services How are they made aware of the incident and what information about the dangers of the confined space is given to them upon arrival? Source: HSE INDG258 Page 4 of 5
5. FURTHER INFO The following HSE publications may provide further advice. Safe work in confined spaces. Confined Spaces Regulations 197. Approved Code of Practice, Regulations and guidance L101 HSE Books 1997 ISBN 0 7176 1405 0 Safe work in confined spaces Leaflet INDG258 (rev7) HSE Books (single copy free or priced pack of 20) ISBN 0 7176 1442 5 Guidance on permit-to-work systems: A guide for petroleum, chemical and allied industries HSG250 HSE Books 2005 ISBN 0 7176 2943 0 5 steps to risk assessment Leaflet INDG163 (rev2) HSE Books 2006 (single copy free or priced pack of 10) ISBN 0 7176 6189 X Page 5 of 5