Confined Space

PAUL RANDALL AND ASSOCIATES
Health and safety Training
CONFINED SPACES
NEBOSH Certificate: 1.3.10
Confined spaces
1 Confined spaces, an introduction ...................................................... 5
2 The Confined Spaces Regulations 1997 .......................................... 7
2.1 Avoiding entry into confined spaces ......................................... 8
2.2 Safe system of work ................................................................. 8
2.3 Emergency procedures ........................................................... 10
3 Typical confined space problems .................................................... 10
3.1 Hazards presented by gases, fumes and vapours ................. 10
3.2 Oxygen deficiency ................................................................... 11
3.3 Fire, explosion and other hazards .......................................... 12
4 Reducing confined space hazaards ................................................ 12
Syllabus coverage
1.3.10 The main hazards and safe working practices associated with
confined spaces; the measures necessary to comply with The
Confined Spaces Regulations 1997
Required reading
Safe work in confined spaces, INDG 258, HSE Books 1998
Confined spaces
24 Stirling Road, Chichester, PO19 2ES

01243 776394 paulrandallandassociates.com
Confined spaces
Confined spaces, an introduction

Those of you who use a word processor are probably used to the
spell checker blissfully displaying its ignorance of matters scientific - mine recently confidently suggested that I should change
earthing (in a book on electrical safety) to earthling.
When checking an early draft of the present text the spell checker
wanted to know if I wished to replace confined space with
confused space (whatever that is). No thanks, I didnt, but it set
me thinking that the spell checker had for once hit a nail on the
head - one crucial aspect of a confined space being the uncertainty as to just what conditions will be encountered.
A formal definition of a confined space would include the words ...
... any enclosed environment ... liable to present hazards to
human health ... as a result of presence of hazardous
substances ... or absence of oxygen ... excessive conditions of
temperature or pressure ... fire and explosion ...
Examples of confined spaces include:
drains and culverts
inside the segments of a box-girder bridge
ventilation ducting
food storage facilities
plant rooms
compartments of a ship
... no doubt you could add many more examples to this list.
Just some examples of confined space fatalities (there are about
20 per year) include:
a devastating fire in a ships compartment in which the air had

been sweetened with oxygen; poor communications between
management and two groups of workers led to inappropriate
use of welding equipment - 8 men died
a lone worker fell into a grain silo and suffocated; no one

missed him, his body was discovered two days later

Confined spaces
a faulty waste disposal system on a ship led to the fumes from

decomposing waste matter killing two children in their bunks
two council workmen died when they were overcome by fumes

from toxic chemicals when cleaning a sewage system
a worker cleaning out a storage tank was overcome by the

vapour from the solvent he was using; he collapsed with a
heart attack and died
a massive explosion in an underground water pumping station

was caused when a build-up of methane gas was ignited.
a welder was killed when the residues in the storage tank

which he was repairing, exploded
a relatively small quantity of fuel oil leaking into building

excavations resulted in a fatal fire
Looking through these examples you will perhaps see a pattern

beginning to emerge, combinations of circumstances and behaviour leading to tragedy. The key legislation designed to prevent
such tragedies is The Confined Spaces Regulations 1997, which
we will discuss shortly.
The legal foundation for the 1997 Regulations are to be found in
earlier legislation, including:
The Health and Safety at Work etc Act 1974; section 2 of this
Act (to which we will fequently return) requires employers to
protect employees against risks to safety and health, and to
provide safe systems of work etc. Implicitly, this will cover
confined spaces although they are not mentioned as such.
The COSHH Regulations deal with the prevention and control
of exposure to hazardous substances in any work environment
including, obviously, confined spaces.
The Management of Health and Safety at Work Regulations
1999 require that the employer undertakes an assessment of
the risks in order to determine the measures necessary for
safety ... MHSWR requires a consideration of:
the work to be undertaken, including equipment etc
the nature of the working environment

Confined spaces
levels of competence
arrangements for emergencies
If the assessment identifies risks associated with confined

spaces, then The Confined Spaces Regulations apply.
The Confined Spaces Regulations 1997

There are three principal duties in these Regulations - what do
you think they might be?
... the three duties as defined by the Regulations are as follows:
avoid entry into confined spaces
if entry is unavoidable, a safe system of work must be followed
adequate emergency procedures must be in place before work

starts
We will look at these three duties in turn in sections 2.12.3

below. The HSE leaflet INDG 258 Safe work in confined spaces
provides a very good coverage of the requirements of the Regulations and we recommend that you read this leaflet in parallel with
your studies of the present book.

Confined spaces
2.1 Avoiding entry into confined spaces
This might be achieved by using remotely controlled equipment,
for example, it may be practical for the inspection and cleaning of
some sewers and other confined spaces.
An possible alternative approach might be to unconfine the
space, so to speak*. It may be possible to remove wall panels
and so on; in the case of, say, ship building activities it may thus
be possible, by careful planning, to undertake some of the fittingout before spaces become confined.
2.2 Safe system of work
A safe system of work must provide a plan that covers all aspects
ot the work - entry and egress, sequence of operations, environmental factors, PPE, and so on.
When an assessment identifies that the hazards to be faced are
particularly serious, then a permit to work will be required; you
can be safe to assume that for confined space work, permits to
work will almost always be necessary.
As you will see later in your studies (section 4.3.6), other common
examples of permits include:
(permits to work in confined spaces)
hot work permits
permits to work on pressurised systems
electrical permits
permits to enter confined spaces
You will appreciate that before a permit to work can be authorised, a permit to enter the confined space may be required, so
enabling inspections to take place prior to work being undertaken.
* Incidentally, the spell checker was reduced to silence by the word

unconfine - it offered no alternatives.
Confined spaces
In the case of confined space working, the permit to work provides:
written authority for the space to be entered and for work to

start and finish
time limits and correct sequences
procedures and responsibilities of all those involved
checks and precautions (for example, continuous atmospheric

testing may be required in deep excavations and tunnels and
the permit to work should provide specifications of the required
equipment)
Q On that point, what requirements would you make for the

person carrying out the atmospheric testing?
A Atmospheric testing (or related activities such as setting up

automated air monitoring equipment) should be undertaken by
someone wearing appropriate breathing apparatus, with a second
appropriately equiped worker (breathing apparatus, rescue line
etc), standing by.
Remember that in this section we are looking at the requirements
of The Confined Spaces Regulations 1997; now to the third
requirement ...

Confined spaces
2.3 Emergency procedures
These should form an integral part of the planning:
communications methods
equipment and training of the rescue team
emergency lighting etc
rescue practice runs
shutting down processes etc
provision of first aid
alerting emergency services
Rescue equipment will include ropes, resuscitation equipment,

communication equipment, breathing apparatus, fire fighting
equipment and so on. The most sophisticated breathing apparatus will be useless if it is too large to allow entry through (say) the
manhole - the suitability of all equipment must be established as
part of the planning.
Typical confined space problems

The following is by no means exhaustive.
3.1 Hazards presented by gases, fumes and vapours
Under this heading, we can include:
substances already present when work begins
substances which are created by work activities
substances which seep into the confined space as the work

progresses
Q Before reading further, you might like to think of some

examples for each of these three categories.

10
Confined spaces
A Compare your answer with the following:
substances already present

remains of stored substances (ie in storage tanks)
sludge and decaying matter (drainage systems, sewers
and so on)
carbon dioxide, the product of acid rainwater reacting with
chalk, may be a hazard in underground pumping systems
and so on
substances created by work activities

welding fumes, adhesives, solvents
heat from human and machine activity
oxygen enrichment from use of oxy/acetylene and similar
equipment
substances seeping from elsewhere

as a result of accidental damage to pipelines etc
a consequence of seepage of air currents bringing contaminants into the confined space, for example: exhaust fumes
from nearby plant such as dumper trucks and compressors
As we mentioned in the book on construction safety, because of

the dangers presented by carbon monoxide, petrol or diesel plant
should never be operated in a confined space.
3.2 Oxygen deficiency
Oxygen deficiency may occur as a result of organic decay processes using up oxygen or as a result of an area being purged by
the use of an inert gas such as nitrogen. This may also be
necessary to flush out explosive gases such as methane. Further
purging with air may be required before the space is safe to enter.
(You will appreciate that the problem of oxygen deficiency relates
closely to the issues we have just discussed.) The normal atmospheric concentration of oxygen is about 21% and, if the oxygen
level falls below 17%, workers will rapidly suffer problems of
fatigue, unconsciousness and so on.

11
Confined spaces
3.3 Fire, explosion and other hazards
A fire or explosion in a confined space represents a very serious
threat and a range of precautions will be necessary in situations
where such problems may arise; these precautions include:
use of intrinsically safe electrical equipment (ie equipment

which produces no sparks)
continuous monitoring of the atmosphere
provision of adequate ventilation
We deal elsewhere with the problems associated with heat stress,

problems which are particularly likely in confined spaces. At this
point, we will mention the hazards associated with workers being
trapped in cold food storage facilities: alarms and emergency
escape devices may be required.
Reducing confined space hazaards

This section forms a summary of the procedures and practices
which we have discussed in this book.
safe systems of work
use of permits to enter and permits to work
substance substitutions: for example use of water-based

adhesives rather than solvent-based.
continuous monitoring of environmental conditions, especially

atmospheric contaminants and oxygen levels
provision of adequate ventilation
exclusion of ignition sources
purging of (in particular) flammable and explosive gases

12

Confined Space

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PAUL RANDALL AND ASSOCIATES

Health and safety Training

NEBOSH Certificate: 1.3.10

Safe work in confined spaces, INDG 258, HSE Books 1998

24 Stirling Road, Chichester, PO19 2ES

Confined spaces, an introduction

drains and culverts

inside the segments of a box-girder bridge

food storage facilities

a devastating fire in a ships compartment in which the air had

a lone worker fell into a grain silo and suffocated; no one

24 Stirling Road, Chichester, PO19 2ES

a faulty waste disposal system on a ship led to the fumes from

two council workmen died when they were overcome by fumes

a worker cleaning out a storage tank was overcome by the

a massive explosion in an underground water pumping station

a welder was killed when the residues in the storage tank

a relatively small quantity of fuel oil leaking into building

Looking through these examples you will perhaps see a pattern

the work to be undertaken, including equipment etc

the nature of the working environment

24 Stirling Road, Chichester, PO19 2ES

arrangements for emergencies

If the assessment identifies risks associated with confined

The Confined Spaces Regulations 1997

... the three duties as defined by the Regulations are as follows:

avoid entry into confined spaces

if entry is unavoidable, a safe system of work must be followed

adequate emergency procedures must be in place before work

We will look at these three duties in turn in sections 2.12.3

24 Stirling Road, Chichester, PO19 2ES

(permits to work in confined spaces)

hot work permits

permits to work on pressurised systems

permits to enter confined spaces

* Incidentally, the spell checker was reduced to silence by the word

written authority for the space to be entered and for work to

time limits and correct sequences

procedures and responsibilities of all those involved

checks and precautions (for example, continuous atmospheric

Q On that point, what requirements would you make for the

A Atmospheric testing (or related activities such as setting up

24 Stirling Road, Chichester, PO19 2ES

equipment and training of the rescue team

emergency lighting etc

rescue practice runs

shutting down processes etc

provision of first aid

alerting emergency services

Rescue equipment will include ropes, resuscitation equipment,

Typical confined space problems

substances already present when work begins

substances which are created by work activities

substances which seep into the confined space as the work

Q Before reading further, you might like to think of some

24 Stirling Road, Chichester, PO19 2ES

A Compare your answer with the following:

substances already present

substances created by work activities

substances seeping from elsewhere

As we mentioned in the book on construction safety, because of

24 Stirling Road, Chichester, PO19 2ES

use of intrinsically safe electrical equipment (ie equipment