The Management of Health and Safety at Work Regulations 1999 places a duty on employers to carry out suitable and sufficient risk assessments for all work activities. Risks posed by infrequent, but necessary, activities need to be given as much consideration as those of day to day procedures and practices.
For work in confined spaces, the risk assessment should include consideration of:
- The task
- The working environment (e.g. the general condition of the confined space, including contents, residues, contamination, oxygen levels, physical dimensions etc., and potential ingress of substances from outside)
- Working materials and tools (i.e. use of chemicals, sources of ignition or gases, heat generation, electricity)
- The suitability of those carrying out the task
- Arrangements for emergency rescue
The person carrying out the risk assessment must have knowledge and experience of all the relevant processes, plant and equipment so that they understand the risks and can devise necessary precautions. More than one person may need to be involved, and employees and their representatives should also be consulted.
Where the risk assessment identifies a risk of serious injury through confined space working, then the Confined Space Regulations 1997 apply, even if the specified risk is controlled.
The Regulations place the following duties on an employer:
- to avoid entry to confined spaces
- if entry to a confined space is unavoidable, follow a safe system of work
- put in place adequate emergency arrangements before the work starts
The priority must always be to try to avoid workers having to enter or work in a confined space. Employers should consider whether the work is really necessary and, if so, whether the space or working practices can be modified to eliminate the need for entering the space. For example, could the work be done from outside or by remotely operated equipment?
Safe system of work
If confined space working cannot be eliminated, the employer must design a safe system of work for the tasks to be undertaken. Priority must be given to eliminating any sources of danger before establishing precautions. Any actions taken to mitigate a risk must be monitored to ensure they remain effective throughout the work.
Where there is a reasonably foreseeable risk of serious injury, a permit-to-work system may be required. This provides a formal written way of recording and checking authorisations, precautions, test results and emergency arrangements. It is important to recognise that a permit-to-work system supports rather than replaces the safe system of work, monitoring and auditing that the system is working as intended. It does not in itself make the job safe.
Any safe system of work must consider the suitability of the people who will carry out the work. This should include physical and mental attributes, such as physical build, strength or pre-existing medical conditions such as asthma or claustrophobia, as well as competence in the specific tasks to be undertaken.
The Regulations stipulate that no one should enter or work in a confined space unless there are suitable emergency arrangements in place. These must include procedures for raising the alarm and getting the workers out, and the provision and use of rescue and resuscitation equipment. Procedures for shutting down or making safe any plant or equipment being used in the confined space must also be considered.
Many fatalities and injuries occur when workers impulsively attempt to rescue trapped or injured colleagues and are overcome by the same conditions as the original victims. It is vital that everyone understands what should be done in the event of an emergency and who should undertake any rescue operations. Employers must ensure rescuers are properly trained, protected and equipped to deal with any potential emergencies that could arise.
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