Although confined spaces can be found in a variety of situations, identifying them can be a challenge. RICHARD MILLAR offers an essentials guide to designing and implementing an effective confined space program and rescue plan.
By nature confined spaces constitute a variety of hazards that include: atmospheric (in that certain gases will displace breathable air), toxic (with the accumulation of the flammable materials) and physical (in that confined spaces limit the ability to avoid contact with electricity, moving mechanical components or unstable substances). Guidance on defining what is or is not a confined space is in itself open to individual interpretation, yet what is not open to interpretation is that they are high-risk work environments and require competent persons able to bring first-hand knowledge of the possible hazards that may be encountered, and who are able to present a safe work method statement (SWMS) for the work to be carried out.
SWMSs are required for high-risk work as defined by the Australian work health and safety (WHS) regulation and should be designed to outline the risk in the activity to be carried out at the workplace, providing: an overview of the work activities, the hazards that may arise from these activities and the control measures to be put in place to reduce the risks. A sound confined space program normally begins with knowledgeable/competent persons taking a thorough look at the employer’s workplace and conservatively identifying every area or space that is big enough to get into, not easy to get into and not intended as a designated workspace. Often the area has another purpose, such as: housing equipment or storing product; shielding hazardous areas; or being a pathway for liquid, gases or solids to flow through.
Once all confined spaces have been identified, the employer has the responsibility of clearly marking all associated entry points with signage that prohibits personnel from going into them without taking specific precautions and control measures. Securing the access points against unauthorised entry is also highly recommended and can be achieved by locking hatchways, bolting or welding covers in place, or securing obvious barrier protections. Before work inside these potentially dangerous areas is authorised by the employer, a detailed hazard assessment needs to be performed for each identified confined space. If, after a thorough evaluation, some of these confined spaces are determined to have no possible dangers associated with work performed inside, entry restrictions can be removed and full access can be restored. But this circumstance is uncommon.
In most cases, dangers cannot be fully removed or work being done inside these areas may introduce new hazards within the confined space. Routinely, the employer has an obligation to put into effect a full confined space entry program that requires permits to be issued to authorised personnel whenever entry must take place. Safe Work Australia WHS Regulation 76 Confined Space provides guidelines and information on training and instruction for workers. Employers must train their personnel to conduct confined space entry procedures or hire qualified contractors who can protect them with a permit entry system. This involves working from the guidance provided in the hazard assessments, continuously monitoring working conditions and having all necessary safety equipment to prevent accidents from occurring.
If, despite the precautions, an accident does occur, employers must have in place an effective rescue capability to quickly get entrants out without jeopardising the safety of participating rescuers. Preventing these kinds of accidents starts with the identification and securing of all confined spaces and prohibiting unauthorised entry. Employers should be sure a complete hazard assessment is performed for each space on their premises and use the completed assessments to fully prepare their employees or contractors for safe entry operations.
If an employer allows entry into permit-required confined spaces, then it is critically important to have a rescue plan for each of those spaces. The old adage “proper planning prevents poor performance” is especially true when lives are at stake, and permit-required confined space entry rescue certainly fits that description. It does not matter if the rescue will be performed as non-entry retrieval or if rescuers need to enter the space to perform rescue — the need to have a clear and comprehensive rescue plan goes a long way in ensuring a successful outcome for workers. There are many reasons to have rescue plans completed for all permit-required confined spaces. First, the regulators require that the employer make those spaces available to the rescue service for the purposes of rescue planning. But more importantly, a number of confined space fatalities in multifractality confined space incidents involve the would-be rescuer.
By preplanning the strategies and requirements for a potential future rescue, the rescue team is able to perform a thorough evaluation without the pressure of having to make quick decisions, as would be the case in an actual emergency. The level of detail in a rescue plan varies depending on several factors and should be determined by the rescue service that completes the plan. Some, but not all, of those factors include: configuration of the space, immediate surroundings, location of the space, position/dimensions of entry portals, hazards of the space, personal protective equipment required, number of authorised entrants, experience of the rescue team and available rescue equipment.
When preparing rescue plans the configuration of the space will determine if non-entry rescue is feasible. It is important to get an idea of what opportunities and limitations are included in the immediate surroundings of the entry portals. What are the anchor opportunities? Is there room to operate the rescue systems or to stage breathing air equipment? Is there enough headroom to complete a vertical lift of a litter? Will an elevated rescue be required to get the victim to the ground once clear of the space? Where possible rescue should be performed as non-entry retrieval, or if rescuers need to enter the space to perform rescue, having a clear and comprehensive rescue plan goes a long way in ensuring a successful outcome. Once the rescue plans have been completed, they should become part of the confined space program and be updated and/or reviewed as conditions, team members or any other factor that may affect the plan change. But what about those spaces that are not clearly marked as confined spaces? Storage tanks, sewers, boilers, manholes, ship voids, tunnels, silos, vats and wells are locations that we commonly consider confined spaces. But there are also some areas, such as trenches (that have their own code) on a worksite and pits used to house control valves, which contain many hidden dangers.
Just because it is not marked as a confined space does not mean that workers should not exercise caution prior to entering. When you have identified a confined space or even an area you believe has the potential to be a confined space, you want to test the area appropriately before you or your workers go in, and make sure that you perform continuous monitoring to keep those who enter safe. Always remember that the gases within confined spaces will have their own molecular weight and will be found at different levels. That is why it is important to test the top, middle and bottom before entry is made. Also, do not get tunnel vision to get the job done quickly, it is more critical that the job gets done safely. After reading this, I hope that the next time you walk down the street and take a look around, you see a few confined spaces you might not have noticed before.
Richard Millar is Chief Executive Officer of the Working at Height Association, which has had confined space as an area of focus since 2016.
Image credit: ©stock.adobe.com/au/Kings Access