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Posted By Angela Oakey-Jones
Can anyone advise on whether an HGV trailer (refrigerated or otherwise) can be considered as a confined space. Staff routinely access containers and trailers with a variety of loads (e.g. rotting vegetables, fish etc) to recover items are concealed (e.g. cigarettes) The atmosephere can be odourous, but I am uncertain whether oxygen levels can be compromised. I'm trying to decide whether these environments could be harmful and require engineering-type controls or whether they pose little threat to health. If the confined spaces regulations apply, I'll need to factor in those requirements too.
Kind regards
Angela Oakey-Jones
HM Customs & Excise
Law Enforcement
London
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Posted By Robert Whent
Angela,
Any trailer could become a confined space. If it is foreseeable that the atmosphere could be compromised (and from what you describe it could be) then the regulations apply.
This shouldn't worry you though. A simple gas test would provide information on the state of the respirable air and thus tell you what precautions you need to take. You do need to be careful of this changing as you disturb any debris as this may then allow trapped pockets of gas to escape. You probably need to assess the likelyhood of methane and hydrogen sulphide being present(as a result of the decomposition of organic matter) as well as the possibility of low oxygen. Again not too difficult as most triple gas monitors would be pre-set to test for these.
As a further precaution you may wish to introduce fresh air into the backs of the trailers by using forced air ventilation or get the employees to wear air-fed hoods (easier to manage in your case than masks). Training for all of this is simple and available from many suppliers.
Confined spaces tend to be held in awe as they are outside the normal daily working environment for most of us, but if you assess the risks systematically and ensure that the employees are well trained, most are no more difficult to work in than 'normal' environments. The others are right *******s!!!
Any help I can give, e-mail me direct.
Rob
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Posted By Ian Bruce
Angela,
In my opinion they are definetely confined spaces - the Regs do apply.
You will need to risk assess the access routines that your employees (and others) use. It may be sufficient to prepare a safe system of work for this entry so that you don't have to go through the pain of permits for every occassion; if there is regular access.
In a previous job, we used containers for storage and I prepared a safe system of work for access and use. If you would like to see this, please e-mail me and I'll forward it to you; it may be of use if you develop your own.
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Posted By Jim Walker
Freight containers and their loads reacting with oxygen is specifically mentioned in INDG 258, (but not in the regs, so far as I can see).
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