Posted By Richard McLellan Folks We have two cranes on our offshore installation which are mounted on steel pedestals. At the top of each of these pedestals there is a small store accessed by a hatch in the wall (like a ships bulkhead door. Hatch is big enough to step through rather than climb, so egress is easy. The store is about 10 foot high and 10 foot in diameter and contains small fittings, antifreeze, lube oils, greases etc. The space is unventilated. The store is accessed daily by the crane operator / mechanic. Interestingly, there is a 1 foot diameter hole in the floor which communicates with the rest of the circular steel pedestal below (about 50 feet high column of unventilated space). The question is should we classify the small store as a confined space? The oils and greases have zero vapour pressure at room temperature, there are no fuel, gas, exhaust or other pipes in the spaces. Pedestal base is dry, but water could gather at bottom ? H2S generated. Little rust seen, so no oxygen depletion. Reviewed CSR 97 and company procedures for 'reasonably foreseeable risk of serious injury from hazardous substances or conditions within the space'. My feeling is that I can rule that CS precautions are not required if I exclude volatile flammables (guidance on this would be welcomed) and daily checks that bottom of pedestal is dry (look down hole with torch) It is not possible to fall down the hole in the floor due to large diameter wire in centre. Confined space or not? Your opinions are welcomed Thanks Richard

Posted By Richard McLellan The walls are a structural element of the crane so we cannot cut holes in the walls. We could replace the door with a mesh one but then the weather would get get in. Richard

Posted By Richard McLellan Frank, The problem in my offshore world is that if it is defined as a confined space (due to possibility of hazardous conditions)then we have a whole raft of controls that must be put in place. Entry by permit only, gas testing before entry, standby man, , radio comms, emergency response equipment on site etc etc. There is no leeway, if it is a confined space, we must do this. Not your normal daily precautions for going into the store for a grease cartridge. So, an unventilated store becomes a confined space when there are sufficient hazards to cause forseeable risk of serious injury. I am interested in other practitioners opinions of the forseeable risk of this space. I would prefer good scientific justification, but I will settle for wildly unsubtantiated opinion - in the interests of maintaining consistency with normal safety practice (but not yours Frank!)

Posted By Richard McLellan Although it is unventilated, it is full of air. When the man opens the door and enters, there will be air exchange across the door and he will not use a significant amount of the oxygen in the room. An onshore analogy would be a store room with no airbricks in the walls - only the door for ventilation. After 9 years of using the store daily the air tests at normal O2 levels. I suppose my main concern is build up of hydrocarbon vapours in event of spill of oils, or h2S from stagnant water at bottom of column. As far as providing a storage cupboard, perhaps I did not explain clearly that the store is at the top of a crane pedestal on a north sea oil rig. We cannot put / build a store outside a the same level (no space and awful weather). The alternative is keeping everything in the main stores, but that involves much manual handling and inconvenience as the stores are several vertical ladders and a long way away.

Posted By Crim Hi Richard, I have only a little knowledge of the C S Regs, but I do seem to remember a secondary means of escape is required and it would appear difficult to provide a means of escape in your location. I would look to be within the Regs. but use BATNEEC to avoid undertaking any expensive alterations as it does appear to be quite a safe area and you are being very thorough in your risk assessment.

Posted By jay2005 Hi There, Why not take a confined space detector into the area. Costs about £400 and test the air? We recently purchased one form A1 Safetech. I think their website is www.a1-safetech.co.uk

Posted By Stuart Nagle Richard Yes, the procedures you define above are 'top-heavy' for what if anything would normally be regarded as a low risk confined space on-shore (if at all). The problems associated with off-shore work though are often high risk, and it is not unknown for apparently safe environments to become unsafe very quickly given a set of unusual circumstances. Would it not be possible to fit an 02 monitor inside the space that could be read from outside the space? this may alleviate the problems of indecision in whether the space is safe to enter, and remove the need for a confined space entry procedure to be in place, leaving no doubt of the quality of the atmosphere inside the space (unless there are other concerns over gas,fume and vapour that the 02 would not responde to?) In addition, is there no capacity to formulating a categorised confined space procedure (e.g. low risk, moderate risk and high risk confined space procedure), where a space is assessed in relation to the precautions necessary to permit safe entry? this may be a way forward in these circumstances rather than adopting a one case fits all category, which clearly it does not! Regards... Stuart