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#1 Posted : 09 November 2006 16:02:00(UTC)
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Posted By James Midlake
All

I am currently doing a review of our "confined spaces" but have managed to confuse myself on a couple of them so far:

The first is a space approx 6 feet deep and 12 feet long. This is a concrete lined pit with a removable metal sheeting lid arrangement. The lid is completely removed prior to work commencing making the space fully exposed to the outside air. Engineers need to access the space to perform electrical work ( not live work ). The pit is clean and the walls and floor are sound. Confined space? My gut feeling is no. Access & egress is by fixed ladder.

The second is a vehicle inspection pit. I am more concerned with this as I suspect that engines may be running in the area at times and oily deposits tend to be left to build up in the "drip tray" under the grating style floor. Has anyone got any experience with vehicle inspection pits? Would appreciate comments on what is best pratice in this area.

Many thanks.

Midlake
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#2 Posted : 09 November 2006 16:19:00(UTC)
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Posted By David Bannister
My view is that both should be considered a confined space on the basis that there is a foreseeable chance for heavier-than-air gases and vapours to accumulate down there and displace the breathable oxygen. Once there they probably have nowhere to go except in to the lungs of the next person in there. CO2 is a particular killer and is most likely from a vehicle exhaust.

Sorry to sound dramatic but CO2 asphyxiation is deadly.

HSE website has very good info on controls.
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#3 Posted : 09 November 2006 16:24:00(UTC)
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Posted By Kenneth Patrick
David is giving you poor advice.The first case does not meet the crtiria for a confined sapce from the information you have given. It could be if there was heavier than air gases around.
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#4 Posted : 09 November 2006 16:32:00(UTC)
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Posted By Norman T
To be a confined space, the space must be substantially enclosed, and there must be a reasonably foresseable risk of serious injury from hazardous substances or conditions within the space or nearby. (almost direct quote from L101 Safe Work in Confined Spaces)

So just because there is a pit doesn't mean it is a confined space - it might be a confined space sometimes, e.g. if a certain type of work is being carried out there.

So you have to decide whether the space is likely to become dangerous - could it, and why?


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#5 Posted : 09 November 2006 16:33:00(UTC)
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Posted By James Midlake
Guys,

In the first example the chances of any gas getting into the space are next to zero ( or at least I think so ). The only chance of this I could see would be if someone parked next to it and left an engine running ( very unlikely due to the position of the space and working procedures anyway ).

What about the vehicle inspection pit - any experts on line.

Midlake

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#6 Posted : 09 November 2006 16:46:00(UTC)
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Posted By Andy Brazier
People tend to get confused between a confined space and the perceived need for controls. In other words, they avoid defining something as a confined space (when it should be) because the company system says you need a Permit-to-work and that seems to be over the top.

Both examples sound like confined spaces to me. The first one needs to be considered on at least two fronts:
1. How would you get someone out if they fell ill?
2. A hazard may result from the task being performed.
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#7 Posted : 09 November 2006 16:47:00(UTC)
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Posted By Paul Leadbetter
Midlake

A vehicle inspection pit could easily be a confined space under the Regs due to the ingress of exhaust gases, petrol vapour, etc.

Paul
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#8 Posted : 09 November 2006 16:47:00(UTC)
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Posted By Pat Hannaway
Hi James,
the inspection pit is almost certainly a confined space. Not only is there a risk of build up of spilled fuels, lubricants etc, but if the pit is in a workshop or close to where vehicles are serviced / tuned, there is a strong possibility of build up of toxic exhaust fumes, Nitrous Oxide / Dioxide, and also (possibly) welding fumes from nearby work.

You can get full details in HS(G)67,Health and Safety in Motor Vehicle repair.

Pat H
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#9 Posted : 09 November 2006 16:50:00(UTC)
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Posted By Catman
Hi James

I would not get too tied up on what it is called and simply assess the risks. Sorry if you have already considered the aspects below but this is how I would approach it.

Does your place of work have LPG, solvents, paints, thinners etc present? Fumes/gases like these could migrate into the pit. In that case how is ventilation achieved?

Is the pit fitted with suitable lighting in terms of IP rating and explosion rating? What power sources are permitted for use in the pit and are they suitable?

Have you considered lighting, fire fighting measures, slips & trips when the sump grating overflows, hot work on vehicles, any painting/sealing the underside of vehicles in the pit, work on air con systems etc.?

Falls into the pit, how are they prevented, is the pit covered when not in use, is there clear lighting and warning lines around the pit?

When the pit is cleaned what chemicals are used and do they present a hazard in the given situation?

There will be more than this, but that would be my approach, call it a confined space or not as you desire, but make sure you have controlled the risks.

Cheers
TW
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#10 Posted : 09 November 2006 16:52:00(UTC)
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Posted By Mark Stewart
James

In relation to your first location. I would class it as a confined space.
As a qualified approved electrician and a health & safety officer I have come across this and actually carried out similar work myself.
You have to remember that concrete is a porous material. May look nice and clean but gas can penetrate it and buildup (possibly causing Asphyxiation). As others quite rightly pointed out, the chances of this are remote but there still is a chance. Also what if something happens to the operatives carrying out the work. Can you treat them normally? (No). Does special rescue techniques / equipment required? (Maybe). All this constitutes the area being a confined space.
Just to clarify, a confined space doesn't necessarily need to be a small volume / area. Example: If a new floor is being lay-ed to a large hall and is being glued down, does that not make the area a confined space (because of the fumes, not the area it is in), even though it is a large area?

Regards

Mark Stewart
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#11 Posted : 09 November 2006 16:58:00(UTC)
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Posted By Norman T
I agree with much of the above - I also agree that the first pit could become a confined space depending on the work being carried out.

We may agree that during the work you describe - engineers going in to carry out work - then it isn't a confined space; but if different work in future is carried out then it might be a confined space.

I also agree that we shouldn't get hung-up on the 'confined space' designation - when a certain work is being done (now or in the future) could the pit become a dangerous place do to its atmosphere, access/egress, etc....etc

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#12 Posted : 09 November 2006 16:58:00(UTC)
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Posted By Charley Farley-Trelawney
James

I am certain you will have this, but just in case: http://www.hse.gov.uk/pubns/indg258.pdf

I apologise if you already have this document but it is always difficult to know the exact background when attempting to answer a question.

The first part identifies an area that one may deduce immediately falls into the category of a CS, although there is the one opening clearly it would seem large enough to enter and egress an both ends, is this two points of escape? What % does the opening form as a % of the total space? With the electrics there are of course issues and reg 3 of the management regs starts to kick in, as does a PTW issue, again I don't what your situation is so am probably teaching you to suck eggs and I apologise for that.

With regards to the pit there is of course a plethora of information available, including the following link from the HSE which again you probably have but I will include it for you anyway. http://www.hse.gov.uk/ri...casestudies/mvrepair.pdf
http://www.hse.gov.uk/mvr/index.htm

Health and Safety in Motor Vehicle Repair HS(G)67 ISBN 0-7176-0483-7 (HSE) - (£5.50) could be of use.

Don't hesitate to come back with further questions.

CFT
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#13 Posted : 09 November 2006 17:00:00(UTC)
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Posted By William
Here are a couple of definitions of confined space from google.

Any enclosed area with only one entrance, and/or where hazardous vapour, dust or fumes may accumulate, and/or where oxygen may be deficient,

is any space that is large enough and so configured that an employee can bodily enter and perform assigned work, has limited or restricted means for entry or exit, and is not designed for continuous employee occupancy.

So i would say yes on both counts.
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#14 Posted : 09 November 2006 17:01:00(UTC)
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Posted By James Midlake
All

Many thanks.

If I say both spaces are confined spaces what are the emergency rescue implications?

In a drain you would have your man on a harness connected to a winch. This would not be very practical in either of my spaces as people need to move about and work ( hold on I sound like the engineering manager!!! ). Would you make breathing apparatus and a winch available, therefore if someone collapsed in the space from causes unknown you would get suited up and go in after them and connect them to the winch?

Midlake
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#15 Posted : 09 November 2006 18:04:00(UTC)
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Posted By Merv Newman
James,

whether or not the first example is a CS is debatable (see debate above) Do the RA and make your decision. I would tend to play safe.

If you do decide that CS entry is required then you have to go the whole hog. Management approval (signed at (not in) the CS), watcher equipped with means of rescue and of summoning the alarm. Signing in and out, atmospheric testing before each entry, ....


And in case of problem the watcher summons help but DOES NOT ATTEMPT A RESCUE BEFORE THAT HELP ARRIVES.

Confined spaces are reputed to kill three people ; the worker, the guy who sees his mate in trouble and tries to help, the passer-by who, some time later, sees two people lying at the bottom of the tank and goes to help.

Merv
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#16 Posted : 10 November 2006 09:14:00(UTC)
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Posted By James Midlake
All

Many thanks to all who have responded.

I am slightly clearer on how to approach this but still confused over rescue arrangements.

The ACOP doesn't help much ( ! )

If ( following risk assessment, gas testing etc ) I allowed work to continue in these spaces how would I recover someone? Remembering that it would not be practical to wear a safety line and harness in these spaces due to the nature of the work?

Midlake
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#17 Posted : 10 November 2006 09:21:00(UTC)
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Posted By Andy Brazier
Merv
Sorry, with all due respect, I can not agree with your statement that if it is a CS you need to go the whole hog. The key, as always is risk assessment. There are low and high risk CS, and there are some very high risk where your suggested precautions would be totally insufficient.

Sorry - this is one of my hobby horses. The trouble with this whole hog approach is people spend too long trying to argue something is not a CS so they can avoid putting the onerous precautions in place.

No doubt plenty of people will disagree with me.

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#18 Posted : 10 November 2006 11:07:00(UTC)
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Posted By Andrew Beveridge
Hi James,
If the 'pit' is open across the whole of its top, why will the wearing of a harness be a problem?
The use of a retrieval winch that acts like a seat belt and is 'free running' most of the time would appear to be the solution. This needs to be attached to an appropriate anchorage, which could be a tripod or gantry or any other suitable point. It 'snatches' if there is a fall. If the faller can 'self recover' (ie slipped onto one knee and got back up with no injury) the winch will continue to act in free running mode. If the faller collapsed, the rescue operative on the surface can convert the winch to winding mode and wind the faller out of the hole. (Other procedures in support of this will be needed; constant air monitoring in the hole, trained rescuer, etc, etc.)
We have this system in sucessful operation and I would be happy to discuss it further with you if you think it would help. Please feel free to contact me off forum.
Good luck!
Regards
Andy
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#19 Posted : 10 November 2006 12:00:00(UTC)
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Posted By Philip Harrison
James,
They both could be confined spaces, see previous entries, however what is the forseeable risk. Would you consider testing the atmosphere prior to entry?
Regards
PH
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#20 Posted : 10 November 2006 14:53:00(UTC)
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Posted By Gwahir
Hi Guys,

I always use this:-

1. Contains or has the potential to contain a hazardous atmosphere;

2. Contains a material that has the potential for engulfing an entrant;

3. Has an internal configuration such that an entrant could become trapped or asphyxiated;
or
4. Contains any other serious safety or health hazard.
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#21 Posted : 10 November 2006 15:56:00(UTC)
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Posted By William
James here a couple of ideas for when entering a confined space.

First of all have any emergency procedures planned and have all employees involved aware of these.

Decide what equipment is to be used, you have mentioned a harness and winch, which would be best, also a gas test done before he enters and a gas monitor onsite for continious gas monitoring. An emergency BA set with around 20 minutes of air would be a good idea as well as if the gas monitor went off the first thing to do would be put that on and then escape.

A standby man must be positioned in a safe place at the worksite where he can see or speak to the worker in the CS. It must be pointed out to the standby man that he cannot leave the CS area not matter how briefly and he is not there to do anything else than keep watch over the worker in the CS. As someone else has rightly pointed out if the worker in the CS " DO NOT ATTEMPT TO RESCUE UNTIL HELP HAS ARRIVED" as the last thing any rescue team needs is 2 people to rescue instead of one.

A rescue team would use a minimun of 2 people both first aiders, both using full BA sets, if the worker is not clipped onto the winch at least have him with a harness on so the rescue team could clip him on, and also have a winch outside the CS.

I can remember a case from when i was studying when 1 man collapsed in a Cs, so the standby man went into rescue him, and he collapsed, then the safety officer went in and he collapsed, i guess that the perfect example of why you use the right procedures.
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#22 Posted : 10 November 2006 16:38:00(UTC)
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Posted By James Midlake
Merv, All

Thanks - I'm with you I think ( ! ).

On both examples I don't think going the whole hog is necessary but I don't have enough experience in this area to feel very comfortable with my decision!

The risk of collapse from lack of oxygen etc I think is very low ( providing engines in the area are turned off ). The risk from the work being conducted is generally low ( providing in the first instance the lock out / tag out is done ). If someone collapses in the pit it will be from causes unknown. What is the best emergency plan to have? Under these circumstances can you simply rely on a call to the emergency services? Is the winch ( or similar ) an absolute requirement?

Midlake
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#23 Posted : 10 November 2006 16:50:00(UTC)
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Posted By William
If they collapsed you would need some way of getting them out so the worker having a harness on and a winch onsite would be best, as the person working may just go over their ankle and not be able to get up the ladder and not require the fire brigade to rescue them. In the event of the worst case scenario it would be best to have all the equipment onsite, both for rescue and legal reasons.
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#24 Posted : 10 November 2006 17:05:00(UTC)
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Posted By p winter
here's something to think about - a pub cellar with cylinders of gas confined space?
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#25 Posted : 10 November 2006 17:07:00(UTC)
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Posted By p winter
Is a pub cellar a confined space? Discuss.
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#26 Posted : 10 November 2006 17:08:00(UTC)
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Posted By p winter
sorry I posted twice
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#27 Posted : 11 November 2006 07:01:00(UTC)
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Posted By jom
Just install a fan.

John.
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#28 Posted : 11 November 2006 07:58:00(UTC)
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Posted By p winter
Hi John - so the answer is a yes - it is a confined space and because of the CO2 cylinders which could leak there is a foreseeable risk and An appropriate means of controlling the risk is ventilation?
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#29 Posted : 11 November 2006 08:33:00(UTC)
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Posted By Adrian Watson
Dear All,

Let's go back to basics:

the confined space regulations 1997 states space" means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk; and

"specified risk" means a risk of -

(a) serious injury to any person at work arising from a fire or explosion;

(b) without prejudice to paragraph (a) -

...

(ii) the loss of consciousness or asphyxiation of any person at work arising from gas, fume, vapour or the lack of oxygen;

...

So the simple question is there is (a) serious injury to any person at work arising from a fire or explosion in the pit. If the answer is yes then the Confined space regulations 1997 apply.

If the regulations apply then regulation 4. - (1) states that "No person at work shall enter a confined space to carry out work for any purpose unless it is not reasonably practicable to achieve that purpose without such entry." This effectively bans the use of a vehicle inspection pit if the regulations are deemed to apply.

So the questions are does the pit have:

Means of access and egress?
Is there intrinsically safe lighting and electrics?
Are training leads used?
Are the air powered tools used fed from a pressure line? (no petrol compressors)
Are engines run with persons in the pit?
Is the pit ventilated?
Are fuel spills immediately dealt with?

If the answer is yes then it is not a confined space as there is no reasonably foreseeable specified risk.

Regards Adrian Watson
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#30 Posted : 11 November 2006 08:34:00(UTC)
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Posted By Adrian Watson
Dear All,

Let's go back to basics:

the confined space regulations 1997 states confined space" means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk; and

"specified risk" means a risk of -

(a) serious injury to any person at work arising from a fire or explosion;

(b) without prejudice to paragraph (a) -

...

(ii) the loss of consciousness or asphyxiation of any person at work arising from gas, fume, vapour or the lack of oxygen;

...

So the simple question is there is (a) serious injury to any person at work arising from a fire or explosion in the pit. If the answer is yes then the Confined space regulations 1997 apply.

If the regulations apply then regulation 4. - (1) states that "No person at work shall enter a confined space to carry out work for any purpose unless it is not reasonably practicable to achieve that purpose without such entry." This effectively bans the use of a vehicle inspection pit if the regulations are deemed to apply.

So the questions are does the pit have:

Means of access and egress?
Is there intrinsically safe lighting and electrics?
Are training leads used?
Are the air powered tools used fed from a pressure line? (no petrol compressors)
Are engines run with persons in the pit?
Is the pit ventilated?
Are fuel spills immediately dealt with?

If the answer is yes then it is not a confined space as there is no reasonably foreseeable specified risk.

Regards Adrian Watson

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#31 Posted : 11 November 2006 08:52:00(UTC)
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Posted By Adrian Watson
Just a quick addendum CO2 may kill you but not from a vehicle exhaust! That is CO (Carbon Monoxide). The LCLo for CO (Carbon Monoxide) is 5,000 ppm for 5Min. Petrol vehicle exhaust emissions may contains around 1-3% CO!
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#32 Posted : 11 November 2006 12:03:00(UTC)
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Posted By p winter
Good posting Adrian - the question I posed about pub cellars was not intended as frivolous. These are enclosed and there is a reasonably forseeable risk of a leak of CO2 (is it a significant risk - probably not, is it reasonably forseeable - it is.)

The reason for my posting is my frustration at others who seem to see confined space risk as opposed to an enclosed space where none exists and this often creates elaborate and sometimes unnecessary precautions. I agree you should not take chances with confined spaces - but suggest we need to be careful defining such a space.
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#33 Posted : 13 November 2006 14:53:00(UTC)
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Posted By James Midlake
All,

I'm still confused.

Standby breathing apparatus and a winch for someone working in a vehicle inspection pit?

Where the risk is low ( space one in my original posting ) what would be the minimum emergency procedures to have in place?

Heeeeelpppppp!!!!!!!

Midlake
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#34 Posted : 13 November 2006 16:10:00(UTC)
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Posted By Jeffrey Watt
P Winter

Cellars? Depends on the cellar.
All our Quality technicians had personal CO2 alarms worn on the waist.
We worked out that in our customers premises that multiple cylinders would have to fail to dilute the atmosphere to a dangerous level, all had louvres for general ventilation.

By the same token two men died in an excavation from CO2 asphyxiation when they dug a trench on brewery premises in England (I will not say which one)No vehicles, no genny running just litres of CO2 in the fabric of the soil from generations of brewing on the site.

No help I know.

Jeff
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#35 Posted : 13 November 2006 16:46:00(UTC)
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Posted By William
i think we may be getting our wires crossed here james when i say winch i am not meaning a large mechanical machine, more a retriever set which you would use for someone working at height, we all know the type, the one which could be used as a fall arrester but also has a handle on the side so if they were to fall you could retreive them, one of those mounted on a load bearing beam or suitable tripod stand would do the trick. Also a gas monitor onsite would also be best and a gas check carried out prior to work starting and continually monitored using the gas monitor onsite, a BA set onsite would probably not really be required so long as you dont have any chance of H2S or other gases that could cause any effect before you evacuate the area.
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#36 Posted : 13 November 2006 16:56:00(UTC)
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Posted By David Bannister
It is my understanding that CO2 is generated by combustion of fossil fuels as well as CO, the proportions and quantities depending upon the efficiency of the comnbustion process.

Furthermore, CO2 is particularly dangerous as it not only displaces breathable oxygen but also has acute systemic effects that lead to rapid collapse due to heart failure. That is why old type CO2 flooding systems in computer suites had to be locked off when people were present.

Please don't underestimate the possibility and severity of harm from this source.
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#37 Posted : 13 November 2006 17:02:00(UTC)
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Posted By Catman
Hi James

I dont think you are going to get an answer on this, at least not as specifically as you are asking.

The emergency procedures will be determined by the outcome of your risk assessment, in your workplace with your procedures, it is nigh on impossible to prescribe appropriately without detailed assessment on site.

I would use all the info already given above & the HSE guidance, compare it to your situation and form my procedure which will be specific to you and you will be able to stand by it with confidence in the knowledge that it is well thought out, not just prescribed from a leaflet or website.

Sorry if that does not help much!!

Cheers
TW

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#38 Posted : 13 November 2006 17:25:00(UTC)
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Posted By James Midlake
All

I'm still stuck on the rescue.

If I judge the risk as low. If I take gas / oxygen readings. If the access is good. If the ventilation is good. Can I then say that my rescue arrangements are simply to rely on the emergency services?

In short, must I have some way of getting a person out of the space myself.

Midlake
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#39 Posted : 13 November 2006 17:43:00(UTC)
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Posted By p winter
Hi Midlake - don't think you can rely on the Emergency Services for this. If you need a rescue procedure - which I am doubtful about - then you need it there and ready

Pete
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#40 Posted : 13 November 2006 19:31:00(UTC)
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Posted By Pugwash
James
Are you confused by all this? I certainly am! Is there a mention of confined spaces in HSG67? Not that I can find! I think I would be much more concerned that people are going to fall into these pits once you have opened them up than I would be about the likelihood of an unbreathable atmosphere developing.

If these pits are not visited very often, I would open them up, check the air with a gas monitor and then make the assumption that because (1) the air is breathable at the start of the operation and that because (2) the work to be carried out in the pits will not make it unbreathable, there is no foreseeable risk of an unbreathable atmosphere developing and therefore these are not confined spaces for the duration of this work. (Do make sure that the work to be carried out by the engineers will not affect the atmosphere - no welding, cutting, use of chemicals etc). No need for harnesses, no need for rescue arrangements etc etc.

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