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Posted By col
I work for a water treatment company and have been asked to write a policy in relation to confined spaces and cold water storage tanks. The problem is if I put together a policy in relation to the regs then we would never get the work done mainly impossible to use harness etc, and would certainly be a lot more expensive than our competitors. Can anyone advise the best way forward to implement the regs and keep the directors happy(if there is a way to keep the directors happy)
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Posted By Clarke Kent the 2nd
Did I just read that right .......?
You currently don't implement the regs as it would make you more expensive and less competitively priced!!!
That's like a steel erector not using nets and harnesses so they can bid a cheaper price and be more competitive. It should never happen.
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Posted By Helen C It is a popular misconception that entry into all confined spaces must involve the use of gas detection, harnesses, escape breathing apparatus, rescue teams, standby men, winches and the like. Realistically the control measures put into place should be commensurate with the level of risk. It may be that you can make the job safe, adhere to the regulations (and cover your back) by implementing simple control measures like the use of a portable gas detector and a top man. With regard to harnesses - why is it impossible to use them? If it is becasue they may snag on the structure, then consider wearing them under a paper type overall, then in the event of an emergency the overalls can be torn to access the harness. If it is because the space is too small, then consider the fact that your operatives probably shouldn't be entering the space in the first place. Please email or call if you need advice. helen@csts.co.uk, 01925 244144.
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Posted By Andy Brazier
Helen C is entirely correct. Your policy should be that you will assess all potential confined space entry, apply a hierarchy of control (e.g. avoid where possible) and measures commensurate to risk and have specific rescue plans in place.
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Posted By col
At present we use a 2 man system, 1 in the tank and 1 out, most of the tanks are approx 2m long by 2 metres wide by 1.5 metres high, some of the tanks have fixed lids with a 500mm- 1m opening other tank sizes vary and some of the tanks can have the lids totally removed. I have worked for several water treatment companies and the local council.All of which do not use harnesses or gas detectors or any other devices....most dont even use a second man.
The company I work for now wishes to try to safeguard the work force and that is why I am asking for advice.
If the space is too restrictive to use a harness and a retrieval device the tank is GRP with no fumes as is full of water (remember that you actually fill a tank with water to expell gases) Apart from having a safe system of work and ensuring that you are in constant communication with the operative, what other preventative measures can you put in place when the tanks require you to enter
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Posted By Helen C
Hi there,
I'm still not sure why the tanks are too restrictive to wear a harness?
However, you certainly sound like you're on the way to adhering to the regulations.
One important thing to consider is the requirement to have emergency arrangements in place. I appreciate that the likelihood of an incident occurring (gas alert, collapse etc) in one of your tanks is low, but you still need to have in place suitable emergency procedures and other incidents such as heart attacks, fits etc should also be planned for.
I usually apply a hierachy such as:
SELF RESCUE - your entrant will have been trained, be following a safe working procedure they have been trained in, be using a gas detector. In the event of an incident (gas alert, feeling unwell, minor injury) they will simply stop work and get out.
NON ENTRY RESCUE - Where your operative is permanently attached to a retreival line (which may be a winch, retrieval block or similar). In the event of an incident the attendant will haul the casualty to safety.
ON SITE RESCUE TEAM - Where a dedicated team is on site standing by to carry out a rescue if required.
EMERGENCY SERVICES - should not be relied upon for anything that is foreseeable!
From what you have said, I should imagine that self rescue and non entry rescue would be sufficient.
Also consider that your attendant should have suitable confined space training (to the same standard as the entrant).
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Posted By col
all our ops are confined spaces trained and at 1 of the ops are 1st aid trained
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Posted By akm The water industry normally operate a classification system for confined spaces which then dictate the level of controls required (subject to a specific assessment). If you haven't seen the enclosed already, it might be worth a read. There is also related C&G training through Develop based in Derby. http://www.water.org.uk/...spaces-guidance-note.doc
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Posted By Phil
You must also not get reeled in on the only a confined space if a risk of gas scenario, my water is clean so its not a confined space.
Dont forget, a vessel can be a confined space due to the nature of its access and egress alone.
for example how do you recover the worker from the tank if he has an M.I and has no harness on?
Phil
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Posted By Helen C
Poor / awkward / narrow etc access into an area does not in itself define an area as a confined space.
The definition of a confined space makes no reference to size of, access into or exit out of an area. Please see below.
“’confined space’ means any place, including any chamber, 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;
‘specified risk’ means risk of –
(a) serious risk to any person at work arising from a fire or explosion;
(b) without prejudice to paragraph (a) –
(i) the loss of consciousness of any person at work arising from an increase in body temperature;
(ii) the loss of consciousness or asphyxiation of any person at work arising from gas, fume, vapour or the lack of oxygen;
(c) the drowning of any person at work due to an increase in the level of liquid; or
(d) the asphyxiation of any person at work arising from a free flowing solid or the inability to reach a respirable environment due to entrapment in a free flowing solid;
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Posted By Phil
I agree that that is the definition of a confined spaced straight out of the ACOP, however, if you do the R.A you STILL have to recover the person from the vessel (clean water or not).
And due to the nature of the access and egress, unless you take measures, ie wearing a harness and having a tripod, you would be unable to recover an unconscious casualty.
I fully agree that in the definition of the regs. it may not be a confined space. We still need to do the R.A, and if it drops out that we need mitigation measures, then we need to include them.
Phil
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Posted By safety medic
Lets not get too hung up on the definition or application of confined spaces and specified risks.
1. Why are you worried about what your director thinks? Write the policy along with the risk assessment and s/he can decide otherwise.
2. It is clear that the job needs a risk assessment. The results will be clear enough.
3. Specified risk in relation to confined space does not mitigate the need to safeguard the employee from all hazards under HSAW Act.
4. The risk assessment produced will identify any rescue provision and will form part of the policy document.
Keep it simple and dont get bogged down with terminology. To do something may be negligent but to do nothing is criminal.
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Posted By Helen C
well said
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