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#1 Posted : 29 August 2008 12:17:00(UTC)
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Posted By mark limon
Would you define a person working inside in a steel conical cylinder approximately 15 foot high and about 12 foot diameter with holes in the bottom about a foot diameter with the only access from the top.It is completely open at the top with no gas,liquid and flowing substances to worry about.The means of access is via a ladder properly attached
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#2 Posted : 29 August 2008 12:23:00(UTC)
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Posted By graeme12345
Mark, it can be any space of an enclosed nature where there is a risk of death or serious
injury from hazardous substances or dangerous conditions (eg lack of oxygen).

so if you are it is
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#3 Posted : 29 August 2008 12:26:00(UTC)
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Posted By A Campbell
Mark,

you don't mention of what is inside this cylinder, what work is being carried out, anything that may cause fumes, dust etc?
Lone worker? Has this been risk assessed apart from the question you are presenting?
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#4 Posted : 29 August 2008 12:27:00(UTC)
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Posted By NJS
it certainly sounds enclosed to me!
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#5 Posted : 29 August 2008 12:47:00(UTC)
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Posted By anon1234
I'd say it is - but you may be able to declassify it by ensuring appropriate checks are made at the outset and that controls ensure the situation cannot change due to either the work activity, or other activities outside
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#6 Posted : 29 August 2008 13:12:00(UTC)
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Posted By mark limon
There is no lone worker issues or hazardous substances or fumes.I have my own idea but it is always good to hear other peoples.
The process carried out creates no further hazards by it taking place in this location than it would if it was in the open.
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#7 Posted : 29 August 2008 14:58:00(UTC)
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Posted By Andrew Beveridge
What works are likely to be carried out inside the cylinder, as these will have a bearing on safe atmosphere etc?

I would suggest that you will also need a rescue plan.
Regards
Andy
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#8 Posted : 29 August 2008 15:22:00(UTC)
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Posted By Adam Worth
I'm confused why the urge to declassify it, by now you could have filled out the permit and written the risk assessment :) ?

Of course it's a confined space as its nature leads to an increased risk as it's hard to escape.

Imagine having a heart attack inside, how would you get out?

Imagine a fire outside - how would you get out?

Think worst case and go from there!

So as said above you need a risk assessment that considers the hazards presented by a confined space ensuring you consider things such as escape!

Thanks goodness Friday is almost over!

OH and Happy Birthday Michel Jackson - ShamoOoo!
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#9 Posted : 29 August 2008 15:24:00(UTC)
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Posted By D H
A confined space is defined as somewhere that has a restricted agress and egress. It may also fill with fumes or dust etc that may cause a reduction of oxygen.
INO - what you have described is definately a confined space so there fore the Regulations apply.

Dave
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#10 Posted : 29 August 2008 15:33:00(UTC)
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Posted By Kenneth Patrick
There is a very clear HSE leaflet on this topic INDG 258. From Mark's description this is clearly not a Confined Space but if he reads this he will be able to determine if he has circumstances that would make it so.
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#11 Posted : 29 August 2008 16:01:00(UTC)
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Posted By Fornhelper
Mark

I would avoid 'think worst case and go from there' and tend to think 'what could reasonably be expected to go wrong' and go from there.

If the work is short duration ...say 1 - 2 hours.. is it reasonable to take precautions for the possibility of someone having a heart attack, a fire breaking out within the '2 hour window of opportunity' (given you stated that there is no obvious hazardous task being carried out) - I think not.

I'll put my neck on the line....given the detail we have I wouldn't class it as a confined space.

My office is no bigger than some of the modules I used to work in when working in shipbuilding but my office is certainly not a confined space but these modules would be due to potential gases / working conditions. Just because somwhere is enclosed or has limited access doesn't automatically mean it is classed as a 'confined space' within the context of the legislation

Beer time !!!

Regards
FH

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#12 Posted : 29 August 2008 16:22:00(UTC)
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Posted By Ron Hunter
I refer you to the Confined Spaces Regulations 1997 (from opsi website)
"confined space" is a defined term and 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;

"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) -
(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 arising from 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 by a free flowing solid.

From what you describe then ( and not knowing what the task is) I suggest that this IS NOT a confined space as defined.
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#13 Posted : 29 August 2008 16:38:00(UTC)
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Posted By anon1234
That was where I was coming from earlier. It could be a confined space but it can be declassified from being a confined space on the grounds that none of the sort of aforementioned issues are reasonably foreseeable
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#14 Posted : 29 August 2008 17:07:00(UTC)
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Posted By Paul Leadbetter
It is without doubt an enclosed space but not necessarily a confined space (see definition above).

Paul
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#15 Posted : 30 August 2008 07:41:00(UTC)
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Posted By bill strachan1
So what is an enclosed space then??

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#16 Posted : 30 August 2008 22:03:00(UTC)
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Posted By Pete48
An enclosed space is one that may give rise to a confined space dependant on a number of factors. I would say that the original poster is asking that question.

He has recognised that an assessment of this working space is required due to the fact that it is an enclosed space.
He has outlined specifics which he questions might rule it out as a confined space as defined in the regs and guidance (A confined space is a place which is substantially enclosed, though not always entirely, AND where serious injury can occur from hazardous substances or conditions within the space or nearby (e.g. lack of oxygen).

However, he has not told us the nature of the work that might require entry to this enclosed space. That work may indeed make this a confined space. Furthermore, we do not know what the adjacent processes or works are and which may give rise to the risk of serious injury.

So, it may be or it may not be a confined space but as Paul suggests it is definitely an enclosed space and therefore requires careful consideration.
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#17 Posted : 31 August 2008 04:19:00(UTC)
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Posted By bill strachan1
Thank you. That makes sense.
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#18 Posted : 31 August 2008 13:03:00(UTC)
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Posted By mark limon
I purposely did not describe what the process taking place was other than to say it was not exacerbated by it taking place in the cylinder.
There are no fire,gases,,liquids,substances,processes or anything else to cause any more harm in the cylinder than they would outside in the open.
All the risk assessments that need to take place for activity outside ,around and over the cylinder are in place.
There is a new piece of kit that is being introduced that doesnt introduce any real hazards in fact it reduces them significantly
This is a change that requires a review of the current risk assessments which were last done some years ago.Since then new legislation has been introduced and this is being taken into account.
The need to possibly have to remove someone ill or injured is being taken into account,my question was and still is

"Would you define a person working inside in a steel conical cylinder approximately 15 foot high and about 12 foot diameter with holes in the bottom about a foot diameter with the only access from the top.It is completely open at the top with no gas,liquid and flowing substances to worry about.The means of access is via a ladder properly attached"

As usual there is a variety of opinions which I thank you all for.

Although I am confused a little by Adam Worths confusion

"I'm confused why the urge to declassify it, by now you could have filled out the permit and written the risk assessment :) ?"

Where in my post Adam can you glean that I have an urge to de-classiffy anything.I asked for an opinion from the many knowledgeable people on this site to make sure that not only is the risk assessment suitable and sufficient to comply with current legislation but also everything possible is taking into consideration to make the working enviroment as safe as possible.
Please read my post lines and not between them,
Mark
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#19 Posted : 31 August 2008 16:14:00(UTC)
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Posted By Pete48
Mark, sorry I did realise after I posted that I hadn't read your post closely enough.
To confirm my view: Provided that you have assured that the second, and most important part of the definition of a confined space could not or cannot occur in any foreseeable situation, then I would classify it as enclosed but outwith the confined space definitions. An opinion based solely on your notes of course.

This is a good question about a subject that is much misunderstood IMHO. All too easy to go "over the top"--excuse the pun.
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#20 Posted : 31 August 2008 17:29:00(UTC)
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Posted By D H
Hi people - can we clarify a few things.

Are the holes at the bottom escape routes?
Can we safely evacuate someone who falls ill quickly and easily?
Do we employ a standby man?
Have we taken into account the WAH Regs?
Would you be happy to stand in a court of law and state this is not a confined space?

If the answer to the above questions is yes - apart from the standby man - then I suggest we have a potential high risk activity

As in all safety matters it is the perception of risk that is important and a lot of people here have stated their perception on the limited information given. But how can people give a reasoned argument on the information provided - without actually seeing the task.

Mark - you decide - your job mate.
But I would suggest before you are asking the question - you are also unsure. And the replies you have had would not stand in a court of law either.

Good luck!

Dave
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#21 Posted : 31 August 2008 21:08:00(UTC)
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Posted By mark limon
Thankyou for the help,it has confirmed what I was thinking especially the WAH regs.I didnt describe the task being carried out because in this case the main issue is the location.
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#22 Posted : 01 September 2008 09:29:00(UTC)
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Posted By Pete48
D H, I would be more than happy to meet you in court.
I think that you have, as many others often do,confused work in an enclosed space with work in a confined space. Unless life has changed greatly, confined spaces have always been about the atmosphere that may or could develop within.
I agree with your list of hazards and some of the controls but they are not specifically relevant to a discussion about a confined space(thet title of the thread). They belong in the RA for entry to an enclosed space and nothing more.
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#23 Posted : 01 September 2008 10:52:00(UTC)
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Posted By Tabs
Dave your comment "And the replies you have had would not stand in a court of law either." only applies to those which seem to describe it as a confined space.

Given the information and clarification of the original poster, the space does not meet the legal description of a confined space (kindly reproduced above) and a court cannot change that definition to take into account difficulty of rescue, etc.

Colleagues suggesting proper arrangements suited to the risk are correct. I am not sure about the term "declassify" but let's suggest that just because a tank is not a confined space, it doesn't follow that a permit is still not the best option for a safe system of work.

Permits are for high risks, and it is up to the company if they want to apply outside of the classic descriptions (we do).

Confined space no - high risk, sounds like it, case for Permit, I'd say so.
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#24 Posted : 01 September 2008 11:05:00(UTC)
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Posted By D H
Thanks people - I stand corrected

Dave
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#25 Posted : 01 September 2008 12:40:00(UTC)
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Posted By Stewie
Classify the area as confined, apply the necessary precautionary measures, and hey presto a safe situation even if it is not a confined space.
There should not be an argument from a safety perspective on this, but an argument from a cost cutting perpective could materialise....
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#26 Posted : 01 September 2008 13:07:00(UTC)
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Posted By graeme12345
so waste time which = money needlessly then

Mark, as they are not already there, if you are creating any of the significant risks it is, if you are not it is'nt
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#27 Posted : 02 September 2008 10:47:00(UTC)
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Posted By Pete48
Stewie, I disagree with you, there is an argument about your approach because it is using one set of risk controls for a different risk. It would promote the use of the essential high level risk controls in much lower risk situations. That devalues those risk controls over time and introduces a risk of confusion and over protection for a lower risk task.
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#28 Posted : 02 September 2008 13:25:00(UTC)
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Posted By Robert K Lewis
Mark

A neatly worded question in which key information is omitted. You give a single diameter rather than the two required if describing a conical space, together with an indication of wwhich is which at the top. You imply also that people will simply enter the space and fail to provide information concerning natural ventilation potential for the air in a space or for how long the entry will take place.

In free space the volume of air I breathe is irrlevant to the percentages that are present - in an enclosed space this is not so and you must provide information with a degree of precision before any judgements can be made on whether the space is confined. Remember that a confined space is effectively defined by a risk assessment that does not just involve a description of the task and other environmental factors. An assertion that there is no materials or situation present that could produce liquid ingress or noxious gas sufficiency or oxygen deficiency simply is but one part of the assessment as to whether the space is confined for the purposes of the regulations.

One must also remember that a possiblity exists to a measurable degree that the operative could fall from the ladder, unless of course you are about to tell us that it is a fixed hooped ladder with landing platforms and an ascending safety line. More than one person may then enter this space and how does that affect your assessment of oxygen depletion/CO2 buildup? I would also look at the heat and humidity potential before jumping to an answer.

I am against the unbridled use of the definition of a space as confined but still need full information to make a decision. Clearly though there seems to be no productive work other than inspection possible and light hand tool use.

Bob
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#29 Posted : 02 September 2008 13:52:00(UTC)
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Posted By mark limon
Because these threads usually go of an any number of tangents I did not describe the task taking place so as to to keep people concentrated on the original question but it proved difficult.
So once again for clarification I will state the only issue is the location.
The width of the cylinder is roughly the same all the way up being slightly wider at the top
There are no ventilation problems,there are no noxious gas problems,there are no hazardous material problems,there are no flowing liquid problems.
The only issue is the location,all the materials used in the task have been coshh assessed,all lifting has been manual handling assessed,all SWPs are in place,the only issue is,is it classed as a confined space or not.
I would like to add I work for a company that always goes way beyond what is required by law in safety .
The question has sparked a good debate with varying opinions which have been really helpful which is great.
I think that not stating the task was a mistake because a lot of people have concentrated on this rather than the question asked,however I think the thread is going around in circles now and has run its course so probably should be closed.
I thank you all for your help,
Mark
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#30 Posted : 02 September 2008 14:14:00(UTC)
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Posted By bill strachan1
Spoilsport!!

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