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The Ear Defender  
#1 Posted : 25 November 2009 11:56:16(UTC)
Rank: New forum user
The Ear Defender

I work for an electrical contractor whose activities often involve repairing supply faults in private housing. In many circumstances the electricity meter is in the cellar.

Work is often carried out by one or two operatives and tasks can last for up to and around 90 minutes. There are currently no monitors or other CS equipment provided as the subject has not been approached before.

My primary query is Confined Space or not??

We may talk of the legislative definition and requirements for assessment, but I'm looking for practical controls (RA included) to assist the operatives (some of which are trained and further training may be planned) who will more than often be undertaking extremely low risk CS activities.

I am unable to rely solely on operative discretion and would like managerial involvement to establish information, instruction etc.

Has anyone had experience or have any salient points to discuss?
Jon.Dawson  
#2 Posted : 25 November 2009 12:06:00(UTC)
Rank: Forum user
Jon.Dawson

Ear defender -

It sounds like a CS in some circumstances, or at least the potential to be one. I suggest a 2-tier approach:

a) establish some generic risk assessments/procedures for confined spaces, with the appropriate training (access/egress, atmospheres, hazardous substances/processes etc) - a one-day CS awareness course wouldn't hurt.

b) based on the above, establish some kind of dynamic RA pro-forma, where each engineer assesses for himself the workplace he is about to enter - some basements are full of old materials, paints, chemicals, unstable racking, damp, dodgy electrics(!), etc. The client has a duty to warn you about these, of course.

Have a look at the HSE ACoP L101 (free download now) and you may need to adapt some of the guidance.

Best of luck

Jon
DaveDaniel  
#3 Posted : 25 November 2009 12:54:49(UTC)
Rank: Forum user
DaveDaniel

A confined space, as defined in law, is a place where there might be an irrespirable atmosphere. In theory this can be any enclosed space above or below ground, but I've not heard of any incidence of homeowners being overcome in their own cellars, and on that basis and that of having ventured into a number, I would not regard these as being "confined spaces" just because they are below ground. It may well be that conditions in a cellar are congested and possibly even unsafe to work in as a result of what's there, but this is a separate issue.

Of course this might change if you had reason to believe the cellar might contain a dangerous atmosphere - perhaps if you were engaged in flood clearance for example, or there was a smell of gas. most cellars contain a coal chute which provides some ventilation anyway.

I guess the practical advice is to proceed with care but not to automatically assume that any cellar is a confined space.
grim72  
#4 Posted : 25 November 2009 13:04:58(UTC)
Rank: Super forum user
grim72

You might want to consider assessing for lone workers too?
Safety Smurf  
#5 Posted : 25 November 2009 13:35:19(UTC)
Rank: Super forum user
Safety Smurf

Forgive my ignorance on this because I've never (knowingly) been in a house with a cellar. Are all cellars accessed by permenent staircases? or are some accessed by ladders?

I would imagine if it were accessed by a ladder then it may be considered a confined space.

Outside of the box and at the other extreme of the building. Do attics qualify as confined spaces and do contractors consider this when working in them?
UVSAR  
#6 Posted : 25 November 2009 14:21:25(UTC)
Rank: Forum user
UVSAR

A statutory confined space is not just about the atmosphere, nor does it have to be particularly small or difficult to access to fall into the five risk categories in the Regulations. The "ladder vs stairs" question is not relevant at all - we deal with SCCs at ground level with 50ft roller shutter doors, and compartments accessed via a 30cm hatch that aren't SCCs.

For domestic cellars, it is *unlikely* that the statutory definition applies, though it cannot be discounted in every case, especially if nobody's been in there for ages. Non-domestic premises are more of an issue, for example in pubs where buildup of CO2 is a real concern (many have monitors fitted), and where fumes from the floor above (vehicles, solvents, etc.) can collect in the cellar. The fact there's no smell means nothing.

Depending on where you are in the country, you must also address the risks from occupational exposure to radon.


Smurf - attics in the UK generally aren't SCCs unless they're non-domestic, where you may have fumes percolating up from the rooms below. Elsewhere in the world they could be caught under the "overcome by heat" clause, but that's about it.
Canopener  
#7 Posted : 25 November 2009 19:07:15(UTC)
Rank: Super forum user
Canopener

Ok - lets start with "My primary query is Confined Space or not??"

Yes of course it COULD depending on the circumstances and the same can be said for an attic. It depends on a number of factors that are discussed within the ACoP. Arguably, a cellar or any other space for that matter, could be a confined space one day but the same space or cellar may not be the next, again depending on the circumstances.

As has been pointed out, the atmosphere isn't the onky factor that should be taken into account, and I DO think that the means of access, or more importantly egress may well be relevant (I am pretty sure this is a factor 'discussed in the ACoP).

I aren't sure if the domestic/non domestic argument is relevant. If someone is accessing the space as part of their WORk then I would have thought that the domestic/non domestic 'status' is pretty irrelevant; isn't it?
PJW74  
#8 Posted : 27 November 2009 14:13:53(UTC)
Rank: New forum user
PJW74

Sounds over complicated to me
Not a confined space - serious injury from hazardous substances or conditions, such as collapse? No on both counts.
Risk assessment should in place to cover their working activities
And you said training taking place / is organised
Is the idea not to keep things simple?
jwk  
#9 Posted : 27 November 2009 14:26:44(UTC)
Rank: Super forum user
jwk

A confined space is defined as 'any space... [in] which by virtue of its enclosed nature... ' 'there arises a reasonably foreseeable specified risk'. Specified risks are (to paraphrase): fire or explosion; unconsciousness or asphyxiation because of gas, fume or vapour; unconsciousness because of an increase in body temperature ; drowning from an increase in the level of liquid, or entrapment or suffocation in a free flowing solid, such as flour or play-dough. A cellar is not ordinarlily a confined space; the definition could conceivably apply e.g in times of flooding; or to a fitter investigating a gas leak, or in a house occupied by a play-dough obsessive.

There would need to be some reasonable precautions against the usual hazards arising from the work being carried out, or against being locked in (more of an inconvenience that a serious hazard), and some simple arrangements for communication, so a standard RA would be quite enough,

John
son of skywalker  
#10 Posted : 27 November 2009 15:07:27(UTC)
Rank: Forum user
son of skywalker

So we are agreeing not to agree here.

Definitiely, maybe, could be and is an enclosed space.

Possibly potetially maybe an confined space but only under certain conditions in the cellar and what tasks are being undertaken.

Glad that is clearer
jwk  
#11 Posted : 27 November 2009 15:18:52(UTC)
Rank: Super forum user
jwk

Hi SoS,

Seems fairly clear to me; except under exceptional and clearly defined circumstances (which haven't been mentioned by the OP as applying), a domestic cellar is not a confined space as defined in law,

John
jwk  
#12 Posted : 27 November 2009 15:23:38(UTC)
Rank: Super forum user
jwk

But then again, lay all the safety professionals in the world end to end and they still wouldn't reach a conclusion :-)

John
David H  
#13 Posted : 27 November 2009 18:53:38(UTC)
Rank: Super forum user
David H

Maybe more a "restricted" space rather than a confined space.

I would ask the question - could I get an injured worker out of there quickly. If the answer is no - because there is hardly room to stand up, then a restricted space. If no because people have to crawl on all fours then a confined space. Down to each persons perception but I would certainly consider the lone working suggestion.

David
Canopener  
#14 Posted : 27 November 2009 20:29:32(UTC)
Rank: Super forum user
Canopener

PJW74 wrote:
Sounds over complicated to me
Not a confined space - serious injury from hazardous substances or conditions, such as collapse? No on both counts.
Risk assessment should in place to cover their working activities
And you said training taking place / is organised
Is the idea not to keep things simple?


While I agree that it is unlikely that such a space would be a confined space, but, I for one could never say catergorically that it was or wasn't without examining the circumstances present in that space. I most certainly could not reach a definite conclsuion from the information that I have in front of me.
Canopener  
#15 Posted : 28 November 2009 17:27:42(UTC)
Rank: Super forum user
Canopener

I have been mulling this one over (sad I know). I have been doing this job for a good few years and have been dealing with confined spaces for around 20 years or so including entry into aircraft fuel tanks, and confined spaces associated with sewage works.

Now, before we go any further, can I say that I would think that it is unlikely that such a cellar would be a confined space BUT with the information that has been placed in front of me (and everyone else here) so far, there is NO way that I could say with any great conviction whether the space referred to either is or isn't a confined space and I would not do so. I am surprised that anyone else here has been able to reach any definite conclusion either way. Surely the only RESPONSIBLE answer to give 'Ear Defender' is that the space COULD be a confined space if the 'conditions' described in the definition provided within the regs/ACoP are met?

And at the risk of repeating myself, surely the 'privately owned' or 'domestic' argument is spurious at best.

Just before I go though, could I provide something for us all to think about. The cellar in question, houses a gas boiler that runs on LPG. The boiler was installed some years ago by someone that was not Corgi registered or otherwise a competent gas installer, and the boiler hasn't been serviced or inspected since installation. The owner very rarely goes into the cellar but has asked you to go and replace a light that has failed so at least he can see what he is doing when he climbs down the vertical ladder into the cellar. Oh by the way the owner casually mentions that he thought he could smell gas last time he went down there.

Could the cellar be a confined space?

Answers on a postcard!
firesafety101  
#16 Posted : 30 November 2009 14:32:13(UTC)
Rank: Super forum user
firesafety101

I once attended a domestic address with a cellar where there was a strong smell of petrol in the cellar. On arrival the smell was very strong and the gas detector registerd a high level of petrol vapour present.

Upon investigating the surrounding area we discovered a local petrol station that had a leak of petrol from one of its underground pipes from tank to pump.

There had been lots of rain at the time and the water table was quite high.

Water was dripping into the cellar and with it petrol in a diluted state.

One spark and ....................well you can guess the potential outcome?

Confined space or not, there was a single staircase down from the ground floor into the cellar?

jwk  
#17 Posted : 01 December 2009 15:58:26(UTC)
Rank: Super forum user
jwk

Phil,

I would treat your case as a confined space; see my first post on this,

John
Canopener  
#18 Posted : 01 December 2009 22:03:18(UTC)
Rank: Super forum user
Canopener

Chris, John, thank you for your recent responses.

Ear def - I fear that overall this has not really helped with what you were after which was some practical advice on procedures to adopt, as we all got hooked up on the confined space issue. In fairness, you did ask the 'confined space or not' question, and the answer is a 'hong kong phooey style' - 'could be'. Despite our various postings, I would think that the sort of situation that you have described is unlikely to be a confined space but do be aware that even seemingly innocuous spaces can prove to be deadly at times. People have bene caught out before, and not lived to tell the tale.
The Ear Defender  
#19 Posted : 04 December 2009 10:36:17(UTC)
Rank: New forum user
The Ear Defender

Thank you for your contributions.

I think the thread perhaps became clouded with the initial question 'Confined Space or not?'. I think apart from the very clear cut cases, apparent 'grey' areas or low risk spaces creates debate and everyone has their own take perhaps based on experience. I should have explained clearly that if it was a Confined Space, what are the practical steps to allow a two man team to assess an area and if anyone had any first hand experience of such situations (Cellar work).

I have requested that all operatives likely to enter cellars in the course of thier work undertake a Confined Space Awareness course which will allow them to understand the subject a little better and assess each job prior to entry. A proforma risk assessment will be produced along with the provision of monitoring equipment. If they consider a cellar or space to be termed 'confined' then sutiable measures will be taken to meet the requirements and control the remaining risk. A team will be CS trained and the job re-allocated to the CS team.

Thanks again.
son of skywalker  
#20 Posted : 04 December 2009 14:33:08(UTC)
Rank: Forum user
son of skywalker

Ear Defender

Can I ask why you have chosen a two man team? Surely this will have to be based on a risk assessment?

I have in the past (although not for a cellar) been advised that I should have a three man (person) team. In the event that something happened to the person in the confined space, that left one to go in to rescue mode and one to call for help.

I agree with the previous sentiment that it is difficult to answer the question without the specifics.

Son of Skywalker.
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