Rank: Forum user
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Hi I am wanting some thoughts on issuing permit to work into confined space entry.
I'm a H&E coordinator who has passed the NEBOSH Cert and awaiting my Dip results, I was asked the other day at work to issue a permit to work to carry out cleaning of a flour vessel as no one on site was able to do it due to both competent members were away on holiday.
I've covered confined space entry in both of my courses but not in great depth only the basics, does that make me competent? also we have an internal database for permit to work which I have not used or recieved any training on.
I requested for the following information off the contractors before I would even consider issuing a permit to work for confide space entry
List of employee names, what training recieved and copy of certificate
List of equipment i.e Gas monitor and calibration certificate
Method statement
Confined space entry risk assessment
Emergency rescue procedures
What are your thoughts? any feedback would be great thank
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Rank: Super forum user
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Fisher
Most companies have or at least should have a confined spaces procedure which should include a permit system encapsulating a safe system of work. Assuming your company does, then you should adhere to that procedure and the guidance in it. The permit must only be issued by an authorised person, usually a manager. Are you an authorised person as per your procedure?
Not ever had confined space training I am not sure of the level of competence related to the subject. However, I have written a procedure for confined spaces in the past. Persons involved in confined space work are trained, competent and should know their own role. If there is any doubt then the work should not proceed. That is all I can advise.
Ray
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Rank: Forum user
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Thank you very much Ray,
The company does have a PTW sytem that outlines the requirements to confined space entry, BUT I am not an authorised person to issue these.
Just as I thought before this I can not demonstrate competence in the internal PTW on confined space entry so won't be issuing any PTW to proceed with any work as if anything happend then its on my head as I am signing for someones life.
In the health and safety training i've recieve so far it has always states that to be a H&S Officer/Adviser is to competent but also know your own limitations.
Fisher
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Rank: Super forum user
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Two important competence areas for confined spaces which you didn't mention are:
1) Thorough understanding of the possible hazards, i.e. sources and types of dangerous gas/fume, and means to reliably remove or isolate these sources.
2) Use of portable gas detector to sample the atmosphere and confirm that all such sources are absent.
It is the person who 'owns' the space when it is operating normally who should issue the Permit, possibly after approval of all the planned and agreed controls at a higher level. Gas testing requires a thorough understanding of the relevant gas properties, and the sampling instrument(s), and typically some of that would come from a formal course.
An OSH advisor might be involved in/lead a risk assessment where they key parties would agree the hazards and controls, and possibly might be a competent gas tester (I used to have that role when working on shifts offshore), but wouldn't normally 'issue' the permit in any way. Nor would the contractor be expected to 'lead' the planning for it as you seem to suggest in your posting, except in very specialist situations, such as an inert gas entry in a refinery.
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Rank: Super forum user
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Cleaning flour vessels poses some interesting problems = explosive/flammable gases are not one of them but dust explosions are. Oxygen measurements will be required even with forced ventilation and cleaning methods should be dustless. There are a number of other issues around the dust handling equipment as well.
I am a trifle concerned that you are being put into this position and I imagine your internal procedures do not envisage such a situation. If all authorised persons are not available I think the procedure is already in breach as all those I have seen have systems in place to ensuree the availability of an authorised signatory. Keep clear of this job if you can but you do not clearly state copuntry of work.
Bob
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Rank: Super forum user
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Fisher, I second the comments from the previous two posters. You should check over the HSE guidance found here.
http://www.hse.gov.uk/pubns/indg258.pdf
And in particular the bottom of page 4 where you will find the following phrase amongst others:
"clear identification of who may authorise particular jobs (and any limits to their authority) and who is responsible for specifying the necessary precautions (eg isolation, air testing, emergency arrangements etc);
The whole purpose of applying p.t.w. to hazardous operations is to ensure that adequate s.w.p. are established for each and every occurrence and understood by all involved or affected by the work. After all, the lives of those carrying out the work depend on just that.
If you have no training, no understanding of relevant hazards and risk controls, no understanding of how the work relates to adjacent or relevant operations that may continue alongside this entry, no authority according to your own procedures etc...then you are not within a safe working system...and you have your answer on how to proceed.
P48
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Rank: Forum user
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Again I would like to thank everyone who has posted their thoughts on this subject and it has just confirmed my own feelings about this when I was first approached to issue a permit to work for confined space entry.
One good thing that has come out of this it has made me read the ACOP and guidiance on this and feel more confidant about the subject.
As part of my CPD I will be looking to do some training around this in the future.
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Rank: Super forum user
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Fisher, I would also grab some CPD from your involvement with this incident, thread and subsequent research if I were you!
p48
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Rank: Super forum user
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Absolutely no advice from me on the possible hazards and controls on this issue to encourage you to proceed with the job. Good to see you stood back from the situation.
The intermediate cause of this problem goes back to the Manager / Engineer who set this job up in the first place; he actually fell at the first hurdle. He did not plan the job but simply set it up expecting someone else to dot the I,s etc, manage, control and take responsibility for the job when it went wrong.
The way I read it is that you would have initiated this permit against the established policy and without the necessary competence for the task. Well done for challenging this.
The root cause goes back to the H&S Management System ie it needs some robust Audit protocols for such a high risk activity to ensure that they are followed correctly, every time.
Steve
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