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zoltangera  
#1 Posted : 05 July 2011 13:59:28(UTC)
Rank: Forum user
zoltangera

Ive been asked by our PC for a "confined space" method statement for domestic housing loft spaces.

I can think of heat and maybe dust hazards, anything ive missed?
Kate  
#2 Posted : 05 July 2011 14:07:49(UTC)
Rank: Super forum user
Kate

Access, lighting, flooring, obstructions, asbestos ...
Dazzling Puddock  
#3 Posted : 05 July 2011 14:27:53(UTC)
Rank: Forum user
Dazzling Puddock

A domestic loft space would not in normal circumstances be a confined space but depending in the work being carried out and the potential for fumes from faulty twin wall flues etc it may in certain circumstances become one.

I would stick to purely confined space issues as you will already have carried out a method statement for general risks eg asbestos, lighting, restricted, work space etc.

Access and egress, potential for fume/asphyxiant from work process and or flues/ boilers fitted in loft space, heat.
zoltangera  
#4 Posted : 05 July 2011 14:30:37(UTC)
Rank: Forum user
zoltangera

Dazzling Puddock wrote:
A domestic loft space would not in normal circumstances be a confined space but depending in the work being carried out and the potential for fumes from faulty twin wall flues etc it may in certain circumstances become one.

I would stick to purely confined space issues as you will already have carried out a method statement for general risks eg asbestos, lighting, restricted, work space etc.

Access and egress, potential for fume/asphyxiant from work process and or flues/ boilers fitted in loft space, heat.


Yes the things Kate mentioned are already covered in the RAMS
zoltangera  
#5 Posted : 05 July 2011 14:50:04(UTC)
Rank: Forum user
zoltangera

“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 a 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;

It seems that im looking at an increase in body temperature...(confined space regs)

Betta Spenden  
#6 Posted : 05 July 2011 15:03:17(UTC)
Rank: Super forum user
Betta Spenden

ALWAYS treat as a confined space if not undertaking DIY.

Looking at what you have already got hows about:

Irritation from loft insulation (skin/lungs).
Electricity from hidden cables under insulation.
Trip hazards, rafters cables and junk.
Obstructions from house holders junk.
Falls from height both back out of the hatch and through the ceiling.
Manual handling especially as staff maybe stooping.
Banging heads on rafters.
Rodents (mainly mice).
Birds (feathers and droppings) especially Starlings they favour getting into lofts, but mainly stay on top of the roofing felt. Disturb any nests and it’s anything up to £5000 fine with an additional £5k per egg or chick.
Bats and their droppings. Again environmental legislation kicks in as bats are protected.
Cold water tank.

Got solar panels installed? = lethal voltage.

And will the task involve hot work?
Dazzling Puddock  
#7 Posted : 05 July 2011 15:10:24(UTC)
Rank: Forum user
Dazzling Puddock

Sorry Betta, but to me, none of the hazards you mention apply to confined space method statement.
A confined space is a specific term given to a specific set of circumstances detailed by zoltangera in an above post.

The hazards you describe have there place in a RAMS but a confined space RA should be specific to confined space issues.
TDS1984  
#8 Posted : 05 July 2011 15:17:04(UTC)
Rank: Forum user
TDS1984

Have to say I agree with Dazzling Puddock, I think the PC is stretching things a bit to call a household loft a confined space. Obviously there is the possiblity of some kind of hazard that we don't know about which skews things but, the average loft IMO not a confined space.
Kate  
#9 Posted : 05 July 2011 15:17:09(UTC)
Rank: Super forum user
Kate

While you might have multiple risk assessments for the same job covering different aspects of it, I don't see how it makes any sense to have more than one method statement for a single job.
andybz  
#10 Posted : 05 July 2011 15:18:43(UTC)
Rank: Super forum user
andybz

I can't say this is what your PC is thinking, but I suggest that you should consider all lofts as 'potential' confined spaces. I would want reassurance that part of your planning process would be to consider how hazardous access and work in the loft is going to be, and hence whether you do need to treat it as a confined space entry.

Something I would expect you to demonstrate is arrangements for rescue. You may want to document a generic philosophy, but you should assess all work in lofts to determine if a specific rescue plan may be required.
zoltangera  
#11 Posted : 05 July 2011 15:49:24(UTC)
Rank: Forum user
zoltangera

I think the key is in the regulation where it says "foreseeable specified (what I listed earlier) risk". When I started this job at my current employment I would have gone into great detail on why I would not consider a household loft to be a confined space......now I cant be bothered Ill just do as they ask and get paid the end of the month!

My MD like it that way too.......I wont be surprised if this company has everybody wearing BA to work in lofts by the end of the month....and I'm serious...(puts head in hands and starts to cry)
Zimmy  
#12 Posted : 05 July 2011 15:52:07(UTC)
Rank: Super forum user
Zimmy

Electric shock due to open covers of live electric joint (connection) boxes. Poor visibility, Falls from height (treading between joist or joists not being strong enough). PV D.C. Voltage (if any). Dust, vermin, heat, access egress..and yep...confined space.
zoltangera  
#13 Posted : 05 July 2011 15:57:15(UTC)
Rank: Forum user
zoltangera

Zimmy wrote:
Electric shock due to open covers of live electric joint (connection) boxes. Poor visibility, Falls from height (treading between joist or joists not being strong enough). PV D.C. Voltage (if any). Dust, vermin, heat, access egress..and yep...confined space.


These are hazards yes but not ones under the confined space regulations as previously listed.....you'll have the method statement on your desk on Thursday boss......just kidding :-)
Ron Hunter  
#14 Posted : 05 July 2011 15:59:14(UTC)
Rank: Super forum user
Ron Hunter

Looks like we can add the Confined Spaces Regulations to the list of statutes that are widely misunderstood!
Zoltanegra Posted: 05 July 2011 14:50:04 with the context and legal definition of confined space. Anything outwith the legally defined specified risks is wholly irrelevant to confined space definition.
Dazzling Puddock  
#15 Posted : 05 July 2011 16:07:44(UTC)
Rank: Forum user
Dazzling Puddock

quote=ron hunter]Looks like we can add the Confined Spaces Regulations to the list of statutes that are widely misunderstood!
Zoltanegra Posted: 05 July 2011 14:50:04 with the context and legal definition of confined space. Anything outwith the legally defined specified risks is wholly irrelevant to confined space definition.

Totally agree!! Confined Spaces Regulations IMNSHO are some of the simplest, easy to read Regs there are but even those are being misinterpreted on a daily basis.

I despair!!
Zimmy  
#16 Posted : 05 July 2011 16:13:18(UTC)
Rank: Super forum user
Zimmy

Pays your money...as was said..Perhaps not a 'confined space'? But some would argue the point. I've been called out when a fellow electrician had taken a hit from the an open joint box hidden under loft insulation when looking for a cable. We had a bugger of a job getting through the little opening between roof spaces as he had a problem with a badly burnt hand. It was confind enough for us!

The listed problems still remain. Work for a common sense point of view. Bob :-)
cliveg  
#17 Posted : 05 July 2011 16:19:19(UTC)
Rank: Forum user
cliveg

http://www.hse.gov.uk/pubns/indg258.pdf

Seems to agree with the view that 'unventilated or poorly ventilated rooms' (page 1) can be deemed a confined space, as they can lead to 'Hot conditions leading to a dangerous increase in body temperature.' (Page 2)

Seems to fit most loft spaces in summer?
zoltangera  
#18 Posted : 05 July 2011 16:33:05(UTC)
Rank: Forum user
zoltangera

cliveg wrote:
http://www.hse.gov.uk/pubns/indg258.pdf

Seems to agree with the view that 'unventilated or poorly ventilated rooms' (page 1) can be deemed a confined space, as they can lead to 'Hot conditions leading to a dangerous increase in body temperature.' (Page 2)

Seems to fit most loft spaces in summer?


Id like to see the HSE definition of "hot" and "warm"

From HSE confined space guidance L101 "This can occur where work in hot conditions is being undertaken in a confined space or where, for example, boilers or furnaces have not been allowed sufficient time to cool before people are allowed to enter to undertake maintenance work, or where equipment has been steam cleaned to remove hydrocarbons."
zoltangera  
#19 Posted : 05 July 2011 16:42:03(UTC)
Rank: Forum user
zoltangera

Confined space Acop with regard to ventilation

Some confined spaces are enclosed to the extent that they require mechanical ventilation to provide sufficient fresh air to replace the oxygen that is being used up by people working in the space, and to dilute and remove gas, fume or vapour produced by the work. This can be done by using a blower fan and trunking and/or an exhaust fan or ejector and trunking (provided that there is an adequate supply of fresh air to replace the used air). Fresh air should be drawn from a point where it is not contaminated either by used air or other pollutants. Never introduce additional oxygen into a confined space to ‘sweeten’ the air as this can lead to oxygen enrichment in the atmosphere that can render certain substances (eg grease) liable to spontaneous combustion, and will greatly increase the combustibility of other materials. Oxygen above the normal concentration in air may also have a toxic effect if inhaled.
118ncg  
#20 Posted : 05 July 2011 17:50:04(UTC)
Rank: Forum user
118ncg

Whats The FUSS,, IT was stated a domestis roof space... I was always lead to believe that a roof the thing above the space needs ventilation around it to do its job IT's a CDM thing (Design out any forseeable hazards). Thus it would be ventilatated all the time,, Thus not a confinded space in the correct sense of Page 2 of the regs. Most of us live in houses with a domestic roof space (ATTIC). Just do a basic risk assessment. If you still think it is a confined space ensure the person doing the RA has the correct training and Competent...
boblewis  
#21 Posted : 05 July 2011 20:30:30(UTC)
Rank: Super forum user
boblewis

The first requirement for any CS wark isw to avoid entering the space where possible - it is eminently possible in a domestic house - simply remove the roof. Of course the PC should have priced for this as he recognised the CS as existing. Of course he could change his mind!!

Bob
RayRapp  
#22 Posted : 05 July 2011 21:32:03(UTC)
Rank: Super forum user
RayRapp

'Ive been asked by our PC for a "confined space" method statement for domestic housing loft spaces.'

I would respond that a domestic housing loft is not normally confined a space per se and therefore I have not got a MS. A normal MS detailing the potential hazards and risks should suffice.

Those that argue a house loft is a confined space are taking things to the extreme, or backside covering. Of course, dependant on the tasks and hazards associated with the work a house loft could be construed as a confined space. So could working in a domestic garage, but only if you have a car engine running at the same time!

The CS regulations are designed to ensure that typical environments where there could be lethal hazards from a lack of or too much oxygen, chemicals, gases, heat, etc may be prevalent are properly controlled and managed. This does not mean that every enclosed area now becomes a confined space. On the railway we treat the underside of platforms as a confined space, not necessarily because of the aforementioned hazards, but because of the dangers of sharps and specifically needles associated with HIV/hepatitis.

Instead of adopting a risk averse attitude one could also argue that good training of operatives to recognise potential hazards associated with confined areas would be a good idea - but that may be a step too far.

cliveg  
#23 Posted : 05 July 2011 21:32:36(UTC)
Rank: Forum user
cliveg

All I know it was jolly hot and cramped when I was laying insulation in my loft. Hadn't thought of taking the roof off ;-)
Canopener  
#24 Posted : 05 July 2011 21:36:40(UTC)
Rank: Super forum user
Canopener

I like it Bob!

Of course any space can become a confined space if the conditions exist or could exist during the course of the work. I suggest that in the majority of cases a 'domestic' loft space is unlikely to be a confined space as defined under the regs. Do bear in mind that some gas boilers are installed in roof spaces though; that doesn't necessarily make it a confined space. Similarly, there are confined spaces, and there are confined spaces. Some will require pretty basic precautions, and others something more elaborate. .

Some of the various risks being mentioned, seem to me, to be largely irrelevant in the context of a confined space!
Betta Spenden  
#25 Posted : 05 July 2011 21:41:02(UTC)
Rank: Super forum user
Betta Spenden

Dazzling Puddock wrote:
Sorry Betta, but to me, none of the hazards you mention apply to confined space method statement.
A confined space is a specific term given to a specific set of circumstances detailed by zoltangera in an above post.

The hazards you describe have there place in a RAMS but a confined space RA should be specific to confined space issues.


Its a confined space AND you ALSO need to consider the following (ref to list provided by me and others above).

Now just crack on, stop dilly-dallying and get the job done.
Betta Spenden  
#26 Posted : 05 July 2011 21:50:50(UTC)
Rank: Super forum user
Betta Spenden

now I cant be bothered Ill just do as they ask and get paid the end of the month!

My MD like it that way too.......

I think that that just about closes the lid (or should I say loft hatch) on the subject.
Kate  
#27 Posted : 06 July 2011 08:23:29(UTC)
Rank: Super forum user
Kate

Maybe I'm being naive here and the method statement is just for show to the client while the people doing the job will never see it, but isn't the idea of a method statement that it sets out what the people involved are going to do in order to do the job safely? So how could you use a method statement that only addressed the specified confined space hazards without mentioning all the other hazards that you expect to encounter?
zoltangera  
#28 Posted : 06 July 2011 09:43:15(UTC)
Rank: Forum user
zoltangera

Kate wrote:
Maybe I'm being naive here and the method statement is just for show to the client while the people doing the job will never see it, but isn't the idea of a method statement that it sets out what the people involved are going to do in order to do the job safely? So how could you use a method statement that only addressed the specified confined space hazards without mentioning all the other hazards that you expect to encounter?


Kate if the blokes we work for, that pay our small company to keep it going, say a method statement has to be a fairytale about a building pixie written on vellum that is what a "method statement" is....I found out very quickly in this role that I may as well throw my NEBOSH Dip & Cert along with 10 years H&S working experience out the window......what they say goes. It is actually quite easy doing my job now....I just do what they want!
Zimmy  
#29 Posted : 06 July 2011 11:03:10(UTC)
Rank: Super forum user
Zimmy

For what it's worth (if anything) as an electrician with humble H&S quals (NEBOSH Gen Cert Occ) and (NEBOSH construction cert) Tech IOSH - I can only say that:

If I have a chap, maybe a big lad/lady working in a tight roof space with unknown electrical wiring lurking under a cover of insulation, unseen rodent infestation, airborne particles,heat,balancing on joists (no space to get crawl boards in) I try to ensure that the do not work alone and we have a panic plan (sorry, emergency plan) in place. Heat? Summer time wearing overalls, dust mask and safety glasses and steel boots..yep heat!

On the RA will be all the hazards Falls from height electric shock etc that I can think of as I want them in and out in one piece and not bothered of what other people think. After all, we all try and take care of each other don't we?

If needed then a method statement.
As for a confined space, I'll call it that for now.

Having said that I'm unemployed at this time so perhaps it's just me!

Bob
Wizard  
#30 Posted : 06 July 2011 11:38:27(UTC)
Rank: Forum user
Wizard

zoltangera, it maybe prudent to start with a description of a "CONFINED SPACE", then classify the area you describe in reflection to the same.

Regards

Wizard
Zimmy  
#31 Posted : 06 July 2011 11:49:51(UTC)
Rank: Super forum user
Zimmy

Now that sounds like a plan Wizard

Bob :-)
jde  
#32 Posted : 06 July 2011 12:37:27(UTC)
Rank: Forum user
jde

I think the flow of this topic is exactly what we are trying to get rid off with the review into "red tape" and bureaucratic nonsense. It is extremely unlikely that a domestic loft would come under the confined spaces criteria, restricted space certainly, confined no.I would certainly challenge the PC interpretation and provide a detailed RAMS for working in a restricted space with details of the works / hazards and risks clearly spelt out.
Zimmy  
#33 Posted : 06 July 2011 14:16:24(UTC)
Rank: Super forum user
Zimmy

Restricted space? Yep, I can live and work with that.

We live and learn.

Bob
boblewis  
#34 Posted : 06 July 2011 21:29:50(UTC)
Rank: Super forum user
boblewis

Perhaps we need to recall that the problem of CS definition stems from the PC and not the OP. We can only correct PCs by making it costly to them if they pursue their wild fantasies.
paul.skyrme  
#35 Posted : 06 July 2011 22:54:35(UTC)
Rank: Super forum user
paul.skyrme

bob,
No mate we can't they will just go elsewhere and find another Mug who is willing to do their bidding for now.
Welcome to UK PLC we only buy the cheapest to heck with everything else.
boblewis  
#36 Posted : 07 July 2011 10:03:50(UTC)
Rank: Super forum user
boblewis

Paul

Be like them and ignore it in the tender, do not price for it and then increase the price after tender because it was not in the contract. My reading of the post is that the CS question was raised once on site. Whether they like it or not any request for something additional to the tender is a cost item. Defining a loft as a CS after the subcontract award is a change to contract terms. Especially when they are normally not so perceived or defined.

I do however generally agree with your last phrase, many of the majors are playing word games every day including the and especially the multinationals. The HSE do diddle all to assist either.

Bob
roydalby  
#37 Posted : 07 July 2011 10:43:56(UTC)
Rank: New forum user
roydalby

Dont forget your rescue plan, first aid and positioning of additional staff or public just in case anyone falls through the roof and lands on them or debris falls on them
Nevos  
#38 Posted : 07 July 2011 11:48:20(UTC)
Rank: Forum user
Nevos

What a "can of worms" has been opened here. I found a massive wasps nest in our loft last year, which hasn't been mentioned either, and they didn't seem to like the idea of me entering the loft space with a bright light. Problem solved! I didn't bother entering!
Jane Blunt  
#39 Posted : 07 July 2011 17:06:29(UTC)
Rank: Super forum user
Jane Blunt

Nevos, I have encountered that problem several times. You can buy a spray that you can use from a considerable distance, with quite good accuracy. It worked for me, and since I am somewhat allergic to wasp stings, I have to take care!
Nevos  
#40 Posted : 08 July 2011 08:42:17(UTC)
Rank: Forum user
Nevos

I know about the spray for wasps Jane, as I bought one. Unfortunately, I have rather a large loft that I can only stand up in at the middle, which was quite a distance from the hatch. The wasps nest was approx three cubic feet (old money) in volume and my mental risk assessment reminded me that I should leave well alone and await their exit in the colder months, which they duly did! I may have seriously injured myself, due to a hasty exit from the loft, which wasn't possible, on release of the spray and more than likely stung many times.
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