Rank: Super forum user 
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We have had some discussions with our FM contractors confided spaces specialist.
He has identified number of areas on our site as being confined spaces and has suggested strongly that they be included on his list of places requiring a Permit to Work. We are challenging this assessment.
As everybody knows confined spaces are defined as:
“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;”
So the two areas of concern are
a) A lab which contains fumigation chambers. These are filled with poisonous gas to study the effect that toxic gases. Our scientists work outside the camber. Putting samples and probes in through an air lock. I concede that the interior of the chamber is a confined space but our expert is arguing that the whole laboratory be described as a confined space, despite the fact that it is a very spacious ventilated room with 20 air changes an hour. The access to the exit door is a straight forward stroll of about 2 steps. Furthermore having done their risks assessments the scientist have decided that as there is a risk of some of the gas escaping, access to the labs is restricted and the scientists have to wear self contained breathing apparatus when they put samples in and out of the airlock. I think it that fact that they are wearing this breathing apparatus has made our confined spaces guy think that this a confined space
b) The other scenario is we have a number of grain bins, 10-15 m high (deep). Again I concede that when they are partially full they could be classed as confined spaces but when they are full to the top with the level of the grain coming 1 m or so below the lip there is no way that they can be called a confined space. It is possible to walk over the grain when the silo is full and this is what out scientists do to take samples and insert probes. Again this is over kill. The main risk identified here is working at height as there is a risk that someone could fall from the top of the silo.
Sorry this is a bit long winded but are there any confined space specialist out here who can comment. Do you agree with my assessment that neither environment could be classed as a confined space or have you come across similar scenarios which have been classified as confined spaces?
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Rank: Super forum user
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It depends.... as usual down to risk assessment.
Do you have the specified risks that the CSWRegs discuss?
“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 the information you have given I would say your (a) is not a confined space (b) depends - what is he head space between the silo roof and the top of the grain when the silos are full?
All down to your risk assessment, you are quite at liberty to draw your own conclusions, which may not be the same as your FM contractor.
You could classify your potential confined spaces, according to your own criteria, something like
Type 1 - Definite confined space, considerable risk of injury/death - known hazardous materials/chemicals have been stored, definetly insufficient ventilation etc
Type 2 - Some hazards present, some past hazardous materials present, no liquids, but a dangerous atmosphere could be created if in the confined space for long periods of time but there is some natural ventilation
Type 3 - As 2 No fire/explosion risk, no hazardous chemicals classed as toxic, corrosive, simply confined space due to the small working volume. Not fully enclosed i.e. an open top to the confined space
Basically develop some sort of criteria similar to DSEAR hazardous area classification Zone 0, 1, 2
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Rank: Forum user
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Lets deal with the silo first as it is the simplest.
If there is not significant risk of being entrapped in the grain either by sinking into ot or from other material being added, it should not need to be a confined space. Whether or not it can be filled while it is occupied is probably the relevant question. If the fill point is above the work area it is likely to be a confined space. It is difficult to be definitive without detail.
For the lab, you need to consider a few other aspects. What is the toxicity of the gas? Poisonous is rather meaningless this determination. If the gas could form an atmosphere in the lab that presents a risk to life, or from a certain point of view would be above the relevant WEL, it is likely that the lab should be a confined space. The fact the BA is used as a precaution from a potentially toxic atmosphere makes it very difficult to argue that the lab is not a confined space as you accept that there is a risk of gas escape that could present a significant risk. It is possible that the work activity in the lab creates the confined space and so it may not need to be a confined space continuously, only when the potential of gas escape is present, or rather reasonably foreseeable. I get into this problem also with a room used to store very toxic gas that is not consistently classified the same.
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Rank: Super forum user 
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Just to play devil's advocate,
Regardless of the trigger, what are your reasons for not using PtW's to manage work in this area?
Even if they're not confined spaces by the letter. I can see how it would be prudent to use a PtW for work in these areas.
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Rank: Super forum user
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Forgot to add to my first post.
With out further details - however for the lab scenario, you CoSHH assessment of the task should drive you to the control measures you already have in place.
I think the CSWReg aspects is just an extra driver to ensure thst the risks/hazards are identified. Not so sure that you would do much additional work, that wouldn't already be identified by a comprehensive COSHH risk assessment.
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Rank: Super forum user 
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I'd say (a) si no, and (b) might very well be yes.
My concern about (b) would be that if grain were to discharge while someone was standing on the top of it then you can get columnar flows within the body of grain and that pulls someone down into it, even if they are a long way above. The 'discharge' might actually not be someone taking grain from the bottom, it could be a void within the silo (due to arching or material hanging up) collapsing.
I don't know about your grain, but I have worked with designing silos for other materials, and arching and voids can occur in the bulk, and can spontaneously collapse.
I have a recollection of a case with fatalities when someone entered a silo to do a rescue and someone else, thinking they were being helpful, started discharging from the base - the people at the top got sucked down into the mass.
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Rank: Super forum user 
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Whether an environment is deemed as a confined space per se will depend on the potential hazards, the controls to mitigate those risks and whether extra controls are needed in the form of a permit. For example, I have deemed the underside of a railway platform a confined space due to the unforeseen hazards, whereas a lift shaft has not been deemed a confined space.
I suggest the laboratory scenario could be better defined as a Restricted Area - which is often used to describe and a work area which may not fit into a recognisable 'confined space' criteria, but the inherent hazards determine that unusual or extra precautions are required for those entering or working in that area.
Ray
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Rank: Forum user
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From the scenario set, I would agree with you on the first instance, you have obviously put in the required controls measures for the chambers etc.
For the 2nd, I would lean towards the bin being a confined space, access is still possible if there is a 1 metre gap, your assessment should take into account all scenarios (full, part full, etc).
Although not mentioned, is there a possibility of lone working?
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Rank: Forum user
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I'm not a confined space specialist but I would chip in with a) probable, the wearing of BA screams 'confined space' at me. I know BA is only worn in certain circumstances in the lab area you have described but maybe you classify into 'types' as has been suggested already, and b) definitely, this is an obvious one to me by dint of the grain being a free flowing solid. As someone suggested there was indeed fatalities somewhere in the Perth area a few years back resulting from a similar scenario.
Just to chuck in...asbestos working enclosures...confined space or not? What do you all think? I work in the asbestos industry, see. So its a kind of loaded question. I have my views, what are yours?
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Rank: Super forum user
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To be honest is that the FM contractor has just put this person through confined spaces training and he has been looking for things to add to his list and I am looking to take over responsibility for these two areas away from the and into our remit. The scientist running the projects have done this for years and are highly trained. They would in effect self authorise acess to these areas. I’d like to keep our FM bods away from this.
Assessments have been carried out under COSHH etc I am not convinced that a PTW would help in any significant way.
I like JJ Prendergast classification idea. I might steal that.
Bins are only accessed from the top, no hatch at the bottom. As said my main concern with the bins is working at height when they are full.
Our guys say voids and arching is only happens if the grain in the bins is damp. Before they step on the grain they probe it first . The hopper at the bottom is locked off when people are working on the silo so grain can’t suddenly be released.
In the lab various gases are used from carbon-dioxide to phosphine (not Phosgene which is the chemical weapon).
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Rank: Super forum user
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A Kurdziel,
'Our guys say voids and arching is only happens if the grain in the bins is damp. Before they step on the grain they probe it first . The hopper at the bottom is locked off when people are working on the silo so grain can’t suddenly be released'
The above 'critical' safety measures could be controlled under a PTW System. To me it suggests a PTW could be valid.
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Rank: Forum user
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Although respirable atmosphere, oxygen enrichment / depletion are top of everyone's list when considering confined spaces.
Before ALL of that. Can you safely extricate an unconscious casualty without help from 999?
If YOU have special circumstances YOU need to make the special arrangements.
And as always it comes down to doing the risk assessment and mitigatin anything that drops out.
People seemed to be obsessesed with BA, escape sets, monitoring, TWA etc etc.
Start with the basics. I one of the ops has a medical incident that renders them unconscious, can YOU safely extricate them without help from the emergency services, cos if you can't, you may have a problem.
Phil
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Rank: Super forum user
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HeO2
All good stuff, but that still doesn't automatically make the lab scenario a confined space - as defined
As per previous post a detailed CoSHH assessment, should still pick up such issues.
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Rank: Forum user
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Fully agree with the fume cupboard scenario JJ, my rant was more a general rant at confined space projects and tasks in general>
Phil
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Rank: Forum user
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Folks,
There seems to be a bit of confusion cheeping in here.
COSSH, Asbestos Regs, and Confined Spaces Regs are entirely different.
Asbestos
An asbestos working enclosure is not a confined space. It does not include a specified risk as defined in confined space regs, i.e. loss of consciousness, asphyxiation etc, despite the risks of inhaling fibres.
COSHH
This is about personal exposure to harmful substances, the assessment of the potential to that exposure, and putting controls in place to prevent or limit exposure.
Confined spaces
Regardless of the personal exposure controls applied, e.g. breathing apparatus (BA), it is a confined space if the specified risk exists because of the enclosed nature. If you are working with small quantities of very toxic gas in the back of a transit van it can be a confined space even if you are using BA, the same quantities of gas in a aircraft hanger may not mean it is a confined space. This is about can a atmosphere be formed that presents the specified risk as defined. Your COSHH assessment may say X or Y controls are needed to control personal exposure, but that does not mean the work area is not a confined space because you have applied those controls.
IMHO
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Rank: Super forum user
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No confusion on my part.
Quite aware of what CoSHH & CSWRegs require.
From the information available, it would seem a sufficiently thought out/detailed CoSHH assessment should also cover the CSWRegs angle (even if CSWRegs apply) - no point in duplicating the work.
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Rank: Super forum user
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Gerry D,....Respect!
Working in an asbestos enclosure must be pretty hard, hot and uncomfortable work.
Understanding the evacuation issues surrounding an asbestos enclosure and the decontamination regime, often working in service risers, ceiling voids etc, I'd say it could certainly be categorized as CSW.
Simon
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