Rank: Forum user
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My company carries out heavy fabrication work for the offshore industry. This includes working on vessels in a wet dock area, sometimes involving confined space working in ballast tanks and enclosed areas below deck level. The work regularly involves welding, oxy-propane cutting and painting. My works Director is adamant that we do not need to have any formal training in place for the workers as long as we can demonstrate that we have a safe system of work.
My interpretation of the regulations is that we do need to provide training and to be able to demonstrate competence we should provide training by a recognised training provider.
Could anyone provide some direction on this please?
My position is Health and Safety Advisor.
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Rank: Super forum user
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bluefingers - your Works Director is so wrong that it's off the scale.
This looks as if it could very nasty indeed.
If you wish to contact me directly I shall put you in touch with a guy who'se in the same line of work as you and had 2 fatalaties 10 years ago - he has become a good friend since the event [I only got involved after the fatalaties!].
He will probably give you chapter & verse of the very stressful trials [in every sense of the word] & ongoing HSE perusal following that event.
Frank Hallett
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Rank: Forum user
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Frank, thanks for responding to my posts today. I have just joined IOSH today, and I can see that it is going to be one of the best investments that I have made. I would be interested in contacting your friend as I obviously need to put a strong case together to convince my WD about this training. Being new here, how do I contact you directly?
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Rank: Forum user
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Bluefingers,
Frank is spot on the money with this one.
But to be all legal about it, sadly, the Confined Spaces Regulations themselves do not specify a training requirement and it is left to the ACOP and guidance to specify training in respect of Regulation 5 - Emergency Arrangement, which provides:
"Those likely to be involved in any emergency rescue should be trained for that purpose. The training needs for each individual will vary according to their designated role. It is important that refresher training is organised and available on a regular basis..."
In addition, I am sure our colleagues in the HSE would successfully argue that the provisions of Reg 13(2) of the MHSWR (capibilities and training) would apply to work in a confined space.
Regards.
DJ
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Rank: Forum user
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djupnorth
Thanks for the response. I have just joined IOSH today and I feel very supported already by members.
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Rank: Super forum user
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Your Director is 110% wrong.
How did he get his job?
Also a general requirement under HASWA to provide training to employees
I don't usually go for calling the HSE, however in this high risk situation, if all else fails - then quietly request a visit?
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Rank: Forum user
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JJ Prendergast
This could well be the only course of action left open to me if I feel workers are still being put at risk. I don't know how he got the job.
Thanks for your response.
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Rank: Super forum user
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I would also consider having trained and competent employees to be an essential part of your 'safe system of work' that you mention.
Being able to show that they are trained and competent (or not) should be picked up via your audit system
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Rank: Forum user
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I agree with djupnorth. But for the chapter and verse check the confined space regs either through the HSE website or the OPSI website (office of public sector information).
I work on a nuclear site where emergency rescue is covered by the on site emergency services, but even we do operator training in confined spaces so folks going into them know what to do for O2 meter alarms etc., watchers should have 1st aid training etc, and I would also recommend a permit to work for CS entry.
Training is a must!
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Rank: Forum user
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Bluefingers
Having just responded to your other post on air monitoring you are obviously in a difficult position.
Agree with JJ that a system of work is not suitable until you can demonstrate competence.
I work in the tunneling industry. Rather than try to reply in a post please PM and I would be happy to discuss.
regards
Sweep
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Rank: Forum user
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Hi Bluefingers,
Even if your Director tries to claim the exemption of the confined space regs as it is a vessel He is still wrong on a massive scale.
As the vessel is on dock, and not part of normal cargo movements, they don't apply. You must have a robust rescue plan and trained teams with the correct equipment. Welding and burning inside tanks and vessels should only be carried out when declared has free by a chemist, and with constant monitoring.
A massive one is making sure cylinders stay topside for oxy acetylene work, and torches and hoses are removed for breaks and lunch and only in the space when required. Access for rescue and recovery of a casualty can be a nightmare from a vessel ( especially in SCBA!! ) if you need any more steer just message me.
Phil
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Rank: Forum user
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Oh for an edit button!!!
Has free should be GAS FREE
And I meant that the exemption to the regs doesn't apply!!
Phil
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Rank: Super forum user
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If the Director is so confident of his position, suggest that HSE be brought in for their view? I would bet that he will be dead against this, or failing that, do you not belong to a trade body where you get a benchmark "second opinion"?
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Rank: Forum user
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Bluefingers, If your WD is still questioning further training on confined spaces. As a last resort get the
guy from c/b safety service, see what happend to him when he was using a cutting torch in a C/space.
He just might change his mind when he sees how much it cost the company for the accident and the blokes injuries. He certainly changed our minds on the shop floor about health & safety as a whole.
He wouldnt like that on his safety record ?
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Rank: Forum user
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Bluefinger , from the HSE
Under the Confined Spaces Regulations 1997 employers must first try to avoid the need to enter a confined space. Where this is not possible, they must:
carry out an assessment of the risks associated with entering a confined space and draw up a safe system of work;
limit entry to the confined space to employees who are competent for confined space work and who have received suitable training;
verify, prior to entry, that the atmosphere in the confined space is safe to breathe;
provide any necessary ventilation; and
make sure suitable rescue arrangements are in place before anyone goes in to the confined space. These rescue arrangements should not involve risks to the safety of the people intended to carry out the rescue.
Regards Dave
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