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LATCHY  
#1 Posted : 05 November 2013 13:26:54(UTC)
Rank: Forum user
LATCHY

My question, is what I am about to describe a confined space, the chamber we have on site is called an air classifier, you need ladder access to get down inside and it needs to be isolated before you enter, there can be all sorts of debris in there sharps, rubbish etc, I my self consider this to be a confined space for the reason of a safe op procedure, but this is the description I have uncovered on an old safe op. For the purposes of this Safe Operating Procedure and work activity, the Air classifier is not being designated a confined space for the following reasons. • There is a good airflow through the machine. • No cleaning products or chemicals are used in the work activity. • No spark or exhaust-making tools are being used for the cleaning. • Access and egress can be made via the access ladder. • An escape procedure is detailed later in this document • The majority of material will be ‘run out’ of the machine prior to entry Advise please is it or is it not a confined space?
zeb  
#2 Posted : 05 November 2013 13:35:37(UTC)
Rank: Forum user
zeb

http://www.hse.gov.uk/confinedspace/ It sounds like it could be, yes. Assess the risks and if you feel there is enough potential for serious harm, then classify it as one and put in the appropriate control measures and training if required. The fact it needs isolated before entry would be the reason I'd classify it as one. Unless there is an interlock switch? Has anything changed since the last assessment you refer to?
Cerith  
#3 Posted : 05 November 2013 13:41:09(UTC)
Rank: Forum user
Cerith

The regs and guidance are quite clear on this one. There has to be a "specified risk" for it to come under the regs. These are listed in the regs. Liquid, heat, asphyxiation, fire, explosion, free flowing solids etc. If one or more applies, it's a confined space, if not then not. However, many of the controls will be the same even if it is not covered.
Steve e ashton  
#4 Posted : 05 November 2013 13:50:29(UTC)
Rank: Super forum user
Steve e ashton

Don't get too hung up on definitions. If it walks like a duck and quacks like a duck you can treat it as a duck even if its only a small goose. Don't ask 'do these Regulations apply?' - ask rather What can these Regs teach me about how I can keep these people safe.... A confined space subject to the confined spaces Regulations must meet one of the criteria established in those Regulations. A confined space not subject to the regulations may still be a confined space which needs appropriate management controls for safety in entry and working. From your description, it sounds as if your space does not meet the defined criteria - so if someone is injured during entry - you probably wouldn't be prosecuted for breach of the confined spaces regs. But if you don't have suitable controls in place then you would be prosecuted for breach of the management regs, the workplace regs or the HaSaWA.... What are the appropriate management controls? Read the Confined Spaces Regs. Steve
RayRapp  
#5 Posted : 05 November 2013 16:11:38(UTC)
Rank: Super forum user
RayRapp

Good comments and advice from Steve. I once declared the underside of a station platform a 'confined space' because of the hazards which it posed eg sharps, poor lighting, animal carcass, an uncovered shaft, etc.
SP900308  
#6 Posted : 05 November 2013 16:17:11(UTC)
Rank: Super forum user
SP900308

Ray, I think I'll skip the busman's holiday this time round thanks!
andrewcl  
#7 Posted : 05 November 2013 20:15:04(UTC)
Rank: Forum user
andrewcl

I'm with Steve on this. From memory the CS regs defines one as enclosed area with risk of:- 1) fire/explosion (oxygen enrichment) 2) oxygen depletion/increase in toxic gases/fume 3) free flowing solids 4) free flowing liquids 5) hi/lo temperature By this definition probably not a confined space... But it wouldn't be the law without the good ol' fashioned get-out clause! As far as I recall there is a statement after the "specified risks" (could be in the ACOP...) that says any enclosed area containing a hazard is going to be more risky to work in so feel free to treat as a confined space. We have enclosed areas on site that have quite different hazards from those mentioned in the law and we definitely class them as confined spaces. Conclusion:- treat as a confined space. I'd rather be a little too safe than a little not safe enough!
Billy Morrison  
#8 Posted : 05 November 2013 21:04:13(UTC)
Rank: New forum user
Billy Morrison

I personally would advise classifying as a Confined Space (CS) and as such put in the necessary control measures. Albeit you have identified the reasons why it should not be a CS which would be the positives the negatives appear to be the entry and exit. A CS can also be defined by the of nature of the access and egress. Can I assume that bearing in mind you have alluded to having an escape procedure in place you also have rescue plan? This would also bolster my thought to the classification of a Confined Space.
Bruce Sutherland  
#9 Posted : 05 November 2013 21:41:00(UTC)
Rank: Forum user
Bruce Sutherland

its not a confined space so don't call it one -- just put in place what ever precautions you think are required
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