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There is a small room, above ground, about 8 metres wide, 3.5 metres deep and about 3 metres high. Within the room. There are two small 'kitchen type' extract fans, no forced fresh air in fan and only a relatively small grill on one of the entry doors, and which is entry from a production area.
Within the room there are 15 cigarette smokers and the door is closed. Also there are several gas bottles in the room, some with Carbon Dioxide in, some with Carbon Monoxide in and some with Nitrogen in. These bottles have regulators on but are not generally leaking, in normal circumstances.
There is a Carbon Monoxide alarm and a sign on the wall which says maximum exposure limit is 50ppm (wrong value I know) and the sign says if the alarm goes off then leave the room immediately.
Would you see this as in no way a confined space, definitely a confined space or possibly a confined space but only in particular circumstances?
Thanks for your considerations and answers.
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If this small room is enclosed with a roof (presumably it is) is in the UK (etc.) and is being used as a smoking area then the employer is breaking the law.
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I agree with Ron but also think not a confined space as too large.
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You could define it as a Confined Space (although that's irrelevant).
In the regulations a Confined Space is described as having two defining features: · It is a place which is substantially (though not always entirely) enclosed and, · There will be a reasonably foreseeable risk of serious personal injury from hazardous substances or conditions within the space or nearby. The Confined Space Regulations defines those risks as Specified Risks, which include loss of consciousness arising from gas, fumes, vapours or the lack of oxygen.
However, as Ron has alluded to, that's not the issue. You can't introduce a Permit to Smoke system!
Ian
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It's not normal practice to store pressurised gas cylinders inside a building, unless there are very strong fire precautions, plus suitably designed forced ventilation (i.e. in + out) to control foreseeable small leaks within the storage/use area. An example is laboratories, where the high pressure cylinders are typically outside the building, with only the lower pressure feed line passing into the lab. However, I've seen some labs with the cylinders inside, but with very good ventilation controls. Also I've seen cylinders kept in an internal store that is designed with suitable fire barriers plus local ventilation - but both are unusual and not to be planned without thorough risk assessments. In contrast, it's OK to 'use' gas cylinders inside a building for a specific task, but to ensure they are not left unattended, including for work breaks.
So to store the cylinders with regulators on and then to allow local smoking seems extremely poor practice. I'd be worried less about the confined space potential and more about how this is covered in your building fire risk assessment.
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FireSafety101 wrote:I agree with Ron but also think not a confined space as too large. Size does not matter.
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Maybe the "smokers" are machines.
Putting aside whether this room is classified as a confined space we are still left with the potential exposure to harm to anyone entering or working in the room.
A full and complete risk assessment will determine whether adequate precautions are in place and whether any extra control measures need to be taken.
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redken wrote:FireSafety101 wrote:I agree with Ron but also think not a confined space as too large. Size does not matter. As the actress said to the Bishop :-)
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David Bannister wrote:Maybe the "smokers" are machines. I pondered that too. Irrespective, compressed cylinders of Carbon Monoxide are highly flammable. Ignition sources are a no-no; I'd also doubt that "kitchen type" fans are appropriate.
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It the smokers are people then it breaches the Smoke Free stuff...if it is just about confined space there is 3 specified risks...asphyxiation, flammability and toxicity....might still be low risk but a confined space nonetheless..
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Is this some sort of R&D set up?
If it is ( and not some sort of joke…sorry some of the posting recently have been a bit odd and I am getting suspicious) then I’d say it is not confined space as it is easy to get in and out of ( ie it’s not confined) but that is largely a red herring. The main responsibility is (as always) to carry out a suitable and sufficient risk assessment including issues under COSHH and DSEAR.
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It may not be a confined space, but may well be a Dangerous Space as defined in statute - an example (not directly relevant to a shore installation) is SI 1988 No 1638 ""dangerous space" means any enclosed or confined space in which it is foreseeable that the atmosphere may at some stage contain toxic or flammable gases or vapours, or be deficient in oxygen, to the extent that it may endanger the life or health of any person entering that space;"
In the guidance it further goes on to advise that a Dangerous Space may not necessarily be enclosed on all sides (e.g. a hole in the ground with heavier than air gas).
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A Kurdziel wrote:I’d say it is not confined space as it is easy to get in and out of ( ie it’s not confined) That's as irrelevant as the size of the space to the definition of confined space. Confined space means it's contained - substantially enclosed, not that it's difficult to access. Is this space enclosed? I'd say yes. Is there a reasonably foreseeable risk of serious injury arising from fire or explosion? Since it contains pressurised cylinders of flammable gas and a number of sources of ignition, I'd say yes. Is there a reasonably foreseeable risk of loss of consciousness or asphyxiation arising from gas? Since it contains pressurised cylinders of three different gasses, all of which are asphyxiant or toxic (or both, to varying degrees), I'd say yes. By that reasoning, it meets the definition of a confined space in the relevant regulations. The guidance in the ACOP does state that 'inadequately ventilated rooms' may be confined spaces.
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I will say thank you to all for your replies and discussion, it helps a lot to have a different perspective. The smoking is being done by an experiemental machine and not directly by people, and I could point out several other issues but have tried to keep it as basic as I can, for obvious reasons. However one or two people are in the room monitoring the process during testing. This is not a UK related process, I should add.
If I look at something which is definitely and easily a confined space and then on the other side something which is definitely and easily not a confined space then somewhere in the middle there is a line. Now either side of that line it is and is not and yet the difference between the two is not a lot. So we are into a very subjective zone, I know, and hence the question.
I consider that the combination of a relatively small room and the process and gas bottles, which can give off gas in fault/error conditions and which replace normal air, and the lack of what I would consider to be proper ventilation mean this is likely to be one side of the line and hence becomes a confined space. I also think the use of air sampling and an alarm adds to the case for it being a confined space.
Overall I think the precautions have been adequate for the past, and hence no issues, however I am evaluating the process and deciding how to improve things and move them forwards and hence the question.
Thanks again for your input, it helps.
Regards, Phil.
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Rank: Super forum user
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A Kurdziel wrote:Is this some sort of R&D set up?
If it is ( and not some sort of joke…sorry some of the posting recently have been a bit odd and I am getting suspicious) then I’d say it is not confined space as it is easy to get in and out of ( ie it’s not confined) but that is largely a red herring. The main responsibility is (as always) to carry out a suitable and sufficient risk assessment including issues under COSHH and DSEAR.
I can agree with your point; but sometimes it is not easily on either side of the scale and is somewhere near the middle and so it is best to get other well considered opinions. A risk assessment is always an essential and good process to follow, but maybe that process leads to a line which is somewhere near the middle and so other advice is sought. Regards.
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See the common sense thread.
Congregating in an enclosed space with gas cylinders with inerting gases- I would say not very clever. Smoking also not very clever, especially not in a area not fit for purpose.
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achrn wrote:A Kurdziel wrote:I’d say it is not confined space as it is easy to get in and out of ( ie it’s not confined) That's as irrelevant as the size of the space to the definition of confined space. Confined space means it's contained - substantially enclosed, not that it's difficult to access. Is this space enclosed? I'd say yes. Is there a reasonably foreseeable risk of serious injury arising from fire or explosion? Since it contains pressurised cylinders of flammable gas and a number of sources of ignition, I'd say yes. Is there a reasonably foreseeable risk of loss of consciousness or asphyxiation arising from gas? Since it contains pressurised cylinders of three different gasses, all of which are asphyxiant or toxic (or both, to varying degrees), I'd say yes. By that reasoning, it meets the definition of a confined space in the relevant regulations. The guidance in the ACOP does state that 'inadequately ventilated rooms' may be confined spaces. I would rather hope that this answer would have been every ones preferred choice absolutely spot on in my view , with a risk assessment which would follow the general principle of prevention. As previously stated there were some undesired circumstances in the OP . I recently engaged the local fire station manager to look around our site for there base records in case of being called out and he says the confined spaces regulations heading has caused a lot of confusion ie the thought of people with arms down by their side and not being able to physically move scenario. Very clearly not always the case but still just as potentially dangerous
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Many thanks to all for taking the time to give your opinions and reply. Your inputs are most welcome and helpful.
Regards,
Phil.
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