Rank: New forum user
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Hi, Could you guys either clarify my thoughts for me/or point me in the right direction for the following?
We have an ammonia plant room, which people enter to take various readings etc, this has the usual atmosphere monitoring/ restricted access / alarms/ Auto shut downs etc but obviously, if there was an ammonia leak, then this would become a confined space. My understanding is that because this was taken into consideration when it was built (circa 2009) and is supposedly 'safe by design' then this is not classed as a 'confined space', just a 'potential confined space'? Thank you in advance as this is not my area of expertise.
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Rank: Super forum user
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If you read the guidance at http://www.hse.gov.uk/pUbns/priced/l101.pdfIf the criteria apply, then you have a confined space. From the information you have given, you appear to have a confined space under fault conditions i.e. ammonia leak. Therefore follow the HSE guidance. You appear to have some controls in place - gas detection and monitoring. Probably others that you don't realise, such as continnous piping (welded) incorporated at the design stage - less chance of leaks, than from flanged connections etc.
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Rank: Super forum user
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Good post from Ian. I am not aware of the term 'potential' confined space. It is either a confined space or it is not. The confined space does have control measures to ensure it does not become a hazard - but it is still a confined space per se in my opinion.
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Rank: Super forum user
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I agree with Ian. Your plant room is already a confined space. You now need to risk assess and decide if the controls in place are suitable & sufficent.
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Rank: New forum user
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Hi, Thank you all for the clarification. I am happy that all our controls are sufficient, and the risks are low, my issue was how I dealt with it against the company 'policy' for need for permits etc.
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Rank: Super forum user
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If they are entering the plant room to take reading why can’t this been done remotely thereby eliminating the risks. I have worked in places where there was a control room that received amongst other things all instrument and plant readings and alarms.
I believe it is not classed as a confine space providing there are strong controls in place, some of which have been mentioned, that reduces the risks to an acceptable level for the task posted. There must be no reasonably foreseeable specified risk.
Having a well maintained and inspected gas room sealed boiler in a room does not make that room a confined space even throw there is a carbon dioxide hazard.
However you cannot rely solely on the fact it met the criteria through design when new. Since 2009 a lot of things could have changed making it a confined space. It may have been modified, seal may have degraded, and poor maintenance for example could result in a reasonably foreseeable specified risk. You need to regularly update your risk assessment, inspect/check, review your controls etc. If a leek has been identified as likely this would make the plant room a confined space. It not, how to deal with a leek needs to be set out in your emergency procedures for a leek, particularly how to stop the flow.
However it may for ease of management purposes easier just to class it as a confined space.
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Rank: Forum user
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One thing to consider when defining an area as a confined space is the ease of access or egress.
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Rank: Super forum user
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stevejones wrote:We have an ammonia plant room, which people enter to take various readings etc, this has the usual atmosphere monitoring/ restricted access / alarms/ Auto shut downs etc To my mind you have a series of controls that make entering the room safe. If the alarm goes off, or whatever, then entry should not take place except under an EOP of some kind. The likelyhood of something going wrong when a person is in the room then becomes a problem to consider. How many minutes per day is the room occupied? Just my thoughts, jim
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Rank: Forum user
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Our company uses the following criterion to define a confined space.
Confined spaces are fully or partially enclosed spaces that are not designed and constructed for continuous human occupancy, have limited or restricted means for entry or exit, and where there is a risk of injury or health effect from hazardous substances or conditions. You need to meet all 3 conditions before you can assign the area as Confined Space (CS). The definition of a Confined Space also includes trenches and pits as confined spaces “in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk”.
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Rank: New forum user
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Thanks again for the comments, I am learning new things every day.
My thoughts follow Alfasev's otherwise we would end up having hundreds of confined spaces. For this instance, the room is occupied for a few minutes each day by one or two persons, it has not been modified and is maintained, tested and inspected, I am not just relying on safe at time of design. So it come back to 'without a reasonably foreseeable specified risk', which can be subjective but I believe the risk is low due to the controls, therefor there isn't a risk of change of atmosphere, therefor not a confined space.
I fully accept that there is always 'some slight risk' if 'x' and 'y' were to happen and if 'z' did 'a', but just because a pipe could leak ammonia into the room, shouldn't make it a confined space. If I use troopers C/S requirements, because there is easy entry/exit, (x2 doors in a clean and tidy 10'x10') then it isn't a C/S. looking at the guidance, I read that (and as Ian said), it would become a confined space under fault conditions, so by virtue, not a C/S under normal conditions?
I know its easier to just say, yes, its a confined space, but I just need my brain to accept exactly WHY its a confined space.
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Rank: New forum user
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I've slept on this, and still the debate goes on in my head. Firstly, I know it is easier just to class them as a confined space, but please here me out. I have checked the guidance, and this seem open for debate as some say yes, some no.
if we think about the ammonia plant room; "by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk ie"the loss of consciousness or asphyxiation of any person at work" arising from gas, fume, vapour or the lack of oxygen". at first glance, then yes they should be a confined space but the controls in place: inspection, continuous pipework, monitoring of atmosphere, auto shutdown, alarms, remove the reasonably foreseeable specified risk. therefore don't fall into the guidelines, therefor not a confined space. So we need to justify the reasonably foreseeable part: I am not aware of any incident where an ammonia leak in a controlled room has ever led to loss of consciousness or asphyxiation, I could find nothing through a Google search either. therefor not reasonably foreseeable, therefor, not a confined space.
Does this argument stand up to your understanding of the regs requirements? (thank you in advance for your time and effort in trying to help me understand this)
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Rank: Super forum user
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if you look in the Dutch Purple (PGS 3) CPR 18E book the frequency of leaks from pipelines can be estimated for pipes upto 75mm dia the leak frequency is in th eorder of 5x10^-6 per metre length per year.
The most likely cause for a loss of containment will be during maintenance activities - some maintenance engineer 'fiddles' with something he shouldn't .... fails to shut down and/or isolate the system he is working on.
I would agree the controls seem to be in place - you just need to justify why no further action is required. Save having good maintenance procedures/isolation procedures and an emergency plan to cover potential leaks of ammonia.
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Rank: Super forum user
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The problem arises from what people immediately think of as a confined space and what controls should be applied. There are work spaces which might be classed confined spaces but going the whole hog and training staff to use self-contained breathing apparatus with rescue equipment etc is unnecessary. I’ve arguments with contractors refusing to go into rooms containing liquid nitrogen tanks on the grounds that the gas might leak and that makes it a confined space. It all comes down to good old risk assessment.
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