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damian2701  
#1 Posted : 16 August 2017 15:41:20(UTC)
Rank: Forum user
damian2701

I am working with a sub-contractor on a hospital refurbishment which includes the removal of existing services to the kitchen, the task requires all obsolete services to be removed located within an enclosed plant room cellar directly below the kitchen area, the operative in question has queried myself about his employer’s safe system of work. I am of the opinion the cellar where the work is being carried out is a ‘confined space’ based on the specified risk namely “the loss of consciousness of any person at work arising from an increase in body temperature”. However, the Principal Contractor has deemed the work area not a “confined space” purely in the absence of a toxic atmosphere and all services have been made dead. We have taken a reading of the work area atmospheric temperature which came back at 27.3˚ Celsius, the cellar in question has a low head clearance approx. 4ft in height and is quite difficult with very cramp conditions.

There is only one entrance leading in and out of the work area which kind of justifies my query.

In my opinion, all the conditions detailed above attributes to what merits a “confined space”.

Has anyone else come across a similar scenario and what was the outcome.

A massive thanks to any responses.

Damian

SNS  
#2 Posted : 16 August 2017 22:31:13(UTC)
Rank: Super forum user
SNS

As stated the situation leads to more questions than answers ...

What is your interest? If the sub-contractors employee has come to you, why? Do you have a 'professional' relationship to carry out?

They should take their query back to their employer, the place being a defined 'confined space' does, as you say, include more that services being dead and atmosphere ok etc. Size of and type of access, size of the space itself , The ACOP changed in 2015 http://www.hse.gov.uk/pubns/priced/l101.pdf so it may not start out as one, but may become one depending on the work going on - welding / cutting using gas etc. The definition has become a bit tighter so the PC may be correct under the ACOP.

What does the RA / MS say?

As its Hospital work it may be worth asking NHS England H&S guru's (If its NHS work) what they think??

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damian2701 on 17/08/2017(UTC)
damian2701  
#3 Posted : 17 August 2017 07:57:12(UTC)
Rank: Forum user
damian2701

Thanks for your response.

I am an H&S advisor to the sub-contractor in question where I carry out workplace inspections/site audits on their behalf.

As you state, what do their RAMS arrive at?  unfortunately, the task of working within the cellar has been assessed but not as confined space work, in fact their RAMS are pretty much generic reiterating manual handling, working at height, emergency arrangements and so on……

I like the idea you mention of contacting the estates H&S guru to see what their thoughts are, interestingly, the entrance into the cellar does not display any warning signs as a confined area warranting a permit to work before entry, however, like you say, the task of removing the services may not start out as  confined space but as a result of taking a temperature reading and the task requiring significant effort (occasionally requiring an abrasive cutting wheel to cut through stubborn fixings) would inevitably bring the task under the remit of confined space work – would you agree?

Additionally, would you agree that working in an enclosed area with only one entrance in and out, with no air movement, working in an environment using abrasive wheels where the air temperature remains at a constant 27.3˚C would bring about a ‘specified risk’ requiring measures to be put in place as per the confined space regs?

RayRapp  
#4 Posted : 17 August 2017 08:43:00(UTC)
Rank: Super forum user
RayRapp

Damian

Given the description of the area and the task I would say with some confidence the cellar is a confined space per se. Apart from the heat, the potential for a lack of oxygen and only one entrance ticks all the boxes as far as I'm concerned.   

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damian2701 on 17/08/2017(UTC)
Alfasev  
#5 Posted : 17 August 2017 08:53:46(UTC)
Rank: Super forum user
Alfasev

I agree with the Principal Contractor, it is not a confined space due to heat. Having worked in high temperature high humidity atmospheres a temp of 27.3 C would not trigger any additional measures. We had temperatures of 47 C, 100% humidity.

A loss of consciousness of any person at work arising from an increase in body temperature does not occur like a loss of consciousness due to toxic gases like hydrogen-sulphide. There are many warning signs and opportunities to leave the space.

However, as stated there is a risk of creating a confined space and it is also important that you also obtain confirmation of the decommissioning of the plant and equipment in the cellar.

That said you still need to have an emergency plan, and consider if people are comfortable working in the space. .

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damian2701 on 17/08/2017(UTC)
SNS  
#6 Posted : 17 August 2017 21:50:35(UTC)
Rank: Super forum user
SNS

Whilst maybe not under the letter of the guidance could there be fresh air pumped in for comfort and work efficiency reasons?

Maybe have the 'generic' RAMS tightened up to specific for the job and assess what that brings to the fore?

Had something very similar under a hospital in darkest Cornwall, happily I didn't have the H&S remit at the time.

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damian2701 on 21/08/2017(UTC)
Kate  
#7 Posted : 18 August 2017 08:24:54(UTC)
Rank: Super forum user
Kate

I've encountered 30°C as a threshold above which a confined space (considered confined for other reasons - a chemical tank) should not be entered.  Obviously this is arbitrary.

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damian2701 on 21/08/2017(UTC)
Ian Bell2  
#8 Posted : 18 August 2017 09:21:05(UTC)
Rank: Super forum user
Ian Bell2

From the information given the scenario sounds like it could meet the definition of a confined space. Regardless of the exact legal definition, I would take the view that there is a more holistic view to ensure the job is carried out safely and with at least some attempt at considering the heat stress impact on the guys/girls doing the work.

There is a heat stress risk assessment form on the HSE website, which might help to reach a final decision.

http://www.hse.gov.uk/temperature/assets/docs/heat-stress-checklist.pdf

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damian2701 on 21/08/2017(UTC)
RayRapp  
#9 Posted : 18 August 2017 10:22:54(UTC)
Rank: Super forum user
RayRapp

Any enclosure can be deemed a 'confined space' due to the inherent hazardous properties. In fact, I recall once when working underneath a railway platform installing cabling I deemed the area to be a confined space because there was little natural or borrowed lighting, trip hazards including glass, animal carcasses and the potential for other nasties like syringes, plus an unprotected shaft.  

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damian2701 on 21/08/2017(UTC)
Bigmac1  
#10 Posted : 20 August 2017 08:51:39(UTC)
Rank: Super forum user
Bigmac1

So what was the specified risk Rayrapp?

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damian2701 on 21/08/2017(UTC)
RayRapp  
#11 Posted : 20 August 2017 19:01:34(UTC)
Rank: Super forum user
RayRapp

Bigmac1

There were a number of specified risks mostly emanating from trips, slips and falls.

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damian2701 on 21/08/2017(UTC)
damian2701  
#12 Posted : 21 August 2017 08:45:18(UTC)
Rank: Forum user
damian2701

RayRapp

I rely value your opinions and guidance but aren't specified risks Bigmac1 referes to are:

“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;

Damian

RayRapp  
#13 Posted : 21 August 2017 09:43:35(UTC)
Rank: Super forum user
RayRapp

Damian

Cut and pasted below from the HSE website - http://www.hse.gov.uk/confinedspace/

'A confined space is a place which is substantially enclosed (though not always entirely), and where serious injury can occur from hazardous substances or conditions within the space or nearby (e.g. lack of oxygen).'

So, a confined space does not have to include any of the specified risks - these are just examples.

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damian2701 on 22/08/2017(UTC)
Kate  
#14 Posted : 21 August 2017 13:38:42(UTC)
Rank: Super forum user
Kate

Specified risks are not just examples though.  They are part of the legal definition of what constitutes a confined space.  If there isn't a specified risk then legally it isn't a confined space.  Of course, you might still want to apply your confined space procedures to spaces that are not legally confined spaces, if it will give a benefit.

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damian2701 on 22/08/2017(UTC)
RayRapp  
#15 Posted : 21 August 2017 18:41:02(UTC)
Rank: Super forum user
RayRapp

Kate, fair point.

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damian2701 on 22/08/2017(UTC)
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