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PBacca  
#1 Posted : 13 September 2021 20:42:24(UTC)
Rank: New forum user
PBacca

Hi all I am reviewing entry into a pipe gantry, which has an access-way that is restricted and In some cases very restricted. The pipe bridge is at height and is accessed from a fixed ladder from a gantry floor. There is only one entrance hatch and the pipe bridge area (with a mesh floor deck) is restricted To less than head height. In the pipe bridge (some areas which can only be accessed by climbing over pipes) pipes run which contain have flammable liquids. There is a small chance they could release vapours but it is low. The gantry below, when in use, is used for offloading from tanker lorries And is DSEAR zones 1 and 2. The task being undertaken is cleaning of bird faeces. Whilst it is not confined in a true sense of the definition, there is a risk that those cleaning the bird faeces, wearing tyveks and ffp3 respirators could overheat (if on a hot day) and, whilst ventilated (because the floor is a mesh grate) there is a small chance of flammable vapours being present. My concern is that should someone be injured during the gantry cleaning task, it would be extremely difficult to extract them from the gantry, in fact near impossible, as once out of the pipe bridge bridge it would mean traversing down a fixed ladder 8-10ft, which then leads to a gantry deck, which is another 12 feet and a spiral stair a case from the floor. Can anyone give thoughts on this being a confined space? I feel the specified risks (as per confined space definition) are low (only over heating if on a hot day and low risk of vapours.....but not an asphyxiating risk) but with the access being extremely difficult and rescue being ver very difficult, I am inclined to say it is. There is also the additional risk that the cleaning of bird faeces could lead to dusts, even though they are being damped down. I appreciate your thoughts, especially if you feel this could be a confined space ‘depending on the task undertaken’.
Roundtuit  
#2 Posted : 13 September 2021 21:11:51(UTC)
Rank: Super forum user
Roundtuit

So how are the birds accessing the zone to physically leave deposits?

With a mesh floor the space is open to atmosphere? Heavier than air vapours are not likely to be an issue. Open the access hatch the day before to give a good blow for any lighter than air vapours trapped under the hood (cover with netting to stop unwanted visitors).

If the mesh floor is suspended within the bridge consider forced air ventilation for a period before entry.

The bridge cover may increase operating temperature on hot days so plan the clean for cooler periods either during the day morning / evening or by season e.g. autumn after nesting.

If you would struggle to remove an injured party how are you intending removing the solid deposits?

Roundtuit  
#3 Posted : 13 September 2021 21:11:51(UTC)
Rank: Super forum user
Roundtuit

So how are the birds accessing the zone to physically leave deposits?

With a mesh floor the space is open to atmosphere? Heavier than air vapours are not likely to be an issue. Open the access hatch the day before to give a good blow for any lighter than air vapours trapped under the hood (cover with netting to stop unwanted visitors).

If the mesh floor is suspended within the bridge consider forced air ventilation for a period before entry.

The bridge cover may increase operating temperature on hot days so plan the clean for cooler periods either during the day morning / evening or by season e.g. autumn after nesting.

If you would struggle to remove an injured party how are you intending removing the solid deposits?

PBacca  
#4 Posted : 13 September 2021 21:40:31(UTC)
Rank: New forum user
PBacca

Thanks for your queries. The birds have accessed where pipes protrude from the ends of the bridge. Vapours probably would be heavier but could accumulate. Forced air ventilation would be difficult due to the height and length of the area. The waste material will presumably fall through the mesh or be bagged up (yet to see this) The hatch is small and the bridge fairly dark. In one area, I feel it would be difficult to climb over pipes, if you hurt an ankle for example. Can definitely try to plan on cooler days, I would request this. I don’t anticipate it will be a pleasant environment spraying a cleaner And brushing of bird waste, in tyvek and mask. I anticipate some dust. Visibility could be impaired slightly.
John Elder  
#5 Posted : 14 September 2021 07:09:45(UTC)
Rank: Forum user
John Elder

When considering the risk of overheating in regard to confined space works they are refering to working inside enclosed space where there is the risk of direct sunlight, steam pipework, adjacent furnaces or heating systems increasing the ambient temperature within the enclosure is the first instance as opposed to physical exertion.  If the risk of overheating through physical exertion at the ambient temperature on the Pipe bridge is no more than completing the same job at ground level then its not a confined space risk.

In regarde to gases or vapours and the risk of fire of explosion/asphyxiation there should be no tanker operations taking place during the cleaning operation and any delevery systems should be isolated. Check for any tank vents in the local area that may cause an issue otherwise after fuel transfer operations have ceased within a short period of time any residual fumes or vapours should have disipated.

The fumes and vapours in the area would normaly be from the tankers vents as the tanks are being filled the internal fumes and vapours are displaced to atmosphere. if no filling is taking place fumes and vapours shouldnt be present unless there are any permant tank vents located in the area. Any DSEAR Zones in this type of operation are normally present during fuel transfer only.

Holliday42333  
#6 Posted : 14 September 2021 07:53:28(UTC)
Rank: Super forum user
Holliday42333

From your description, it doesn't appear that this area is a confined space as per the current definition.

This does not mean you cannot identify that a rescue plan isn't identified as a reasonable control in the risk assessment for the task. 

Even with a fully trained rescue team, it sounds like a situation that would be difficult to efect a rescue. 

Perhaps the services of a specialist rescue team with experience of boilers or ship/sub fit outs would be appropriate.  Assuming you have contracted the cleaning out, you could ask the cleaning company how they have assessed this task and propose to extracate someone in difficulty or how long they estimate it will take the workers to evacuate the space in an emergency situation.

All of a sudden you may find that the best (and perhaps most efficient in time and cost) way to do the task is to remove the mesh and clean from a scaffold or MEWP

peter gotch  
#7 Posted : 14 September 2021 10:12:05(UTC)
Rank: Super forum user
peter gotch

PBacca

To quote from the Confined Space Regulations...

“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;........"

Nowhere in the Regs does it mention WHAT might cause that increase in body temperature!

But it seems to me that whether or not the CSR apply is somewhat immaterial.

You have identified a series of risks which need to be mitigated and that also it would be difficult to extract someone who was incapacitated whether as a result of accident, being overcome or whatever other possibility.

So, perhaps ignore all the law other than the need to do what is "reasonably practicable".

In the UK we can tend to the habit of wasting time pondering the intricacies of the application of various codes of regulations, rather than remembering that if all else fails the Health and Safety at Work etc Act 1974 and common law will still apply.

thanks 1 user thanked peter gotch for this useful post.
aud on 22/09/2021(UTC)
Gasman  
#8 Posted : 14 September 2021 18:04:13(UTC)
Rank: Forum user
Gasman

A.) Not a confined space.

B.) Granted your control measures require a lot of effort, but ultimately doing what can be seen as reasonably practicable will suffice. You seem to have had a good think about it and thats a start! 

Good Luck 

Roundtuit  
#9 Posted : 16 September 2021 07:32:14(UTC)
Rank: Super forum user
Roundtuit

Could you use a pressure washer from a cherry picker to clean the bridge?

Roundtuit  
#10 Posted : 16 September 2021 07:32:14(UTC)
Rank: Super forum user
Roundtuit

Could you use a pressure washer from a cherry picker to clean the bridge?

Holliday42333  
#11 Posted : 16 September 2021 13:36:52(UTC)
Rank: Super forum user
Holliday42333

Originally Posted by: Roundtuit Go to Quoted Post

Could you use a pressure washer from a cherry picker to clean the bridge?

It is not considered good practice to potentially aerosolise bird droppings by jet washing
dawsoni  
#12 Posted : 23 October 2021 12:49:25(UTC)
Rank: New forum user
dawsoni

Hi 

I would suggest a pre-entry assesment is carried out to determine if the area is a confined space as per the confined space classfication / guidelines 

From my own experince & knowledge when an area has been assesed as a non-confined space, there is still a high degree of working at heights involved into the majority of spaces Ive asssesed 

As per working at height regulations, an adeqaute rescue plan must be in place 

stevedm  
#13 Posted : 28 October 2021 13:34:56(UTC)
Rank: Super forum user
stevedm

Isn't a confined space...however you have identified the risk of hyperthermia which can induce syncope...rescue at height plan should be in place for routine operation and a specific SSOW for the cleaning activity..

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