Rank: New forum user 
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Hi All
I'd very much like to receive your thoughts on this potential confined space issue, and what is reasonable and proportionate measures to control.
We are manufacturers of a product whereby in a segment of this product we have a restricted working area space. This space has two access manholes at either side of the space that is openable from both the inside and outside. However, adjacent to this space is some heat generating components - the ambient temperature in this working space is dependent on the output of the machine and environmental factors, but we have determined that the ambient temperature in this area can reach around 50 deg.C.
We have mounted temperature sensors in this area and this information is readily available for the operatives on the machines control system. Further there is active cooling system installed, and our safe systems of work instruct that this active cooling should be activated 2 hours prior to entry, and advise of rehydration requirements. There is always a second operative on the "outside" of this restricted working area.
There are no other identified CS specified risks in this area.
We have a rescue preparedness plan in place.
So far the decision has not been to classify this area as a confined space and therefore need to specifically train all persons in confined space entry, have additional rescuers on standby, and adopt permit to work systems for this task. From a practical perspective, we have a significant number of operatives around the world who would need retraining and
Given the above, would anyone have any opinions on whether the above seems reasonable and proportionate.
I'm finding it difficult to identify what ambient temperature ranges would constitute a credible loss of consciousness risk.
Any advise, guidance or opinions would be valued
Many thanks in advance
Ben
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Rank: Super forum user 
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Seems that so far you've taken a pretty pragmatic approach but the issue of heat is the sticking point.
Do you have any data with respect to the temperature which the cooling system will reduce the ambient temperature too in the workspace? Its clearly going to reduce it from ~50C but by how much is key - as is how quickly the area will likely warm back up again if the cooling is off during occupancy. Anything above 30C is pretty uncomfortable. Ideally you'd want to keep the cooling system active and on whilst the operators are occupying the space, that way negating the heat issue to a certain extent (so long as its not then too cold!).
I suspect its a similar occurrence to those maintaining wind turbines, so might be worth a quick search for such. I've a few colleagues in that sector so i'll see if I can get their thoughts.
Best wishes
Jamie
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Rank: Super forum user 
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Ben, from what you describe it would appear you have adequate control measures in place, although despite your good description seeing it in practice would be better. That said, I believe the working environment is a confined space.
The purpose of identifying a confined space is to ensure you have the right systems in place. One area of concern is training of personnel. In my opinion all those who enter and act as a second person should be trained in confined spaces and your risk assessment should identify this.
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Rank: Super forum user 
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Hello Ben. From your description of the space and the environment, it appears that should your control methods fail then there is significant potential for harm. On that basis I think your space does fall within the definition contained in the (UK) Confined Space Regs 2007.
The training and documented procedures need not be excessive and should be specific to your scenario (i.e. no need for loads of stuff on engulfment, non-breathable atmospheres etc).
The factors leading to harm are several and not limited to working temperature but will include humidity, fresh air flow, posture, fitness and general health, individual personal characteristics, clothing, the task and effort needed to complete, duration of exposure plus probably more that I can't think of right now.
All of this needs to be considered as part of your risk assessment and any consequent controls.
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Rank: Forum user
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Hi Ben
I can understand why you're having difficulties in relation to the ambient temperatures however, if it was me I'd initially err on the side of caution and designate it as a confined space.
Why? A couple of reasons....
Looking at the CS ACOP (L101):
Page 9 flowchart could suggest it being a CS due to the "loss of consciousness arising from increased body temperature" especially if the heat source is present 100% of the time.
Also, Page 10 para 20(g) could be used in your scenario.
Another good HSE document is INDG451 "Heat Stress and in the Workplace" which gives some good advice. HSE guide on "Preventing Heat Stress in Mines" provides useful info on how to measure whether the temperature is too hot or not as well.
Hope that this helps
Pete
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Rank: Super forum user
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50C heat is not a dangerous condition that presents a certain risk of death or serious injury. I have worked in temperatures close to 50C and while there is a risk of heat exhaustion there is no immediate risk of loss of consciousness arising from increased body temperature.
We regularly entered heat zones for inspections for short periods of time without any issues for nearly two years, something you would not do in a confined space. We did cool the space with fans for the physical work and had a raft of other controls (regular breaks, water, no hard hats, light paper overalls, close supervision, temperature monitoring etc.)
It is a risk that has to be controlled which as mentioned is quite possible but it does not make the space a confined space. It is the relative humidity, exertion, hydration and working time that control the risk of heat exhaustion at this temperature. There are early signs of heat exhaustion that will allow a fit and healthy person to leave the heat zone.
The argument about equipment failure can be eliminated by a testing and inspection programme. A lot a censors fail safe resulting in an alarm.
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Rank: Super forum user 
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You haven't described the task and potential risks arising from it, any PPE, clothing or other movement restrictions and the relative dimensions of the entry/exit and travel distance.
Oxygen depletion is a possibility (i.e. in a large enclosed steel structure) if your cooling system isn't air circulatory.
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Rank: New forum user
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A key pieces of information currently missing is the likely duration of entry into what is definitely a confined space, that is what will determine if there is a likelihood of heat exhaustion or heat stroke . I believe you should amend your system of work to stipulate a maximum ambient temperature in the space at which workers can enter, rather than relying on the 2 hr active cooling period you are relying on at present as this does not tell what the residual temperature is after 2 hrs, as well as stipulating maximum entry time per worker. The temperature at entry should be recorded as part of the risk assessment.
Other responses have already mentioned P.P.E ( which could potentially exacerbate heat issues) and oxygen depletion. Your say you have a rescue plan don't say whether the second worker is trained and equipped to initiate the rescue process. They need to be. I would suggest you should pursue formally classifying this as a confined spaceand initiate the PTW and other requirements.
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Rank: New forum user
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''The temperature at entry should be recorded as part of the risk assessment'.
That should have read 'required as part of the risk assessment and recorded as part of the PTW'!
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Rank: New forum user
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A lot of good responses above.
The key parts for me are the potential for a rise in body temperature due to excessive heat (specified risk)and the fact that an Emergency Response plan has been developed.
Confined Space In my opinion and workers who are entering should be trained accordingly.
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