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Low15562  
#1 Posted : 04 January 2018 13:30:58(UTC)
Rank: Forum user
Low15562

Hi a couple of questions.....

I am updating our young persons procedure and for some reason I believe that a young person (between 16-18 years) cannot work in confined spaces and this is what I wrote in the procedure originally (approx 5 years ago), however in line with a young person due to join us in the near future I am reviewing the content yet I am unable to find this anywhere and cannot remember why I included this last time.  As far as I can see providing the young person has received the appropriate training, supervision etc and has been given the ok from an OH medical and they are not lone working I cant find why they should not be permitted to work in a confined space (assuming controls are in place and supervision etc).  Can anyone shed any light on this or am I just going mad?? 

Secondly my understanding is that anyone entering a confined space should be trained and this training should be refreshed every 3 years and across our organisation this is the case for all of our workers, however our head of HSE has bascially said that for the maximum of 5 occasions that he personally enters a confined space in the course of a year to "have a look" it doesnt warrent completing the training refresher and he does not want to spend a day out of his busy schedule to attend a training course that is just common sense.  How can I respond to this?  As far as I can see in the regulations he should attend the training - any advice is welcomed.

Many thanks for your views in advance :)

Kate  
#2 Posted : 04 January 2018 16:21:24(UTC)
Rank: Super forum user
Kate

Well, here's my perspective.

Depending on what the confined space work involves you might have concluded that it fell under the requirements for protection of young persons in the Management Regs - although these do not specifically mention confined spaces, they do menion some things that could occur in some confined spaces: http://www.legislation.gov.uk/uksi/1999/3242/regulation/19/made

I wouldn't expect refresher training for entering a confined space to take a whole day unless there is more involved such as practical training in using breathing apparatus, conducting rescues etc.  Remember that refresher training doesn't have to be a repeat of the original training, it can be just a review of the main points and a check that they are still understood.  If the confined space procedures themselves are simple and straightforward (eg you are not using BA, hoists etc) then I reckon you could do a refresher in half an hour tailored to the type of confined space work you have on site and your internal procedures.

David Bannister  
#3 Posted : 04 January 2018 16:34:08(UTC)
Rank: Super forum user
David Bannister

A person making frequent entries to a confined space should become very familiar to the controls and habitualised to using them. An infrequent "entrant" may be more likely to forget or overlook a vital control.

The refresher may therefore be more useful to the latter.

I often encountered the same argument with FLT refreshers by managers who said they were too busy to be refreshed, the argument being that they rarely used the trucks anyway.

Interesting discussions ensued.

matelot1965  
#4 Posted : 04 January 2018 18:43:12(UTC)
Rank: Forum user
matelot1965

Originally Posted by: Low15562 Go to Quoted Post
Hi a couple of questions..... I am updating our young persons procedure and for some reason I believe that a young person (between 16-18 years) cannotwork in confined spaces and this is what I wrote in the procedure originally(approx 5 years ago), however in line with a young person due to join us in the near future I am reviewing the content yet I am unable to find this anywhere and cannot remember why I included this last time. As far as I can see providing the young person has received the appropriate training, supervision etc and has been given the ok from an OHmedical and they are not lone working I cant find why they should not be permitted to work in a confined space (assuming controls are in place and supervision etc). Can anyone shed any light on this or am I just going mad?? Secondly my understanding is that anyone entering a confined space should be trained and this training should be refreshed every 3 years and across our organisation this is the case for all of our workers, however our head of HSE has bascially said that for the maximum of 5 occasions that he personally enters a confined space in the course of a year to "have a look" it doesnt warrent completing the training refresher and he does not want to spend a day out of his busy schedule to attend a training course that is just common sense. How can I respond to this? As far as I can see in the regulations he should attend the training - any advice is welcomed. Many thanks for your views in advance :)


Hi Low,

Please see the link below which is perhaps the reason that you wrote in your procedure that 16-18 year olds cannot work in a confined space ?More specifically see below the line “ An employer must consider the work that the young person will do”

Hope this helps
matelot1965  
#5 Posted : 04 January 2018 18:47:21(UTC)
Rank: Forum user
matelot1965

Woolf13  
#6 Posted : 05 January 2018 12:59:08(UTC)
Rank: Forum user
Woolf13

Hi,

In terms of competence and training of the individual who thinks he does not require it, see, Safe Work in Confined Spaces ACoP pages 25:

Competence for confined spaces working 

“Workers must have adequate training and experience in the particular work involved to be competent to work safely in a confined space. Training standards must be appropriate to the task, and to the individual’s roles and responsibilities, so that work can be carried out safely.”

“Must” is an absolute duty under law. Also if they are saying they do not require it I would question their competence. I have my confined space ticket renewed every three years. This is despite working in confined space for over ten years and delivering my own training on confined space entry/rescue.

In terms of a young person refer to the Management of Health and Safety at Work Regulations. However, in relation to confined space see also, Safe Work in Confined Spaces ACoP pages 48 and 49:

An employer shall not employ a young person unless he has, in relation to risks to the health and safety of young persons, made or reviewed an assessment.

 In making or reviewing the assessment, an employer who employs or is to employ a young person shall take particular account of —

(a) the inexperience, lack of awareness of risks and immaturity of young persons;

(b) the fitting-out and layout of the workplace and the workstation;

(c) the nature, degree and duration of exposure to physical, biological and chemical agents;

(d) the form, range, and use of work equipment and the way in which it is handled;

(e) the organisation of processes and activities;

(f) the extent of the health and safety training provided or to be provided to young persons; and

(g) risks from agents, processes and work listed in the Annex to Council Directive 94/33/EC on the protection of young people at work.

Any group of his employees identified by the risk assessment  as being especially at risk………

I hope this helps?


Low15562  
#7 Posted : 11 January 2018 13:49:12(UTC)
Rank: Forum user
Low15562

Many thanks for your opinions, some I had already covered but appreiciate the input as its a sanity check!

Bigmac1  
#8 Posted : 12 January 2018 22:49:17(UTC)
Rank: Super forum user
Bigmac1

Why on earth would you want to put a 16 year old in a confined space?

Dickens chimney sweep perhaps

thanks 2 users thanked Bigmac1 for this useful post.
A Kurdziel on 15/01/2018(UTC), Brian Campbell on 16/01/2018(UTC)
stevedm  
#9 Posted : 24 January 2018 14:45:11(UTC)
Rank: Super forum user
stevedm

'No person shall work in a confined space unless they are deemed physically and psychologically capable and medically fit for the work activity'. Taken from the Water OGN Industry Guidance.  We do not issue medical fitness or confined space training certificates for those under the age of 18.  Not everyone is the same but those working in the water/utilities should be following that guidance.  And of course it only guidance... :)

Adams29600  
#10 Posted : 25 January 2018 11:11:23(UTC)
Rank: Forum user
Adams29600

Originally Posted by: Bigmac1 Go to Quoted Post

Why on earth would you want to put a 16 year old in a confined space?

Dickens chimney sweep perhaps

As part of my training as a Deck Cadet on oil tankers (many years ago) at age 16, we were supervised entering ship's boilers and any other confined space on board that was being accessed (cofferdams, ballast tanks, double bottoms etc. to give us an appreciation of what they were and how they worked. Also spent several weeks on that voyage working in cargo tanks (under supervision) assisting with pipe turning but learning first hand the requirements for working safely in a confined space.

This because as junior ships officers at age 20 to 21, we would potentially have been responsible for teams entering and working in those spaces in both routine maintenance and emergency situations.

Depending on the 16 year old's chosen career path, it may be something that is going to be a major part of their future so why wait until they are 18 to start training them?

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