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We have an outside lock up where thinners has been stored for a number of years. Recently it was reported that there were strong vapours in there so when I went to investigate the thinners had seaped through the tins. The container was not the correct type for flammable goods with just ventilation at the top of the crate. The insides of the crate had peeled.
The site asked for a waste company to collect and were told that they would have to empty the container themselves and have it ready for collection.
I read the SDS and wrote a safe procedure including the APF for the RPE.
The site didn’t clear the container and the collection company refused to do it classing it as a confined space and they would need air lined RPE.
Is a container classed as a confined space?
Also because it’s a confined space is it correct about the airlines RPE? Edited by user 16 July 2019 14:19:21(UTC)
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It's been a while since I taught confined space training so had to look up the definition, the following is taken from the Confined Spaces Regulations 1997, lifted from the HSE website. “confined space” means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk;
I don't think that a shipping container is a confined space, as long as it is ventilated correctly, all of the other options have the potential to hold heavy vapours where as a shipping container that has it's door open can't unless it's not been levelled in correctly with a slight slope to the door end.
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From experience I would say containers are a confined space as most of them are very poorly ventilated and fumes hang around at the back for some time, we use them as tool stores and there is a significant smell of petrol whenever rail saws etc are stored at the back. So unless your container has some mechanism for propelling the air out of the back of the unit or has an decent extractor we would treat it as a confined space.
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 1 user thanked jmaclaughlin for this useful post.
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Originally Posted by: jmaclaughlin  From experience I would say containers are a confined space as most of them are very poorly ventilated and fumes hang around at the back for some time, we use them as tool stores and there is a significant smell of petrol whenever rail saws etc are stored at the back.So unless your container has some mechanism for propelling the air out of the back of the unit or has an decent extractor we would treat it as a confined space.
Thanks for the response but I’m now assuming that workers would now need to be trained in confined spaces to even enter the container due to the current temperatures and with the subsequent increase in vapours ?
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Strictly by definitions I would agree you have a confined space as you appear to potentially meet the definition of one of the confined spaced 'specified' risk, namely (i) fire or explosion (ii) loss of consciousness from a vapour. However, keep thing in proportion, out of the 2 risks I would be much more concerned about the fire & explosion risk. The vapour concentration would have to be very high and/or prolonged exposure before loss of consciousness.
I would say its more important to consider the fire & explosion risks - as such you need to complete a DSEAR risk assessment if the vapours are from solvent based/hydrocarbon based paints/thinners.
I wouldn't expect an overly complex DSEAR assessment for this type of situation. The key will be getting enough ventilation / air movement though the container. If its an old shipping container, are there doors at both end, to open up?
Training isn't too onerous, just ensure people are aware the container is considered to by confined and the vapours are potentially flammable. Therefore the control of ignition sources is essential until the vapours are dispersed.
A hydrocarbon gas detector could be used to first measure the concentration of hydrocarbons in the atmosphere. A safe atmosphere can be declared once below 50% LEL.
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Is this external storage an old shipping container? Not fully clear from the OP.
Shipping containers are designed to be water tight i.e. not ventilated
Storing solvents in them without prior modification (adequate ventilation) would be a bad idea.
If the solvent containers are now leaking the contents will be soaking in to the deck timbers, and possibly the ground / ground waters underneath
So limited access path, no through ventilation, extreme of temperature and an atmosphere saturated with solvent I would default to confined space, certainly would not be permitting any hot works
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Rank: Super forum user
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Is this external storage an old shipping container? Not fully clear from the OP.
Shipping containers are designed to be water tight i.e. not ventilated
Storing solvents in them without prior modification (adequate ventilation) would be a bad idea.
If the solvent containers are now leaking the contents will be soaking in to the deck timbers, and possibly the ground / ground waters underneath
So limited access path, no through ventilation, extreme of temperature and an atmosphere saturated with solvent I would default to confined space, certainly would not be permitting any hot works
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If it is a classic shipping container then it is a confined space because it is unventilated. Remember the news paper headlines a few years ago about people dying in shipping containers in various situations, stow aways, workers living in them on building sites using gas to cook and heat - classic situation you are describing can catch out the unwary and the uninformed. I agree with the waste company!
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Your DSEAR/ATEX risk assessment should cover it for ventilation etc, but as far as confined space goes it only have two defining features: - It is subtaintially (although not always entirely) enclosed
- There will be a reasonably foreseeable risk of serious personal injury from hazardous substances or conditions within the space or nearby
The regulation also defines 5 specified risks: Loss of consciousness arising from gas, fumes, vapours or the lack of oxygen
Loss of consciousness arising from an increase in body temperature
Serious injury arising from a fire or explosion
Drowning from an increase in the level of liquid
Asphyxiation from a free flowing solid or inability to reach a respirable atmosphere due to entrapment in a free flowing solid
You can risk assess the spaces across your site and class them in line with the Utilities guidance - NC1 - Low Risk, NC2-medium risk, NC3 High Risk, NC4 - High risk Complex. I have an example if you want. PM me and I will send it across.
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Originally Posted by: lisar Originally Posted by: jmaclaughlin From experience I would say containers are a confined space as most of them are very poorly ventilated and fumes hang around at the back for some time, we use them as tool stores and there is a significant smell of petrol whenever rail saws etc are stored at the back.So unless your container has some mechanism for propelling the air out of the back of the unit or has an decent extractor we would treat it as a confined space.
Thanks for the response but I’m now assuming that workers would now need to be trained in confined spaces to even enter the container due to the current temperatures and with the subsequent increase in vapours ?
It doesen't require training, it's a store not a workplace for us, we brief out a tool box talk together with weekly inspections, that way the housekeeping is kept up to a good standard.
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I always thought the point of the Confined Spaces Regs was that there had to be a rescuse plan, which implies a situation needing rescue. Will your guys feasibly need to be rescued from the container? If so, treat it as a confined space, if not, don't,
John
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Originally Posted by: Mark-W It's been a while since I taught confined space training so had to look up the definition, the following is taken from the Confined Spaces Regulations 1997, lifted from the HSE website. “confined space” means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk;
Mark, a confined space is a confined space, ventilation is a control measure however it is still a confined space. It does not cease being a confined space just because you have ventilation, you are just managing that confined space.
In answer to the original question, a more suitable storage arrangement would seem to be the answer.
How can you get ito a position where containers have been there so long the material is seaping from them?
I don't think that a shipping container is a confined space, as long as it is ventilated correctly, all of the other options have the potential to hold heavy vapours where as a shipping container that has it's door open can't unless it's not been levelled in correctly with a slight slope to the door end.
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#10 If you can remove the reasons for the confined space to be considered to be a confined space, then you don't need a specific rescue plant.
Its not clear from the original post if the container has doors just at 1 end or both ends. Or if it is actually a shipping container or an otherwise locally fabricated container that meets no particular standard.
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1 user thanked Ian Bell2 for this useful post.
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Originally Posted by: Bigmac1 Originally Posted by: Mark-W It's been a while since I taught confined space training so had to look up the definition, the following is taken from the Confined Spaces Regulations 1997, lifted from the HSE website. “confined space” means any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk;
Mark, a confined space is a confined space, ventilation is a control measure however it is still a confined space. It does not cease being a confined space just because you have ventilation, you are just managing that confined space.
In answer to the original question, a more suitable storage arrangement would seem to be the answer.
How can you get ito a position where containers have been there so long the material is seaping from them?
I don't think that a shipping container is a confined space, as long as it is ventilated correctly, all of the other options have the potential to hold heavy vapours where as a shipping container that has it's door open can't unless it's not been levelled in correctly with a slight slope to the door end.
I was basing my position on the amount of times whilst serving in the Army that stores get delivered to site and then the container became the site office and then after I left, I worked a civvy contractor to the MOD and we were supplied with containers as an office/workspace.
The MOD has to comply with H&S regs whilst in the UK, but also have to comply as best they can when overseas
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Mark. When using as you say a shipping container as an office, your right its not a confined space until you have a specified risk!
However you also have the potential to create a confined space.
On a site that I visited, there is a shipping container, empty so not a confined space. Owner of the said site doesnt want to get his diesel generator wet when it rains, must be sentimental hehe. So descides to put it in the shipping container - now a coonfined space
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Originally Posted by: Bigmac1 Mark. When using as you say a shipping container as an office, your right its not a confined space until you have a specified risk!
However you also have the potential to create a confined space.
On a site that I visited, there is a shipping container, empty so not a confined space. Owner of the said site doesnt want to get his diesel generator wet when it rains, must be sentimental hehe. So descides to put it in the shipping container - now a coonfined space
I get that but when you have an container used as an office with electric and normal office equipment and then managers close the door to keep the wind/rain out it gets a bit stuffy with 3 or 4 people in there working away. But understand the inherant risk with adding another element to a bare container
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