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forwardpure  
#1 Posted : 22 July 2019 08:18:50(UTC)
Rank: New forum user
forwardpure

<p>Dear fellow practitioners - I wish to ask for your thoughts on the below please. </p><p>If you have an area which is deemed a confined space as per definition within the regulations and you use an engineering control such as extraction (lets say this is a fume hazard) would you agree this is only a control measure and this does not render the space 'not applicable' to the regulations (i.e. as you may feel you are removing the hazard). </p><p>I have a colleague within a new organisation who has been a confined space trainer for a number of years who would say this eliminates and renders the space 'not applicable'. </p><p>Now in some cases I would agree i.e. when pure elimination of a specified risk has been&nbsp;achieved&nbsp;prior to entry however, if you are using extration there is a potential it could fail or even not extract the full amount of fume from the space in which case you would have to monitor the area (so, it is still a confined space). </p><p>We also have a situation where shot blasting is being carried out in the same area and dust is an issue so full oxygen fed helmets are used, extration etc. With this situation I am being informed that if the oxygen fails on the helmets the blaster would stop blasting and the dust would be extracted pretty quick meaning he could remove his helmet in order to breathe however, to me I am still not entirely convinced this is rendering the regs not applicable. I understand dust is different to fume however, this could still give adverse effect to the situation. </p><p>Another thing this person has said is in some cases workers go into a space with a monitor 'just incase' now in this case this of course would make this potentially a reasonably foreseeable case. However, other arrangements are not in place... its a tough one this as I think budget etc. may be getting in the way of safety. </p><p>THANK YOU. </p>

Edited by user 22 July 2019 10:38:23(UTC)  | Reason: Not specified

peter gotch  
#2 Posted : 23 July 2019 10:31:00(UTC)
Rank: Super forum user
peter gotch

Forwardpure

There are two QQ - one is it a confined space within the meaning of the legislation at the time of work being done. Since we don't know what legislative regime you are working in, it is very difficult to answer that Q.

The other is whether the controls are adequate. That depends to some degree on how you define adequate and takes you back to a degree to the first Q.

So more information, needed, preferably in paragraphs so that it is easier for readers to understand what you are asking.

thanks 1 user thanked peter gotch for this useful post.
forwardpure on 24/07/2019(UTC)
Bigmac1  
#3 Posted : 23 July 2019 10:35:46(UTC)
Rank: Super forum user
Bigmac1

A confined space is still a confined space when you put in an engineering control. All you are doing is managing the risk. 

thanks 1 user thanked Bigmac1 for this useful post.
forwardpure on 24/07/2019(UTC)
forwardpure  
#4 Posted : 24 July 2019 20:10:23(UTC)
Rank: New forum user
forwardpure

Hi. I have reposted my first post as the formatting had gone a little wild.....

Dear fellow practitioners - I wish to ask for your thoughts on the below please.

If you have an area which is deemed a confined space as per definition within the regulations and you use an engineering control such as extraction (lets say this is a fume hazard) would you agree this is only a control measure and this does not render the space 'not applicable' to the regulations (i.e. as you may feel you are removing the hazard).

I have a colleague within a new organisation who has been a confined space trainer for a number of years who would say this eliminates and renders the space 'not applicable'. Now in some cases I would agree i.e. when pure elimination of a specified risk has been achieved prior to entry however, if you are using extration there is a potential it could fail or even not extract the full amount of fume from the space in which case you would have to monitor the area (so, it is still a confined space).

We also have a situation where shot blasting is being carried out in the same area and dust is an issue so full oxygen fed helmets are used, extration etc. With this situation I am being informed that if the oxygen fails on the helmets the blaster would stop blasting and the dust would be extracted pretty quick meaning he could remove his helmet in order to breathe however, to me I am still not entirely convinced this is rendering the regs not applicable. I understand dust is different to fume however, this could still give adverse effect to the situation.

Another thing this person has said is in some cases workers go into a space with a monitor 'just incase' now in this case this of course would make this potentially a reasonably foreseeable case. However, other arrangements are not in place... its a tough one this as I think budget etc. may be getting in the way of safety.

THANK YOU. 

Bigmac1  
#5 Posted : 25 July 2019 14:06:13(UTC)
Rank: Super forum user
Bigmac1

Originally Posted by: forwardpure Go to Quoted Post

Hi. I have reposted my first post as the formatting had gone a little wild.....

Dear fellow practitioners - I wish to ask for your thoughts on the below please.

If you have an area which is deemed a confined space as per definition within the regulations and you use an engineering control such as extraction (lets say this is a fume hazard) would you agree this is only a control measure and this does not render the space 'not applicable' to the regulations (i.e. as you may feel you are removing the hazard).

I have a colleague within a new organisation who has been a confined space trainer for a number of years who would say this eliminates and renders the space 'not applicable'. Now in some cases I would agree i.e. when pure elimination of a specified risk has been achieved prior to entry however, if you are using extration there is a potential it could fail or even not extract the full amount of fume from the space in which case you would have to monitor the area (so, it is still a confined space).

We also have a situation where shot blasting is being carried out in the same area and dust is an issue so full oxygen fed helmets are used, extration etc. With this situation I am being informed that if the oxygen fails on the helmets the blaster would stop blasting and the dust would be extracted pretty quick meaning he could remove his helmet in order to breathe however, to me I am still not entirely convinced this is rendering the regs not applicable. I understand dust is different to fume however, this could still give adverse effect to the situation.

Another thing this person has said is in some cases workers go into a space with a monitor 'just incase' now in this case this of course would make this potentially a reasonably foreseeable case. However, other arrangements are not in place... its a tough one this as I think budget etc. may be getting in the way of safety.

THANK YOU. 

Forwardpure

I would suggest what your talking about is "Low risk confined spce" against "Medium risk" or even "High risk"

The control measures would be diffenernt for each.

Low risk confined space may only require wearing say oxygen depletion monitors for example where high risk would neen the whol shooting match, confined space supervisor, ventilation, communication, emergency rescue arrangements etc

However each are still classed as confined spaces, only the levels of controls are different.

Hope this make sense

thanks 1 user thanked Bigmac1 for this useful post.
forwardpure on 25/07/2019(UTC)
forwardpure  
#6 Posted : 25 July 2019 17:24:08(UTC)
Rank: New forum user
forwardpure

Yes it does - it was kind of the lines of what I was thinking anyway it has just been one of these cases where you question yourself several times i.e. is the person saying it isn't a confined space actually right in what they say. You thoughts have helped justify my own as well as my Director's.

With thanks.

RayRapp  
#7 Posted : 26 July 2019 09:24:00(UTC)
Rank: Super forum user
RayRapp

The concept is similar to any other hazard. For example, working at height, just because you have control measures in place to mitigate against the risk of falling e.g. edge protection - the activity is still working at height and the risks if the control measure should fail are just the same as if there was no control measure.

Martin Gray  
#8 Posted : 30 July 2019 14:16:08(UTC)
Rank: Forum user
Martin Gray

There are several stated cases where mechanical means of ventilation in confined spaces have not be working maintained resulting in fatalities, yes, the mechanical ventilation etc may reduce the risk to low but your should still consider the need to monitor for the presence of gases/fumes which may reduce the amount of life sustaining oxygen prior to entry reliance on mechanical ventilation alone would not be sufficient.

If you follow the guidance in the HSE ACOP L101 you should not go wrong.  Many H&S Manager etc do not understand the guidance and I would recommend they attend an awareness course as they/we are not experts in all H&S legislation because we have a Diplome etc or have read the book.

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