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The PPE Regulation (EU) 2016/425 and the Control of Substances Hazardous to Health also state: ‘The risk to health and safety should be assessed on how to prevent or reduce the workers exposure to hazardous conditions and substances. The Personal Protective Equipment Guidance HSG53 stipulate that PPE and RPE (Respiratory Protective Equipment) is to be supplied and used at work wherever there are risks to health and safety that cannot be adequately controlled in other ways. It is essential that anyone using PPE and RPE, understand why they require the equipment, when and how it should be used, repaired or replaced and if there are any limitations. The employer is duty bound to provide training on all PPE and RPE equipment.
In the UK the Confined Space Regulations 1997 is the legislation specifically pertaining to the identification and management of confined space working and the regulations are published with an accompanying Guidance and Approved Code of Practice (ACOP) (HSE L101). The L101 ACOP was revised, updated and re-issued by the Health and Safety Executive (HSE) in December 2014.
Effectively this means that anyone involved in the accessing or entry into a confined space scenario must be trained and certificated to the degree required to cover these regulations.
So, what is a confined space? Most of these are quite obvious, others are not. Effectively anywhere where there is a potential for the atmosphere to become unsafe can be a confined space. This includes not only pipelines (whether limited in diameter or not); storage tanks (where there may or may not be just a single entry point); shafts and/or trenches which are greater than 1.5 m in depth even if open the fresh air at the top; or even tunnels which will normally require some form of ventilation circulation set up, (which of course can fail). Taken to the extreme, there is even the argument that site containers, if not correctly ventilated, can become confined spaces, almost without anyone noticing.
ASSESSING THE SITE
Given that this is the case, how does the operator go about deciding if the workplace is a confined space or not? The Regulations and guidelines give advice on this. The Regulations identify confined spaces primarily as somewhere that is substantially, but not always entirely, enclosed and the presence, or reasonably foreseeable presence, of one or more of the ‘specified risks’ detailed in the Regulations and the L101 ACOP. So anyone working with anything that might be or which might become a confined space should have copies of these available.
In looking at a worksite with a view to establishing whether it is a confined space or not a risk assessment has to be carried out. If the site meets both the stipulation that it is an enclosed or at least a substantially enclosed space and that there are risk factors that are listed in the appropriate regulations and guidelines then yes it is a confined space. It should however be pointed out that if only one of these criteria is met it may not be that the site has to be treated as a confined space but another working circumstance. These in themselves would usually carry their own set of regulations and guidelines that would need to be adhered to. So, just because your workspace is not a confined one it does not mean that there are no regulations to apply, so beware!
ARE THERE OTHER OPTIONS?
As previously mentioned the question being raised within this article is that which is addressed by a small part of one sentence above, that bit being ‘and try to eliminate entry in to the confined space by reviewing a different approach’. As is often the case with regulations it is often the smallest bit that
gets overlooked. It may also be that a great many procurers and planners do undertake this investigation, but it is perhaps a question that must be asked even if only to remind those in the positions of choice that such action is required of them.
There was argument some years back when the New Roads and Streetworks Act was introduced that alternative methodologies were all but side- lined when the regulations effectively said it might be useful to look out for any technologies that might prevent open trenching being used to install, repair or replace buried utilities. Again this was one small sentence in a huge document that appears to have taken many years of engineers experiencing trenchless options to adopt. In many ways this might also be the case in the confined space world.
It is now many of these ‘new’ trenchless technologies that might offer the solution to the elimination of much of the confined space working that still occurs today. The ‘new’ is used here because even now, almost half a century after the first trenchless techniques were introduced, we still here some engineers referring to the technologies in such a manner despite the fact that in other sectors these technologies are now considered as the go-to methods before any other option is considered and are only not used where the circumstances indicate that they would be impractical to use.
Examples of these technologies that have become wide-spread in some areas but not in others include CCTV pipeline inspection, where in smaller diameter pipes camera systems and recording software is used simply because no-one can get into the pipes at those sizes. There are however situations where these cameras may not be being used in preference to human access using confined space entry techniques where perhaps they could be, normally due to the size of the pipe. Higher definition cameras on robotic carriages that can position the camera in a position to view almost anywhere within the pipe do now exist for somewhat larger diameter pipes, but they may not always be being used. Is this because the procurement teams and/or the CCTV companies are not seeing the opportunity to prevent man- entry as required by the regulations or is it because some are simply not aware of the current capabilities of the cameras available?
Another example might be the availability of lining systems that could replace the need to utilise man-entry into confined spaces. Larger diameter systems with stronger, yet thinner walled liners are available that may well meet the needs
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May 2018 | drain TRADER 5
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