GUIDANCE
According to various sources, it is estimated that an average of 15 people die annually in the UK due to work in Confined Spaces, and that many others are often seriously injured.
Spaces Regulations 1997 regularly has an impact on my NHS clients. Only last year I was helping an NHS Trust to implement a Confined Spaces management procedure after it received multiple improvement and prohibition notices from the HSE (not to mention the six-figure fines). The one that should hit home however, is the HSE report from January this year of an NHS engineer entering a drain on a hospital site, being overcome by gases, and unfortunately suffering from severe permanent brain injuries. Again, the Trust received a significant fine, but – more importantly – that man and his family have been impacted forever.
Mechanical (Boilers and Pressure Systems) Boilers and Pressure Systems are an often overlooked or misunderstood Safe System of Work. People often think that because, for example, they can demonstrate compliance with the Pressure Systems Safety Regulations (PSSR) 2000 (i.e. they have a written scheme of examination for relevant systems, and they are inspected at the required frequencies), they have covered all the bases. This isn’t necessarily true. There may be some high-risk mechanical systems that do not fall under PSSR, (e.g. low temperature hot water) that will still require maintenance and examination. There is reference to safe systems of work in PSSR, as follows: ‘Before each examination take all appropriate safety measures to prepare the system for examination’. Therefore, a risk-based approach is required to identify systems and equipment that will need a formal approach to making them safe to work on.
Inspection by a Competent Person A critical element in any Safe System of Work is the ability to make a system safe
A critical element in any Safe System of Work is the ability to make a system safe for operatives to work on or in.
for operatives to work on or in, and, where PSSR applies, for a Competent Person to carry out their inspection. For example, the need – before setting people to work on a steam system – to ensure that everything is correctly isolated/cooled/de- pressurised/drained etc, and that there is no remaining risk to the person performing the work. Unfortunately, this is often largely left to chance, with accidents still a regular occurrence – for example, valves being only shut, and not correctly secured and signed (with safety locks and safety signs), or systems being worked on before they are sufficiently cooled. There was an incident where a
maintenance worker at a hospital received serious burns to the lower half of his body while stripping down a steam boiler, resulting in permanent disabling injury. Again, the Trust received a fine, and yet again, that man and his family have been impacted forever. There will often be an overlap with
working at height, and confined spaces as well. For example, working on high- level pipework or on top of a boiler (away from a fixed walkway), or carrying out an internal inspection of a large steam boiler. Again, with a tied-together and centralised management system and set of procedures to support it, all these things can be covered safely. I haven’t even begun to cover all the bases here, and there are plenty more topics for discussion when it comes to Safe Systems of Work in the world of engineering and estates management However, I hope this has provided food for thought, and will hopefully be the catalyst for a conversation to begin. In conclusion, now is the right time to refresh the Health Technical Memoranda and update them with everyone’s safety – and not just that of the patients – in mind.
Ashley Morpeth
Ashley Morpeth CertIOSH, MIIRSM, MIHEEM, MInSTR, is an experienced and qualified health and safety professional with over 15 years’ experience in the Work at Height and Confined Spaces industry. He specialises in developing bespoke Safe Systems of Work, writing and implementing policy and procedures, and delivering custom, tailor-made training in an engineering and estates management environment. In addition to his extensive experience with NHS clients, he has a broad and detailed knowledge of operating and implementing other health and safety management systems such as JSP375 (Applicable to the MoD), and many other similar commercial and industrial management systems and Safe Systems of Work. He has delivered training and provided consultancy services both across the UK, and in countries such as Kenya, Nepal, Cyprus, Gibraltar, the Falklands, and throughout the Middle East.
April 2024 Health Estate Journal 59
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