Confined Spaces – a discussion and memoir of an experienced health and safety practitioner

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confined spaces part 1

In this series of articles, Dr Richard Brown gives a detailed account of his experience in confined spaces during his time as a health and safety practitioner.

Confined spaces are perhaps the most misunderstood of hazards in the UK safety world. Since I have been a health and safety practitioner since the 1990s I have regularly observed this. In this article, I write about the history of confined spaces in the UK, with reference to the law and significant events, what are confined spaces, and what are the common misperceptions that are held about them.

From my experience, I have observed over many years that health-related hazards are more difficult to comprehend in a workforce rather than traditional safety hazards. Workers understand that moving machinery and workplace transport can cause significant injury – they can see it and hear it and therefore their understanding of it is a simpler process. Confined spaces have prescribed hazards which are defined within the Confined Space Regulations 1997[1]. Hazards such as high or low oxygen levels however cannot be seen, have no smell and therefore cannot be properly considered as a hazard in some workers’ minds. From my experience, this extends to managers and supervisors who assess hazards and indeed send their workforce to work within environments such as these.

What is a confined space?

This very question seems to confuse workers and indeed health and safety practitioners. To best assess what is a confined space, we need look no wider that the regulations and the helpful Approved Code of Practice L101[2]. For a space to be confined as defined it must meet the following criteria:

(2) “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;

“specified risk” means a risk of—

(a) serious injury to any person at work arising from a fire or explosion;

(b) without prejudice to paragraph (a)—

(i) the loss of consciousness of any person at work arising from an increase in body temperature;

(ii) the loss of consciousness or asphyxiation of any person at work arising from gas, fume, vapour, or the lack of oxygen;

(c) the drowning of any person at work arising from an increase in the level of a liquid; or

(d) the asphyxiation of any person at work arising from a free flowing solid or the inability to reach a respirable environment due to entrapment by a free flowing solid.” (Confined Space Regulations 1997, Regulation 2)

In summary, for a space to be a confined space within the meaning of the regulations, it must meet the definition of confined and there must be one of the significant risks detailed at (2)(a) to (d).

Misunderstanding, misinterpretation, and misapplication.

I have found that the definition of confined spaces is often misunderstood, misinterpreted, and misapplied in industry. I worked for much of my work life in the power industry. Starting at one station, in my first few weeks, whilst getting to grips with the site, I was taken on a tour. After seeing the boiler (confined space – ‘tick’), the gas turbine (confined space – ‘tick’), the steam turbine (confined space – ‘tick’) I climbed to the turbine hall roof with my colleague and guide. At the top ladder, prior to stepping on to the roof I noticed a confined space warning sign. I queried this and was told that the roof had been classified as a confined space because it had restricted access and was high risk.

I discussed this with my colleague, and it appeared that the health and safety department had classified the roof as a confined space. I discussed the requirements for a space to be confined as defined with my colleague, and we chatted about the regulatory requirements for the definition to apply. It appeared that the misunderstanding had arisen by a simple misapplication of the regulations. The roof was restricted – it required a ladder to access it, and this was rightly controlled by permits, roof ladder locks etc. – but it was not a confined space. It was clear that none of the hazards in (a) to (d) were present or foreseeable. There was certainly a significant hazard from work at height, but this is not one of the defined hazards from the regulations. However, whilst not being part of the confined spaces definition, work at height and other hazards should always be considered as part of a risk assessment within a confined space.

Similarly, at the same power station, a cable pit was marked as a confined space. It had four walls, ladder access and therefore was restricted. However, it had none of the hazards detailed at (a) to (d). In this case, the application of ‘confined space’ had been allocated based on OSHA requirements and definitions[3]. OSHA is the US regulator, carrying out a similar function to the UK’s HSE. OSHA categorise their spaces as confined spaces in two categories – non permit entry and confined spaces  requiring permit entry. The cable pit met the OSHA definition of a non-permitted confined space.

Other industry examples

In the paper industry, paper pulpers are used to mix the large paper bales with water and sometimes bleaches and other chemicals. They are similar to a very large food mixer, with a rotor at the bottom. Pulper are fed paper product by conveyers, have a large water tank above them, which releases large volumes of water on demand, to mix with the paper pulp. Paper pulpers are clearly confined spaces as defined. They are entered by ladder or platform from above, have sloping sides and fill rapidly with water. They therefore have a largely/fully enclosed structure, and they have a foreseeable risk of drowning. Many pulpers are often open topped, and this sometimes causes risk assessors and workers due to enter them to mentally ‘downgrade’ them as confined spaces. However, the risk of drowning does not require that there be a top to the pulper – the rapid filling of water from a water tank would quickly cause drowning, aided by the confined nature of the pulpers walls. HSE state “A confined space is one which is both enclosed, or largely enclosed”[4] (my emphasis).

I have often observed confined space teams gas testing pre entry to paper pulpers. This appears to be another misperception in confined space risk assessment. Paper pulpers have product changes every hour or less. Once the pulp and water have been suitably mixed, and the consistency is as desired, the pulp mixture is pumped to a storage tank and the pulping process begins again. There can never be gas arising from empty, regularly emptied pulpers – the risk is from drowning, not from gas. I have observed this practice in other industries – assessment teams appear to believe that because something is classified as a confined space there must be a hazard from gas. This is not the case – any of the hazards from (a) to (d) can apply in isolation or there may be a combination of hazards.

Look out for part 2 coming soon where Richard will be detailing the history of confined spaces.

For any more information on confined spaces or anything else you’ve read here please contact [email protected].

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[1] https://www.legislation.gov.uk/uksi/1997/1713/contents/made

[2] https://www.hse.gov.uk/pubns/priced/l101.pdf

[3] https://www.osha.gov/confined-spaces

[4] https://www.hse.gov.uk/toolbox/confined.htm

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