Peter Henderson
What is a Confined Space?
A Confined space has the following characteristics:
Although an employee can enter and exit the space, and can carry out the required work while within the space, access and egress from the space is limited and the space is not designed for continuous occupation. Additional hazards may include restricted ventilation, or the presence of dangerous substances.
Examples of Confined Spaces
Examples of confined spaces include tanks, silos, pits, sewers, and storage bins.
What is a confined space entry certificate?
A confined space entry certificate verifies that an individual has been trained to operate safely within a confined space by performing effective risk assessment, using the appropriate equipment and using the correct techniques for access and exit from the space.
Why is a permit required to work in a confined space?
A permit to work is generally required whenever the task planned carries risk of injury, harm to the environment or damage to equipment. Confined spaces often carry severe risk of injury due to the possible presence of gases or other dangerous substances. The permit acts as a control to ensure that the work is properly planned, risks have been assessed and the person performing the task is qualified to do so.
What does a permit include?
Confined space permits have the same broad format as any other permit to work, however the detail will reflect the unique issues relating to confined spaces:
- Risk Assessment
- Isolations if required - e.g. isolation of pressurised piping, valves etc.
- Controls applied to reduce risk e.g. use of PPE
- Sign-off/Authorisation
- Safety Checks - E.g. gas tests,
Who is Involved in a permit ?
At a minimum there are some key roles involved:
The Creator is responsible for initiating the permit request, providing all necessary details and documentation. This role is often filled by someone who needs the permit to perform a specific task, such as a maintenance worker or a project manager.
The Approver reviews the permit request to ensure it meets all regulatory and organisational standards. This role is usually held by a supervisor, manager, or a HSE compliance officer who has the authority to approve or reject the permit based on the provided information.
The Issuer is responsible for formally granting the permit once it has been approved. This role may be held by an administrative staff member or a compliance specialist who ensures that all legal and procedural requirements are met before the permit is issued.
Finally, the Handback person is responsible for verifying that the work specified in the permit has been completed and that all conditions of the permit have been met. This role is often filled by the same person who created the permit or a designated inspector who ensures compliance and proper closure of the permit
Permits may also require additional approval stages - e.g. area manager approvers and person made aware approvers who can sign off at different stages of the task.
Key Components of a Confined Space Entry Permit
Space Classification:
Determine the Space Classification:
Identify whether the area in question is considered a 'confined space' under relevant regulations. There isn't too much difference in the general definition of a confined spaces - an area with limited means of entry and exit, not designed for continuous occupancy, and likely to contain or produce hazardous atmospheres or substances, however it is worth understanding the local regulations to allow for any specific measures which must be taken before work commences. We've included some examples here:
Global Regulatory Frameworks: Various countries have specific regulations and guidelines governing confined space work, including:
- United States: The Occupational Safety and Health Administration (OSHA) has set forth detailed standards under 29 CFR 1910.146, which outlines the requirements for Permit-Required Confined Spaces. These regulations mandate that employers must evaluate the workplace to determine if spaces are permit-required and ensure that employees are properly trained and equipped to enter these spaces safely.
- United Kingdom: The Confined Spaces Regulations 1997, enforced by the Health and Safety Executive (HSE), require employers to avoid entry to confined spaces where possible. When entry is unavoidable, employers must follow a safe system of work, including adequate risk assessments, emergency arrangements, and continuous monitoring of the atmosphere.
- European Union: The EU does not have a single confined space regulation, but member states are required to comply with the Council Directive 89/391/EEC on the introduction of measures to encourage improvements in the safety and health of workers. Individual countries, such as Germany and France, have additional specific regulations that align with this directive.
- Canada: Canadian regulations vary by province, but a common standard is provided by the Canadian Standards Association (CSA) in the form of Z1006-16: "Management of Work in Confined Spaces." This standard outlines the essential requirements for identifying, evaluating, and controlling hazards associated with confined spaces.
- Australia: Safe Work Australia provides model regulations and codes of practice, including the "Confined Spaces Code of Practice." This document provides guidance on managing risks associated with confined spaces, including hazard identification, risk control, and emergency response.
- Singapore: The Workplace Safety and Health (Confined Spaces) Regulations 2009 set out the requirements for safe entry and work in confined spaces, including the need for a permit-to-work system, proper ventilation, and continuous monitoring of the atmosphere.
- Other Regions: Many other countries have their regulations that align with these international standards, often drawing from OSHA, EU, or national standards to develop localized frameworks for confined space work.
- Identify Specific Hazards:
Risk Assessment
Each confined space could present unique hazards, such as toxic fumes, oxygen deficiency, flammable gases, or the potential for injury due to encountering liquids or solids. The specific risks must be identified through a thorough risk assessment, again in compliance with the applicable local/national regulations.
Staff Qualifications
- Ensure that all personnel involved in the confined space work are adequately trained and qualified. Ideally the permit system should log details of competencies, and expiry dates for any certification.
- Verify that the workers understand the risks and the safety procedures required for confined space entry. Toolbox talks etc. can be used to reinforce the importance of safety precautions, but staff can also be required to sign into a permit to indicate their understanding of the task and their acceptance of the risks,
Atmosphere Testing
- Conduct pre-entry tests to check for the presence of hazardous gases or low oxygen levels.
- Continuously monitor the atmosphere during the work to detect any changes in air quality. Record the results in an accessible format so that any increasing trends can be identified.
Emergency Plans
- Develop and document an emergency rescue plan tailored to the specific confined space. This should be part of the risk assessment process and made easily accessible to all involved personnel.
- Ensure that rescue equipment is available and that the team is trained in its use.
Ventilation Requirements
- Identify and implement proper ventilation strategies to ensure safe air quality.
- If necessary, use mechanical ventilation to remove contaminants or to supply fresh air.
Access and Egress Points
- Clearly define the entry and exit points for the confined space.
- Ensure that these points remain unobstructed and that they are adequate for the size and number of personnel.
Communication Protocols
- Establish clear communication methods between workers inside the confined space and those outside.
- Equip workers with communication devices such as radios or signalling systems.
Isolation management
- Lockout and tagout any hazardous energy sources, pressurised vessels, valves etc. to prevent accidental activation.
- Isolate the confined space from other potential hazards, such as machinery, electrical systems, or hazardous materials.
Safety Equipment
- Ensure that appropriate personal protective equipment (PPE) is provided and used, including respirators, helmets, gloves, and protective clothing.
- Confirm the availability of emergency equipment like gas detectors, harnesses, and retrieval systems.
Work Duration and Monitoring:
- Specify the duration of the work and the time limits for workers inside the confined space.
- Continuously monitor the health and safety conditions of the workers, ensuring regular breaks and observation.
Supervision and Accountability:
- Assign a competent person to supervise the confined space work and to enforce compliance with the safety procedures.
- Maintain a log of all personnel entering and exiting the confined space, with clear records of times and conditions.
Implementing the Permit to Work System
