Confined spaces and asbestos removal often go hand in hand, yet the lack of understanding about risks and controls could be putting people in danger.
As I discussed in an article last year, the Health and Safety Executive (HSE)’s confined space rules changed back in 2014. The changes were subtle, though. The minimal fanfare around them has meant that – even six years on – those that commission projects and their appointed consultants still miss much of the point. But the fact that licensed asbestos-removal contactors (LARCs) are unwilling or unable to correct the misguided instructions they’re getting has the potential to make dangerous situations worse.
To recap briefly, there are two triggers that together will make a work area a ‘confined space’. The first is whether access to the area is substantially confined, with ladders, ducts, and ‘enclosures for the purpose of asbestos removal’ specifically listed. The second is whether one or more of five proscribed hazards – fire, heat, gas, or free-flowing solids or liquids – are present. In essence, if the access arrangements restrict people’s ability to get in or out of the workspace, and there is a risk of sudden death, then the confined space regulations apply.
What’s The Hazard?
It seems simple, but the nature of the hazard is absolutely critical to determining what the correct controls should be. The proscribed hazards are for the most part quite different in the risks they pose:
- Serious injury from fire or explosion
- Loss of consciousness arising from increased body temperature
- Loss of consciousness or asphyxiation arising from gas, fume, vapour or lack of oxygen
- Drowning from an increase in the level of liquid
- Asphyxiation from free-flowing solid
It only takes a moment’s thought to realise that the controls to mitigate risk from explosion, say, are entirely different to those required for drowning, poisonous gas or elevated temperatures. In fact, the controls required for any single hazard could actually make other risks more serious. Despite this, what LARCs often see is an insistence from their clients on implementing the stock controls for poisonous gasses – regardless of the situation.
This problem is particularly serious if we consider ‘increased body temperature’. Elevated body temperature can cause loss of coordination and serious health risks, and untreated can quickly become a major risk to life.
In warm weather, many typical asbestos enclosures – in roofs, for example – are going to become confined spaces by risk of heat. But when contractors realise that an area is a confined space, the common response is to require equipment such as an escape kit. Not only will an escape kit do nothing to help, but the extra bulk might make matters worse. And the outcome could be catastrophic.
Read more on safe working at high temperatures.
So how do you avoid catastrophe? Firstly, whether you’re the client, principal designer, principal contractor or a subcontractor, you must be aware that all asbestos enclosures satisfy the first trigger for the confined spaces regulations.
Secondly, and most important, as soon as you confirm that a second trigger is present, you must understand in detail what the hazard is. If you can’t eliminate it, you need to implement controls specifically to deal with that hazard.
The threats that trigger a confined space are different in their nature, and there is no one-enclosure-fits-all approach to properly managing them. The consequences of applying inappropriate controls could be as bad as – or worse than – not managing the risk at all. And if you’re imposing the wrong controls on a subcontractor out of ignorance you could be liable for the consequences.
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