It is – or it should be – easy to identify when you’re working at height, but when does a work area constitute a confined space? You might think it’s equally obvious, but the seemingly subtle change in the regulations that occurred in 2014 has made some dramatic changes in what is and what isn’t a Confined Space.
For a workspace to be considered confined, there must be restricted access AND risk of one of five proscribed hazards:
- Serious injury from fire or explosion
- Loss of consciousness arising from increased body temperature (e.g. due to hot pipes or strong sunlight)
- Loss of consciousness or asphyxiation arising from gas, fume, vapour or lack of oxygen (e.g. stale air within subterranean ducts)
- Drowning from an increase in the level of liquid
- Asphyxiation from a free-flowing solid
A basement boiler house, for example, is largely enclosed and might have restricted access, but if the heat is turned off, it’s unlikely to be a confined space for the purposes of the Health and Safety Executive (HSE) guidance.
When the HSE updated its confined spaces ACoP (approved code of practice) in 2014, it specifically added asbestos-removal enclosures to the list of ‘largely enclosed’ areas which could be considered Confined under the guidance. Since then, all enclosures should have communication and escape procedures specific to that situation. Standard enclosures can be covered by standard procedures, but as soon as you add in a loft ladder it needs to be bespoke.
Because the first (enclosed) trigger is automatic for all enclosures, the risk of stale air, hot conditions, or fire will qualify many more asbestos projects. If the hazards can’t be avoided – for example by isolating heat sources or using different equipment – the confined space code of practice needs to be followed. That does not mean escape kits and tripods on all sites – but it does mean you need to specifically address the identified hazard, eliminate or mitigate it and factor it into your emergency procedures.
Some unusual work areas will now count as Confined, whereas others that were considered to qualify do not. An open air enclosure, in the height of summer – will be Confined because of the risk of heat exhaustion. A subterranean duct might not be!
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