This is the first of a series of short LinkedIn articles I will run identifying legislation that might have passed under the radar.
The Confined Space ACoP was amended in December last year and its impact on asbestos removal works is more than expected.
How has asbestos removal been impacted?
There are now two official triggers for categorising a work area as a confined space. The first is the obvious – is the area largely enclosed – is the access / egress restricted? These would be good examples:
- Trench >1m deep
- Basement boiler house
- Vertical ladder entrance
However the ACoP now specifically adds asbestos enclosures to this list. Any such area will require a specific escape / evacuation procedure and a means of communicating.
What makes one of these ‘largely enclosed’ work areas a Confined Space is the addition of the foreseeable risk of one or more of the following proscribed hazards:
- Serious injury from fire or explosion
- Loss of consciousness arising from increased body temperature (e.g. un-isolatable hot pipes or exposure to 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 free flowing solid
Confined spaces therefore represent varied and very hazardous working environments. However, for the asbestos project, it is no longer just stale or bad air within a subterranean duct that qualifies – the two others I wanted to highlight, increase the number of potential Confined Spaces dramatically:
- Chance of fire
- Loss of consciousness due to a rise in body temperature
Selecting grinders or burning pipes is, fumes aside, hot works and will therefore trigger the confined space regs because of fire. In addition that hospital boiler room where isolation is impossible will also qualify because of heat stress…
The following should be the approach taken in every case:
Is the area substantially enclosed (if it’s an asbestos enclosure – then yes).
What are the hazards? Are there any on the proscribed list? If so, does the job really need to be done? Can the hazard be removed (e.g. using recips, rather than grinders, isolating pipes etc…)
If the proscribed hazards are present and can’t be removed, then the Confined Space regs will apply.
If the enclosure does not involve one of the proscribed hazards, it is not a Confined Space, but it will still require a specific escape / evacuation procedure and a means of communicating.
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