Just one year before the Confined Spaces Regulations 1997 and Approved Code of Practice (ACoP) came into force, the HSE prosecuted Tayside Fire Board for the death of a firefighter who was killed trying to rescue two men trapped inside a silo containing soda ash.
Since 1997, the relevance of these regulations across both the emergency response sector and for fire and rescue officers in particular has remained unchanged. However, a recent review of ACoP L101 ‘ safe work in confined spaces’ by the HSE revealed a need across all industries for further clarification of the risks and individual requirements when entering a confined space. Following consultation with fire service personnel and other workers heavily involved in confined space work, a revised ACoP was published at the end of last year. This firmly places a wide range of potential fire and rescue call-out scenarios at the centre of the Confined Spaces Regulations.
Identification is key
A ‘confined space’ is defined as a place that is substantially enclosed, although not always entirely and where there is risk of serious injury from hazardous substances or conditions within the space or nearby. This can include 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 risks are:
- Serious injury arising from a fire, explosion or excess of oxygen
- Loss of consciousness arising from an increase in body temperature
- Loss of consciousness or asphyxiation arising from gas, fume, vapour or the lack of oxygen
- Drowning arising from an increase in the level of liquid
- Asphyxiation arising from a free flowing solid or the inability to reach a respirable environment due to entrapment by a free flowing solid e.g. underground rescue
Under this definition, a confined space must be both substantially enclosed and also present a reasonably foreseeable risk of one or more of these specified risks. Although it may appear easy to identify simple confined space scenarios on this basis, such as entering sewers and closed tanks used to store chemicals, it is not always so simple. The traditional understanding of a ‘confined’ space is not necessarily accurate or all-encompassing in reference to the regulations. For example, confined spaces aren’t necessarily enclosed on all sides and do not have to be small, difficult to work in, or difficult to enter and exit. As a result not all enclosed environments are subject to the Confined Spaces Regulations.
An enclosed area without a specified risk is not classified as a confined space, even when there are other hazards present, such as restricted movement when working in lofts or cellars. In this case, fire and rescue officers must still consider how people will be safely evacuated if they suffer an injury. Any risk assessment should instead draw from the relevant regulations such as Electricity at Work Regulations 1989, for example.
Another misconception of confined spaces is that they are uncommon places of work that are entered on an intermittent basis. However everyday workplaces, including car repair centres where spray painting takes place and large warehouses where gas cylinders are stored, also constitute a confined space. Therefore it must be taken into account that an area that may appear to be free of contaminants, with a safe level of oxygen, can become a confined space if there is a change in conditions or in the degree of enclosure.
The most significant shift in emphasis as part of the HSE’s recently revised ACoP for confined spaces is the identification of a confined space as part of an increasingly task based definition. Rather than looking at a specific area as a confined space, fire and rescue officers are reminded that each task must be reviewed in relation to the Confined Spaces Regulations. This challenges a previously accepted view that environments with relevant control measures in place, such as officers wearing the correct protection equipment, could be de-classified as a confined space. The revised ACoP makes it clear that these environments must retain a confined space definition and be risk assessed accordingly.
Another recent clarification within the 2014 ACoP states that all storage locations are to be classified as a potential confined space. On a practical level, this encompasses a huge variety of potential call-out scenarios for fire and rescue officers in locations as varied as pubs, where gaseous pumps and barrels are stored, to recycling centres where storage piles often absorb excess oxygen and the metabolic breakdown of organic matter generates heat. As a result, many fire and rescue officers that had previously deemed their likelihood of attending a confined space incident to be rare now find themselves at the centre of numerous instances.
The first step in identifying the potential risk of entering a confined space is to conduct a risk assessment. This will ensure a safe system of work for all individuals by enabling the provision of suitable equipment and training for every individual. All fire and rescue officers, whether directly entering the space, providing support or preparing safe systems of work, should be experienced and competent both in confined space entry and the potential scenarios and hazards that they may be faced with. This could include firefighting in building or compartment fires, investigating smoke, odours or vapours in cellars and rescue from sewers, tanks, silos, wells or trenches. It is essential that all individuals undergo a thorough practical training programme to ensure that they are prepared to respond to these scenarios and are familiar with the expected safety standards and processes.
Confined space scenario training should cover the recognition and identification of possible hazards, evaluation and control procedures, and the setup, use, and restrictions of any equipment used in the confined space rescue process. Familiarisation of the use of emergency equipment, ventilation equipment, hazardous energy control, isolation and lockout equipment and air quality monitors such as oxygen or combustible meters is also key, in addition to practising the setup, use, and restrictions of all personal protective equipment (PPE) such as respirators and full body harnesses. Each element of training must be designed to ensure that work is undertaken in a manner that will not endanger fellow officers’ lives or those of the public.
Offering an alternative to off-site training centres, Arco has a fleet of state-of-the-art mobile confined space training units available to offer realistic and practical training for fire and rescue officers without the usual costs involved of having to loose fire cover at the station. These mobile units offer the added benefit of being able to reach brigades based in any location across the UK, providing a flexible training solution. Arco’s team of experts provides hands-on guidance and support, developing and delivering a bespoke training programme tailored to the specific requirements of each brigade. This allows individuals to learn in a way that suits them, exposing them to some of the potential hazards of working in confined spaces in a fully monitored and safe training environment.
Realistic simulation of confined space scenarios is created with the use of the mobile unit’s extensive tunnel configurations in addition to the ability to introduce lights, sounds, smoke and water. A camera system also allows the trainer to guide each individual and provide real-time feedback, as well as recording video footage for later review and assessment.
Recent changes to the Confined Spaces ACoP by the HSE is an effort to clarify confined space working requirements and to make individuals more aware of the risks involved, places officers at the centre of numerous confined space incidents that were previously believed to be declassified by control measures. This makes it more important than ever to ensure that each brigade is safeguarded against the potential hazards that they may face in the field by delivering practical training.
It is clear that a one-size-fits-all approach to training is impossible as every service is operating in a unique environment and each fire and rescue officer has a different way of learning. This makes Arco’s tailored mobile training offer ideal for providing quality, accredited and assured training delivered in a realistic and safe environment.
For further information, go to www.arco.co.uk/confinedspaces