PRM Training are occasionally approached to provide specialist advice on risk management with respect to a confined space. From our experience, there is still a lot of uncertainty in industry as to what actually constitutes a confined space, and what exactly are the legal requirements around working in that space.
Employers seem to be afraid of confined spaces, as there is this idea that if a work area is classified as a confined space, actually performing any work in that space will be ridiculously complicated and prohibitively expensive. Whilst there is a little truth in this opinion, it is mostly ill-informed.
In Australia, the Work Health and Safety Regulation 5 provides a concise definition of what constitutes a confined space:
Confined space means an enclosed or partially enclosed space that:
(a) is not designed or intended primarily to be occupied by a person; and (b) is, or is designed or intended to be, at normal atmospheric pressure while any person is in the space; and (c) is or is likely to be a risk to health and safety from:
(i) an atmosphere that does not have a safe oxygen level; or (ii) contaminants, including airborne gases, vapours and dusts, that may cause injury from fire or explosion; or (iii) harmful concentrations of any airborne contaminants; or (iv) engulfment, but does not include a mine shaft or the workings of a mine.
So for an area to be classified as a confined space, it must first be an area that persons are not “primarily” intended to be in. Entry to a space for maintenance, repairs or cleaning would not be deemed as normal occupancy.
Secondly, to meet the definition, the space must be at normal atmospheric pressure whilst a person is in the space. So a pressure vessel would not meet the definition of a confined space whilst it is pressurised, but once it is depressurised to allow access, it may then meet the definition.
Thirdly, the space must potentially pose a risk from just one of the following hazards:
An atmospheric oxygen concentration outside the safe range (19.5% to 23.5%), or
A flammable contaminant (whether airborne or otherwise) which may lead to fire or explosion, or
An airborne contaminant (gas, vapour or dust) which may harm one’s health, or
Engulfment – being rapidly covered by a liquid or free-flowing solid (such as cereal grain in a silo).
Safework Australia defines risk as “the possibility that harm (death, injury or illness) might occur when exposed to a hazard”. So it follows that if a hazard is present, there is some risk, regardless of how low or high that risk may be. Note that the confined space definition makes no mention of the ease or otherwise in accessing and egressing the space. So simply installing a nice big door or set of steps will do nothing to change a space’s classification. Part 4.3 of the Regulations lists the employer’s duties with regard to any confined space, including conducting risk assessments, permit requirements, signage, communication and safety monitoring, managing the risks posed to workers inside the space, emergency procedures, and training requirements for workers.
All of these requirements may seem onerous and costly to an employer, so there may be a temptation to deny a space is actually a confined space. But burying one’s head in the sand is not really a good course of action here, as firstly, the requirements of the WHS Act and Regulations are law, and non-compliance may attract some pretty significant penalties. Secondly, there is actually a very good reason (other than keeping the regulator off our back) to do the right thing. A lot of people die in confined spaces every year. And they really needn’t.
What is it about a confined space that is so deadly?
The US Occupational Safety and Health Authority reports that from 1992 – 2005 there were 431 confined space incidents with 530 fatalities in the US due to oxygen deficient and/or toxic atmospheres (http://www.confinedspacecontrolcovers.com/osha-statistics/).
The fact that on average there is more than one fatality per incident indicates how serious a confined space incident usually is. The US data also indicates that there are over 3 times as many fatalities as hospitalisations resulting from confined space incidents. This should be particularly concerning for us all – it is unlikely you will get a second chance in a confined space if you don’t get it right.
Whilst Australian data is somewhat scarce, a Western Australian study found that between 1982 and 2004 there were 15 fatalities in that state as a result of working in a confined space, with over a quarter of these due to a hazardous atmosphere. Alarmingly, 92% of these fatalities were attributed to inadequate training and/or supervision. (MacCarron, C. (2006). Confined space fatalities. Retrieved from http://ro.ecu.edu.au/theses/81)
So are we justified in our fear of confined spaces?
Being scared won’t save lives. Knowledge will. Understanding the potential hazards associated with a confined space, and the risk they pose, is the first step. Knowledge is the answer, and knowledge is gained by quality training and education.
Talk to PRM Training about the Confined Spaces training we can provide your team.
Ph: 1800 304 944