Gary Watts highlights the dangers of confined space complacency.
At the time of writing, the United Kingdom’s Health & Safety Executive (HSE) had released statistics for workplace accidents, including fatalities, for the period of April to December, 2012. Alarmingly, 192 workplace fatalities are listed for this period. With the last quarter’s statistics still to be submitted, there is already an increase on the previous year’s fatalities of more than ten percent. Within these figures, confined space related deaths make up approximately one quarter of the total fatalities. The causes of these deaths will undoubtedly be far and wide, but one thing links them all: they could have, and should have, been avoided.
While some working requirements come with an inherent elevated risk attached, no sane person goes to work content in the knowledge that they could be harmed or even killed as a result of the work they will be undertaking that day. The figures, however, speak for themselves - confined space accidents still happen.
The HSE regulations define confined space works as “Any place in which, by virtue of its enclosed nature, there arises a specified risk of harm from fire or explosion; loss of consciousness from increase in body temperature; loss of consciousness or asphyxiation from gas, vapour or lack of oxygen; drowning or asphyxiation from free flowing solids.”
Additionally, the regulation also surmises that “Confined space entry should be avoided if an alternative means of achieving work can be completed. If entry is unavoidable, however, then a safe system of work should be followed. No person shall enter or carry out work in a confined space without sufficient arrangements for the rescue of persons in the event of an emergency. Also, where there is a likely consequence of a relevant risk, the provision of resuscitation equipment must be provided.”
Case studies on confined space incidents include a junior officer on a cargo ship who entered a cargo hold via a ladder. Overcome by gases, he fell unconscious, falling as he lost his grip on the ladder. Despite retrieval by shipmates after the alarm was raised, the officer later died in hospital.
Another report highlights a UK based business which had been reported by the HSE for failing to provide staff with adequate confined space training and appropriate equipment. Despite being served with an improvement notice in 2008, on two further site visits conducted by the HSE in 2011 it was identified that the company had not adhered to the improvement notice. Along with insufficient safe systems of work, uncalibrated and unsafe equipment was still being used, putting workers’ lives at risk.
A particularly worrying case study in a US based business involved a single operative who entered a confined space vessel without any breathing apparatus, was overcome by harmful gases and was rendered unconscious. During a lengthy attempt to retrieve the casualty, rescue personnel cut away at the vessel to create a viable access point for casualty retrieval. The resulting sparks combined with gases within the vessel causing an explosion, which ultimately caused two fatalities and injured 15 others.
Contrary to this apparent lack of knowledge, confined space work is not a new concept. With health and safety legislation guiding employers on safe systems of work, these environments should be safer places. Manufacturers are constantly developing safety and rescue based equipment and the marketplace as it stands is saturated with products that assist with safe entry and egress from confined space works.
On the whole, gas detection equipment and self-rescue breathing apparatus are utilised by operatives during confined space entry, along with some form of fall arrest system for safer entry and egress. Training on safe working procedures within these environments is also readily available to all levels of abilities, so why are people still being harmed - or worse yet killed - when working in confined spaces?
The guidance on defining what is or is not a confined space is in itself open to individual interpretation. In recent years, I have witnessed contractors attempting to declassify what was clearly an enclosed works location in an effort to bypass the costs associated with confined space work.
I have also seen method statements for confined space work created by someone office based who hadn’t even seen the location first hand, and therefore perhaps lacking a working understanding of the associated hazards. I have conducted site visits where, upon questioning a ‘what if’ scenario at a grain processing plant, I was told that to clear a blockage in the overhead ducting a lone engineer would enter via a ladder - with no more than a shovel as PPE.
I have no doubt that ten people could all review the same enclosed or confined space environment and create ten different risk assessments, method statements and emergency action plans to accommodate the same works. These safe systems of work would also vary depending on the individuals’ attitudes to risk - so who’s right and who’s wrong?
General attitudes towards working in confined spaces have improved dramatically since the enforcement of legislation, with conscientious employers addressing all related issues with the deserved respect. Some businesses, however, view these operational duties thinking only of the job in hand, perceiving that the entrant needs only to enter, achieve the task required, then exit. In other cases, insufficient understanding of the hazards and misplaced concerns regarding finances and potential expenses associated with achieving the task can have an impact on the safe works process. Ultimately, it’s the appropriate consideration given to the ‘what if’ scenario that will ensure a safe system of work in any given workplace.
With confined space works covering a wide range of industries and operational requirements, there are various working scenarios to contend with and one plan cannot fit all eventualities. Confined spaces are not just ‘holes in the ground’, and as industry and commerce evolve so do the associated workplace locations and hazards. Appropriate consideration must be given to safe systems of work at each workplace environment based on its own merits.
If you aim to ensure that the operational requirements of working in a confined space are fulfilled by planning for worst case scenarios that include all associated hazards - both present and introduced by the works party - then you should also factor in the manpower and equipment needed to ensure an expedient extrication of a casualty if required in an emergency.
It’s this element that in my experience is overlooked the most. Planning for an emergency is often perceived as an expensive and potentially unnecessary objective, or perhaps it’s not planned to an accurate level relative to the hazards to which the workforce could be exposed. Either way, not enough emphasis is placed on the safe system of casualty extrication during an emergency situation.
In addition to the statistics initially listed, there is one more to be aware of. Around 60 percent of all confined space related fatalities in the UK are not attributed to the individual who became impaired in the first place, but rather to the would be rescuer who went in to assist. This figure confirms, to some extent at least, that considerations of emergency planning are not always what they should be. Whether it’s down to a lack of understanding and training, or inadequate or nonexistent safety and rescue equipment, somebody somewhere in the loop didn’t pay due diligence to the severity of workplace hazards.
Risks associated with workplace hazards can be reduced with appropriate management and enforcement of additional safety measures. What cannot be reduced, however, is the severity of those hazards if they are realised. It is perhaps this element of planning the safe working system that is overlooked most frequently. A general misconception is that by addressing the risk, the severity associated with that risk is also somehow reduced.
If something can go wrong in the workplace, appropriate measures should be planned and implemented. Just as you would expect to find a first aid kit located within every office environment, on that basis so too should confined space works include rescue and recovery equipment, along with appropriate first aid supplies. This should also include resuscitation equipment where the potential for respiratory based injuries are identified.
Onsite emergency response teams should approach every hazardous workplace project encountered prepared first and foremost for the worst case scenario. From that point on they can work backwards towards the actual task being undertaken by the contractor. In doing so, responders can work towards reducing the exposure of risk, but more importantly they will be physically prepared and equipped to deal with the severity of those risks in the event of an emergency.
This attitude to workplace risks can be and indeed has been perceived as excessive on occasion. When attending an industrial based site in an emergency response capacity, contractors witness - with eyebrows raised - rope rescue and fall arrest systems being erected along with the placement of stretchers and emergency response grab bags.
This ‘safety to excess’ also attracts debate, including validity of purpose among operatives towards the team itself; however, if this preparedness means that works are conducted without incident, and that any incidents responded to can be dealt with promptly and professionally with appropriate intervention applied, then I say let them raise their eyebrows. By expecting the worst in any given situation, you’re better prepared to meet and manage the challenge of an emergency should it arise.
Some incidents are more likely to attract a potentially fatal outcome. A serious fall from height, either in or out of a confined space environment, without any form of fall restraint or arrest in place could lead to a casualty suffering from skeletal damage with possible internal injuries; however, through correctly identifying the workplace hazards prior to commencement of works, selecting the appropriate risk controls and planning for the severity of actual harm, workplace incidents could be significantly reduced and should no longer include the potential of a fatal outcome.
In this current global economic climate, we acknowledge that now more than ever workplace costs are being scrutinised and assessed. As such, some areas of business operations may be deemed unnecessary or lack the deserved priority. When lives are at stake, however, it is worth asking ourselves ‘What are the personal and business costs associated with workplace injuries and fatalities?’
Working processes in any given worldwide industry should not come with the potential price tag of loss of human life. Morally, ethically and financially, this is far too high a price to pay for what boils down to the underestimation of a hazardous working environment.
Other than working at height, no other type of work generates the same number of incidents or fatalities as working within confined space. If for only that reason, ensure that when you plan for your next job where these related hazards are present, you can honestly say that you have planned for a worst case scenario where the potential for an emergency response is accommodated.
Published: 02nd May 2013 in Health and Safety Middle East