Working in Confined Spaces

1.

Objective

Confined spaces at the University shall be eliminated where possible. Otherwise, the need for access into the confined space shall be limited. Where access into the confined space is necessary, appropriate controls shall be in place such that the risk associated with entry into and performance of work within the confined space is minimised as far as is reasonably practicable.

2.

Policy

Flinders University is committed to preventing injuries to staff, students and visitors whilst on its premises and to minimising property damage due to incidents in the workplace.

Confined spaces can be hazardous and have been the cause of many injuries and deaths in the workplaces of Australia. All reasonable efforts shall be made to eliminate any unnecessary confined spaces in the University.

The University will ensure that all persons carrying out work involving confined spaces are trained and work in such a manner so as to maintain a safe working environment.

To this end the University has established procedures which are designed to assist the University in providing a safe working environment for University employees, contractors, sub-contractors and their employees.

3.

Scope

This policy covers University staff and contractors who carry out work in confined spaces or provide support outside the confined space. A confined space is an area that is identified in the Flinders University register of confined spaces.

4.

4. Definitions

Confined space

An enclosed or partially enclosed space which:
is at atmospheric pressure during occupancy; and
is not intended or designed primarily as a place of work; and
may have restricted means for entry and exit; and
may have atmospheric contaminants or an unsafe oxygen level; or
may cause engulfment.

Examples being (but not restricted to):
A storage tank, process vessel, boiler, pressure vessel, or other tank-like compartment; an open-topped space (such as a degreaser or pit); a pipe, sewer, shaft, duct or similar structure; a shipboard space entered through a small hatchway or access point, ballast or oil tank or other void space, other than a dry cargo hold.

Workplace

Any work area within or external to the University which is under the control of the University.

Trained persons

Staff members and others who have undergone a training program provided by a registered training provider and can provide documentary evidence of having undertaken a program.

Hazard management

The processes of hazard identification, risk assessment and risk control. Refer to the University Hazard Management booklet for further detail.

Stand-by person

A competent person assigned to remain on the outside of, and in close proximity to, the confined space and capable of being in continuous communication with and to observe those inside, if practicable. In addition, where necessary, initiate rescue procedures and operate and monitor equipment used to ensure safety during entry and work in the confined space.

5.

Responsibilities

5.1 Vice Chancellor

The Vice Chancellor as "Responsible Officer" under the Occupational Health Safety and Welfare Act 1986 (OHSWA), is ultimately responsible for ensuring the University meets its obligations in the area of Confined Spaces.

In accordance with the University Occupational Health Safety and Welfare Policy, the Vice Chancellor must ensure that the University has in place a policy and procedures to provide, so far as is reasonably practicable, a safe working environment for all staff members and contractors and ensure the safe implementation of projects undertaken within the University by such, and that appropriate resources, both human and financial, are made available to meet legislative requirements and policy objectives.

5.2 Executive Deans/Academic Organisational Unit Heads

The Executive Deans/Major Organisational Unit management have overall responsibility for the health, safety and welfare of staff, students and visitors (including contractors) in their Faculty/Area. They will manage the implementation of the University's OHSW policies and programs and allocate resources to ensure the University standards are achieved. They will assist Project Managers in identifying hazard situations, which may pose risks to persons entering and/or working within the areas under their control.

5.3 Supervisors

Supervisors are responsible for the management of confined spaces and entry to such within their control, responsibilities include:

• Approving entry, via a work permit system, to a confined space;
• Implementing of this procedure in their area of responsibility and accountability;
• Identifying of all confined spaces within the workplace;
• Planning work involving entry into a confined space;
• Ensuring a risk assessment has been completed with the staff members and/or their representatives and/or the Occupational Health and Safety Unit prior to the commencement of any work in a confined space;
• Keeping and maintaining confined space entry records;
• Providing training for all employees who carry out confined space work;
• Ensuring that all contractors who are engaged to carry out confined space work are competent, have developed procedures;
• Liaising with Occupational Health and Safety Unit for advice and compliance with this Policy document;
• Ensuring that the Confined Space Register is completed;
• Ensuring that all staff and contractors who have been trained in confined space work within their area are aware of their responsibilities to work and act safely in accordance with this document;
• Arranging for all individuals who are required to enter confined spaces to attend a training program arranged through the Buildings and Property Division prior to entry of confined spaces;
• Ensuring that individuals under their control are not exposed to any potential hazardous situations from working in confined spaces;
• Ensuring that all individuals always follow the example of the Standard Operating Procedure applicable to the confined space entry permit;
• Ensuring all appropriate equipment is provided and maintained within safety requirements;
• Supervising or arranging for supervision of the confined space, including providing a stand-by person.

5.4 Staff members
Staff members entering confined spaces or on stand-by duties are responsible for:

• Undertaking required training;
• Not placing themselves or others at risk of injury;
• Conforming to the requirements of this document;
• Consulting with supervisors and other staff members in relation to a hazard analysis associated with confined space entry requirements;
• Entering confined spaces only after authorisation, knowledge and approval by a manager or supervisor;
• Complying with the requirements and procedures of Australian Standard 2865: Safe Working in a Confined Space. The Occupational Health and Safety Unit can also be contacted for advice and interpretation.

5.5 Contractors
Contractors and subcontractors are responsible for:

• Complying at all times with the University Confined Space Policy and Procedure;
• Attending the University OHS Induction for Contractors;
• Showing evidence of their current confined spaces training;
• Obtaining a Confined Space Entry Permit from the Buildings and Property Division or work supervisor prior to commencing work in a confined space;
• Preparing of safe work procedures for confined space work;
• Ensuring that any entry to a confined space is carried out in accordance with AS 2865 Safe Working in a Confined Space;
• Notifying the immediate supervisor / competent person of any situation they believe poses a threat to the health and safety of persons involved in confined spaces work.

5.6 Students and Visitors

Students and visitors are required to comply with this Policy document and not to enter any confined space without written authority from the area supervisor.

6.

Procedures

To manage the risk involved in working in confined spaces, the University is committed to a hazard management approach.

The risk will be managed by:

• Identifying confined spaces and listing them on a Confined Spaces Register. This register will include identification number, location, description, plan and potential hazards;
• Maintaining and updating the Register on a two yearly basis, if required;
• All confined spaces will have signage identifying the area: included in this signage will be instructions regarding the procedures for obtaining Confined Space Entry Permit, and requirement for safe work method statements;
• Buildings and Property Division will administer a Confined Space Entry Permit. These permits will be issued by a responsible person who has specific confined spaces training;
• Safe work method statements will be developed prior to any work being undertaken in the confined space. This will take the form of the University Safe Work Method Statement or the Contractor’s equivalent documentation. This safe work method statement/documentation will identify the task to be completed, the steps involved, and the potential hazards and risk control measures to be put in place;
• Structured training will be provided to ensure employees and contractors are able to work safely in confined space conditions. Training for University personnel will be in accordance with the Confined Spaces Regulations. Training will be conducted on a regular basis.

6.1 Personnel Selection and Training

No person will be required to undertake work in a confined space unless they are willing and medically fit.

Only persons with appropriate training and competence, as per AS 2865: Safe Working in a Confined Space, shall be assigned confined space work.
Training of selected staff to carry out confined space work shall include:

• The provisions of the relevant legislation;
• The provisions of AS 2865 which are directly relevant to their work;
• Information about the physical, chemical and biological hazards relating to work in or near confined spaces in general and the particular confined spaces;
• Hazard identification and assessment (general principles);
• Establishing healthy and safe work practices in the workplace, including isolation lockout and isolation procedures;
• Emergency response procedures in the workplace in general and in relation to the confined space, including emergency response drills and the use of safety equipment including personal protective equipment;
• Selection, use, fitting and maintenance of personal protective equipment;
• Emergency entry and exit procedures;
• Communications;
• Recognition of any hazards specific to the activity;
• First aid and cardio-pulmonary resuscitation;
• Fire protection and suppression.

Training shall be given to staff who:

• Perform work in or on confined spaces;
• Perform confined space assessment;
• Issue entry permits;
• Manage and/or supervise persons working in or on confined spaces including any contractors;
• Maintain equipment used for and during confined space entries;
• Are on stand-by for confined space work;

6.2 Planning Work

Work involving entry into a confined space must be planned. An assessment of likely hazards shall be made prior to commencing the work. Precautions must be taken to avoid exposure to harmful substances or oxygen deficient atmospheres by testing, and by using appropriate equipment. Precautions must also be taken to counter the effects of noise that may be encountered or produced by use of equipment in the areas. Planning should also include procedures for handling possible emergencies.

All confined spaces shall be clearly identified by appropriate signage and appropriate Safe Operating Procedures shall be developed and included in the confined space register.

6.3 Permit To Enter

Permission to enter a confined space shall be obtained from the Buildings and Property Division Manager, or nominee, before work is commenced. A confined space entry permit is to be completed for all works in a confined space. The entry permit should state the period of validity and should be re-validated whenever it becomes evident that the duration of work will involve one of the following:

• A change in the person responsible for the direct control of the work in a confined space;
• A significant break in work continuity;
• A significant change in atmosphere or work to be performed.

6.4 Record Keeping

• Entry permits for twelve months;
• Current recorded risk assessment reports for work in a confined space for five years from the time of their validity;
• Training records for the term of the person’s employment – unless longer periods are necessary, as in the case of health surveillance being required;
• All records shall be made available to the person or regulatory authority inspectors on request.

6.5 Review of Procedures
The Buildings and Property Division will review these procedures every two years with assistance from the Occupational Health and Safety Unit and in consultation with the University Occupational Health and Safety Committee and will revise procedures as necessary.

PRE-ENTRY
The pre-entry considerations should be at least as follows:

As per 6.1 of the policy, the staff member is trained in:

• Emergency entry and exit procedures
• Use of applicable respiratory protective devices
• First aid including cardio-pulmonary resuscitation (CPR)
• Lockout procedures
• Safety equipment use
• Rescue drills
• Fire protection
• Communications

Actions required are as follows:

• Coordinate planning of work
• Coordinate supervising of work
• Develop emergency rescue plan
• Initiate safe work practices
• Signpost work area
• Isolate confined space where practical
• Evaluate confined space environment
• Comparison of initial test results with existing standards to determine ventilation and/or personal protection requirements
• Ventilate and/or provide personal protection
• Provide for monitoring of confined space during work
• Ensure that stand-by staff are available for rescue and operation of essential equipment
• Ensure rescue equipment is readily available and in good working order
• Authorise entry by permit
• Suspend work/evacuate space if conditions change to present real/potential danger

Physical Agents:

• Thermal extremes
• Radiation
• Noise
• Flooding

Chemical agents:

• Combustible gases or vapours
• Toxic gases or vapours
• Combustible or toxic liquids or solids
• Potentially explosive dusts

The considerations during entry and re-entry should be at least the following:

• A comparison of initial test results with an existing standard to determine whether ventilation or personal protective equipment will be used
• Continuous monitoring of confined space atmosphere
• Ensure safe work practices are followed
• Re-issue permit after absence from area or if conditions change

The consideration after exit should include at least the following:

• Confirmation that all persons and equipment are accounted for
• Ensure safe work practices are followed
• Review of operation – comment on any unsatisfactory aspects
• Acceptance of completed job
• Secure the entry point to the confined space
• Clean equipment and store away as appropriate.

APPENDIX 2 - RELATED DOCUMENTATION

Occupational Health Safety and Welfare Act 1986
Occupational Health Safety and Welfare Regulations 1995
AS 2865: Safe working in a confined space
Flinders University Occupational Health Safety and Welfare Policy
Flinders University Confined Spaces Register
Flinders University Emergency Control Procedures
Flinders University Contractor Safety Policy and Procedures
Contractor OHS Induction Booklet