A confined space is not defined by its size. The Confined Spaces Regulations 1997 define it as a place that is substantially enclosed and in which there is a reasonably foreseeable specified risk: loss of consciousness from gas, fume, vapour or lack of oxygen, drowning, asphyxiation from a free-flowing solid, or serious injury from fire or heat. A manhole is a confined space. So is a plant room with a gas leak, a tank, a deep excavation with a drain running into it, and a ceiling void where a solvent is being used.
People die in confined spaces in twos and threes, because the second and third person went in to get the first.
The order the regulations set
Regulation 4 is blunt. Nobody enters a confined space to carry out work where it is reasonably practicable to do the work another way. Only where entry cannot be avoided does the rest apply: a safe system of work under regulation 4(2), and, under regulation 5, arrangements for the rescue of anyone in the space that are in place before anyone enters. The Approved Code of Practice, L101, explains what a safe system of work looks like in practice.
The test a main contractor applies is the first one. If the drawings can be checked from outside, the valve operated remotely, the camera sent in instead of the person, that is the method.
What the permit does
Where entry is unavoidable, the permit is the safe system of work written down and signed. It is issued for one entry and it records:
- The space and the work — what it is, what is going in, why it cannot be done from outside
- The hazards found — the specified risks that apply, from the assessment
- Isolation — what has been isolated, locked off and proved, so nothing can flow into the space
- The atmosphere — tested before entry and monitored during it
- Ventilation, lighting, access and communication
- The people — the entrants, the top man who stays outside and never enters, the supervisor
- The rescue plan — how someone will be got out without a second person entering, the equipment on hand, who has been trained on it
- Issue, acceptance, time limit and hand-back
What the gas test does
The atmosphere is tested before entry with a calibrated meter, for oxygen, flammable gas and the toxic gases the space could hold, and the readings are recorded with the time and the instrument. Then it is monitored while people are inside, because an atmosphere that was safe at eight can change by nine when a pump starts or a sludge is disturbed. The record is the evidence, entry by entry, that the test happened and what it read.
What a template does not do
The permit and the record give the sequence, the questions and the signature chain. They do not judge whether entry is necessary or whether your rescue plan would work. Those are a competent person's decisions, and no document makes anyone compliant. Why we will never call a document "compliant".
Documents for this work
- Confined Space Entry Permit — the safe system of work, one entry per permit
- Gas Test and Atmospheric Monitoring Record — the readings, before and during
- Permit to Enter — for controlled areas that are not confined spaces
- The Permit to Work Suite — every permit and the system around them