In our travels in the waste management industry and in particular in our visits to landfills we have found that despite the fact that in the United Kingdom there are Health and Safety Regulations which require (under criminal law) that for all instances of confined space access the responsible persons shall have completed a risk assessment and shall only work to carefully judged and established safe working methods. All this will normally be done in accordance within the employer’s, or site operator’s own safety policy and standing method statements/ or procedures.
Nevertheless, safety in confined spaces can be easily be compromised by over familiarity with the site, and most commonly of all, personnel fail to define a confined space broadly enough.
A confined space is any space in which there is any restraint to access or egress, or any significant confinement at all. Therefore, a confined space could be quite a shallow tank, an small inspection chamber etc. A confined space could be a kiosk or even a shed, if circumstances introduced special risks into that area.
In Wikipedia a confined space is defined as follows:
“Confined space is a term from safety regulations that refers to an area whose enclosed conditions and limited access make it dangerous.”
So, the definition is extremely broad. Please Note – In each country readers must refer to their own local regulations.
In confined spaces, the correct approach to access and egress is crucial, but awareness of some of the basic apparatus involved is often lacking. It is clear from our experience that people are regularly going in and out of confined spaces without using the proper combination of equipment.
In recent times, workers have even been known to lower others into shafts using nothing more than a rope. But, more frequently, errors arise even when proper equipment is available.
Many confined spaces in the waste and landfill industry are accessed via a vertical shaft, perhaps the simplest example of which is a manhole. These can be especially dangerous at a landfill where landfill gas might be present – and if it may be then the ATEX and DSEA Regulations (DSEAR) apply in the UK and national equivalents to the DSEAR apply throughout Europe.
(In all the references which follow we refer to UK regulations. As previously stated – all readers prompted by this article are to refer to their own local regulations.)
Naturally, entry by a manhole like this means that the Work at Height Regulations 2005 would need to be considered.
A suitable approach would probably include a full-body harness, with front-and-rear D attachment points, a fall arrest block, and an anchorage point such as a tripod.
In order to fully comply with Regulation 5 of the Confined Spaces Regulations 1997, there must be “suitable and sufficient arrangements for the rescue of persons in the event of an emergency”. The fall-arrest block should incorporate a recovery mechanism, to enable an incapacitated person to be retrieved.
But this system needs a secondary backup to safeguard against a catastrophic failure of the primary system – that is, the winch.
Clearly in the first mode of entry – the steps or ladder provide the primary means of access, egress and escape in the event of an emergency.
In both modes of entry, a full body harness is essential equipment.
Full-body harnesses, used for fall arrest, must meet the EN 361 standard and, as a minimum, be fitted with a rear D attachment point.
A front D attachment point may also be used for fall-arrest purposes, if fitted. The attachment point can only be used for access/egress, rescue and retrieval purposes. Some higher-specification harnesses also include a waist belt.
Please do take heed of this reminder – your life or that of others may depend upon it.