Confined Spaces

Policy

This policy outlines the Occupational Health and Safety (OHS) requirements for confined spaces.

Summary

• The Occupational Health and Safety (OHS) Act 2004 (Vic) and OHS Regulations 2017 (Vic) require the department to provide or maintain, systems of work that are, so far as is reasonably practicable, safe and without risk to health — including the management of confined spaces.
• No department employee is permitted to enter a confined space for example, storage tanks, silos, ducts, chimney, underground sewer, well, or any shaft or trench, at any time.
• The principal and/or their delegate must ensure that a qualified contractor is engaged for any works to be conducted in a confined space.
• The principal and/or their delegate, in consultation with the contractor, is to complete and sign a Confined Space Entry Permit prior to the commencement of any works in a confined space.
• Under the OHS Act 2004, employees while at work must take reasonable care for their own health and safety and the safety of others who may be affected by their actions or omissions.
• Central and regional offices provide a range of supports and services to assist principals and employees to be safe and well, including access to the OHS Advisory Service and local OHS regional officers who can provide free advice on managing risks related to confined spaces.
• The Confined Spaces Procedure (in the Procedure tab) must be followed, and sets out the practical step-by-step instructions for implementing this policy.
• This policy forms part of the department’s OHS Management System, refer to OHS Management System (OHSMS) Overview for further information.

Details

The principal and/or their delegate must ensure that:

• a suspected confined space is identified in consultation with the Victorian School Building Authority and the OHS Advisory Service
• an identified confined space is recorded in the ‘Hazard Type’ column on the OHS Risk Register (for example, list the hazard as a confined space)
• risk controls are identified and implemented to manage confined spaces using the hierarchy of controls and recorded on the OHS Risk Register
• a confined space is made secure to prevent unauthorised access and has signage at all entry points to the space
• all contractors engaged to undertake works in confined spaces are approved contractors as per the Contractor OHS Management Policy
• the approved contractor supplies a Safe Work Method Statement (SWMS) or equivalent
• in consultation with the approved contractor, a Confined Space Entry Permit is completed and signed prior to the commencement of any works in a confined space. This permit is only valid for twenty four hours
• a copy of the signed permit is retained
• if the scope of work changes, the confined space work is to cease immediately and a new Confined Space Entry Permit is to be re-issued
• all hazards, incidents and injuries are reported on eduSafe Plus (staff login required).

Definitions

Approved contractor
A contractor who has completed the appropriate training for confined spaces and hold current certification in:

• DEFWHS010 — identify confined space
• RIIWHS202D — enter and work in confined spaces
• PUASAR025A — undertake confined space rescue

An approved contractor must also hold current workers compensation and public liability insurance (the department’s stipulated minimum cover for public liability is $10 million).

Confined space
Defined as:

• having an enclosed or partially enclosed space with restricted entry and exit
• containing an oxygen concentration outside the safe oxygen range
• containing a concentration of airborne contaminants that may cause impairment, loss of consciousness or asphyxiation
• containing a concentration of flammable airborne contaminant that may cause injury from fire or explosion
• risk of engulfment in any stored substance (for example, grain, sand or saw dust) except liquids.

Examples of confined spaces include storage tanks, silos, ducts, chimneys, underground sewers, wells, or any shaft or trench.

Confined Space Entry Permit
A Confined Space Entry Permit is to be issued by the principal or their delegate. The permit provides details of a formal check to ensure all elements of a safe system of work are in place before persons are permitted to enter the confined space. A Confined Space Entry Permit is valid for a maximum of twenty four hours.

Hierarchy of controls
There are a number of ways that risks associated with hazards can be reduced however, the effectiveness of each method may vary. The prioritising of approaches in managing the risks associated with a hazard is called the hierarchy of controls and indicates the decreasing level of effectiveness of various approaches. The hierarchy of controls are:

• eliminating the hazard at the source
• substituting the hazard with something else that poses a lesser risk
• isolating the hazard with an engineering control
• implementing administrative controls and changing the way work is done
• providing Personal Protective Equipment (PPE).

Often a number of different approaches are used in conjunction with each other to provide a more effective risk treatment.

Related policies

• Contractor OHS Management
• OHS Management System (OHSMS) Overview

Relevant legislation

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)

Confined Spaces Procedure

The Confined Spaces Procedure must be followed and sets out the practical step-by-step instructions for implementing the Confined Spaces Policy.

It contains the following chapters:

1. Confined space identification
2. Confined space hazard identification
3. Implement controls
4. Record confined space risk controls
5. Additional controls
6. Confined space contractor responsibilities
7. Incident reporting
8. Legislation, codes of practice, standards and guidance

1 Confined space identification

The principal and/or their delegate is to ensure that a suspected confined space is identified within the workplace in consultation with the Victorian School Building Authority and the OHS Advisory Service — contact 1300 074 715 or email safety@education.vic.gov.au

2 Confined space hazard identification

The principal and/or their delegate, in consultation with Health and Safety Representatives (HSR) and employees must ensure that hazards with confined spaces are identified and recorded in the ‘Hazard Description’ column in the OHS Risk Register (for example, confined spaces).

Examples include:

• loss of consciousness, injury or death due to immediate effects of airborne contaminants
• fire or explosion from the ignition of flammable contaminants
• asphyxiation resulting from oxygen deficiency or from stored material, for example, grain
• restricted means of entry and exit, for example, a drain with only one entry/exit point
• contact with micro-organisms, such as viruses, bacteria or fungi potentially resulting in infectious disease, dermatitis or lung conditions
• noise generated in the confined space from the use of plant
• hazardous manual handling

3 Implement controls

Once the confined spaces have been identified, a control strategy to control the risk is to be developed and implemented. The principal and/or their delegate in consultation with the Health and Safety Representative (HSR) and employees must ensure that risk controls to manage working in a confined space are identified and implemented using the order of the hierarchy of controls.

Examples include:

1. Elimination — no persons are to enter a confined space, but instead, are to undertake work outside the space, e.g. use of a high-pressure hose through an access hatch to clean the inside of a tank, or use a remote camera to inspect the area.
2. Substitution — use of electrical equipment/plant instead of fuel to avoid the build-up of carbon monoxide fumes (where a flammable atmosphere has not been identified)
3. Engineering — install local extraction ventilation system.
4. Administration — develop and prominently display a signed Confined Space Entry Permit near the work area. Display signage at all entry points to the confined space.
5. Personal Protective Equipment (PPE) — use of eye protection or respiratory protective equipment e.g. self-contained breathing apparatus, when required.

4 Record confined space risk controls

The principal and/or their delegate in consultation with the HSR and employees must ensure that risk controls to manage working in a confined space are recorded on the OHS Risk Register.

5 Additional controls

5.1 Securing a confined space

The principal and/or their delegate must ensure that a confined space is secured by ensuring the space is locked, or by installing a Gas and Air Tight Inspection Cover (GATIC) to prevent access by unauthorised personnel.

5.2 Signage

The principal and/or their delegate must ensure that a confined space has signage at all entry points to the space. The signage must:

• state that area is a confined space
• state that a Confined Space Entry Permit is required for entry, and
• warn that personnel not listed on the permit are unauthorised to enter the confined space

6 Confined space contractor responsibilities

The principal and/or their delegate are to approve all contractors engaged to undertake works as per the Contractor OHS Management Policy and Procedure.

6.1 Contractor training requirements

The principal and/or their delegate are to engage a qualified contractor for works to be conducted in a confined space. All contractors must provide evidence of the following completed qualifications:

• DEFWHS010-Identify confined space
• RIIWHS202D-Enter and work in confined spaces
• PUASAR025A-Underatke confined space rescue

6.2 Contractor to supply Safe Work Method Statement or equivalent

The principal and/or their delegate is to ensure the contractor supplies a Safe Work Method Statement (SWMS) or equivalent, for any work to be conducted in a confined space, as mandated by the Department.

The principal and/or their delegate must review and sign the SWMS or equivalent, to verify it has been sighted and retain a copy. The SWMS or equivalent, at minimum, must include the following:

• safety observer and contact details
• continuous communication system
• warning notice / barricades
• emergency equipment and PPE (e.g. harness)
• emergency plan that can be initiated from outside the confined space (e.g. rescue procedures and first aid, in and outside the confined space)

6.3 Confined Space Entry Permit

The Principal and/or their delegate in consultation with the contractor are to complete and sign a Confined Space Entry Permitprior to the commencement of any works in a confined space.

Each Confined Space Entry Permit is valid for a maximum of twenty four hours and only the works and timeframe listed are covered by each permit. If the scope of work changes, the confined space work is to cease immediately and a new Confined Space Entry Permit is to be re-issued.

The principal and/or their delegate is to retain a copy of the completed Confined Space Entry Permit.

6.4 Conducting atmospheric testing and monitoring

A contractor is responsible for ensuring a safe atmosphere, so far as reasonably practicable during confined space work. A safe atmosphere in a confined space is one that:

• has a safe oxygen level (oxygen level is within a safe range 19.5% and 23.5%)
• is free of atmospheric contaminants or contaminants are below their exposure standard
• has any flammable gas or vapour in the atmosphere below 5% of its lower explosive limit

Where a flammable atmosphere may exist in a confined space all ignition sources in the vicinity must be eliminated (e.g. sparking, electrical tools, or open flames etc.)

The contractor is to record the results of the testing in the Confined Space Entry Permit.

6.5 Purging of a confined space

If the confined space atmosphere is unsafe, the contractor is to ensure that the confined space is cleared of all contaminants by purging. This is done by using an inert gas, such as nitrogen, to clear flammable gases or vapours before work in the confined space begins.

The contractor is to record the results of the purging in the Confined Space Entry Permit.

6.6 Ventilation of a confined space

After purging, the contractor is to ensure the confined space is adequately ventilated with sufficient fresh air, by natural (dilution) or mechanical means. The contractor is to consider where fresh air is drawn from and where the exhaust air is vented to, so that fresh air is not contaminated. Mechanical ventilation should be monitored by the contractor to ensure continuous operation while the confined space is occupied.

The contractor is to record the type of ventilation used in the Confined Space Entry Permit.

6.7 Communication and establishment of emergency procedures

The contractor is responsible for ensuring:

• communication systems are established to ensure continuous contact between contractors inside and outside the space
• the role of the Contractor Safety Observer is established to continuously monitor the contractors inside the space, as well as the atmospheric monitoring equipment, ventilation devices and initiate emergency procedures, when necessary
• rehearsing emergency procedures to demonstrate the specific rescue plan for the space is effective

7 Incident reporting

The principal and/or their delegate must ensure that all hazards, incidents and injuries are reported on eduSafe Plus (staff login required).

8 Legislation, codes of practice, standards and guidance

• Occupational Health and Safety Act 2004 (Vic)
• Occupational Health and Safety Regulations 2017 (Vic)
• WorkSafe Victoria Confined Space Compliance Code

Resources

Templates for confined spaces

• Confined Spaces Entry Permit Template — a confined space entry permit is to be issued by the principal or their delegate. The permit provides details of a formal check to ensure all elements of a safe system of work are in place before persons are permitted to enter the confined space.

Other health, safety and wellbeing resources relevant to this policy and procedure

• OHS Risk Register
• Safe Work Method Statement