B ULK D ISTRIBUTOR
Safety
May/June 2019
Confi ned spaces
can be killers
Mike Yarwood from international freight transport insurer, TT
Club looks at the very real dangers of working in the confi ned
spaces inherent in cargo transport
C
onfi ned spaces present risks throughout the global supply
chain, ranging from ship holds and passageways through
to silos and all types of enclosed cargo transport units (CTU’s).
There are estimated to be around 15 confi ned space fatalities each
year in the UK alone, with 60 percent of confi ned space related
deaths involving people attempting to rescue colleagues who are
already trapped or injured. Confi ned spaces present real risks in our
industry and should demand your attention when managing risk.
Awareness training and robust procedures in this context will prevent
serious injuries and save lives.
A confi ned space is a place which has limited openings for entry
and egress, inadequate ventilation and is not designed for continuous
worker occupation, and where serious injury may occur from
hazardous substances or conditions (generally resulting from
asphyxia). Tank CTU’s used to transport bulk cargoes globally,
including road tank trailers, tank railcars and ISO tank containers
present prime examples of a confi ned space risk in the supply chain.
The air we usually breathe contains 79 percent nitrogen and 21
percent oxygen. Once the oxygen content of the air decreases or
increases the associated risks change. Oxygen enriched atmospheres
give rise to an increased risk of fi re and explosion. Where reduced
oxygen content is concerned, judgement becomes impaired and
ultimately life can no longer be supported, even if the remaining
content of the atmosphere is harmless. Clearly, there is also risk that
the atmosphere contains toxic or fl ammable gas concentrations.
Lack of oxygen is a silent killer; there are no obvious warning signs
such as coughing or feeling breathless. Where the oxygen levels are
suffi ciently depleted the fi rst sign is often that the individual becomes
unconscious. This can happen so quickly that there may be no
opportunity to raise an alert. Where there are pockets of atmosphere
lacking suffi cient oxygen breathed, an individual will start to feel very
weak and confused; unable to undertake the simplest of tasks such
as reaching the exit of the confi ned space. If not rescued quickly they
will likely fall into unconsciousness. Rescue operations are therefore
time critical.
Where it is essential that a worker enters a tank CTU, atmosphere
testing in advance is necessary, but critically oxygen levels should be
adequately monitored throughout the required activity. Even where
the tank is certifi ed to be clean and the atmosphere adequate to
support life, undertaking any work within the tank, whether it be
cleaning, polishing or grinding, gives rise to the possibility of changes
to the atmospheric content of the confi ned space.
The key issue is whether the atmosphere is suitable to sustain life.
Initial and monitoring testing of the atmosphere inside the tank
should be undertaken by a competent person using appropriate
calibrated instruments to ascertain acceptable levels of oxygen and
acceptable levels of toxic and fl ammable vapours.
A competent ‘watcher’ should be physically present throughout the
work, providing an immediate response in case of emergency. The
‘watcher’ should monitor each stage of the work undertaken to
ensure compliance with the defi ned safe system of work.
Annex 8 of the ILO, IMO and UNECE Code of Practice for Packing of
Cargo Transport Units (CTU Code) focuses on the risk assessment
process covering items such as competence, working at height and
emergency preparedness.
A risk assessment should consider as a minimum the following
elements:
• The task
• The working environment
• Working materials and tools
• The competence of those undertaking the work
• Arrangements for emergency response/rescue
Access should only be allowed under a safe system (permit) of work
and the supervision of a responsible person.
A permit to work assists in ensuring that a formal check is
undertaken, confi rming that all elements of the safe system of work
are in place ahead of a worker being allowed to enter the confi ned
space. Such a system should provide clear identifi cation of the
person(s) who may authorise entry into the confi ned space and those
who hold responsibility for specifying the necessary precautions. It
should also include training and instruction in the issue of permits,
training and instruction for confi ned space working and monitoring
and auditing to make sure that the system works as intended.
Additional training, instruction and signage should be considered.
Are the workers aware of what is considered to be a confi ned space
and are they suffi ciently trained to recognise such spaces? Do they
have experience of undertaking this type of work? Are the workers
physically capable of entering into and egressing from the tank
container? Consideration may also need to be given where the
person may suffer from claustrophobia or their fi tness to wear and
operate breathing gear.
It is vital to develop an established method of communication
between those workers inside the confi ned space and those outside
The key issue is whether the atmosphere is suitable to sustain life
it. This serves as the fi rst step in emergency response.
Develop and communicate an emergency rescue plan. Regular drills
should be undertaken to ensure effectiveness of the plan and
familiarity of the workforce with procedures. The arrangements of the
emergency rescue plan should be suffi ciently communicated to the
entire workforce who may ultimately need to rely on it.
Where things go wrong, the worker in the confi ned space is likely to
be exposed to serious and immediate danger. It is essential to have
effective and quick arrangements to raise the alarm and trigger rescue
procedures. The watcher should never enter the confi ned space
before securing assistance and taking additional precautions.
Consideration in this regard should be given to the equipment
available and the capabilities of the nominated rescuers.
www.ttclub.com
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