Applying Relevant Standards

Let us move on to the approved Code of Practice. Just as a reminder, it has special legal status, so we need to be following it because that is the recommendation by the Health and Safety Executive. But there are various other codes of practices and industry standards we also need to take into consideration. One is known as the National Occupational Standards for Working in Confined Spaces: Water.

Produced back in 2009, the water industries came up with a documentation that describes the different types of confined space entries. They break it down to the following codes: NC1, NC2, NC3, NC4. Let us go through each one. What is an NC1 entry? Well, it is viewed as a low-risk shallow entry with adequate natural or mechanical ventilation, where access is simple, unobstructed, and there is no likely risk of flooding. So it could be, for example, a meter pit which has a valve in it that somebody is turning on and turning off.

NC2. This is vertical, direct, unobstructed access with continuous attachment to a man-riding winch or hoist or similar mechanical rescue device. So this is what we would normally associate with many confined space entries. The tripod and winch is set up and connected, I have done my gas monitoring, and I am climbing down a ladder. So an NC2 is attached.

NC3. This is when it is not possible to be permanently attached to a safety line; I am working away from my point of entry. So that is known as the NC3. NC4 is a non-standard entry, involving complex operations, which introduce additional risk and require specific controls and rescue arrangements. This is not the everyday type of confined space. For example, it could be somewhere like a petrochemical site. The risk of the chemical or the gases or fumes cannot be removed. We need that rescue team. This needs careful consideration, an NC4 entry.

Now they are the four. What is the application of this? Well, even though in the first instance this was applied to the water industry, the Health and Safety Executive feels it is good practice that all environments, all industries, follow the principle of the NC1 to NC4. So what you need to do as your own organisation is stop, think about the type of entry you do, and give it that classification. Incorporate as part of your Risk Assessment, so it is clear to everyone the type of entry that you intend to do.

Now we can break down the actual procedure as follows. First of all, we must have our documentation in place, random permit in place. We test the atmosphere. We check communications. My safety equipment is then checked. We do a toolbox talk, safe entry and exit, and a safety attendant is to monitor the activity. So that all falls under the National Classification Scheme; having the procedure clear for everybody to follow. And if you follow that, then hopefully we should be safe. But the document does go on to state because things can change, we need to do a Dynamic Risk Assessment. It may be, we started off doing only an NC2 entry but we get to the point where we need to detach, in which case, we now fall under an NC3, and you would change your paperwork to reflect that. It may be that we are at a higher level, maybe that NC4, but with greater controls put in place, we can drive it down to an NC3, which is always the safe option. Or even better, down to an NC2. So the documents are very clear. Make sure we do a Dynamic Risk Assessment as and when required.