Confined Space Rescue - Is It a Legal Requirement?
No. Having a confined space rescue team present at every confined space entry is not a legal requirement.
However, it is a requirement to have suitable and sufficient emergency arrangements in place and this may include the provision of an on-site rescue team.
What do the regulations say?
Regulation 5 of the Confined Space Regulations states:
”… no person shall enter or carry out work in a confined space unless there have been prepared in respect of that confined space suitable and sufficient arrangements for the rescue of persons in the event of an emergency, whether or not arising from a specified risk.”
arrangements shall not be suitable and sufficient unless:
”(a) they reduce, so far as is reasonably practicable, the risks to the health and safety of any person required to put the arrangements for rescue into operation; and
”(b) they require, where the need for resuscitation of any person is a likely consequence of a relevant specified risk, the provision and maintenance of such equipment as is necessary to enable resuscitation procedures to be carried out.”
The full text of the regulations is available on the gov.uk website.
Interpreting the regulations?
Most confined space rescue providers will tell you that the above paragraphs mean that you need a standby confined space rescue team for every entry. Whilst that would be the preferred situation, we do not live in an a ideal world, and it is not exactly what the regulations require.
This is a requirement, however, to plan for all reasonably foreseeable emergencies…
“You should assess the requirements for emergency rescue arrangements. Possible emergencies should be anticipated and appropriate rescue arrangements made. The likely risks, and therefore the equipment and measures needed for a rescue by nearby employees, must be identified and the equipment made available for use.”
“You must make suitable arrangements for emergency rescue which will depend on the nature of the confined space, the risks identified and the likely nature of an emergency rescue. You should not rely on the public emergency services. You should consider accidents arising from a specified risk, and any other accident in which a person needs to be recovered from a confined space, for example incapacitation following a fall. “
and you cannot entirely rely on the emergency services….
”Reliance on the emergency services alone will not be sufficient to comply with these regulations. Employers must put into place adequate emergency arrangements before the work commences.”
Your arrangements should be commensurate with risk. They should be suitable (for level and complexity of the task).,sufficient (identifying and controlling, or mitigating, all relevant hazards) and in accordance with current best practice.
Depending on the entry, suitable and sufficient arrangements may include:
A very low risk entry, with simple access and egress.
Self rescue may include the use of gas detection equipment which gives an early warning, escape breathing apparatus which gives the wearer a sufficient supply of 'clean' air to evacuate and a robust procedure to follow in the event of an emergency.
Self Rescue
A vertical entry where the entrant does not traverse and will not become entangled.
Non-entry rescue may include the wearing of a harness connected to a mechanical rescue device (recovery winch/block or man-riding winch) anchored outside the space (to a tripod, davit or similar), which is capable of lifting a casualty out of the space. Top man can use the equipment to haul a casualty out of a space without them having to enter.
Non Entry Rescue
An entry where there is no risk of a hazardous atmosphere and a rapid extraction is required.
A casualty extraction team may be sufficient to recover a casualty who has become ill or injured in a safe atmosphere. This will likely include a team of first aid (minimum) trained individuals who are capable of evacuating a casualty from the space using a stretcher and/or other specialist evacuation equipment. The team will enter the space to retrieve a casualty.
Casualty Extraction
An entry where there is a hazardous atmosphere present or is reasonably foreseeable.
Will likely include a team competent in the use of full working breathing apparatus and specialist casualty extraction equipment. The team will enter the space to retrieve a casualty.
BA Rescue Team
What else should you consider ?
The Approved Code of Practice (L101) gives other suggestions:
Rescue and Resuscitation Equipment
Lifting equipment should be capable of lifting an unconscious casualty - do not rely on ropes.
Breathing apparatus - ensure sufficient supply of air
First aid - consider need for both circulatory and respiratory resuscitation
Raising the Alarm
Can include lone worker alarms
Consider communication between entrants, to the attendant, to the rescue team, to the emergency services
Safeguarding the Rescuers
Rescuers should be competent and well practiced
Limitations should be clearly defined
A safe working procedure and rescue procedure should be provided for rescue team members
Fire Safety
Consider the introduction of additional hazards, e.g. purging, carbon dioxide
Control of Plant
Adjacent plant may require isolating or shutting down to safeguard rescuers
First Aid and Resuscitation
Suitable equipment should be provided. It is likely that this will include defibrillation equipment (AED), medical oxygen and resuscitation equipment.
Consider provision of casualty immobilisation equipment
Emergency Services
Prior notification to emergency services (usually Fire and Rescue Service) may be prudent - however this is not a mandatory requirement
Understand the limitations of public emergency services, e.g. response times, available equipment and techniques
Training
Rescue operatives should be; trained to use all of the equipment they carry, including resuscitation, AED, oxygen, lifting equipment; competent and well drilled.
The full text from L101 is available to download from the HSE website.
What does all this mean ?
Its all very good quoting from regulations and ACOP’s but but does that translate to reality?
Whilst a rescue team is not mandatory, you should identify what emergencies are reasonably foreseeable and plan for those emergencies.
Your arrangements should mitigate against emergencies arising from both the specified risks and other risks including falling from height, illness, task based injuries and similar.
Your arrangements should be commensurate with the risks - they should take account not only of the layout of the space and the likely hazards but also the likelihood of an incident occurring.
Your entry should be thoroughly risk assessed to determine what type of emergency rescue arrangements are required, e.g. self-rescue, non-entry rescue, casualty extraction or BA rescue.
Ensure the safety of all operatives (including rescue team members if applicable) is protected. Entry procedures, emergency arrangements and rescue procedures should be documented, with limitations clearly defined.
All operatives, including rescue team members, should be competent and well practiced.
The team should be properly equipped not just to make the entry but also to implement emergency arrangements.
Redline Safety Ltd provide dedicated, full time confined space rescue teams, entry teams, supervision and advce. Click here for more information on the services we offer, give us a call on 01925 982566 or email us at info@redlinesafety.co.uk.
