IMS9.4.6.3 Confined Space Procedure

1.0   PURPOSE

To ensure performance and management of SeaLink Confined Space related activities conforms to legislative requirements and Australian Standard 2865 (2009) in that:

• Eliminate or, where this is not practicable, minimize the need to enter a confined space; and

• Provide for the health and safety of all persons who need to enter or work in a confined space by preventing exposure to hazards that may otherwise cause injury or illness.

2.0   SCOPE

It must encompass SeaLink employees, Contractors, Sub-Contractors and Visitors. This procedure applies to all work areas or other locations that Company personnel are required to enter into, that fall within the definition of “Confined Space”.

3.0   REFERENCES

• Queensland Workplace Health and Safety Act 2011

• Queensland Workplace Health and Safety Regulations 2011

• Queensland Confined Space Code of Practice 2021

• AS 2865-2009 Confined spaces

4.0   DEFINITIONS

Confined space

A 'confined space' means an enclosed or partially enclosed space that:

• is not intended or designed primarily to be occupied by a person; and
• is, or is designed or intended to be, at normal atmospheric pressure while any person is in the space; and
• is, or is likely to be, a risk to health and safety from:
  • an atmosphere that does not have a safe oxygen level
  • contaminants, including airborne gases, vapours and dusts, that may cause injury from fire or explosion
  • harmful concentrations of any airborne contaminants, or
  • engulfment.

A confined space is determined by the hazards associated with a set of specific circumstances and not just because work is performed in a small space.

Entry into a confined space means a person's head or upper body is in the confined space or within the boundary of the confined space.

5.0   REQUIREMENTS

5.1   Confined Space Entry Permit

Subject to review of the risk assessment, the Company must provide approval, in the form of an entry permit, prior to work in a confined space being carried out. 

No employee, contractor or sub-contractor of the Company is permitted to enter into a confined space until they:

• Have been trained and deemed competent by a Registered Training Organisation.

• Have been issued a Confined Space Entry Permit.

• Abide by all conditions contained within that Permit.

• Abide by all emergency response conditions for the Confined Space as specified within the permit.

The confined space entry permit must include any precautions or instructions necessary for the safe entry and execution of work.

5.2   Issue and Administration of Confined Space Entry Permits

The Company may nominate persons who are trained and certified competent, as being authorized to issue a confined space entry permit on the Company’s behalf.  These person/s must be readily available within work units where this activity is performed.  After hours access to permits must also be provided.

Details provided within the Confined Space Entry Permit must meet the requirements regarding provision of information, work procedures, records of atmospheric testing and other risk management processes as required by the relevant Australian Standard and Queensland legislative requirements.

Confined Space Entry Permits must be reviewed by, and acceptable to, all parties involved in the identified work prior to commencement of work.

The permit issuing authority and person responsible for direct control of the work are to ensure all personnel working under the permit are given instructions regarding:

• Emergency entry and exit procedures.

• Use and fit of applicable respiratory devices and any other designated personal protective equipment.

• Lockout procedures where applicable.

• Safety equipment required and its correct use.

• Rescue procedures.

• Employees must then be specifically asked for their input with regards to any matter raised at the briefing.

Confined Space Entry Permits are to be closed on termination of the activity for which they are issued.

Permit issuing authorities will keep records of confined space entries for a period of 5 years.

5.3   Managing Risks - Assessment and Control

A trained and competent person must undertake a risk assessment (Job Safety Analysis JSA) before issuing a permit, or before commencing work that requires entry into a confined space. 

The assessment must be recorded and as a minimum take into consideration the following:

• The nature of the confined space.

• The work required to be completed

• The possibility of eliminating the need for entering the confined space.

• The range of work methods by which the task can be done.

• The hazards involved and associated risks.

• The safe handling of plant or materials to be used in the confined space 

• Emergency response and rescue procedures.

Where a risk assessment identifies an unacceptable risk to health or safety arising from entry into a confined space, it is the responsibility of the relevant supervisor to ensure the elimination or minimization of risk before entry is undertaken

Control measures to eliminate or minimise the risk should be followed in order of the following control priority:

• Elimination – can the task be completed without placing personnel in the Confined Space?

• Substitution – can the task be completed through another process, or using something less harmful (e.g. use water for cleaning instead of chemicals).

• Isolation – separating the hazard(s) from the person (e.g. lockout).

• Engineering – purging, ventilation.

• Administrative – procedures, training, use of permits, and limitation of time inside confined space.

• Personal Protective Equipment – Should only be resorted to when one or all of the other control measures cannot reduce risk to an acceptable level (e.g. Breathing apparatus, hearing protection, rubber boots).

A combination of controls should also be considered to reduce the inherent risks

5.4   Critical Risks – Atmospheric Safety

The potential for the atmosphere within a confined space to have an unsafe oxygen level, or be contaminated, poses a high risk to personnel engaged in the activity.

Examples of atmospheric hazards include, but are not limited to: -

• Oxygen deficiency - less than 19.5% by volume.

• Toxic gas -  spillage, fumes, hydrogen sulphide gas released from lines etc.

• Combustible gases - methane or other flammable gases.

Prior to any person/s enters a confined space, the following must be established: 

• The confined space contains a safe oxygen level.

• The atmospheric contaminants in the confined space are reduced to below the relevant exposure standards.

• The confined space is free from extremes of temperature.

• The concentration of flammable contaminant in the atmosphere of the confined space is below 5 percent of its LEL.

Atmospheric testing and monitoring must be conducted and consistent with the hazards identified, suspected, or otherwise indicated during the risk assessment.

Where it is not practicable to provide a safe oxygen level, or atmospheric contaminants cannot be reduced to safe levels, there will be no entry to the confined space unless there is personnel are equipped with suitable respiratory protective equipment (breathing apparatus or other supplied air equipment), and accompanied in the confined space by at least one other similarly equipped and qualified person.

• (A separate, standby person, must also be provided)

5.5   Personnel Wearing Breathing Apparatus Requirements

To ensure accurate testing of suspect atmospheres, gas detection equipment must be used to establish atmospheric conditions, and to continually monitor conditions for the duration of the entry.

Only trained personnel and certified as competent may operate this equipment and perform this function.

Only equipment that is properly maintained, and certified accurate, according to manufacturer’s direction is to be used.

All personnel wearing breathing apparatus must be clean shaven.

5.6   General Safety Issues

Undertaking work in confined spaces may greatly increase the risk of injury from hazards such as: -

• Noise.

• Temperature, which can be the result from the work process or weather conditions.

• Radiation within a confined space.

• Manual handling.

• Falls and trips.

• Fires / explosion.

Personnel supervising and/ or undertaking work within a confined space must re-evaluate the suitability of their equipment, including personal protective equipment, and work procedures, to ensure suitability for confined space work.

5.7   Personnel Assigned to Work Within a Confined Space

Only personnel who have been trained and certified as competent are authorised to enter and work within a confined space.

This does not apply where atmospheric hazards require the wearing of supplied air respirators. In the event of an emergency, members of responding emergency services, having been formally advised of any hazards within the confined space, can enter the confined space without permit approval.

Personnel will be required to undergo medical assessment in order to demonstrate that they are physiologically capable of working under conditions likely to be encountered within a confined space.

Before entering a confined space, personnel are required to review, and sign onto the confined space entry permit and risk assessment to acknowledge their understanding of, and agreement to comply with the conditions contained therein.  Sign on also implies that they are satisfied that risks have been controlled according to the relevant Standards, and this procedure.

• Only those personnel whose names appear on the entry permit are allowed to enter the confined space.  (A person whose upper body or head is within a confined space is considered to have entered the confined space).

• Personnel entering and leaving a confined space must have their name and time of movement recorded on the permit.

5.8   Emergency Response Procedures

Emergency response procedures are to be determined, and provided in advance, and personnel made aware of these, for each confined space entry.

A “Stand-by Person” must be provided and must:

• understand the nature of the hazards inside the particular confined space and be able to recognise signs and symptoms that workers in the confined space may experience
• remain outside the confined space and perform any other task that may interfere with their primary role of monitoring the worker/s inside the space
• have all required rescue equipment (e.g. safety harnesses, lifting equipment, a lifeline) immediately available
• have the authority to order workers to exit the space if any hazardous situation arises
• never enter the space to attempt rescue.
• maintain continuous communication with the worker from outside the confined space
• monitor conditions within the confined space, and if practicable, observe the work that is conducted

The Stand-by Person must be properly equipped for, and certified competent in the performance of first-aid and CPR (12 monthly certification for CPR), confined space rescue techniques, basic fire extinguisher operations, and is competent in the use of self-contained breathing apparatus where applicable.  The Stand-by Person MUST be clean-shaven when the possible use of self-contained breathing apparatus equipment has been identified.

All personnel certified to undertake confined space entry work are to be competent in confined space rescue, basic fire extinguisher operations, and the use of self-contained breathing apparatus when applicable.

Emergency response equipment is to be provided for each confined space entry according to needs identified during risk assessment.  Equipment may include:

• Self contained breathing apparatus.

• Rescue tripod and winch.

• Rescue harness.

• Rescue lines.

• Portable fire extinguisher.

5.9   Critical Confined Space Entry Equipment

Certain items of equipment used in confined space entry require strict maintenance and inspection routines in order to ensure their reliability.

Mandatory inspection and maintenance routines are:

• Self-contained breathing apparatus – Before use check.  Weekly check. Annual inspection/ maintenance by Certified Agent as per Australian Standards 1715 and 1716.

• Gas detectors – Before use check.  Challenge test according to manufacturer recommendation.  Full test according to manufacturer recommendation and Australian Standard 2275. (12 monthly)

• Harnesses and rescue lines – Before use visual check. Annual check/ test per Australian Standards 1800, 1891, and 2626.

• Tripods – Before use visual check. Annual check according to manufacturer recommendations.

5.10  Training

Training is mandatory for all persons who:

• Issue Entry Permits.

• Manage and or supervise confined space work, but do not actually enter the Confined Space or act as “Stand by Person”.

• Manage and or supervise work performed in confined spaces.

• Perform work in or on a confined space

• Perform confined space assessments.

• Are acting as “Stand by Person”, or otherwise involved in rescue and first aid procedures.

Training sessions will provide the following information:

• The hazards of confined space.

• Hazard identification and risk assessment.

• Risk control measures.

• Emergency procedures.

• The selection, use and maintenance of safety equipment.

• SeaLink confined space entry permit – use of.

• First aid and CPR.

• Practical training in the use of breathing apparatus where applicable.

• Practical training in the use of rescue equipment where applicable.

• Practical training in the use of portable fire extinguishers.

• Practical exercise in confined space permit preparation, entry, and emergency drill.

Training will be delivered through a combination of in-house and external modules, including practical entry and rescue training.

Personnel acting as “Stand by Person” during a confined space entry are to have completed a CPR training/ refresher training course.

Confirmation and recording of training is required for all personnel. Records will be maintained by the HSEQ Manager and state due date of next refresher training, and whether “full” or “restricted” certification.

5.11  Medical Assessment

Personnel must be assessed as physiologically capable of working safely in a confined space before being certified competent to work within a confined space.

The assessment will be undertaken by a medical practitioner appointed by the Company to a criteria determined by the medical practitioner as being relevant to the persons capacity to safely undertake this type of activity.

5.12  Steps in Completing a Confined Space Permit

Each confined space entry permit must be assessed individually:

Any request for work to be carried out in a confined space is to be directed to the relevant permit issuing authority.

5.12.1 Permit No

Permit Number is assigned by Permit Issuing Authority and recorded in a register

5.12.2  Work Order

A document detailing the task to be undertaken, who requested the task and the personnel involved.

5.12.3 Permit Issuing Authority

Authorized and accredited person who completes permits details.

5.12.4 On Site Supervisor

Person in direct charge, on location, of the job.

5.12.5 Site Information

Specific details of location, personnel involved.

5.12.6 Work to be Performed

Specifies activity covered under this permit. Only this activity can be performed – anything other than this activity requires a new permit.

5.12.7 Atmospheric Testing

Name of person who is authorized to, and completes – The Permit issuing authority must confirm that the person performing the test is competent to do so and enter this person’s name in this space.

5.12.8 Safe Working Limits

Safe working ranges of identified gases and explosive mixtures.  Readings are to be taken immediately on opening the confined space, and then immediately prior to entry.  Monitoring must be maintained throughout the entry.

5.12.9 Atmosphere is Safe to Work in Under the Conditions

Describes requirement for respiratory protection. Person assigned to atmospheric testing.

5.12.10 Chemicals Approved for use on this job

Only chemicals listed here are permitted within this confined space. Permit authority to complete.

5.12.11 Acceptance of Permit Conditions

People working on this job must sign their acceptance of permit conditions.

5.12.12 Precautions

Any additional precautions that are needed.  Where Isolation or Hot Work permits are indicated, the Permit issuing authority must record the permit number.

Other precautions are determined and ensured by on site supervisor.

5.12.13 Protective Equipment

Protective equipment to be worn – includes specific types. e.g. P1 respirator.  Determined by on site supervisor.

5.12.14 Other Hazards / Safety Issues

Any hazards or safety related issues not otherwise covered.  Completed by Permit Issuing Authority and/ or on Site Supervisor.

5.12.15 Job Status

On completion of present work assignment, what is the status of the confined space job, and the plant/ equipment therein.  Completed by on site supervisor.

5.12.16 Permit closed out (On Site Supervisor)

• Workers and equipment have been withdrawn at ---- hrs.

• Activity completed / not completed as at --- hrs.

• Equipment/ facility is/ is not ready for use ---hrs.

6.0   EXHIBITS

Documentation produced as a result of conducting the above-mentioned activities includes:

SeaLink Confined Space Entry permit process located on DataWeb