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Article By Gordon Cadzow, Secretary of WAHA – for National Safety Magazine.

There still remains significant confusion around the obligations of PCBUs (employers) and operators in working in confined space environments. The tragic death of three members of the same family in a concrete water
tank incident a NSW farming property earlier this year reinforces the point that the true-dangers of this risk are not as well understood as they need to be.

Many people are aware that working in a confined space carries an increased risk compared to those working in an open environment. Most are unaware, however, that the definition of a confined space is different across each state and territory in Australia – something that SafeWork Australia has tried to address by issuing a model ‘Code of Practice’ during the harmonisation of workplace health and safety legislation process that was commenced in 2008. This Code of Practice was recently updated and re-released in February 2016.
Although a number of states and territories have adopted this code, it is for from being national and therefore companies need to be aware of the differences that exist across various jurisdictions. Mony principles remain the some: however, the specific requirements of each region should be accounted for when working in a confined-space environment.

TRAINING AND COMPETENCIES
The requirement to work in confined spaces requires a wide range of operator competencies. There is on overlap with the sofe working at height skillset – including many of the rescue requirements. As such, the Working at Height Association (WAHA) hos a strong Confined Space Category where members focus on the issues in that specific market. Despite this, WAHA receives a significant volume of feedback and questions about issues that occur in confined space work environments.

As the Working at Height Association has category members from all around Australia, member discussions quickly concluded thot there was a need to investigate further and, in late in 2015. the association conducted a nationwide online survey to try and identify the specific issues around the country. There were in excess of 230 respondents to the survey, with all states and territories represented. Interestingly, 60% of respondents operated in more than one jurisdiction – with those respondents again highlighting the problems created by the lock of notional consistency in regulations and the need to operate differently in different state/territory-based sites. Additionally, some jurisdictions referenced the Australian Standard (AS/ NZS2865), while others did not.
While 96% of respondents were aware of the local regulations. 26% hod difficulty understanding them. with 81% having to refer to supporting information.

While 96% of respondents were aware of the local regulations, 26% had difficulty understanding them, with 81% having to refer to supporting information.

Results from a nationwide WAHA Confined Space online survey.

Similarly, while 89% were aware of the Australian Standard, 26% again said the content of the Standard was unclear and 78% hod to search for additional information. The effectiveness of confined space training – for both managers and operators – was also measured. While 94% indicated the training was “satisfactory or better”, only 60% felt they hod obtained sufficient skills to actually operate in a confined space.
Importantly, one of the key outcomes of the survey was that there was a large variation in expectations around the appropriate length of initial training time and refresher training requirements. Although competencies are referenced in the Standards and Codes of Practice. there ore no prescriptions around course length, teacher/student ratios or other elements that con assist to define course quality. This is therefore on area of concern for the association – how can a person doing a single one-day confined space course be deemed competent to not only work in the environment but olso to perform a rescue? Yet training organisations ore issuing Statements of Attainment for this without any checks and balances around this.

TRAINING STANDARDS
Based on these survey outcomes, WAHA has issued guidelines on what is deemed by members to be the range of specific competencies an individual needs to demonstrate, prior to being issued with a confined space certificate. These guidelines align with the Code of Practice and current Standard requirements and are published on the WAHA website. They are available for public access on the WAHA website.

This information provides guidelines to training companies on on ideal/appropriate course length, practical exercises ond teacher-student ratios that would ensure a quality course is delivered. With ASOA focusing on the quality of the ‘system’ of training for RTOs, rather than the quality of the content being delivered and the capability set of the students at the end of a training course, this guideline is designed to provide o benchmark from which companies con assess their own programs.

AUSTRALIAN STANDARDS ON CONFINED SPACE
Australian Standard ASNZS 2865 Confined Spaces was first published in 2003; however, this now aged Standard is well overdue for review. It is understood that this Standard is not presently managed by on active Technical Committee. Under the Standards Australia process, its future will be determined by the Regulators that reference that standard. Currently, this is believed to be only Western Australia that is referring to the Standard. There is no reference to the Standard in the model Code of Practice.
Typically, a Standard is managed by a Technical Committee that has four options available to assess the future of the document. It can:

• Confirm the Stondord (with no chonges made).
• Revise the Standard with suitable updates – this requires o project proposal.
• Make the Stondord “obsolete” – if it is not recommended or reflecting current proctices but should be retoined in order to provide for servicing of existing equipment or requirements.
• Withdraw the Standard if it is considered no longer relevant.

The WAHA Confined Spaces Category members feel thot the Standard should be subjected to review, revision and re-issue. The main reasons for this ore that the Standard provides more detailed guidelines on training requirements, the types of PPE that con and should be used in these environments and more specific information on how to handle rescue scenarios, which ore not provided for in many of the state and territory Codes of Practice (COP), or even the new model COP. This will be a complex process that will require the submission of a detailed project

proposal to Standards Australia that is both supported by a large number of interested industry bodies and, possibly, on external project funding submission.

THE FUTURE
Moving forward, WAHA proposes to campaign with Safe Work Australia and the various state and territory regulators to have the model COP adopted notionally, thereby eliminating workplace confusion and ensuring that confined space training operations can have a notional approach to worker training.
There is no doubt that working in confined space is a hazardous undertaking. As such, the correct understanding and management of the risk is essential. With managers and workers now increasingly operating across state and territory boundaries, it is essential that the some definitions and standards apply nationally. After all, is that not what “harmonisation” was supposed to achieve?
The Working at Height Association has released information that highlights the differences in definitions of a confined space, available on our website.

Article by Gordon Cadzow, Secretary of the WAHA.

Those designing buildings and structures have a responsibility to consider all aspects of safety over the life of the building or structure – during its construction, the maintenance requirements over its life cycle and even its eventual demolition. These requirements are clearly set out in “Safe Design of Structures’ Code of Practice (2014) issued by SafeWork NSW and other state regulators. In reality however, companies are dealing with both new and old structures – which means that the safe design principles will take some time to manifest in building design over the coming decades.

In the intervening period, where an assessment of a planned work activity indicates that there may be a health & safety risk to those undertaking the work, action must be taken to develop a safe work method. This is particularly relevant when work has to be undertaken at height – either to access the work area or where the work area itself is at height.

Where it has been identified that work may have to be carried on at height over the building life cycle, the hierarchy of control should be applied in order to determine if that need can be eliminated – by changes to design or “engineering out” the need to work at height. 

If this is not possible, how then can the risks associated with working at height be minimised by utilising a Height safety system?

System Design

Where it has been identified that work will have to be carried out at height, the focus must initially be directed at the development of the safest possible work method. This is the task of the system designer who should be qualified to the level of Height Safety Manager as defined in AS/NZS1891.4 Section E3(e). The system developed will account for a variety of circumstances, such as frequency of use, the nature of the work being undertaken, the number of users accessing the system and their training competencies etc. Once the safe system is designed and deemed ‘reasonably practicable’ for the purpose, the design of a system can be documented, with details on how the system is designed to be used. Once formalised, this procedure will therefore effectively be the basis for preparing a Safe Work Method Statement (SWMS) – the template document for which can be filed in the Height Safety System File.

The system designer is also responsible for defining the specification of the type of equipment to be used and ensuring that the structure to which it is fixed is capable of sustaining the loads, should a fall from height occur. Again, these design details and calculations should be documented and added to the Height Safety System File.

System Installation

Those contracted to install the system must ensure that the system is installed exactly to the design requirements using the specified equipment. The installers undertaking the installation must be certified by the product manufacturer as accredited installers and copies of such installation certification should be added to the System File and available for review by the asset owner.

The system installer must ensure correct product installation and labelling and may be required to test and certify each component in line with the manufacturer’s instructions (e.g. for concrete mounted anchors, cable swaging tests etc). Any test certification details – along with the required date for re-certification should then be added to the system file. To enable future component inspection and re-certification, the manufacturer’s specific fixing instructions should also be added to the System File.

The system should now be available for safe use. However, it is often at this time that the actual building or structure is passed from the construction company to the owner / operator / facility manager. Where this transfer of responsibility happens, it is essential that the System File is transferred to the new asset manager at that time so a detailed record of these documents can be available for future re-certification of these systems to be undertaken.

System Users

System users are often specialist tradesmen (electricians, plumbers etc.) related to the task being undertaken. Where working at height is involved, the tradesmen must also hold a current Nationally Recognised certification for Safe Working at Height from an RTOP as a minimum requirement. One lead person should be certified to at least Height Safety Supervisor level as defined in AS/NZS1891.4 Section E3(c), with others to at least Height Safety Operator level (AS/NZS1891.4 Section E3 (b)).

System users should review the Hight Safety System File – with particular reference to the template Safe Work Method Statement and the certification date – and carry out a pre-use inspection of equipment to be used with the system. If the system certification period has expired, the system must NOT be used and should be tagged “out of service” until it has been inspected and re-certified as detailed below.

The system should be used in line with the Safe Work Method Statement and, at the conclusion of the work, a user “post use” inspection should ideally be undertaken. The Height Safety System File should be updated with any pre and post inspection comments along with the user details.

System Recertification

There is a requirement to have any height safety system rercertified in line with local regulatory requirements (generally, every 12 months – but check local regulations). This work must be done by an accredited system certifier, qualified to the level of Height Safety Equipment Inspector (AS/NZS1891.4 Section E3(d)) and with endorsement by the manufacturer. The inspector will require access to the Height Safety System File and will check the ongoing validity of the SWMS, equipment suitability, installation in compliance with the manufacturers instructions and then implement the manufacturer’s ongoing testing requirements. 

On satisfactory inspection, the inspector will carry out any system re-labelling requirements and add the next recertification details to the system file as well as advising the system manager (asset owner) of those future recertification requirements.

Where a system fails the recertification requirements, the system certifier should tag the system “out of service” – providing detailed reasons for failure – and advise the asset owner to contact the system installer for remedial action. The system should not be returned to service until it has been re-certified and the appropriate details added to the Height Safety System File.

By following these basic guidelines, asset owners can be assured that their height safety systems remain safe.