Confined space work: training, permits and paperwork for groundworkers

A trench, chamber or manhole is a confined space when it is enclosed or largely enclosed and there is a foreseeable risk of fire, explosion, loss of consciousness, asphyxiation or drowning. If it is, the Confined Spaces Regulations 1997 apply: avoid entry if you can, use a safe system of work if you can't, and have a rescue plan before anyone goes in. Training is matched to low, medium or high risk, and registration lasts three years.

What counts as a confined space on a groundworks job?

Any space that is enclosed or largely enclosed and carries a "specified risk": fire, explosion, loss of consciousness, asphyxiation, or drowning. HSE's Approved Code of Practice lists manholes, shafts, excavations and trenches as examples, but only where one of those risks is present or reasonably foreseeable.

So the same trench can be in or out depending on what's around it. A 1.2 m service trench in open ground on a dry day is usually an excavation, with excavation rules. Put a petrol pump in the bottom, run it next to a leaking gas main, or dig it beside a sewer that can flood, and you have a specified risk.

Common groundworks examples:

• Inspection chambers and manholes on existing drainage, especially live foul sewers
• Deep trenches near gas mains, contaminated ground or landfill
• Attenuation tanks, soakaway crates and pump chambers during install or repair
• Culverts and box sections
• Any excavation where a generator, pump or compressor is running nearby

What do the Regulations require?

Three things, in this order. Under regulation 4, nobody enters unless it is not reasonably practicable to do the work without entry. Where entry is unavoidable, you follow a safe system of work. Under regulation 5, you put rescue arrangements in place before work starts and use them at once if something goes wrong.

The Management of Health and Safety at Work Regulations 1999 sit behind this: you have to assess the risk first. If you employ five or more people, you must write down the significant findings of that assessment.

Which confined space training does your team need?

Match the course to the risk level of the work and the role of each person. The water and utilities industry register (EUSR) splits it into entrants, top persons who stay outside and control the entry, rescue teams and managers, at low, medium and high risk. Registration is valid for three years, and people redo the qualification to renew.

In practice, a small groundworks crew doing chamber connections and drainage repairs usually needs medium risk entrants plus a trained top person on every entry. High risk work, where breathing apparatus is needed or the entry is complex, is a different job; most small firms subcontract it to a specialist.

Training cards expire. Keep a list of who holds what and the expiry date, and check it before you put names on a permit. A principal contractor will ask, and an expired card means that person can't go in.

HSE's code of practice also says anyone likely to take part in a rescue should be trained for it, with refresher training on a regular basis, for example annually, and rehearsals that are realistic rather than a tick-box drill.

When do you need a permit to work?

Usually, whenever there is a reasonably foreseeable risk of serious injury in entering or working in the space. HSE describes the permit as an extension of the safe system of work: a formal check that every control is in place before anyone goes in. It does not make the job safe by itself.

The permit should record the time limits on entry and the gas test results, and be cancelled once the work it covers is finished. For a very simple job where the risks are easy to control, HSE accepts a permit may not be needed, but most groundworks entries into live drainage won't meet that bar.

CONFINED SPACE PERMIT TO WORK        Permit no: number

Site: site address                 Date: date
Space: e.g. MH3, foul sewer chamber, 2.4 m deep
Work to be done: e.g. connect new 150 mm branch to existing chamber
Why entry can't be avoided: e.g. benching must be cut by hand

1. ISOLATION
Flows stopped or over-pumped: how       Checked by: name
Services isolated (gas, power, pumps): which  Locked off: Yes / No

2. ATMOSPHERE (test before entry and at intervals)
Tester: name  Meter: make/serial  Last calibrated: date
Time | Oxygen % | Flammable % LEL | H2S ppm | CO ppm
time |   |   |   |  
Continuous monitoring during work: Yes / No
Ventilation in place: type

3. PEOPLE
Entrants and card numbers: names, EUSR card no., expiry
Top person: name, card no., expiry
Rescue team and equipment: tripod, winch, harness, escape sets
Communication method: radio / voice / line signals

4. TIME LIMITS
Valid from time to time today only.

5. AUTHORISATION
Issued by: name  Signed: ______  Time:  
Accepted by entry supervisor: name  Signed: ______

6. CANCELLATION
All persons out, tools removed, space made safe.
Cancelled by: name  Signed: ______  Time:  

Adapt it to your own risk assessment. If a principal contractor runs a permit system on site, use theirs and keep a copy with your job file.

How do you test the air and plan the rescue?

Test before entry with a competent person and a calibrated meter, in a set order: oxygen first, then flammable gases, then toxic gases. Keep a record of the results. In a space where conditions can change, such as a live sewer, monitor continuously while people are inside.

For rescue, HSE's code of practice is direct: you should not rely on the public emergency services. Your plan needs trained people on top, the right kit set up before entry (typically a tripod and winch with harnesses for a vertical chamber), and a way of raising the alarm. Rescuers must be protected against whatever caused the emergency. In HSE's own example of a confined space incident, two men died and three more had to be rescued after colleagues went in to help someone who had collapsed.

What paperwork does a principal contractor expect?

On commercial subcontract work, expect to hand over a site-specific risk assessment and method statement with a confined space section, the training cards for everyone entering, gas meter calibration certificates, the rescue plan and the permit system you'll use. On larger jobs your RAMS will run to many pages, and the confined space part is often what holds up the start.

That firm's RAMS run to about 30 pages, with confined spaces among the sections. The fix is to build the confined space part once, as a master section with your permit, training table and rescue method, then change only the site details each time. Our guide to a site-specific RAMS master template shows how to structure it, and the free RAMS template gives you a starting document. If your business is under five people, health and safety for small firms covers what you have to write down and what you don't.

If you work on a site under CDM 2015 as the only contractor, you also need a construction phase plan before setting up. And remember the excavation rules still apply alongside the confined space ones: HSE says excavations should be inspected at the start of each shift and after anything that could affect their stability, with a record kept.

This guide sets out the rules; it doesn't replace a competent person's assessment. For high risk entries, breathing apparatus, or anything you're unsure about, get a specialist confined space contractor or adviser in.

Common questions