The Risk Management Tool Box Blog

What is a “Confined Space”?

Graham Marshall - Monday, February 28, 2011

The United States Occupational Safety and Health Administration (OSHA) defines, in its general industry rule, a confined space as having three attributes:

  1. Large enough to enter and perform work;
  2.  Limited access and egress; and
  3. Not designed for continuous occupancy.

Australian Standard (AS2865-2001) defines a confined space as:

“An enclosed or partially enclosed space that is at atmospheric pressure during occupancy and is not intended or designed primarily as a place of work; and

a)                 Is liable at any time to:

i. Have an atmosphere which contains potentially harmful levels of contaminant;

ii. Have an oxygen deficiency or excess; or

iii. Cause engulfment; and

b)           Could have restricted means for entry and exit.

The United Kingdom Health and Safety Executive (UK HSE) says:

It can be any space of an enclosed nature where there is a risk of death or serious injury from hazardous substances or dangerous conditions (e.g., lack of oxygen)”.

Obvious confined spaces include:

»           Tanks;

»           Stacks;

»           Tunnels; and

»           Trenches.

Some less obvious confined spaces include:

»           Rooms which are inadequately ventilated;

»           Shrouded columns or vessels which render them ‘air tight’;

»           The roof of floating roof tanks; and

»           Rooms and areas that become confined spaces by virtue of the activities being undertaken.

In all cases, confined spaces are particularly dangerous because they may frequently:

»           Contain or have the potential to contain an hazardous atmosphere;

»           Contain a material that has the potential for engulfing the work party;

»           Have an internal configuration that might cause an entrant to be trapped; or

»           Contain other recognized serious safety or health hazards.

Because confined space work can be so dangerous, there are a number of safety-critical controls that need to be applied to all confined space entry activities.  The safety-critical controls are highlighted below:

  1. Identify the hazards using the Think 6, Look 6 process;
  1. Once hazards are identified, search for ways of eliminating or isolating them;
  1.  In addition, always consider eliminating the confined space entry activity;
  1. If there are no alternatives to confined space entry, always test for presence of gas;
  1. Remember to continuously gas monitor atmospheric conditions;
  1. Always ensure that confined space entry  is controlled by an authorized “Permit to Work”;
  1. Ensure workers performing confined space entry work are suitable trained;
  1. Ensure that a stand-by person acts as a sentry;
  1. Provide adequate Supervision, especially where contractors are involved; and
  1. Prevent unauthorized entry.

For a useful toolbox presentation on the management of confined space entry work, click the link to our “process safety tools”.

Risk Assessing Major Consequences

Graham Marshall - Sunday, February 27, 2011
In qualitative risk assessment, HSE risk is a subjective description of the likelihood of a hazard being uncontrollably released together with the magnitude and type of resulting consequences to people, assets, the environment or the organizations reputation.

So how do we describe major HSE consequences?

Major HSE consequences are typically inclusive of the following types:

  • Permanent total disability or a single fatality;
  • Major damage to equipment (ranging from $100,000 for small businesses to amounts over $10M for Multinationals);
  • Production loss of several weeks duration due to delay or downtime;
  • Off-site and major environmental impacts with longer-term duration and clean-up requiring several months;
  • Considerable reputation impacts for the organization involving nationwide community recognition of the organizations "brand" and widespread community concern; and
  • There may also be prosecutions, regulatory concern and media attention with impacts on the locations licence to operate.



Risk Assessing Severe Consequences

Graham Marshall - Saturday, February 26, 2011
In qualitative risk assessment, HSE risk is a subjective description of the likelihood of a hazard being uncontrollably released together with the magnitude and type of resulting consequences to people, assets, the environment or the organizations reputation.

So how do we describe severe HSE consequences?

Severe HSE consequences are typically inclusive of the following types:

  • Major injury or illness resulting in partial disability;
  • Lost-time injury of greater than four days duration;
  • Major damage to equipment (ranging from under $50,000 for small businesses upwards to around $10M for Multinationals);
  • Production loss of several days duration due to delay or downtime;
  • Off-site and medium scale environmental impacts with medium-term duration and clean-up requiring several months;
  • Considerable reputation impacts for the organization involving nationwide community recognition of the organizations "brand" and widespread community concern; and
  • There may also be prosecutions or fines for breaches of applicable legal codes with widespread media attention.




Identifying Other Radiation Sources

Jay Stansell - Friday, February 25, 2011

Carrying on the theme from last week where we talked about thermal radiation hazards, this week we move on to address other radiation sources that can be a problem in workplaces.

Non-ionizing Radiation

Non-ionizing radiation involves electromagnetic radiation that does not carry enough energy to ionize atoms or molecules - that is - to completely remove an electron from an atom or molecule.  Examples of non-ionizing radiation include:

»            Near ultraviolet visible light (e.g., radiation found in sunlight);

»            Infra-red radiation;

»            Long Frequency Radio waves;

»            Ultrasound; and

»            Microwaves.

Ionizing Radiation

Ionizing radiation refers to any type of electromagnetic radiation that carries enough energy to ionize atoms or molecules - that is - to completely remove an electron from an atom or molecule. 

In humans, exposure to this type of very powerful radiation can cause cellular and molecular changes such as mutations, chromosome aberrations, and cell-killing.  At high doses, it is well-established that ionizing radiation is capable of increasing the cancer rate in exposed populations; at low levels of exposure, it is not possible to detect changes in cancer frequency.

Common use of ionizing radiation within workplaces includes: Non Destructive Testing (NDT) using X-ray and Gamma-ray isotopes and medical X-rays.

First Prosecution under the UK Corporate Manslaughter Act

Graham Marshall - Thursday, February 24, 2011

The first organization has been convicted under the Corporate Manslaughter and Corporate Homicide Act, providing a reminder our UK customers to ensure that their health and safety and risk management plans are adequate to manage risk.

Cotswold Geotechnical Holdings (CGH) became the first organisation to be convicted and sentenced under the Act since it came into force in April 2008.

The company was fined £385,000 (AUD $750,000) and could now go into liquidation. 

It was charged following the death of an employee in 2008. The employee died when a trench in which he was working collapsed.  Although CGH pleaded not guilty, prosecutors said the company’s system of work was dangerous and it had paid no attention to established industry guidance.

The police said CGH had a “cavalier attitude” to health and safety and that it used “out-dated working methods”.

Key to the conviction was evidence that the employee’s death was directly linked to the way in which the company’s activities were managed and/or organised by its Senior Management. The court decided that this amounted to a gross breach of duty of care .

It is clear that Courts will now treat corporate manslaughter much more seriously than a health and safety offence where death results.

Having rigerous health and safety procedures and HSE plans in place is essential for any company .

Health and safety compliance must be driven by Senior Management. They have to ensure their organisations have comprehensive, high-quality health and safety systems and procedures in place.

These systems must provide full compliance, not only with health and safety Law but also with all relevant guidance and best practice.   And it is vital that they are fully implemented, frequently reviewed and robustly audited.

Feel free to check out the rest of our website to see how the Risk Management Tool Box can assist in ensuring your organization meets its legal responsibilities.

To read more about the prosectution, click this link:

Manage the Risk during Abandonment and Demolition

Graham Marshall - Wednesday, February 23, 2011

Today's blog is about how not to manage risk when demolishing buildings.


Gunns Limited operated a saw mill in the south-west of WA, which included a large disused and unwanted work shed.

The shed was very large being about 10 meters high but almost 135 meters long and 25 meters wide.

Gunns Limited sought to demolish the shed and received several quotes from demolition contractors to perform the work.

At least one of the contractors highlighted to Gunns Ltd in their quote the requirement for the work to be undertaken under an appropriate demolition license.

In spite of that knowledge, Gunns chose to award the demolition contract to two unlicensed people who undertook to perform the demolition for free.

The Prosecution

The chosen contractors indicated that they would work for free but raise income by salvaging materials from the shed.

The demolishers were subsequently observed by a WorkSafe Inspector in the process of demolishing the shed.

Gunns Ltd was prosecuted by WorkSafe on the basis that they failed to ensure that the demolition was performed by a licence contractor.

They elected to plead guilty to the charge and were fined $10,000 with an additional $760 in court costs.

The lesson to learn here is to always ensure you pre-qualify and select competant contractors with the right HSE culture, right skill set for the work, and the correct licences where necessary.

Saving a few bucks early on is no excuse for dodgy practices and often ends in disaster.

There really is no such thing as a "free lunch".  Good Safety outcomes take effort and resources.

Maintaining Situational Awareness Around Mobile Plant

Graham Marshall - Tuesday, February 22, 2011
I was recently sent this picture by one of my customers who thought I might like to use it in my Think 6, Look 6 Hazard and Risk Management Training Program.

I've certainly made good use of it to highlight the hazards when working around forklifts, and I thought you might like to use it yourself. 

Perhaps you could use the picture in a toolbox talk to lead a discussion about hazards, triggers, incidents, consequences and controls for work around any mobile plant in your workplace. 

Hope you like it and have a safe day!

Interactive Tool Box Talks

Graham Marshall - Monday, February 21, 2011
How many times have you sat in a boring toolbox or tail-gate talk?

The key to a good toolbox session is to get the audience interactive and participating.

Below are a couple of photos which show a method to achieve participation that I developed and deployed on a Floating Production and Storage Off-take (FPSO) tanker  ship on the North-West Shelf of Western Australia.

The facilitated toolbox process involved use of a large "toolbox record sheet" together with work activity cards. 

The process involved the work party discussing a work activity and using the Think 6, Look 6 hazard and risk management process to populate the record sheet with the correct information about hazards, incidents and controls. 

Once they'd completed their toolbox, the workparty  took a digital picture which provided an auditable record of the toolbox session. 

Another easy benefit of this toolbox method when it came to audit time.

Look at the pictures and you'll soon get the idea.

Feel free to contact me if you think this program could add value in your workplace.  Also, don't forget to take a look at the tool-box materials in the shop.   That way you might brighten up your tool box talks!

Is there a requirement to use physical barriers?

Graham Marshall - Sunday, February 20, 2011

Yesterday I received an email asking about the requirements for use of barricading on work sites.  I’ve included advice below on dealing with barricades for meeting your duty of care under USA requirements and within the "British system" of law.

In the United States, there is an OSHA regulation that any floor opening which is infrequently used must be guarded by a cover.  When the cover is not in place the opening needs to be constantly guarded.

On that issue, OSHA Regulation 1910.23 (a)(5) states:

Every pit and trapdoor floor opening, infrequently used, shall be guarded by a floor opening cover of standard strength and construction. While the cover is not in place, the pit or trap opening shall be constantly attended by someone or shall be protected on all exposed sides by removable standard railings.

Under legislation in countries like the the UK, Canada, NZ and Australia which have developed over hundreds of years by tort law, specific requirements within the Occupational Health and Safety Acts and Regulations relating to barricades do not exist. 

Rather, the onus is on risk-based decision-making around "general duties of care".  The key question to ask, as always, is "what would a reasonable person do?"

For temporary barricading around a high risk location (e.g., around a dangerous excavation)  the standard safety solution is to apply the hazard and risk management process (i.e., Think 6, Look 6) in a systematic fashion.

In practice the hierarchy of safety controls should always be used.  

1.    Quickly identify if elimination of the hazard is practicable.  For example, can the excavated hole be back filled?

As soon as it’s obvious the hazard can’t be removed, look to implementing hazard exposure reduction controls.   

2.    Are substitution methods available (e.g., digging the hole elsewhere (e.g., away from  high volume traffic route) or at a different time (e.g., when no one is around)?

3.    Using barricades is probably occurring at the "engineering" level of control as it becomes a "physical" factor reducing risk by reducing the possibility of exposure to the hazard (i.e., stops you falling in the hole).

4.    It’s vital when considering temporary barricades that additional administrative control must be a considered.

Put simply, people will bypass temporary barriers (e.g., take a shortcut) and it can’t be assumed that barriers will be complied with.  

For very high-risk situations, consider having a temporary traffic control person to direct pedestrians or vehicles and to prevent unauthorized access to the barricaded area.

Also remember to communicate the reason for a barrier placement to staff using the area.  This can be done during tool-box talks, when preparing a JSA or during the permit to work preparation process.

Finally, it’s  good risk management to ensure that barricades are only deployed for higher-risk situations and that they are removed as soon as the risk is reduced or eliminated by other means of control. 

The indiscriminate placement of barricades and leaving them up when no risk is present serves to undermine the credibility of the Safety Program.   

In summary, risk management is all about using multiple layers of protection.

Risk Assessing Minor Consequences

Graham Marshall - Saturday, February 19, 2011
In qualitative risk assessment, HSE risk is a subjective description of the likelihood of a hazard being uncontrollably released together with the magnitude and type of resulting consequences to people, assets, the environment or the organizations reputation.

So how do we describe minor HSE consequences?

Minor HSE consequences are typically inclusive of the following types:

  • Injury resulting in restricted duties;
  • Lost-time injury of less than four days duration;
  • Minor damage to equipment (ranging from under a $10,000 for small businesses to around $1M for Multinationals);
  • Temporary production loss due to delay or downtime;
  • Localized (off-site) environmental impacts with short-term duration and clean-up over several weeks; and
  • Reputation impacts for the organization involving short-term, local community  concerns.  There may also be prosecutions or fines for breaches of applicable legal codes.


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