WHSMS0068 Sydney Water Confined Space Procedure

We have many Sydney Water Contractors contact us about what level of training do we require to work for Sydney Water.  Sydney Water Confined Space Procedure when read closely does provide an insight to contractors on what is required in the way of training. The procedure is here SW Procedure WHSMS0068 V9

Below is our attempt to summarise WHSMS0068 purely from a training perspective.  This is our interpretation, and after discussions with key personnel at Sydney Water the training I am going to propose meets the spirit of WHSMS0068.  More importantly if you follow the spirit of the Sydney Water Procedure and you are in a situation where an incident occurs, you can feel confident that the level of training of your staff cannot be questioned.  Remember with the bare minimum training, although you may feel it meets the stated requirements, you will still need to verify that it in fact was comprehensive enough for the tasks being conducted.

WHSMS0068 Confined Space Procedure

Section 6. Confined space works procedure

6.1 Hazard Identification and risk assessment. The responsible person must carry out a Hazard Identification and Risk Assessment. All
workers, including stand-by persons and responsible persons, must be involved to help identify hazards working in or on confined spaces prior to commencing the work.

6.2.1 Risk controls – Controls must be documented in a SafeWork Method Statement (SWMS)

6.3 Signage

6.4 Isolation or control of hydraulic assets and hazardous plant and equipment.

6.5 Atmosphere safety – Ventilation

6.6 Purging before entry

MSMWHS201  Conduct hazard analysis.  This unit runs participants through the  the formal task specific risk assessment (confined space risk assessment) which is fully documented and required by law and includes all the above.

6.7 Atmospheric testing and monitoring

6.7.1 Methods and limits of gas testing – states a competent person tst and monitor air quality before entry and while the space is occupied.

MSMWHS217 Gas test atmospheres ensures this competence.  A very basic understanding of gas testing and ventilation is provided during the ONE DAY ENTER & WORK course under the competency RIIWHS202E Enter & Work in confined spaces.  This unit is more a general awareness training than full competency based training.

6.7.2 Gas monitoring equipment – discusses gas monitors provided to workers are within calibration, response tested and pass.  MSMWHS217 Gas test atmospheres

6.7.3 Front Line Advance Gas (FLAG)- tester training – MSMWHS217 Gas test atmospheres – This unit also meets the intention regarding Specialist Gas Tester delegation to other competent gas testers – 6.7.5

6.9 Standby person(s) – A standby person(s) must be assigned to continuously monitor the wellbeing of those inside the confined space. If practicable observe the work being carried out and initiate appropriate incident preparedness if necessary.

MSMPER202 Observe permit work

6.14 Personal Protective Equipment

6.14.1 Inspection requirements for breathing apparatus – deals with inspection of SCBA or SSR units.  Only achieve competence by completing:

MSMWHS216 Operate breathing apparatus

7.  Incident preparedness plan – Responsible persons must ensure a task specific incident preparedness plan is established and communicated. Plans must be rehearsed as necessary to ensure they are efficient and effective for potential emergencies.  All staff gain competence in rescue & rescue planning via

PUASAR025  Undertake confined space rescue

HLTAID009 Provide cardio pulmonary resuscitation

CPPFES2005 Demonstrate first attack firefighting equipment

If your staff are not trained in the above, the procedure states “engaging a specialist rescue service if the confined space team does not have sufficient capability for a rescue”.

Note: Although emergency services can form part of overall incident preparedness plan, they are not to be relied upon as the sole form of emergency response / rescue.

8. Confined space entry permit – A responsible person must complete an entry permit and controls are confirmed….

MSMPER300  Issue work permits

 

Section 12.2 Training and competencies.  Confined space initial training –  states that all workers must have the unit of competency either NWP219A Work Safely in Confined Spaces or RIIWHS202D Enter and work in a confined space and CPR training.  RIIWHS202D is ONLY designed to provide sufficient training for participants to safely ENTER & WORK in a confined space through a thorough understanding of what support systems are supposed to be in place for them to do this.  In other words if they are not there, this person should then be questioning why, and not entering.  This person is not competent to gas test, but understands the basic use of a gas monitor, they cannot use breathing apparatus, they cannot enter a confined space to rescue, they do not have CPR (as required), so be aware this is a very general unit, and does not meet the spirit of many areas of WHSMS0068 on its own.

Disclaimer

So in summary the training we provide in confined space is:

 

Confined Space 1 Day ENTER & WORK for confined space workers, not standby people and not rescuers.  The training they receive and the units of competency issued reflect their level of training:

RIIWHS202D Enter and work in a confined space

MSMPER205  Enter confined space

MSMWHS201  Conduct hazard analysis

MSMPER200 Work in accordance with an issued permit

 

Confined Space 2 Day ENTER & WORK, GAS TEST & ISSUE PERMIT.  This training moves the one day course people on to day two where they cover gas testing atmospheres in a lot more detail, and complete training in administering and issuing work permits.  Their certificate of attainment will show.

RIIWHS202D Enter and work in a confined space

MSMPER205  Enter confined space

MSMWHS201  Conduct hazard analysis

MSMPER200 Work in accordance with an issued permit

MSMWHS217 Gas test atmospheres

CPPFES2005 Demonstrate first attack firefighting equipment

HLTAID009 Provide cardio pulmonary resuscitation

MSMPER300  Issue work permits

 

Confined Space 3 Day Standby / RESCUE course.  This course meets the spirit of WHSMS0068 in all areas other than first aid training.  We have been conducting this flagship course in Sydney now for ten years for predominately Sydney Water Contractors and other responsible organisations who understand the importance of having their staff fully trained to meet the requirements also of AS2865.

RIIWHS202D Enter and work in a confined space

MSMPER205  Enter confined space

MSMWHS201 Conduct hazard analysis

MSMPER200 Work in accordance with an issued permit

MSMPER202 Observe permit work

MSMWHS216 Operate breathing apparatus

MSMWHS217 Gas test atmospheres

HLTAID009 Provide cardio pulmonary resuscitation

CPPFES2005 Demonstrate first attack firefighting equipment

PUASAR025  Undertake confined space rescue

MSMPER300  Issue work permits

The person completing this three day course is competent to fill ALL ROLES in a confined space entry team.  Provided your policies, procedures and documentation are correct you have a work team that cannot be faulted when it comes to confined space compliance. 

Your only concern now is maintaining currency of training of your staff.  Now WHSMS0068 Section 12.2 Confined space refresher training clearly states if you are working on a Sydney Water site you need to have completed refresher training every 3 years.  But WHSMS0068 also states that all of your personnel need to be CPR qualified, and REFRESHER TRAINING for CPR is recommended to be done ANNUALLY.  So what do you do, you understand that WHSMS0068 is a Sydney Water Procedure, and not the law, so if anything was to go wrong during a confined space entry, you will not be judged on WHSMS0068, you will be judged on best practice.   That is why all of our major Sydney Water Contractors have their staff REFRESHER TRAINED ANNUALLY..  Please consider this as best practice.