HSP0001 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.

Below is our attempt to summarise HSP0001 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 HSP 0001.  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.

HSP0001 Confined Space Procedure

1.3 Summary states:

  • People planning confined space work must consult people that it will affect.
  • Responsible managers of assets must ensure confined spaces under their control are identified. Asset designers must identify confined spaces at the design stage.
  • All people involved must identify confined space hazards.
  • Responsible managers of confined space work (CSW) must ensure competent peopleassess risks, and try to eliminate entry through new work methods or technology.
  • Asset designers must determine if entry can be eliminated through design.
  • If entry is unavoidable, controls must be applied, such as:

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

Ventilation, and air quality testing and monitoring of the confined space.

Enough standby person(s) to assist and maintain continuous contact with the people inside and                           the responsible person for entry.

Protective barriers and signs to prevent unauthorised entry.

A task specific emergency response plan (ERP) established and rehearsed.

A written entry permit approved by the responsible person for entry.

  •  People must be trained to do their relevant confined space tasks.
  •  Risk control procedures and emergency response plans must be documented and communicated to people that they affect.
  • There must be inspection, testing and monitoring (ITM) of confined space items relating to the worksite, work methods, plant and equipment, and people’s health.
  • Incidents and non-conformances must be reported and addressed by corrective action.
  • Relevant confined space records must be kept.

All people involved must identify confined space hazards. To meet this requirement Sydney Safety Training include in their ONE DAY ENTER AND WORK course a unit of competency called RIIRIS201B Conduct local risk.  This unit runs participants through the various ways to assess risk, including Standback Take 5s for repetitive daily minor tasks, workplace risk assessments which cover general areas of risk in any workplace, be it an office or production floor and finally the formal task specific risk assessment (confined space risk assessment) which is fully documented and required by law.

Responsible managers of confined space work (CSW) must ensure competent people assess risks.  See above.

Ventilation, and air quality testing and monitoring of the confined space.   A very basic understanding of gas testing and ventilation is provided during the ONE DAY ENTER & WORK course under the competency RIIWHS202D Enter & Work in confined spaces.  This unit is more a general awareness training than full competency based training.  Further into the HSP0001 Section 2.5.5 outlines the needs of the standby person in regards to gas testing.  To meet this section we have a national unit of competency “MSAMPER 217A Gas Test Atmospheres”  in our TWO DAY GAS TEST ATMOSPHERES & STANBBY course.  In this course participants are made thoroughly competent in the operation and reading of a four gas monitor and therefore receive the unit of competency MSAPMOHS217A Gas test atmospheres.  Gas is a major concern in Sydney Water confined spaces with Methane (CH4) and Hydrogen Sulphide (H2S) being the main issues.  This unit also meets the intention regarding Specialist Gas Tester delegation to other competent gas testers – see bottom of page 11 of 33.

 

A task specific emergency response plan (ERP) established and rehearsed.   Each and every contractor must have & rehearsed a confined space rescue plan.   Refer Section 2.5.10 Emergency Response Plan (ERP).  If your staff are not properly trained for rescue, you are required to engage a specialist rescue service (not 000) to fulfill this role.  So in this case participants should complete the Sydney Safety Training 3 DAY CONFINED SPACE RESCUE course.  This training provides participants with additional units of competency to provide your workers with the full ability to rescue.  They are MSAPMOHS 216A Operate Breathing Apparatus, CPPFES2005A Demonstrate first attack fire fighting equipment, HLTAID001 Provide cardiopulmonary resuscitation & PUASAR025A Undertake confined space rescue.  All our major Sydney Water Contractor clients have their staff trained in the 3 DAY CONFINED SPACE RESCUE course, as that then covers all aspects of HSP0001, and they should not then be found wanting in their training needs.

 

Refer 2.5.10 Rescue Equipment is also included in the 3 Day Confined Space Rescue Course.

2.5.10 & 2.7.5 First Aid & cardio pulmonary resuscitation (CPR) state that you MUST have all people in the confined space team CPR qualified ( Sydney Safety Training 3 Day Confined Space Course).  Remember though that your standby and rescue staff also need a current first aide certificate to meet this section of the procedure.

 

Section 2.5.11 Entry Permits – requires a responsible person for entry to fill out and sign an entry permit before entry is allowed.  It also requires that responsible person for entry to complete and sign the permit before the confined space is returned to service.  Sydney Safety 2 Day Confined Space Course GAS TEST & STANDBY cover you off here, as participants receive the unit of competency MSAPMPER202A Observe Permit Work which provides training in administering and signing off a permit (Standby responsibility).

 

Section 2.7.1  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.  We provide the RII accreditation as a part of our Confined Space 1 Day ENTER & WORK course.  Be aware this unit 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 HSP0001 on its own.

 

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

RIIRIS201B Conduct local risk

MSAPMPER200C 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

RIIRIS201B Conduct local risk

MSAPMPER200C Work in accordance with an issued permit

MSAPMOHS217A Gas test atmospheres

CPPFES2005A Demonstrate first attack firefighting equipment

MSAPMPER300C  Issue work permits

 

Confined Space 3 Day Standby / RESCUE course.  This course meets the spirit of HSP0001 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

RIIRIS201B Conduct local risk

MSAPMPER200C Work in accordance with an issued permit

MSAPMPER202A Observe permit work

MSAPMOHS216A Operate breathing apparatus &

MSAPMOHS217A Gas test atmospheres

HLTAID001 Provide cardio pulmonary resuscitation

CPPFES2005A Demonstrate first attack firefighting equipment

PUASAR025A  Undertake confined space rescue

MSAPMPER300C  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 HSP0001 Section 2.7.2 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 HSP0001 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 HSP0001 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 HSP0001, 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.