• Section 1 - Key Information
• Section 2 - Purpose
• Section 3 - Scope
• Section 4 - Key Decisions
• Section 5 - Policy Statement
• Section 6 - Procedures
• Part A - Accountability and Responsibility
• Part B - Design, Manufacture, Supply and Modification
• Part C - Risk Assessment
• Part D - Contractor Management
• Part E - Training and Competency
• Part F - Confined Space Emergencies
• Part G - Atmospheric Testing and Monitoring
• Part H - Security and Sign Posting
• Part I - Permit to Work and Isolations
• Part J - Natural Confined Space
• Part K - Compliance and Assurance
• Section 7 - Definitions
• Section 8 - Authority and Associated Information

Section 1 - Key Information

Section 2 - Purpose

(1) This procedure documents how to comply with the Health and Safety Policy in regard to all work undertaken in a confined space to ensure it is appropriately administered and follows the health and safety regulatory requirements.

Section 3 - Scope

(2) This Procedure applies to:

1. all Confined Space (as defined below under the Victorian Occupational Health and Safety Regulations 2017) work undertaken by La Trobe University staff, and all contractors engaged directly or indirectly by the University.

Section 4 - Key Decisions

Section 5 - Policy Statement

(3) This procedure forms part of the Health and Safety Policy suite which governs its application.

Section 6 - Procedures

Part A - Accountability and Responsibility

(4) The Executive Director, Asset Transformation is responsible for ensuring: 

1. a safe system for entry and the conduct of tasks within Confined Spaces is established; and
2. the effective management of all activities associated with entry and exiting Confined Spaces.

(5) The Infrastructure and Operations Senior Leadership Team are responsible for ensuring:

1. all facilities under their control implement a safe system for entry, exit and the conduct of tasks within Confined Spaces; 
2. delegation of accountability for entry and activities conducted within Confined Spaces; 
3. assign appropriate permit authority for Confined Space works; and
4. the implementation of process to monitor, audit and review on the compliance with the safe system of Confined Space works.

(6) The Health and Safety (H&S) team is responsible for: 

1. periodically monitoring, reviewing and updating this Procedure. 
2. providing compliance advice and support on this Procedure.

(7) Persons in control of Confined Space work are responsible for ensuring: 

1. a risk assessment is completed and risks are adequately controlled prior to entering into Confined Spaces;
2. all persons associated with the work are advised and understand the contents of the risk assessment;
3. methods are implemented to prevent persons without Confined Space Permits from entering Confined Spaces;
4. the planning and return of Confined Space Permits and other required permits are properly coordinated; 
5. persons conducting confined space work  and relevant works (e.g. supervisor, standby person, emergency response team) are formally trained and assessed as competent; 
6. all records relating to entry, exit and activities conducted within Confined Spaces are accurately maintained and readily available; 
7. processes are in place to monitor the compliance with and effectiveness of the Confined Space system; 
8. atmospheric testing is carried out appropriately by a competent person prior to work commencing; 
9. team members associated with the confined space work are briefed on the risk and control measures and emergency procedures for the job.
10. emergency response procedures are established for Confined Space works;
11. emergency response procedures are carried out immediately after an emergency arises in Confined Spaces;
12. emergency response procedures are rehearsed by relevant persons having roles in Confined Space works.

(8) The Permit Authority’s role and responsibilities include:

1. Participate in the risk assessment process;
2. Review and confirm the adequacy of the requestor’s permit request;
3. Communicate with other work related areas for interface hazards;
4. Review and verify with the Permit Holder, the implementation of agreed controls;
5. Review and verify with the Permit Holder, the permit conditions and other associated controls;
6. Manage other Permit To Work (PTW) essentials, such as, suspension, handover and emergencies;
7. Verify that permitted work sites are safe at the time the permit is handed back at the end of the work and that the PTW is closed and cancelled as required.

(9) In accordance with Part D, the La Trobe University Manager who engages the contractor will be responsible for the following tasks associated with Confined Space work undertaken by contractors:

1. verify a risk assessment has been completed by the contractor with LTU consultation and the controls are implemented before confined space work begins.
2. where contractor Health and Safety management systems are used to control work in confined spaces, verify that they meet or exceed the minimum standards set by this Procedure.
3. ensure all potential energy sources associated with the confined space are isolated prior to entry.
4. identifying any simultaneous operations that may affect the confined space work and de-conflicting any overlaps.
5. consulting with contractors to establish emergency management planning.
6. auditing and reviewing confined space work undertaken by contractors to ensure controls are implemented and in-line with the risk assessment.
7. upon completion of the work, confirm all personnel have exited the confined space, confirm that the equipment is in a safe condition to be made available for service, and that all permits associated with the confined space work have been closed.

Part B - Design, Manufacture, Supply and Modification

(10) Where new facilities and plants have confined spaces incorporated the University will ensure that the design minimises the need for entry. Where confined space requires entry, consideration will be given during the design phase.

(11) This will be captured as part of the LTU safety in design processes for commissioning new plant and infrastructure and will ensure the design of confined spaces meet the minimum requirements set out in AS2865-2009.

(12) Any modification made to confined spaces by LTU, will not detrimentally effect the safe means of entry and exit or the conduct of other tasks. This will be captured as part of a risk assessment and design review initiated by LTU. 

Part C - Risk Assessment

(13) A risk assessment will be conducted by the persons undertaking the work before entering a Confined Space. The person controlling the confined space work will be responsible for leading the process and approving the risk assessment.  The assessment will be documented and will at a minimum, cover the following aspects:

1. the tasks to be conducted including the justification for the need to enter the Confined Space
2. The hazards and risks associated with the selected work methods, the nature of the Confined Space, foreseeable changes in oxygen levels or air contaminants, any work outside the Confined Space, entry and exit of the space. 
3. Emergency response procedures.
4. The competence of the persons conducting work associated with the Confined Space. 
5. The methods to control the identified risks.

(14) Whenever there is a change of conditions that may affect the risks associated with the confined space work, the risk assessment must be reviewed to adequately control the risks. Where the risks are unacceptably high as a result of changed conditions, work must be suspended until controls are implemented to reduce the risks to an acceptable level. 

(15) For further guidance and requirements of the LTU risk assessment process, refer to the Health and Safety Procedure - Hazard Identification, Risk Assessment and Control.

Part D - Contractor Management

(16) This section applies to confined space work undertaken by contractors on behalf of La Trobe University.

(17) Contractors may work under their own Health and Safety Management System processes for confined space work as agreed to under the arrangements with LTU. Where contractor systems are used, the system must at a minimum, meet the requirements and level of safety of this Procedure. This will be determined as part of the LTU pre-qualification process through RAPID Induct.

(18) Depending on any specific arrangements, contractors will typically be responsible for the following:

1. Conducting the confined space risk assessment in consultation with La Trobe University. 
2. Ensuring that all personnel are suitably trained and competent. 
3. Undertake atmospheric testing to establish required controls for entering a confined space in line with Part G of this document.
4. Establish and resource emergency management in line with Part F.
5. Control entry into confined spaces through a permit to work system in line with Part I.
6. Confirm isolation of all potential energy sources associated with the confined space in line with Part I.

(19) For further guidance and requirements of the LTU contractor management process, refer to the Health and Safety Procedure - OHS Contractor.

Part E - Training and Competency

(20) All persons with tasks associated with confined spaces will be trained and assessed as competent to conduct those tasks. Persons will be reassessed at appropriate intervals to maintain their competency. This training will be recorded in the appropriate system at LTU:

1. Contractors – Training will be verified upon issue of a confined space permit by the permit issuer (either LTU or contractor permit issuer).
2. LTU Employees – These must be recorded in the area database for staff competencies and verified upon issue of the permit.

(21) All personnel associated with confined space work will be required to have successfully completed the relevant national unit of competency via statement of attainment for enter and work in Confined Spaces. 

(22) In addition to the national units of competency, adequate instruction and training must be provided to persons in:

1. hazards of the Confined Space;
2. appropriate use of control measures;
3. the selection, use, fit, testing and storage of any use of personal protective equipment;
4. the content of confined space permit;
5. emergency procedures.

Part F - Confined Space Emergencies

(23) Emergency response procedures must be developed, rehearsed and implemented for all confined space work. The emergency response procedures will include the procedures for:

1. the rescue of any person from the Confined Space, and 
2. first aid to be provided to any person in the Confined Space and after rescue from the Confined Space.

(24) An emergency response team, including standby person, is to be in place and on hand for the duration of work while people are occupying a confined space. The emergency response team must be involved in the planning of confined space work.  The emergency response team must be properly trained and assessed to be competent to conduct the emergency response activities in the Confined Space.  

(25) The emergency response procedures will vary depending on the circumstances, however the procedures must consist of the following minimum elements:

1. an effective method of communication to raise the alarm in the event of an emergency e.g. radio or telephone;
2. identification of first aid personnel and provisions to be on hand for the work;
3. how emergency vehicles and the emergency response team will access the Confined Space;
4. how any casualties will be extracted from the confined space;
5. a list of equipment necessary to perform the rescue;
6. the proof that the relevant people (i.e. response team, people entering the Confined Space, standby people, supervisors) have rehearsed and understood the emergency plan. 

Part G - Atmospheric Testing and Monitoring

(26) The atmosphere within all Confined Spaces, must be tested and assessed prior to work commencing.  Testing must be carried out by a suitably qualified or competent person, using an appropriate and correctly calibrated gas detector.  When planning for entering a Confined Space, persons conducting the risk assessment will determine the risks associated with undertaking atmospheric testing and plan accordingly. 

(27) The atmospheric testing required in Confined Spaces will depend on the nature of the Confined Space and the work conducted in and around the Confined Space. Factors to be considered will include:

1. whether ongoing monitoring is required, and/or
2. testing of remote areas of the Confined Space is required 

(28) No person will enter a Confined Space to conduct atmospheric testing or monitoring without a permit to work and the permit will include any risk control measures necessary for undertaking the atmospheric testing including entry into the Confined Space where required. The results of any atmospheric testing, will be recorded on the Confined Space permit.

(29) Atmospheric testing will include testing by scientific means for:

1. oxygen concentration;
2. concentration of flammable airborne contaminants; and
3. concentration of airborne contaminants.

(30) Persons will only enter a Confined Space if the Confined Space is maintained to have the following conditions:

1. the oxygen concentration of the atmosphere is equal or to greater than 19.5% but equal to or less than 23.5%;
2. the flammable airborne contaminants are lower than 5% LEL (lower explosive limit);
3. airborne contaminants are below the exposure standard.

(31) If there is a likelihood of fire or explosion in a Confined Space, no source of ignition is introduced to the space.

(32) Where there is no exposure standard for any hazardous substances that will be encountered in Confined Space work, guidance will be obtained by a hygienist or other competent person on the required controls.

Part H - Security and Sign Posting

(33) Confined spaces will at all times be secured against unauthorised access. Sign posting should be permanently installed where a Confined Space is likely to be entered and where a risk assessment deems it necessary. 

(34) Where entry and exit to a Confined Space is required, signs and protective barriers will be erected to prevent entry of persons not involved in the tasks prior to anyone entering. This must be planned in advance to ensure the correct equipment is available. Signage will comply with AS1319-1994. 

(35) In addition to the abovementioned, the sign must:

1. identify the Confined Space;
2. notify that people must not enter the Confined Space without a Confined Space entry permit;
3. be clear and prominently positioned for any period that there is work related to Confined Space.

Part I - Permit to Work and Isolations

(36) One permit can only apply to one Confined Space.  A permit must be issued before any person enters a Confined Space. The permit to work template used by La Trobe for Confined Spaces can be found in T370-Permit to Work in Confined Spaces (available upon request from Infrastructure and Operations), however, where approved, contractors can use their own permit to work systems to manage confined space work at LTU.

(37) The permit will be issued by a person separate to the permit holder as a third-party check.   The permit holder must be the person responsible for direct control of the tasks in the confined space and by accepting and signing onto the permit, will provide their written authority for persons to enter.  

(38) The permit will be displayed in a prominent place adjacent to the confined space entry to facilitate: 

1. signing on for entrants, 
2. clearance that the space is safe to enter and all persons associated with the work have read and understood the risk, and 
3. to validate authorization and the controls for auditing and assurance.
4. The party issuing the permit (contractor or LTU) must retain a copy of the permit for a minimum of 30 days from the date the permit is closed.  If a notifiable incident occurs in connection with the work to which the permit relates, the permit must be kept for at least 2 years after the date when the incident occurs.

(39) A record sheet controlling the entry and exit of persons must be maintained (a sample can be found in T370-Permit to Work in Confined Spaces). 

(40) Before any person enters a Confined Space, all hazardous services connected to the confined space must be isolated. This includes any services that could introduce: 

1. any materials, contaminants, agents or conditions harmful to persons occupying the confined space; and 
2. the activation or energising in any way of equipment or services that could pose a risk to the health or safety of persons within the confined space.

(41) For confined spaces managed by contractors, an isolation plan must be submitted to LTU for approval prior to any person entering a confined space. This must be a documented approval process and records of this are to be retained by LTU and the contractor. 

(42) Isolations will only be removed and the permit will only be cancelled, after the permit holder has advised in writing that all tasks have ceased and all persons have vacated the Confined Space.

Part J - Natural Confined Space

(43) For works in natural Confined Spaces (e.g. caves), additional requirements are to be in place.

(44) Additional to the requirements in part C, the risk assessment for work in a natural Confined Space must consider additional hazards and risks arising from:

1. Fauna and flora of that confined space area and surrounding areas;
2. Distribution of other biological hazards (e.g. virus, bacteria, fungus);
3. Recent and forecasted weather conditions (e.g. rain, flood);
4. Nature of surrounding areas that can increase the risk on entry, exit and work in the natural Confined Space;
5. Physical abilities, skills, fitness level of persons entering the natural Confined Space;
6. Likelihood to get lost inside the space;
7. Likelihood to be stuck in the space (e.g. inside hole, trench, at height);
8. Factors that may hinder the emergency procedure.

(45) Person(s) who prepare risk assessments must take reasonably practicable steps to gather information about factors that can introduce or impact hazards and risks in the natural Confined Space.

(46) Additional to requirements in part G, initial atmospheric test should be done remotely from outside the natural confined space as far as is reasonably practicable.

(47) If it is necessary to enter the space to conduct initial atmospheric test, air-supplies respiratory equipment should be used by person conducting the test. The entry must only be undertaken after ensuring appropriate methods in place to control identified risks. 

(48) After entering the natural confined space, continuous atmospheric monitoring must be carried out by at least one competent person for each work group.

(49) A reasonable number of people for each work group must be agreed on before work commences. A person must not enter the natural Confined Space alone.

(50) Each work group must have at least one person with competency in providing first aid.

(51) Standby person(s) to be outside of the natural confined space and maintain continuous communication with people inside the space until work is completed and all people have exited the space.

(52) Throughout the work, all people are responsible to make continuous assessment on whether they are able to continue or need to exit the natural confined space. 

(53) Before commencing work in natural confined spaces, person managing the work must notify their responsible manager about the plan of the work (e.g. time, location, expected duration).

Part K - Compliance and Assurance

(54) Compliance with the requirements established in this procedure must be reviewed as part of the LTU Assurance Plan and internal audit schedule, and included in the H&S management system audit cycle.

(55) Monitoring and verification of the key requirements of this procedure must also be included in the areas key performance indicator reporting requirements.

(56) Annual reviews will be undertaken on this procedure by the Health and Safety Team and must include:

1. changes in legislation, industry best practice and Australian Standards
2. changes in the organisational structure
3. approved variations of Confined Space procedures
4. changes in available or applied technology
5. changes in processes, equipment and facilities
6. lessons learned from Confined Space incidents
7. continuous improvement recommendations
8. audit results
9. Key Performance Indicator (KPI) outcomes.

(57) The process of continuous improvement must include:

1. collecting feedback from persons in the workplace and in relation to specific activities
2. identifying improvement opportunities in the management of Confined Space activities
3. conducting system audits and Confined Space activity inspections
4. conducting quality investigations to determine the correct root causes of any incidents and their relevance to Confined Space activities
5. developing and implementing corrective actions to control identified root causes of any Confined Space incidents
6. documenting any changes in procedures that result from the continuous improvement process.

Section 7 - Definitions

(58) For the purpose of this Procedure:

1. Competent person: A person who has acquired through training, qualification or experience the knowledge and skills to carry out the task.
2. Confined Space: A space in any vat, tank, pit, pipe, duct, flue, oven, chimney, silo, reaction vessel, container, receptacle, underground sewer or well, or any shaft, trench or tunnel or other similar enclosed or partially enclosed structure, if the space:
   1. is, or is intended to be, or is likely to be, entered by any person; and
   2. has a limited or restricted means for entry or exit that makes it physically difficult for a person to enter or exit the space; and
   3. is, or is intended to be, at normal atmospheric pressure while any person is in the space; and
   4. contains, is intended to contain, or is likely to contain:
      1. an atmosphere that has a harmful level of any contaminant; or
      2. an atmosphere that does not have a safe oxygen level; or
      3. any stored substance, except liquids, that could cause engulfment.
   5. This definition does not include a shaft, trench or tunnel that is a mine or is part of the workings of a mine.
3. Natural Confined Space: An enclosed or partially enclosed space that is not mainly formed by human activities.
4. Permit Authority: A competent person who directs and supervises the work and has been nominated and authorized to complete the permit on behalf of the business or undertaking. List of LTU Permit Authority is available in R006 – IO Permit Authority .
5. Superintendent: A person who is responsible for engaging contractor to do tasks at the university (e.g., project manager, director).

Section 8 - Authority and Associated Information

(59) This Policy is made under the La Trobe University Act 2009.