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International Journal of Mechanical Engineering and Technology (IJMET) Volume 8, Issue 11, November 2017, pp. 423–448, Article ID: IJMET_08_11_047

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A REVIEW ON GUIDELINES RELATED TO THE RISK ASSESSMENT OF A CONFINED SPACE

Zamree Amin, Roslina Mohammad, Norazli Othman, Astuty Amrin, Shreeshivadasan

Chelliapan, Saárdin Abdul Aziz

Department of Engineering UTM Razak School of Engineering and Advanced Technology,

Universiti Teknologi Malaysia, Jalan Sultan Yahya Petra, Kuala Lumpur, 54100, Malaysia

Nurazean Maarop

Advanced Informatics School (AIS), Universiti Teknologi Malaysia,

Jalan Sultan Yahya Petra, Kuala Lumpur, 54100, Malaysia

ABSTRACT

The aim of this paper is to identify, review, and compare seven Guidelines, mainly

focusing on risk assessment elements related to confined space activities. This is due

to the lack of a specific approach regarding Guidelines for confined spaces such as

entry procedure requirements, risk assessment methods, rather general existing risk

assessment practices, and additional references that are required for conducting risk

assessments, which could lead to industry non-compliance. The selected Guidelines

are summarized in terms of requirements, followed by a review of Guideline

contribution factors towards: (i) practical application; (ii) enhancing a safe system of

work; and (iii) suitability as elements of risk assessment. The final section presents a

brief comparative study of the Guidelines. The results from the study contribute

towards the formulation of an ideal method to develop effective risk assessment tools

for working safely in confined spaces. Furthermore, several literatures have been

referred to provide additional input for developing these risk assessment tools.

Keywords: Guideline Requirements, Risk Assessment, Confined Space, Guideline

Comparison

Cite this Article: Zamree Amin, Roslina Mohammad, Norazli Othman, Astuty

Amrin, Shreeshivadasan Chelliapan, Saárdin Abdul Aziz and Nurazean Maarop, A

Review on Guidelines Related to the Risk Assessment Of A Confined Space,

International Journal of Mechanical Engineering and Technology 8(11), 2017,

pp. 423–448.

http://www.iaeme.com/IJMET/issues.asp?JType=IJMET&VType=8&IType=11

Zamree Amin, Roslina Mohammad, Norazli Othman, Astuty Amrin, Shreeshivadasan Chelliapan,

Saárdin Abdul Aziz and Nurazean Maarop


1. INTRODUCTION

Every task that is carried out in an organization requires specific safety and health guidelines

to ensure any risk involved in the work is controlled and the safety, health, and welfare of

workers are taken care of. This includes working in confined spaces, which requires special

attention prior to the work starting such as applications of Permit to Work systems and

Atmospheric Gas Testing. On top of that, management participation is also a key requirement

to ensuring the safety of the entrant during occupancy. This is done by ensuring the

procedures are adhered to according to an established safe work system. By definition, a

confined space is an enclosed or partially enclosed space at atmospheric pressure during

occupancy and not intended or designed primarily as a place of work. It is liable at any time to

have an atmosphere, which contains potentially harmful levels of contaminants, an oxygen

deficiency or excess, and cause engulfment and restricted means of entry and exit. Examples

of confined spaces are storage tanks, tankers, boilers, silos, pipes, sewers, tunnels, shafts, and

ducts. The definition of risk assessment can be described as a process of evaluating the risks

to safety and health arising from hazards at work [1].

The review of seven Guidelines carried out in this study applies to the United Kingdom,

the United States of America, and Malaysia. The Guidelines are taken from the UK Ministry

of Defense Health and Safety Handbook: Safe Working in Confined Space UK [2], HSE UK-

Confined Space: A brief Guide to Working Safely, British Compressed Gas Association: The

Application of the Confined Spaces Regulations to the Drinks Dispense Industry [3], US

ASHRAE Guideline: Guideline for the Risk Management of Public Health and Safety in

Buildings [4], Malaysia Industrial Code Of Practice 2010: Safe Working in Confined Space

[5], Malaysia Guidelines for Hazard Identification, Risk Assessment, and Risk Control [6],

and Malaysia Guidelines on the Occupational Safety and Health Management System [7]. The

selection of Guidelines is observed through the main elements presented-whether or not these

are able to assist in the development of an effective risk assessment tool for a confined space.

In addition, the risk assessment tools used in confined space risk assessment require further

enhancement due to the lack of a specific approach for confined space work such as entry

procedure requirements, risk assessment methods, rather general existing risk assessment

practices, and additional references that are required for conducting risk assessments, could

lead to poor response from industries. Therefore, this paper aims to identify, review, and carry

out a comparison of seven Guidelines where the main focus is on risk assessment elements

related to confined space activities. The outcome of the study will be used to contribute

towards developing effective risk assessment tools for working safely in a confined space.

In this study, several literatures are referred to in regard to the review of Guidelines, risk

assessment, and safe confined space entry. In designing an effective risk assessment tool for

confined space entries, Vienney [8] stated that the Guidelines used are an important input

during the tool development process. For example, the risk estimation process involve various

work conditions such as usage of machines, building constructions, and oil and gas

operations. For building construction risk assessment, Aneziris [9] proposed a risk assessment

based on the Occupational Risk Model for quantifying occupational risk in order to mitigate

risk more effectively prior to confined space entry. In the oil and gas industry, Aneziris [10]

presented an integrated risk assessment framework for Liquefied Natural Gas terminals,

which could be useful for enhancing existing safe systems of work being practiced. The above

study on risk assessment aims to clearly demonstrate the importance of industrial Guidelines

as reference documents during the risk estimating process, mainly for works related to

confined space entry.

The selected Guidelines focus on the risk assessment concept where their entire content

will be reviewed in order to ascertain input relevancy for the risk assessment of a confined

A Review on Guidelines Related to the Risk Assessment of A Confined Space


space. The list of Guidelines in Table 1 outlines the objectives and application, similarity,

difference, and significance of the Guideline content.

Based on the summary of content listed in Table 1, the Guideline requirements are

identified. A review of each Guideline with respect to risk assessment elements of a confined

space is then conducted. The review of Guidelines is based on the current industrial practice.

It will provide an overall conclusion to the suitability and practicability of each Guideline

towards enhancing health and safety standards for confined space work.

2. GUIDELINES

The summarized Guidelines are further elaborated in regard to their requirements, and their

contributing factors towards confined space risk assessment described in the next section.

Table 1 Summary of the Seven Guidelines

GUIDELINE OBJECTIVE & APPLICATION

SIMILARITY DIFFERENCE SIGNIFICA

NCE

MoD UK

(Ministry of

Defense,

United

Kingdom)

Applicable for all MoD

UK facilities either in the

United Kingdom or

abroad. The Guidelines

are not applicable for

shipboard activities,

mining operations, diving

operations, confined

space containing

petroleum products, and

any task involving works

at height.

Introduction None None

Roles and duties,

general

arrangements,

management

arrangements,

confined space

entry procedure,

training, health

requirements, and

example of forms

& signage.

Confined

space entry

procedure.

HSE UK

(Health and

Safety

Executive,

United

Kingdom)

The Guidelines are

purposely formulated for

industries in the United

Kingdom. It is also used

to comply with Confined

Space Regulations 1997.

Introduction None None

Type of confined

space, dangers of

confined space,

related laws, avoid

entering confined

space, safe system

of works,

emergency

procedures, and

capability of

rescuers.

Safe system

of work,

emergency

procedures.

BCGA UK

(British

Compressed

Gas

Association,

United

Kingdom)

To establish a common

standard for working in a

confined space in the

drink dispenser industry

and is applicable for all

businesses involved in

the use of drink dispenser

gases as well as gas

suppliers.

Introduction Scope None

Key properties of

gases used for

drink dispensers,

related confined

space regulation,

assessment of risk,

actions resulting

from assessment,

competence &

training, and

Personal

Protective

Equipment.

Assessment

of risk,

actions

resulting from

assessment.

ASHRAE US To provide guidance for None Scope Purpose, Risk management Risk




GUIDELINE OBJECTIVE & APPLICATION

SIMILARITY DIFFERENCE SIGNIFICA

NCE

(American

Society of

Heating,

Refrigerating

and Air-

conditioning

Engineer,

United States)

the practical evaluation,

design, and

implementation of

measures to reduce

multiple risks in new and

existing buildings. To

address the aspect of

building performance

that affect occupant

health and safety.

definition approach, design

for new and

existing facilities,

and operation &

maintenance of

buildings.

management

approach,

example

methods for

assessing risk.

HIRARC MY

(Hazard

Identification,

Risk

Assessment,

Risk Control,

Malaysia)

Provides a systematic

and objective approach

for assessing hazards and

their associated risks;

provides an objective

measure of the hazard

being identified and

followed with risk

control measures. It is

applicable for all types of

industries in Malaysia.

None None Purpose,

definition

Basic concept,

planning &

implementing of

HIRARC,

documenting

HIRARC,

consultation and

training.

Concept for

conducting

HIRARC.

OSHMS MY

(Occupational

Safety and

Health

Management

System,

Malaysia)

To provide guidance for

any organization or

industry in Malaysia on

the implementation of

MS 1722: 2011

None Scope Purpose,

definition

The OSHMS in

the organization.

Description of

OSH

management

elements in

an

organization.

ICOP MY

(Industrial

Code of

Practice,

Malaysia)

To provide guidance for

industries involved in

confined space entry to

prevent exposure to

hazards and thereby

prevent collapse, injury,

illness or death arising

from exposure to these

hazards. Not applicable

to underground mining

works and spaces in other

than atmospheric

pressure.

None None None

Preliminary,

confined space

entry program,

detailed

requirements, and

duties of the

responsible

person.

Confined

space entry

program and

detailed

requirements.



2.1. UK Ministry of Defense Health and Safety Handbook: Safe Working in

Confined Space

The Legislation requirements for MoD UK is outlined in Table 2:

Table 2 Guideline Requirements for MoD UK

NO. REQUIREMENTS CONTRIBUTING FACTORS

CONCEPT SUITABILITY RELEVANCE

1 Roles and duties

Summarizes the roles

and duties of the

Authorizing Engineer,

Authorized Person,

Person in Charge, and

Work Team.

The role of each

personnel in a confined

space that are outlined

could be used as a

reference and guideline

for appointing key

personnel for confined

spaces.

This is part of risk control

measures and is much

related to the risk

assessment process for

confined spaces the

consideration of its

requirements for the process

of developing risk

assessment tools.

2 General

Arrangements

Describes the nature of

the confined space,

initial classification to

define features of the

confined space,

categorization of

confined space, and

safe work procedures.

The brief description of

the confined space is

suitable for the

management to plan for

confined space

occupancy by

considering the

prevention of risk to be

faced.

The description of confined

space is relevant because the

hazards generated by the

confined space depend on

the physicality and type of

work to be carried out in

order to conduct an effective

risk assessment process.

3 Management

arrangements

Lists the arrangement

by management for a

confined space

document center,

confined space register,

confined space

schedule, confined

space records,

equipment register, key

register, management

of remote sites, safety

signs, and safety rule

books.

The approach to manage

documentation and

records for confined

space can be used as

reference to ensure the

data is traceable if any

changes were made.

The effectiveness in

managing documentation is

not much related to the

process of risk assessment

but it still contributes in

terms of revision history of

records.

4 Operational

procedures

Explains the

requirements to adhere

to prior to entry such as

risk assessment, level

of control, safety

program, Permit to

Work, and procedure to

entry.

It is highly suited as a

reference for key

elements prior to

confined space entry,

especially in determining

the level of control of an

Authorized person for

the confined space and

procedure for

management for entry

into a confined space.

The requirements that are

described are related to the

process of risk assessment

for confined spaces through

the provision of several

sample forms and the risk

likelihood, severity, and risk

action table.

5 Training

Provides requirements

for training for the

Authorized Engineer,

The training

requirements for related


The training requirements,

part of which are under

administrative control, is






Authorized Person,

Person in charge, and

Work team.

space is compulsory and

the example list of

training standards is

could be referred to as a

basic guideline.

relevant as an input for the

risk assessment process for

a confined space.

6 Health requirements

Describes the fitness

level of employees,

correct method of

wearing PPE, and viral

infections.

These are suitable

requirements to be

referred to by employers

to ensure all workers

involved in hazardous

atmospheres are healthy

and free from infected

diseases.

The health requirements is

an important part to include

in risk assessment for a

confined space, especially

when exposed to a toxic

atmosphere and viruses.

2.1.1. A Review of MoD UK

This review on the Ministry of Defense Health and Safety Handbook: Safe Working in

Confined Space, United Kingdom (MoD UK), is in accordance with the identified

requirements that are outlined in Table 2, where the review approach is based on the most

practical implementation relevant to the process of risk assessment for a confined space.

The requirements of MoD UK are reviewed in terms of roles and responsibilities, general

arrangements, management arrangements, operational procedures, and training and health

requirements. The roles and responsibilities of each key personnel involved in confined space

entry have been clearly defined to secure the safety and health of all workers throughout the

entry period. Examples of key personnel for confined spaces are the Entry Supervisor,

Authorized Gas Tester, Standby Person, and Authorized Entrant. The initial arrangement

made by the employer is to provide information to workers on the danger, type, characteristic

of confined space, and relevant safe work procedures that must be complied with prior to

occupancy. Besides that, all documentation related to confined space must be documented for

easy reference and tracking purposes. Examples of confined space documents are Permit to

Work, Safe Work Procedure, and equipment register. During confined space entry, all

workers are briefed about the safety rules that they must comply with such as risk assessment,

the Permit to Work system, procedure for entry, and emergency response. For training

requirements, all workers are required to attend awareness training conducted by the employer

to ensure that they acquire the skill, knowledge, and competency to work in a confined space.

Workers who intend to enter a confined space are required to undergo medical check-up by a

certified occupational doctor. Only fit workers that are free from viral infections are allowed

to work in a confined space. Apart from all these requirements, the quality of risk assessment

that is carried out also plays a major role in controlling risks and preventing accidents. In light

of this, a study conducted by Pinto [11] surveyed and ensured the quality of occupational

safety risk assessment (OSRA) by examining the current occupational safety risk assessment

method in order to improve its quality and relevance to the task being assessed.

The outcome of the results showed that most safety experts agreed on the proposed OSRA

process, including giving positive feedback from Questionnaires, which can be used as the

basis for researchers to evaluate the quality of OSRA in future studies. This is relevant to the

process of risk assessment for a confined space. The enhancement of the quality of risk

assessment would contribute to an effective safety program and efficient use of resources. In

the next section, the MoD UK requirements are further reviewed based on three factors that

contribute to the process of risk assessment for a confined space, as follows:



a. Practical application for confined space safety activities

At MoD UK, there is a wealth of useful information that could be utilized as valuable

references. It is also possible to apply the information provided in daily confined space safety

activities. The requirements that could directly be applied to confined space safety activities

are the roles and responsibilities of the Authorizing Engineer, Authorized Person, Person in

Charge, and Work Team. The method of application could be done by conducting regular

safety briefings with all personnel. In addition, the responsibilities of each personnel should

be attached to the Permit to Work document. In the safety program requirements, several

approaches that could be applied are the servicing of equipment’s, isolation from gases and

electrical equipment, wearing Personal Protective Equipment, ensuring sufficient ventilation,

conducting the process of cleaning and purging, and communication amongst the work team.

In addition, Permit to Work is also applicable for implementation in confined spaces,

followed by conducting regular training for all confined space personnel. Besides that, all

entrants are required to regularly check on their health condition prior to occupancy.

b. Opportunity to enhance the safe system of work for confined spaces

The requirements that could enhance the safe system of work include establishing a procedure

regarding the roles and duties of key personnel for confined spaces such as the Authorizing

Engineer, Authorized Person, Person in Charge, and Work Team. In the beginning, prior to

occupancy, it is practical to include the definition of the features and categorization of

confined space in the confined space procedure. This is then followed with the confined space

register, confined space schedule, and equipment register, which would be used for tracking

purposes in case any issues related to confined space arise. Furthermore, the safety rule

handbook could also be relevant to enhancing the safe system of work for a confined space. In

the entry procedure that is outlined, it is relevant to include all elements to enhance the safe

system of work. As an example, in determining the level of control for an Authorized Person

of the Confined space, the flowchart provided would be beneficial for reference, as a

precaution prior to confined space entry. The procedure for entry under Permit to Work

should be provided with a flowchart to ensure all work teams understand the process of entry.

In addition, the training procedures that are outlined are a useful guidance, including the list

of training plans to be conducted. Lastly, the emergency and rescue procedure is also key

towards enhancing the safe work system for a confined space.

c. Suitability for inclusion in the elements of risk assessment

The elements of risk assessment that could be included are the assigning of roles and duties of

confined space key personnel such as the Authorizing Engineer, Authorized Person, Person in

Charge, and Work Team. All relevant personnel must be briefed about the confined space to

be entered, effectiveness, and practicality of risk assessment (a sample of likelihood table,

severity table, and risk action table should be provided), requirements for isolation from

electricity or any other potential sources, criteria in selecting Personal Protective Equipment,

suitability of ventilation, purging and cleaning method, communication method, emergency

response readiness and effectiveness, approval and validity of Permit to Work, and provision

for the health declaration of all workers.

From the review, it can be concluded that the MoD UK requirements contribute towards

the process of risk assessment even though some of the requirements do not directly mention

confined space risk assessment. However, examples of forms provided such as Confined

Space Schedule, Confined Space Operation Record, Confined Space Safety Sign, Confined

Space Risk Assessment, Safety Program, and Permit to Work are useful for reference and as

additional input for improving the process of risk assessment for a confined space.




2.2 Health and Safety Executive UK: Confined Spaces: A Brief Guide to Working

Safely

The Guideline requirements for HSE UK are outlined in Table 3:

Table 3 Guideline Requirements for HSE UK

NO. REQUIREM

ENTS

CONTRIBUTING FACTORS


1

What is

confined

space

Defines confined space, and

type and categories of

confined space.

The definition of confined

space provides useful

knowledge and information

for industries when

identifying a hazardous

workplace.

Different types of confined

spaces contribute to

different types of hazards.

This is important

information that must be

collected while conducting

the risk assessment

process.

2

What are the

dangers of

confined

space

Lists the dangers of a

confined space, which arise

from the hazardous

atmosphere and

occupational hazards.

The list of dangers could be

used by industries as a

useful guideline prior to

confined space entry.

A basic input regarding the

dangers arising from

confined spaces is very

much related to the

development process of

confined space risk

assessment tools.

3 What the law

says

Risk assessment

requirements by Health and

Safety at Work Regulations

1999

The general arrangement of

risk assessment and the

proposal on the preventive

measures for working in a

confined space is useful as a

reference prior to entering a

confined space.

The input from the laws

about confined space risk

assessment is relevant to

the process of risk

assessment for confined

space work.

4

Avoid

entering

confined

space

Proposes alternative ways to

carry out works in a

confined space such as using

robotic methods or special

devices.

The consideration in

deciding whether or not it

entering a confined space is

required is a useful guide for

employers to minimize the

risk to their workers.

The decision making for

confined space entry

determination is relevant

as an input in the risk

assessment process for a

confined space.

5 Safe system

of work

Describes a safe system of

work such as appointment of

Supervisor, selection of

workers, Permit to Work,

testing of atmosphere,

breathing apparatus,

communication, and

emergency response.

The elements of a safe

system of work are useful to

practice at the workplace to

ensure all persons involved

in confined space works are

protected from accidents.

The contribution input

from the safe system of

work is very much related

to confined space risk

assessment tools to be

developed due to the

critical information

obtained.

6 Emergency

procedures

Sets out the requirements

during emergency situations

such as Emergency response

& preparedness, rescue

team, and rescue

equipment’s.

Emergency response and

preparedness is part of the

important criteria to be

practiced prior to confined

space entry for which

employers should make this

information a priority.

The emergency procedure

is much related to risk

assessment activities for

confined spaces and the

input of each element

would contribute towards

minimizing risk during

emergency situations.



NO. REQUIREM

ENTS



7 Capabilities

of rescuers

Sets out the requirements for

the Rescue team

competency and ability to

respond effectively during

emergency.

The requirements outline the

responsibilities of

employers to provide a

required competency for the

rescue team as well as fire

drill exercises.

The competency of the

rescue team will be part of

the elements in the risk

assessment checklist to

identify the risk level

during occupancy in case

of any emergency.

8 The law

Confined Space Regulations

1997, The Provision and use

of Work Equipment

Regulations 1998

(PUWER), Workplace

(Health, Safety and Welfare)

Regulations 1992, The

Personal Protective

Equipment Regulations

2002

The list of laws is useful as

further information to

improve the safe work

system that is implemented.

The additional information

on the law contributes as

additional input towards

developing confined space

risk assessment tools.

2.2.1. A Review of HSE UK

This review on the Health and Safety Executive-Confined Space: A brief Guide to working

Safely (HSE UK) is performed according to the identified requirements outlined in Table 3,

where the review approach is based on the most practical implementation relevant to the

process of risk assessment for a confined space.

The review on HSE UK requirements targets confined space definition, dangers from

confined space, relevant laws, option for working in a confined space, safe system of work,

emergency procedures, and capabilities of rescuers. The definition of confined space is a basic

requirement that must be provided as information for all confined space personnel.

Information on the type and category of confined space must be clearly described in order to

increase the awareness of all entrants prior to occupancy. This is followed with the dangers

arising from confined spaces such as the hazardous atmosphere and any works that might

contribute to hazards such as the welding process. Besides that, there is also an option for

doing certain activities in a confined space by deciding whether or not the entry is required.

For example, the task of measurement and inspection works could be delegated to remote

devices such as robots. Another important approach to be implemented for confined spaces is

the safe system of work. The effectiveness of a safe system of work depends on the

management leadership and co-operation from all levels of workers. Examples of a safe

system of work include the Permit to Work, atmosphere measurement, and communication

procedure. During emergency situations, all workers need to have the knowledge to prepare

themselves in evacuations and rescue events. The procedure for emergency response and

preparedness must be provided and explained to all personnel to prevent panic.

Apart from that, the capabilities of rescuers also plays an important role in the rescuing

process such as response time, skill, and rescue equipment’s. The relevant laws pertaining to

confined space requirements are also practical for inclusion as a reference in complying and

improving the present procedures that are practiced. Vienney [12] compared four risk

assessment tools for confined spaces by applying them in three hazardous scenarios in order

to determine the weakness and distinctive parts of the tools. The four tools used in the study

were presented in the form of a checklist without risk estimation, a checklist with risk scale,

risk calculation without formal hazard identification stage, a questionnaire, and followed by a




risk matrix. This approach proved to be a useful method in determining the best risk analysis

tools that could be used for confined space risk assessment. The HSE UK requirements are

further reviewed in regard to three factors that contribute to the process of risk assessment for

a confined space, as follows:


Referring to the HSE UK Guidelines, several practical applications are observed useful for

application in confined space safety activities. Examples of practical applications are safety

briefings, Job Safety Analysis, Permit to Work, inspection, and consultation. The definition of

confined space and the explanation of confined space categories are useful information that

could be practiced for confined space activities. This could be done through safety briefings

and consultation. Even though the information provided is generic, it could still give valuable

input to all workers. The dangers of a confined space must be described in all aspects relevant

to confined space entry such as health hazards and safety hazards. Besides that, the

requirements, which mention the alternative approach to work in a confined space, can be

practically applied where it could directly eliminate risk exposure to entrants. Another input

to be applied is emergency and rescue where all workers are recommended to attend

emergency response training in order to assist in rescue works in case of emergency. In the

safe system of work explanation, several important topics that could be practiced are isolation

of confined space, cleaning before entry, and ventilation.

b. Opportunity to enhance the safe system of work

The safe system of work is clearly explained in the HSE UK Guidelines. All elements of a

safe system of work described in the Guidelines can be included for enhancement purposes.

The arrangements provided in HSE UK pertaining to a safe system of work are supervisor

engagement, inexperienced workers, isolation from sources, recommendation of cleaning

prior to entry, checking for access into the confined space, air testing, usage of special tools

and lighting, breathing apparatus, emergency arrangements, rescue harness, communication

with entrant, and necessity of Permit to Work. Even though explanations on the topic are

quite general, these would still give a basic idea for the development of a comprehensive safe

work procedure.


In the HSE UK Guidelines, several requirements that can be practically included in the

elements of risk assessment are identified. Firstly, the explanation on the dangers of confined

space could be included in risk assessment elements due to the nature of confined space being

a hazardous workplace. Examples of dangers that commonly lead to accidents include lack of

oxygen, poisonous gas, fire and explosion, and dust. In safe system work requirements,

several significant requirements have been identified for inclusion in the elements of risk

assessment. The requirements are: (1) isolation of confined space from vapors, gas or fumes;

(2) cleaning of confined space prior to entry that would assist in minimizing the exposure to

vapors; (3) ventilation of the confined space as much as possible through mechanical

ventilation or manhole openings; (4) testing of the air inside the confined space to determine

atmospheric condition; (5) usage of special tools and lighting such as low voltage lighting or

non-spark tools; (6) emergency preparation in order to increase the effectiveness of rescue

response; (7) communication amongst confined space personnel; and (8) Permit to Work

application.

From the review, the HSE UK requirements indeed contribute towards the process of risk

assessment where its contents directly recommend working safely in confined spaces. Despite



the requirements not purposely describing risk assessment tools, it is still of much help in the

practical application of confined space safety activities, further enhancing the safe system of

work, and is also suitable for inclusion as risk assessment elements.

2.3. British Compressed Gas Association: The Application of Confined Space

Regulations to the Drink Dispenser Industry

The Guideline requirements for BCGA UK are outlined in Table 4:

Table 4 Guideline Requirements for BCGA UK

NO. REQUIREME

NTS



1

Key properties

of gases used

for drink

dispensers

Lists key properties of

gases such as carbon

dioxide, nitrogen, air,

and mixed gases

including the hazards

of each gas if

accidentally released

to atmosphere.

The explanation on the risk

of gases by presenting its

concentration, effects, &

symptoms is a useful guide

prior to entering a confined

space. especially for carbon

dioxide and nitrogen.

The gases presented are

common toxic gases in a

confined space and are very

much related to confined space

works and the development of

effective risk assessment tools.

2 Confined space

regulations

HSE L101 (5), Safe

work in confined

spaces, Approved

code of practice, and

HSE INDG 258 ((9),

Safe work in confined

spaces.

The approach is more of a

reference to relevant

regulations for confined

space works in the UK.

Reference made by other

countries is according to the

suitability of the regulation

and works to be carried out.

The Laws being referred to are

observed as additional

information in complying with

safe working in a confined

space.

3 Assessment of

risk

The gas concentration

calculation, factors,

which affect the

overall assessment,

and procedure for the

calculation of risk are

outlined.

The method for conducting

pre-risk assessment is

suitable for practice such as

the calculation of carbon

dioxide concentration in air

and classification of risk

categories.

Preparation towards the

assessment of risk is much

related to confined space works

where it could be used as input

for developing risk assessment

tools.

4

Actions

resulting from

assessment

Procedure for

tolerable risk,

medium risk, and

high risk including

action to be taken is

described clearly.

The explanation on the

action to be taken for each

risk category is practical as

reference during the risk

assessment process.

The elements of risk action

categories are very much

related to confined space risk

assessment tools and would be

useful additional input during

the tool development stage.

5 Competence

and training

Sets out the

requirement for

competency training

for all related

personnel.

This could be used as a pre-

assessment checklist prior to

confined space entry and is

one of the important

elements to be adhered to.

It is a pre-condition for every

personnel to undergo

competency training for which

the approach is directly related

to the confined space risk

assessment process.

6

Personal

Protective

Equipment

Personal Protective

Equipment (PPE)

requirements are

outlined in the

Personal Protective

The requirement for PPE

including the correct

selection of PPE is

compulsory for every

personnel and could be

This is an additional input for

the risk assessment process,

especially relating to confined

space activities.




NO. REQUIREME

NTS



Equipment at Work

Regulation (2)

enforced and practiced prior

to confined space entry.

2.3.1. A Review of BCGA UK

This review on the British Compressed Gas Association: The Application of the Confined

Spaces Regulation to the Drink Dispenser Industry (BCGA UK) is according to the identified

requirements outlined in Table 4, where the review approach is based on the most practical

implementation relevant to the process of risk assessment for a confined space.

The review of BCGA UK requirements is in terms of the key properties of gases used for

dispensing drinks, confined space regulations, assessment of risk, actions resulting from

assessment, competence and training, and Personal Protective Equipment. The description of

key properties of gas is given to provide knowledge to all personnel on the characteristic of

gases as a precaution and a means of preparation for conducting risk assessments. This could

also apply to all confined space works to ensure the danger of certain gases and substance is

known for accident prevention strategies. The relevant confined space regulations or any code

of practice must also be included as a reference for complying with any requirements

outlined. The assessment of risk to be carried out involves the process of identifying all

hazards that might be present during works executed followed with a risk assessment and risk

estimation. This is a compulsory arrangement on behalf of the employers for all confined

space entries. In addition, appropriate action from the assessment must be carried out

adequately according to risk level such as low risk, medium risk, and high risk. For

competence and training, it is compulsory for all relevant confined space personnel to attend

training programs organized by the employer. All training topics to be delivered should be

listed and suited to confined space working requirements. Besides that, Personal Protective

Equipment (PPE), which is the last resort in the hierarchy of control, must be complied with

effectively such as the method of selection, usage, and type of PPE. A study on occupational

safety in a hazardous confined space was conducted by Stojkovic [13], which emphasized the

importance of toxic gases, air testing, ventilation, Personal Protective Equipment, and rescue.

The author also described all hazards that might be faced during occupancy and also studied

the core factors that caused confined space accidents.

The outcomes from this study show that most personnel involved in accidents are co-

workers that had attempted to perform rescue works with the main contributor of accidents

being asphyxiation. From the results, it is advisable that every confined space entry has its

own rescue team either from internal or external service. This could also be an important

input for conducting risk assessments for confined space works. In the next section, the

BCGA UK requirements are further reviewed in terms of three factors that contribute to the

process of risk assessment for a confined space:


The requirements presented in BCGA UK are observed as practical for application to

confined space safety activities. Explanation on the effects of inhaling carbon dioxide and

inhaling reduced concentrations of oxygen could be shared during safety briefings, to be put

on the notice board, included in the on-site Job Safety Analysis, and attached to the Permit to

Work document. For carbon dioxide effects, the range of carbon dioxide concentration (%) is

ranked from 1% to 100% where loss of consciousness starts from 10% and above. For oxygen

effects, the range is from 0% to 19.5% where loss of consciousness starts from 10% and

below. Besides that, the requirements on hazard communications such as warning signs, could



be posted at suitable locations to remind workers about hazardous work areas such as No

Smoking, No Authorized Access, Potential Asphyxiating atmosphere, and Gas Cylinder

Store. The requirements for training could also be applied to confined space safety activities

during safety briefings, either conducted by safety personnel or the team leader. In addition,

the requirements for Personal Protective Equipment (PPE) must be made mandatory where

the correct selection of PPE depends on the nature of confined space and type of job to be

carried out.

b. Opportunity to enhance the safe system of work for a confined space

The requirements outlined by BCGA UK could potentially enhance the safe system of work

for confined spaces. The list of key properties of gases that might affect workers while

carrying out jobs could be included in the safe system of work in a confined space. This can

be done through providing a detailed explanation on the effects and symptoms of the

identified gases, which are carbon dioxide and oxygen. The safe system of work could also be

enhanced by improvising on the hazard communication procedure such as introducing

warning signs. In the risk management procedure, the inclusion of factors that affect the

overall assessment, procedure for calculating risk, and actions resulting from the assessment,

could raise the effectiveness of the safe system of work. The procedure could be further

enhanced with the addition of a flowchart that displays the method of risk reduction relating

to carbon dioxide gas cylinders. Additionally, competency and training and Personal

Protective Equipment requirements are other factors that could be included in the safe system

of work.

c. Suitability for inclusion in the elements of risk assessment for a confined space

Several requirements stated in the BCGA UK are observed as relevant for inclusion in the

element of risk assessment for confined spaces. The detailed explanation of the effect and

symptoms of carbon dioxide and oxygen can be practically included as elements of risk

assessment. For example, the effects and symptoms of carbon dioxide are that it starts to

increase the breathing rate as low as 1% volume in air, whereas for oxygen, unconsciousness

starts from 10% in volume of air and below. Moreover, the inclusion of factors that affect the

overall risk assessment, procedure in calculating risk, categorization of risk, and actions

resulting from the assessment can add value to the elements of risk assessment. For example,

the approach on the procedure for calculating risk can be practical as reference prior to

categorization of risk even though the gas calculation is purposely for drink dispenser gases.

The explanation of actions resulting from the risk assessment according to risk level such as

tolerable risk, medium risk, and high risk are also valuable. Besides that, the competency

requirements for personnel could also be included in the element of risk assessment for a

confined space.

From the above review, even though the BCGA UK guidelines for safe working in

confined spaces is targeted for the drink dispenser industry, there are still suitable documents

that can be used as reference and as a platform for the practical application of confined space

safety activities, further enhancing the safe system of work for confined spaces, and also

suitable for inclusion in the element of risk assessment for a confined space.




2.4. American Society of Heating, Refrigerating and Air-conditioning Engineer

(ASHRAE)

The Guideline requirements for ASHRAE US are outlined in Table 5:

Table 5 Key Guideline Requirements for ASHRAE US

NO. REQUIREME

NTS



1

Risk

management

approach

Outlines a general approach

for risk management in an

organization including the

risk assessment process, risk

management plan

implementation, and re-

evaluation of the plan after

implementation.

The risk management

framework for risk

management is part of

the elements that could

be used in planning risk

assessments. The risk

management

methodology provided

would serve as an

additional input for the

risk assessment process.

This is much related to the

stages of developing risk

assessment tools, especially

information on risk

management methodology.

2

Design for new

and existing

facilities

Outlines general concepts of

the protection of occupants

in the facilities, which

consider the requirements

for site planning & design,

utility system, building

planning & design, and

building occupancy types.

The method in

determining risk level

could be used as an

example for the risk

estimation process.

The qualitative method in

determining risk is relevant

for use as input in the risk

assessment process.

3

Operation and

maintenance of

buildings

Outlines the commissioning,

documentation, public

address system, site &

building security, plan for

normal operations, plan for

emergency operations, and

personnel protection.

The approach leans more

towards operation and

maintenance except for

the planning of

emergency operation,

which is a useful

reference.

Planning for emergency

operations is observed to be

an important element for

reference in developing risk

assessment tools.

2.4.1. A Review of ASHRAE US

This review on the American Society of Heating, refrigerating and Air-conditioning Engineer

(ASHRAE) is according to the identified requirements outlined in Table 5, where the review

approach is based on the most practical implementation relevant to the process of risk

assessment for a confined space.

The reviewed requirements for ASHRAE include the general approach on risk

management, design for new and existing facilities, and operation and maintenance of

buildings. An organization is required to implement its own risk management concept in order

to manage risk, and assist in minimizing any threats that could affect its entire operation.

Participation from all functional units is required and the risk management committee must be

held accountable for effectively identifying the risk upfront. This must also apply to confined

space works where the requirements to implement early preparation on the assessment of risk

to prevent incident and injuries to workers are observed. The approach on the new design of

building and facilities could be referred to as a concept for the assessment of risk such as

moderate and high risk. For example, the safe design of the work area prior to occupancy

could minimize risk and result in high quality jobs. Another matter of concern is during



operation and maintenance of the building where the consideration of emergency response

and preparedness should be made. Without appropriate planning for emergency situations,

rescue operations would become slow and stunted. During confined space entry, the

requirement for emergency preparedness is compulsory and authorization from competent

personnel is required. In terms of the risk matrices approach, either qualitative or quantitative,

the method utilized is important because the wrong concept of utilization would lead to

incorrect risk assessment results. A study on the recommendations of the use and design of

risk matrices was objectively conducted to explore their weakness and provide

recommendations on their use and design [14]. Based on the review of previous publications,

it was concluded that a probability sequence diagram with continuous scales be proposed. The

application of this approach is relatively new but could still be considered for the

development process of risk assessment tools for confined spaces. The ASHRAE

requirements are further reviewed in terms of three factors that contribute to the process of

risk assessment for a confined space in the next section:


The risk management approach could be referred to as useful information and can also be

practiced and shared with all confined space personnel, especially during safety awareness

talks and daily briefings. Examples of practical implementations are the risk assessment

activities where all confined space personnel must be involved in developing and complying

with all control measures to be taken. Besides that, the approach for emergency response can

also be practically implemented by all personnel during the occupancy period.

b. Opportunity to enhance the safe system of work for a confined space

The selection of the most appropriate requirements to be included in a safe system of work is

required since most of the requirements are not relevant to occupational safety and health

approaches. Even though explanation on the risk management approach is more relevant for

building applications, it can still be used as input to establish a safe system of work for

working in confined spaces. The same goes for the explanation on risk assessment where the

process of assessment must be designed according to the suitability of confined space

applications. Moreover, the description regarding risk level such as negligible, minor,

moderate, and serious risk could be incorporated into the safe work procedure as well as in the

calculation of risk matrices and methods. Another part that could be added in the safe system

of work is the description of risk categories, which are defined as Critical, Serious, Moderate,

Minor, and/or Negligible. Moreover, the emergency response and rescue approach could also

be used as reliable input in enhancing the safe system of work for confined spaces.


The suitability of adding these requirements to the elements of risk assessment are observed

through the most practical approach since most of the requirements are about safety of

buildings. The requirements that are considered for inclusion are selected based on general

requirements such as the risk management approach. The inclusion of risk categories

assignment such as Critical, Serious, Moderate, Minor, and/or Negligible could be considered

as input for the elements of risk assessment as well as for emergency operation requirements.

Besides that, the risk matrices approach could also be used for additional input even though

the proposal and calculation is more relevant for building safety. Moreover, the description of

Risk Management Example such as identifying the risk, Estimating the probability of risk

occurrence, Assessing the value of loss for risk assessment, and Ranking the risks, are

observed as valuable input for the elements of risk assessment. Generally, even though most

of the requirements in the ASHRAE Guidelines are suitable for use as information and




reference, they are also beneficial as a basis in the development process of risk assessment

tools for a confined space.

From the above review, the requirements of the ASHRAE Guidelines are mostly relevant

for the safety of buildings. However several requirements can be observed and added to the

proposal for practical implementation of confined space safety activities, and to enhance the

safe system of work for confined spaces. It can also be included in the elements of risk

assessment for confined spaces.

2.5. Industrial Code of Practice for Safe Working in Confined Space Malaysia

The Guideline requirements for ICOP Malaysia are outlined in Table 6:

Table 6 Guideline Requirements for ICOP Malaysia

NO. REQUIREME

NTS



1 Confined space

entry program

Describes the responsibilities of

employers during the confined

entry program, which include

Hazard Identification, Risk

Assessment, and Risk Control,

stand-by person, monitoring of

multiple confined space, Permit

to Work system, sign-posting,

employee training, equipment,

means of communication,

external hazard protection,

identification of duties,

information to contractors,

coordination among

contractors, and conclusion of

entry.

The list of the confined

space program is

beneficial for practice

by industry players in

ensuring effective

monitoring of confined

space works, especially

for the Hazard

Identification, Risk

Assessment, and Risk

Control process.

The program proposed

could be referred to as

input during the initial

stage of developing risk

assessment tools for

confined space works due

to its relevance to the

nature of working in a

confined space.

2 Detailed

requirements

Outlines the Permit to Work

system, isolation requirements,

safety of atmosphere

requirements, entry into

hazardous atmosphere, rescue

& emergency services, health

requirements of persons

working in confined space,

training, additional precautions

during occupancy of confined

space, and record keeping.

Most of the

requirements for

working in a confined

space are described

clearly and these are

the key elements that

need to be adhered to

by industries prior to

occupancy.

The description of each

requirement is much

related to the assessment

of risk prior to confined

space entry and the input

from the risk assessment

process could be used for

developing risk assessment


3

Duties of the

responsible

person

Sets out the duties of the

employer as owner, duties of

employer as contractor, duties

of permit issuer, duties of entry

supervisor, duties of authorized

gas tester, duties of stand-by

person, and duties of authorized

entrant.

All responsible

personnel for the

confined space are

listed in terms of their

key duties. This is a

useful reference and is

a basic guidance in

appointing key


space activities.

The duties outlined are

part of the control

measures (administrative

control), which could be

included in the process of





2.5.1. A Review of ICOP Malaysia

This review on the Industrial Code of Practice 2010: Safe Working in Confined Space (ICOP

MY) is according to the identified requirements outlined in Table 6, where the review

approach is based on the most practical implementation relevant to the process of risk


The reviewed ICOP MY requirements are the confined space program, confined space

detail requirements, and duties of the responsible person. A safety program for confined space

is part of accident prevention strategy where every organization involved in confined space

related activities should plan their own programs to suit their work environment. Examples of

such programs are Hazard Identification, Risk Assessment, and Risk Control, atmosphere

monitoring, training, and means of communication. From the confined space program,

detailed requirements should be carried out prior to occupancy such as Permit to Work,

isolation, emergency response and rescue, and worker health. In every confined space

activity, all requirements that are planned must be carried out effectively and the performance

record of confined space entry surrendered to the employer for documentation. Apart from

that, the details of responsibilities of key personnel for the confined space must be established

and distributed accordingly. All responsible personnel such as the Stand-by person should

understand and commit to the task assigned to them, especially regarding the method of

communication among personnel.

Besides these requirements, emergency response is also a crucial issue that needs to be

addressed. Co-operation between the employer and Fire Department must be enhanced

accordingly to ensure effectiveness in rescue attempts. Wilson [15] conducted an assessment

of emergency response practices of the employer and Fire Department where its outcomes

could be used as a reference for improving rescue team effectiveness. This can be realized

through full support from the Fire Department in providing a well-trained and equipped on-

site rescue team, and provision of advanced life support equipment. From the study, it can be

observed that this approach could be useful for inclusion in all confined space procedures and

used as suitable input in the development process of risk assessment for a confined space. The

ICOP MY requirements are further reviewed based on three factors that contribute to the

process of risk assessment for confined spaces in the next section:


The identified practical approach for the elements that could be practiced for confined space

safety activities specifically derived from the ICOP requirements are identified. The

requirements that can be practically applied are regularly conducting briefings about the

responsibilities of all confined space personnel, regulary referring to Hazard Identification,

Risk Assessment, and Risk Control prior to occupancy, updating the Permit to Work

document, allocating suitable signages, checking the equipments for safe operation,

maintaining communication between the standby person and entrant, being alert of external

hazards, which might affect the entrant, measuring the confined space atmosphere, regularly

practicing emergency drills, assessing entrant health condition, and checking isolation

effectiveness.

b. Opportunity to enhance the safe system of work for confined space entry

The components of a safe system of work from the ICOP requirements, which have been

observed, include assigning responsibilities to all confined space personnel, procedure for

conducting Hazard Identification, Risk Assessment, & Risk Control, safe instructions for

monitoring more than one confined space at the same time, procedure for applying Permit to

Work, hazard communication procedure, contractor safety rules, isolation procedure,




instruction for atmosphere testing, emergency and rescue procedures, and instruction on the

health status of entrants.

c. Suitability for inclusion in the elements of risk assessment for confined spaces

The ICOP requirements are stated solely for safe working in confined spaces, but are not

totally directed towards the risk assessment concept except in the ‘confined space entry

program’ section. However, it could still contribute as input for the elements of risk

assessment such as the assignment of competent personnel, review and update of Hazard

Identification, Risk Assessment, and Risk Control, method in monitoring multiple confined

spaces, validity of Permit to Work, availability of hazard communication, training history,

service and calibration of equipment, method and equipment for communication, selection

method of contractors, isolation criteria, atmosphere monitoring criteria, emergency response

and preparedness readiness, and health status of entrant.

According to the above review, it can be concluded that the ICOP requirements directly

contribute towards the process of risk assessment for confined space works, specifically

regarding its practical application, enhancing the safe system of work, and as input for risk

assessment elements. Furthermore, examples of forms provided such as Risk Assessment,

Recommendation for the conduct of Hot work in confined space, Confined Space entry,

Recommendation for Cleaning Tasks in confined space, Recommendation for atmospheric

testing, Health Examination checklist, Health Fitness certificate, and Declaration of Health

Status by Authorized Entrant are also useful as guidance for organizations to further improve

their safe system of work in confined spaces.

2.6. Guidelines for Hazard Identification Risk Assessment and Risk Control

(HIRARC)

The Guideline requirements for HIRARC Malaysia are outlined in Table 7:

Table 7 Guideline Requirements for HIRARC Malaysia

NO. REQUIREM

ENTS



1 Basic concept

Gives a brief

description of risk and

a mathematical

equation of risk.

It is useful to understand the

definition of risk prior to

proceeding with risk assessment.

Mostly, the equation of

risk is used for all risk

assessment processes,

either specifically for

confined spaces or other

activities.

2

Planning and

conducting

HIRARC

Explains the purpose of

HIRARC, planning of

HIRARC activities, and

the process of

HIRARC.

It is useful information, which

has been described, especially

during the process of HIRARC

where the flowchart of the

HIRARC process presented is

clear. During analysis and

estimation of risk, the table

presents in detail the likelihood,

severity, risk matrix, and risk

action.

The overall process of

HIRARC is much related

to the risk assessment of

confined space and would

add value to the

development of risk

assessment tools.

3 Control

Describes the definition

of control, selection of

suitable control, types

of control, monitoring

The hierarchy of control is

suitable for recommending a

control measure during the risk

assessment process. The proposal

The approach on risk

control and additional

relevant inputs is much

related to the process of



NO. REQUIREM

ENTS



controls, safe work

procedures, and

Personal Protective

Equipment.

to review the risk control and

develop safe work procedures is

an additional input to ensure

effectiveness of risk control

measures.


tools for confined spaces.

4 Documenting

HIRARC

Explains the

requirements for

documentation such as

responsibility &

accountability, and the

documenting process.

The method of documenting,

especially HIRARC documents,

is useful in practice to ensure all

HIRARC processes conducted

are traceable in case any changes

are required.

The documentation

approach for confined

space works is required

especially on the PTW and

risk assessment, even

though the documentation

is not directly related to

the development of risk

assessment tools.

5 Consultation

Outlines the

consultation with health

and safety personnel

and employees for

effectively identifying

and controlling risk.

Engagement with health & safety

personnel and workers is

required for collecting further

information about workplace

hazards.

This is much related to the

development of confined

space risk assessment tools

to ensure the information

collected is genuine.

6 Training

Sets out the

requirements about the

importance of training

to all workers and

management to ensure

they have the

knowledge and skills

for identifying and

controlling risks.

Training is part of the important

criteria required for every

personnel and it is practical for

enforcement on all personnel

involved in confined space entry.

This is an additional

element to be added in risk

assessment and is related

to developing confined

space risk assessment

tools.

2.6.1. A Review of HIRARC Malaysia

This review on the Guidelines for Hazard Identification, Risk Assessment, and Risk Control

(HIRARC MY) is according to the identified requirements outlined in Table 7, where the

review approach is based on the most practical implementation relevant to the process of risk


The reviewed HIRARC MY requirements are the basic concept of risk, planning and

conducting Hazard Identification, Risk Assessment, and Risk Control (HIRARC), concept of

control, documenting HIRARC, consultation, and training. The basic concept of risk that is

described provides a basic understanding of risk, which is useful knowledge prior to

conducting a risk assessment. Proper planning on any task is required, especially for

HIRARC. The description of the purpose of HIRARC, activities of HIRARC, and process of

HIRARC that are described provide clear guidelines for conducting a complete HIRARC,

specifically when applied to confined space works. The concept of control is explained for

which the description of hierarchy of control such as elimination, substitution, isolation,

engineering, administration, and Personal Protective Equipment could be applied during the

process of HIRARC. Besides that, during the HIRARC process, consultation and discussion

with safety personnel and workers is required in order to obtain factual information for

inclusion in HIRARC.




The information provided is useful and practical for use as reference rather than

conducting HIRARC based on own observation and judgment. In addition, training

requirement must also be included for all personnel to provide them with relevant knowledge

in identifying hazards, assessing risk, and controlling risk. For easy reference and tracking

purposes, HIRARC documents must be documented by explaining the method for the

documentation process. In terms of the perfectness of risk matrices used in this Guideline,

Ball and Watt [16] examined the reliability and utility of risk matrices used for hazard ranking

purposes. Even though the context of the study involves public leisure activities, the outcome

from the study could still be used to improve current risk matrix tables, which are used

widely. For example, the study showed that different assessors might give different hazard

ranking results from the same hazard, which would affect the effectiveness of control

measures to be taken. Therefore, this is an important input to consider in the development

process of risk assessment tools for a confined space. The HIRARC MY requirements are

further reviewed based on three factors that contribute to the process of risk assessment for a

confined space, as follows:


The HIRARC requirements that could be practically applied are conducting Hazard

Identification, Risk Assessment, and Risk Control (HIRARC) by developing a HIRARC

team, all of which consist of confined space personnel. The personnel would have their own

function in the HIRARC activities where the effectiveness of results from the findings would

be concluded and verified by the team leader. Prior to that, the personnel are required to

undergo training or workshops related to risk assessment to ensure they are equipped with the

required skills and knowledge for the HIRARC process. The approved HIRARC will then be

distributed and briefed to all relevant confined space personnel as guidance and reference

prior to occupancy.

b. Opportunity to enhance the safe system of work for confined spaces

In enhancing the safe system of work, all the HIRARC requirements could be used as

guidance—separated into sub-elements of HIRARC with each element described in detail

such as procedure in planning & conducting HIRARC, controlling method, documentation

procedure, and procedure for training, as suited to the selected workplace environment.

Examples of forms that are provided such as Workplace Hazards and Checklist for Workplace

Hazard could contribute towards enhancing the safe system of work for confined spaces.

c. Suitability for inclusion in the elements of risk assessment for a confined space

The risk assessment approach in the HIRARC Guidelines are suitable for use as input in the

elements of risk assessment for a confined space. The most significant sections - Planning &

conducting HIRARC and controlling the coverage - are clearly explained such as the process

of HIRARC, selection of suitable control, types of control, and monitoring the controls.

Examples of forms that are provided such as the HIRARC form, Worked Example: Scenario 1

& 2, Hazard Identification Technique, and Job Hazard Analysis could serve as valuable input

as elements of risk assessment for a confined space. From the review, it can be concluded that

the HIRARC Guidelines indeed contribute towards improving the risk assessment process for

a confined space, specifically for practical applications, enhancing the safe system of work,

and as elements of risk assessment for confined space work.



2.7. Guidelines on Occupational Safety and Health Management System

(OSHMS)

The Guideline requirements for OSHMS Malaysia are outlined in Table 8:

Table 8 Guideline Requirements of OSHMS Malaysia



1

Describes the OSH

MS in an

organization

according to 5

Categories of OSH

elements from the

ILO-OSH

conceptual

framework.

Policy—Occupational

Safety and Health policy

requirements are outlined

for every organization

and how to formulate the

policy. It also states

employee participation in

safety and health at the

workplace and how the

participation strategy is

undertaken by the

employer.

The requirements to

establish a policy in an

organization is suitable

for implementation, as it

would show full

commitment from the

employer in regard to

the health safety of their

workers.

The policy established

would be used as a

guide in ensuring all

safe work systems are

practiced accordingly,

especially during the

process of developing

risk assessment tools

for a confined space.

Organising—the

responsibility,

accountability, and

authority of an

employee, competency,

training & awareness,

and OSH MS

documentation (ILO-

OSH 2001

Implementation Manual)

and the importance of

communication amongst

all personnel in an

organization are

described.

This element could be

use a reference in the

effective ways of

organizing the

occupational safety and

health management in

workplace.

Effective organizing of

workplace health &

safety would resulted

in a high standard of

safety compliance

which would indirectly

contribute to teamwork

spirit during the

development process

of risk assessment.

Planning and

Implementation—Initial

Review or gap analysis

requirements,


health objectives &


health plan to ensure the

direction is on track,

Hazard Identification,

Risk Assessment & Risk

Control requirements,

emergency prevention,

preparedness and

response requirements,

management of change

in organisation,

procurement

The element outlined is

useful as reference and

can be practiced in

organizations since it

covers most of the

hazard and risks

observed in a workplace

with additional elements

consisting of

administrative

approaches.

This approach is much

related to the process

of risk assessment

since it outlines the

elements consisting of

Hazard Identification,

Risk Assessment &

Risk Control, which

could be used as input

for the development of

risk assessment tools

for a confined space.






requirements, and

contracting requirements

are outlined.

Evaluation—

performance monitoring

& measurement

requirements, incident

investigation, audit and

management review are

outlined.

Measurement of safe

work system

implementation is part

of the requirements that

employers must

undertake to ensure the

effectiveness of the

system, which could be

used for further

improvements.

The sub-elements of

the evaluation stage

consists of closely

monitoring the

performance of the safe

work system in the

workplace, which

could be used and

relates to enhancing the

process of risk

assessment for a

confined space.

Action for

Improvement—

preventive & corrective

action and continual

improvement

requirements are

outlined.

The findings from the

performance

measurements will be

used as a basis for

further improvements

for which the

management must

practice and act pro-

actively.

The elements from

action for

improvements are not

directly related to the

risk assessment process

but the continual

improvement concept

that is practiced would

serve as a useful input

for enhancing risk

assessment tools for a

confined space.

2.7.1. A Review of OSHMS Malaysia

This review on the Guidelines of Occupational Safety and Health Management System

(OSHMS MY) is according to the identified requirements outlined in Table 7, where the

review approach is based on the most practical implementation relevant to the process of risk


The reviewed OSHMS MY requirements refer to the ILO-OSH Conceptual Framework,

which consists of policy, organizing, planning and implementation, evaluation, and action for

improvement. In every organization, there is a requirement to establish a policy, especially a

health and safety policy, to prove the commitment of the employer towards their employees.

Encouraging written words from the employer would also raise the spirits of the employee

when carrying out their duties. To achieve this objective, the employer should take the

initiative to ensure all employees are well-versed with the policy and understand the purpose

of the policy. The element of organizing describes the responsibilities of employees, the

competency requirements—including training and awareness - and communication amongst

all personnel. For planning and implementation, the initiative should be geared towards the

way forward for practicing occupational safety and health management systems. Examples of

this approach include occupational safety and health plan and objectives, requirements for

Hazard Identification, Risk Assessment, and Risk Control, and management of change. The

evaluation stage should review the performance of the approach implementation such as



monitoring, audit, and management review where the outcomes from this evaluation will be

used as a platform for improvement.

The list of actions for improvement must be implemented accordingly through an

appropriate corrective action strategy where the recommendation towards continual

improvement is warranted. Besides that, most organizations that practice the occupational

safety and health management system in the workplace still experience a number of accidents.

It is also observed that certain accidents reported are due to simple mistakes where the task

that was carried out lacked monitoring by the person in charge. Because of these reasons,

Jørgensen and Duijm [17] conducted a study to assess the potential risk that leads to accidents

and the ways to promote safety awareness to all workers by improving the risk assessment

approach. As an example, in their study, two occupations were identified and the risk profile

of each trade collected and analyzed. From the information gathered, an effective risk

assessment for employers and employees was proposed. From the study conducted, the

approach is also practical for use in the process of risk assessment for confined space work as

an accident prevention program via the selection of several critical tasks, which have a high

potential of accidents occurring. The OSHMS MY requirements are further reviewed based

on three factors that contribute to the process of risk assessment for confined spaces, as

follows:

a. Practical application for confined space activities

The requirements to develop a safety and health policy for an organization is observed as a

good method to prove the employer’s overall commitment towards its employees. For

confined space activities, the statement written in the policy could be applied in routine safety

activities while carrying out works as long as everyone is aware of the importance of this

policy. It is crucial that the workers inculcate the word ‘commitment’ in order to achieve the

objectives of the policy. Moreover, regular briefings with all personnel about their

accountability and responsibility are required and should be followed up with effective

communication amongst workers, conducting regular safety training for all workers,

competency validity audits, conducting a review on risk assessment such as Job Safety

Analysis, regularly practicing emergency drills and rescues and conducting safety inspections,

and taking actions for the proposed control measures.

b. Opportunity to enhance the safe system of work

From the Guideline requirements, inputs that could be added to enhance the safe system of

work are the establishment of a policy suited to the nature of work to be carried out, training

and competency of all relevant personnel, communication amongst all personnel, regular

review on the work process, development of safety and health plan for projects, procedure on

risk assessment, emergency response and preparedness, measurement of occupational safety

and health performance, conducting audits and inspections, and taking the appropriate action

regarding the proposed control measures.


The requirements stated in OSHMS MY Guidelines are not directly relevant to the risk

assessment approach except when it comes to the planning and implementation stage, which

describes the requirements to conduct Hazard Identification, Risk Assessment, and Risk

Control. To this end, the requirements that can suitably be included in the element of risk

assessment are the competency of personnel involved in a confined space, relevant training

for jobs to be carried out, communication effectiveness, Hazard Identification, Risk

Assessment, and Risk Control review, update, and effectiveness, emergency response




preparedness readiness, monitoring confined space atmosphere, and effectiveness of

corrective action.

Based on the above review, it can be concluded that the OSHMS MY could be used as

part of the contribution factor to enhance confined space risk assessment activities even

though not all requirements directly apply to risk assessment. However, the example of

formats provided such as safety and health policy, training plans, training records, emergency

management checklist, legal requirements, HIRARC, incident investigation, checklist

compliance audit, and corrective action, are a useful guide to further improve the practical

application, safe system of work, and as an element of risk assessment for confined space

work.

3. COMPARISON OF GUIDELINES

The seven Guidelines that have been reviewed are compared with the risk assessment

elements stated in each Guideline. The outcomes from this comparison will serve as a trigger

towards enhancing the risk assessment method prior to planning for working in a confined

space. Referring to the risk assessment comparison of each Guideline, MoD UK, BCGA UK,

ASHRAE US, ICOP Malaysia, and HIRARC Malaysia directly presented the risk assessment

element concept, whereas HSE UK and OSHMS Malaysia presented this indirectly through

an established management concept approach. Each Guideline also implemented its own

approach in conducting risk assessments. MoD UK conducted its risk assessment by referring

to the HSE Code of Practice L101 and supported by a set of forms. Prior to confined space

entry, the risk rating is determined by referring to the likelihood and severity scale. In

addition, Permit to Work is applied and supplemented by a relevant checklist. The HSE UK

Guideline stated safe working in confined space in general without a specific method for

assessing risk. The BCGA UK Guideline implemented its own method for calculating risk,

specifically for the drink dispenser industry. It also included its own risk category and control

action. The ASHRAE US Guideline provided a comprehensive method for assessing risk.

The quantitative and qualitative methods used are the best approach for this Guideline,

specifically for the management of risk in Public health and safety of buildings. Prior to that,

it also explained the risk management framework, which is useful for the management of risk

in an organization. The risk assessment approach of the ICOP Malaysia Guidelines detailed

out the confined space entry program. The procedure in assessing risk was stated with respect

to confined space work where the method for estimating risk was in accordance to the

HIRARC guideline. The HIRARC Malaysia guideline is aimed solely for Hazard

Identification, Risk Assessment, and Risk Control. The method for conducting HIRARC was

explained in detail. A likelihood and severity table was provided to determine the risk level

and risk matrices of an activity and a risk action table was used for risk control strategy.

Finally, the OSH MS Malaysia Guidelines mentioned risk assessment requirements in the

planning and implementation stage. Its approach in conducting risk assessment is similar to

the HIRARC guideline including its likelihood, severity, risk matrices, and risk action table.

From this comparison, it can be concluded that each Guideline has its own method and

concept for assessing risk, specifically to suit the purpose of the Guideline. The best risk

assessment in confined space works was given by the Mod UK Guidelines. This can be

observed through the arrangement of a safe work system presented, which includes a

flowchart, diagram, and sample assessment forms. In terms of risk assessment techniques,

ASHRAE US is a good example to follow, due to the qualitative and quantitative approach it

applies throughout its Guidelines. In order to improve the Malaysian safe work practices for a

confined space, examples of the method for assessing risk and other relevant inputs from the



Guidelines could be integrated to ensure that the risk assessment tools developed are practical

and suited to all tasks in a confined space.

Furthermore, the hazards that appear during the works must be recognized and acted upon

accordingly. These issues apply to all types of work sites to ensure they are well managed

since most workers would be present at their place of work. The importance of hazard

recognition and risk perception was mentioned in a study that measured the ability of

management personnel to recognize and perceive risk in their routine workplace [18]. A

recent study also showed that the main contributor towards fatality in a confined space in

Canada was due to the hazardous atmosphere [19].

4. CONCLUSION

The seven Guidelines, namely MoD UK, HSE UK, BCGA UK, ASHRAE US, ICOP

Malaysia, HIRARC Malaysia, and OSH MS Malaysia, are reviewed specifically in terms of

the identified requirements and contribution factors, as clearly described in the Guideline

requirements. With each Guideline requirement, it can be observed that the important

approach for risk assessment element is specifically carried out for the purpose of the

Guideline. This review of the Guidelines reveals that every Guideline has its own contributory

elements towards risk assessment, especially in regard to risk assessment methodologies for

confined space works. The comparison between Guidelines conducted in this study, which

specifically focuses on the risk assessment elements, showed that every Guideline has its own

unique method in assessing risk. These could be used to improve Malaysian safe work

practices for a confined space. For instance, the best approach for risk assessment identified

as useful could be integrated to form the basis for enhancing risk assessment tools for

confined space works. Finally, several literatures are referred, which provide useful input for

risk assessment improvement strategies.

ACKNOWLEDGEMENTS

The authors would like to express their greatest appreciation and utmost gratitude to the

Ministry of Higher Education, UTM Razak School of Engineering & Advanced Technology,

and Universiti Teknologi Malaysia (UTM) for all their support towards making this study a

success. UTM Vote No: Q.K130000.2540.15H36.

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