When one standard is better than two
Work in confined spaces claims 15 lives a year. But two different national standards have created some ambiguity in training and assessment - until now. Gordon Lyon reports.
Question: When is the National Standard not the National Standard? Answer: When there are two National Standards.
The concept of standards and standardisation is fundamentally about unifying practice, adopting an optimal single model for all concerned. Nowhere is this more consequential than in health and safety, where life is the commodity at risk.
Work in confined spaces has claimed many lives – it still accounts for an average of 15 deaths each year. Commendably, the water industry has achieved much in improving safety, through training and assessment.
Above all others, the water industry has been active in generating national standards in this area. But it would surprise many to learn that the UK has two national standards by which the competency of people working in confined spaces (CS) is assessed.
How could this ambiguous situation arise? Let’s take a brief look at the development of CS working safety legislation.
In the mid-1990s new regulations for working in confined spaces were formulated. The resultant Confined Spaces Regulations 1997 stated: “No person at work shall enter or carry out work in a confined space, unless they have been prepared, in respect of that confined space.”
Undoubtedly, this brought CS safety into a new era where workers have to provide proof of training and competency before having any direct involvement in CS activity. As contractors are well aware, though, water companies had their own specific training and assessment requirements.
Working for more than one water company meant starting all over again – at considerable extra expense – in order to equip already-competent personnel with the necessary working permit.
Faced with this unwieldy system and its inordinate training costs, the Sewer Renovation Federation, which amalgamated with the SBWI in 2001 to form the Society of British Water & Wastewater Industries (SBWWI), brought its influence to bear. It called for some simplification to cut out the wastage in the system. As a result, Water UK decided to solve the problem by adopting a single standard. Water UK chose City and Guilds 5831, a standard that had already been developed and approved.
With the role of developing National Occupational Standards (NOS), Energy and Utility Skills (EU Skills) could then introduce a registration scheme, producing a record of all trained and competent personnel, centrally held for all to view. Thus was born the City and Guilds 5831 Certification, already adopted by BT, for instance.
Most importantly, the new standard has the full support of the Health & Safety Executive (HSE). It is made up of several standards that are termed Post Training Assessments, and which relate to the National Classifications of Confined Spaces, NC1 to NC4:
- NC1 – Low-risk entries
- NC2 – Vertical entry attached to line or winch
- NC3 – Work carried out away from point of entry detached from life-line
- NC4 – Non-standard entries requiring specific controls and rescue arrangements
It is up to each water company to specify the Entry Classification for its own confined spaces, and decide which NOS therefore applies.
The outcome is that, since January 2007, any contractors working for a water utility have to have their staff assessed and registered to the appropriate standard. Due to the serious dangers of CS operations, each of the assessments is renewable every three years, as are the training courses.
Problem solved? Not exactly. There already existed a national standard for assessing competence to work in confined spaces. This was operated by the Certification and Accreditation Board for the Water Industry (CABWI) and gave successful candidates units toward an NVQ.
Now the industry had two national standards – City & Guilds and CABWI, by which personnel could attain a recognised qualification.
With two national standards in operation, the Qualifications and Curriculum Authority (a public body sponsored by the Department for Education and Skills) considered the situation unacceptable.
EU Skills, therefore, was charged with developing a single assessment standard, giving a clear and unambiguous assessment path for the energy and utility industries, and one that could in the future be extended to other industries.
A committee was formed to develop the new national standard, which it aims to announce shortly. The committee includes four training provider assessment bodies, CSTS, Develop, Mines Rescue and Todo Mundo. Working alongside them are United Utilities, Scottish Water, Clancy Dowcra, City & Guilds and Awarding Body, CABWI.
The new national standard will comprise five different units of assessment, devised in accordance with the suggestions of the HSE:
- Low-risk CS entry – Not requiring escape equipment
- Medium-risk CS entry – Using escape equipment
- High-risk CS entry – Requiring full breathing apparatus
- Top Person duties
- Rescue teams
As a footnote, it should be remembered that the water industry, through Water UK, is provided with an Occasional Guidance Note covering these standards.
The water companies are free to accept, or reject the guidance. But the value of adopting a single national standard is clear, not only in ensuring that personnel are assessed to the same high level.
Also, in the unfortunate event of an accident, it would provide unequivocal evidence for the HSE that the company had taken on board the agreed and accepted, unified standard.
Gordon Lyon is head of CSTS and SBWWI representative on the CABWI committee on assessment. T: 01925 244144. E: Gordon@csts.co.uk
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