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Confined Space Critical Risk Management

Confined Space Critical Risk Management

Working in confined spaces is one of the most hazardous activities across various industries. Confined spaces, such as tanks, silos, pits, and tunnels, present unique challenges due to limited entry and exit points, restricted airflow, and potential exposure to harmful substances or hazardous conditions. Effective management of confined space risks is crucial to prevent incidents that can lead to serious injuries, fatalities, and operational disruptions.


Industries and Work Activities Involving Confined Spaces

Confined spaces are found in a wide range of industries, with tasks varying in complexity and risk level. Key industries include:


Construction

  • Working inside tunnels, manholes, or sewer systems.

  • Inspecting or cleaning enclosed foundations.


Mining

  • Operating in underground shafts or chambers.

  • Inspecting ore passes or crushers.


Manufacturing

  • Cleaning or maintaining storage tanks or silos.

  • Performing repairs inside industrial ovens or boilers.


Utilities and Energy

  • Conducting maintenance on underground pipelines.

  • Inspecting confined spaces within power plants or wind turbines.


Agriculture

  • Entering silos for grain storage or maintenance.

  • Cleaning manure pits or feed storage tanks.


Maritime and Ports

  • Working inside cargo holds, ballast tanks, or engine rooms.

  • Conducting repairs on confined sections of vessels.


Potential Incidents and Scenarios

Understanding potential incidents related to confined spaces is essential for effective critical risk management. Common scenarios include:


Atmospheric Hazards

  • Exposure to toxic gases, such as hydrogen sulfide or carbon monoxide.

  • Oxygen deficiency due to poor ventilation.


Engulfment or Entrapment

  • Workers being engulfed by loose materials, such as grain or sand.

  • Becoming trapped due to structural collapses or equipment failures.


Fires and Explosions

  • Ignition of flammable gases or vapours within the confined space.

  • Sparks from tools igniting combustible dust.


Slips, Trips, and Falls

  • Losing balance on narrow or uneven surfaces.

  • Falling into pits or wells.


Common Dynamics Contributing to Incidents

  • Inadequate hazard identification before entry.

  • Failure to monitor atmospheric conditions.

  • Poor emergency response planning or equipment readiness.


Establishing Your Context for Confined Space Risk Management

To manage confined space risks effectively, it’s critical to define your context:

  • Scope: Are you addressing all confined space activities or focusing on high-risk tasks?

  • Activities: Are tasks routine (e.g., inspections) or non-routine (e.g., repairs)?

  • Spaces: Identify specific confined spaces, their hazards, and how they are accessed and used.


Clearly defining your context ensures that your risk management efforts are focused and effective.


Constructing Your Critical Risk Bowtie Analysis

A Critical Risk Bowtie Analysis is a powerful tool for managing confined space risks. It maps the pathways leading to incidents and identifies controls that can prevent or mitigate them.

Mobile Equipment Critical Risk Management Bowtie
Bowtie Analysis Structure and Elements

Step 1: Define Your Unwanted Event - Centre of Bowtie

The first step is to identify your unwanted event, which is the critical scenario or grouping you aim to manage, such as a worker becoming exposed to an irrespirable atmosphere. This event represents the central focus of your analysis—the point where risk must be prevented or mitigated. Select an unwanted event that could lead to the highest consequence outcomes in your context.


For example, you may choose to prioritise high-risk scenarios first and address lower-priority areas in subsequent analyses.


Step 2: Identify Causes (Threats) - Left-Hand-Side of Bowtie

Once your unwanted event is established, the next step is to identify the causes or threats that could lead to it.

  • These causes must be likely and direct pathways to the event.

  • Avoid being too broad or generic, as this can dilute the analysis and lead to ineffective control identification.


Examples include:

  • Lack of ventilation or monitoring.

  • Improper use of tools or equipment.

  • Failure to follow entry procedures.


By focusing on specific causes, you ensure that your controls are tailored and relevant to managing the risk.


Step 3: Identify Consequences (Impacts) - Righ-Hand-Side of Bowtie

Next, identify the consequences or impacts that could result from the unwanted event occurring.

  • Consequences must be direct outcomes of the event.

  • These help you understand what’s at stake and guide the development of appropriate mitigating measures.


Examples include:

  • Worker injury or fatality.

  • Fire or explosion.

  • Engulfment.


Like causes, keeping consequences specific ensures the analysis remains focused and actionable.


Step 4: Map Preventing and Mitigating Controls

Once you have identified causes and consequences, it’s time to map out controls. Controls are the measures implemented to either prevent the unwanted event from occurring or reduce its impact if it does. Start with identifying what controls you already have in place managing the critical risk, then you can start to identify gaps and opportunities to strenthen your causal pathway with proposed or new controls. Controls are acts, objects or technical systems. Try to call out the actual control, not the document that manages the control.


Preventing Controls

  • These controls address the causes (threats) on the left side of the bowtie.

  • Their purpose is to stop the unwanted event from happening.

  • Think of them as barriers that block or interrupt the progression from a cause to the unwanted event.


Examples include:

  • Atmospheric Monitoring Equipment: Ensures safe oxygen levels and detects toxic gases.

  • Confined Space Entry Permits: Formal procedures for entry and hazard identification.

  • Ventilation Systems: Removes hazardous gases and maintains airflow.


Mitigating Controls

  • These controls address the consequences (impacts) on the right side of the bowtie.

  • Their purpose is to reduce the severity or extent of the impacts if the unwanted event occurs.

  • They act as safety nets that limit harm, damage, or loss.


Examples include:

  • Emergency Rescue Plans: Trained personnel and equipment ready for confined space rescues.

  • Personal Protective Equipment (PPE): Respirators or harnesses to protect workers in hazardous conditions.

  • Emergency Communication Devices: Two-way radios or alarms for rapid response.


By clearly distinguishing preventing and mitigating controls, the bowtie ensures you’re addressing both the likelihood and the consequences of the event.


Why Focus and Specificity Matter

The success of a bowtie analysis hinges on its ability to identify specific controls that effectively manage risks. If the causes or consequences are too broad, you risk overlooking critical controls or diluting their effectiveness. A focused analysis ensures that every identified control is targeted, actionable, and essential.


By following these steps, you can construct a comprehensive bowtie analysis that visualises your critical risks and the pathways to managing them.


Identifying Critical Controls

Critical controls are the cornerstone of managing risks in a bowtie analysis. These are the controls that, if absent, ineffective, or failed, would have a significant impact on the likelihood of an unwanted event occurring or on the severity of its consequences. Proper identification and selection of critical controls ensure that resources are focused on the most important barriers to risk.


Preventing Critical Controls

Preventing critical controls are focused on the causal pathways leading to the unwanted event. These controls act as barriers to stop the event from occurring.


What to Ask:

  • Would the absence or failure of this control significantly increase the likelihood of the unwanted event?

  • Is this control essential to interrupting the causal pathway?


By identifying and implementing preventing critical controls, you can drastically reduce the probability of the unwanted event occurring.


Mitigating Critical Controls

Mitigating critical controls are focused on the consequences of the unwanted event. These controls do not stop the event from occurring but instead limit its severity or extent.


What to Ask:

  • Would the absence or failure of this control result in the highest potential consequence?

  • Is this control critical to reducing harm, damage, or loss if the unwanted event occurs?


Mitigating critical controls ensure that even if the event occurs, the outcomes are managed to minimise harm.


Key Considerations for Identifying Critical Controls

  • Critical controls must be effective, measurable, and reliable to ensure they perform as intended.

  • Avoid overloading the analysis with non-critical controls. Focus only on those that significantly influence the risk pathways or outcomes.


By selecting critical controls with this structured approach, you create a robust system that prioritises the most impactful barriers to risk.


Critical Control Management

Critical control management is an essential component of effective risk management. It ensures that the most important controls in your system are clearly understood, properly implemented, and rigorously maintained to prevent or mitigate high-consequence events. This process involves understanding each critical control’s requirements, verifying their effectiveness, and managing their performance over time.


Critical Control Performance Requirements

To effectively manage critical controls, it is crucial to understand their performance requirements. This involves developing a Critical Control Performance Standard that clearly defines the expectations and parameters for each control. The performance standard should include the following key elements:


Objectives of the Critical Control

Define the purpose of each control, such as maintaining safe oxygen levels.


Performance Requirements

Define how the control must perform to meet its objectives. This includes specifying measurable criteria, such as gas detection thresholds.


Critical Operating Parameters

Identify operational thresholds or conditions under which the control must remain effective, such as maximum exposure times.


Failure Modes

Outline potential mechanisms of failure and how they might occur (e.g., wear and tear, human error, environmental factors, sensor malfunctions).


Training Requirements

  • Specify the knowledge and skills required for personnel to operate, inspect, and maintain the critical control effectively.


Maintenance and Inspection Requirements

  • Detail the frequency and type of maintenance activities, as well as inspection protocols to ensure ongoing functionality.


Critical Control Verification (CCV) Process

The Critical Control Verification (CCV) process is vital for ensuring that critical controls are implemented, effective, and not at risk of failure. This process typically involves three primary activities:


Verifying Critical Controls Are in Place

In-Field Observations: Confirm that critical controls have been physically implemented in the workplace. For example, proper use of entry permits, PPE and RPE is being worn, or procedures are present and accessible.


Verifying Critical Controls Are Effective

In-Field Testing: Test the functionality of critical controls to ensure they perform as intended. For example, confirm gas detectors are bump tested and caliibrated.


Verifying Critical Controls Are Not at Risk of Failure

  • Maintenance Programs: Ensure regular servicing, repairs, and inspections are conducted to prevent degradation or failure.

  • Audits and Certifications: Use independent or internal audits to confirm compliance with performance standards and identify potential risks.

  • Detecting Failure Mechanisms: Monitor and address early signs of failure, such as wear and tear, system alerts, or operational deviations.


Defining Verification Frequency

The frequency of verification activities should be based on the level of exposure and the number of areas where the critical control is implemented. Consider the following factors:


High-Exposure Areas

For controls in high-risk or high-frequency areas (e.g., environments with frequent toxic gas risks), verification should occur more frequently to account for the increased likelihood of failure or incident.


Multiple Implementation Sites

When a control is implemented across numerous locations (e.g., operations with multiple confined spaces), verification activities should be scaled to ensure all instances are regularly checked.


Risk-Based Scheduling

Use the severity of potential consequences and historical performance data to determine appropriate intervals for verification (e.g., daily, weekly, or monthly checks).


Why Critical Control Management Matters

By systematically managing critical controls, organisations can ensure that these essential barriers remain functional, reliable, and aligned with their intended objectives. Performance standards provide a clear understanding of how controls should operate, while verification processes offer confidence that controls are effective and ready to respond when needed.


This structured approach ensures that risks are not only managed but also proactively mitigated, contributing to a safer and more resilient workplace.


Conclusion: Managing the Critical Risk of Confined Spaces

Working in confined spaces poses unique and serious risks, but these can be effectively managed with the right tools and processes. By identifying potential hazards, implementing robust controls, and verifying their effectiveness, organisations can protect workers and ensure safe operations.


To support you in managing this critical risk, we offer the Confined Space Critical Risk Package, a comprehensive solution tailored to your industry and specific confined space risks.

If you have an existing critical risk program in place for confined space that is due for a review, you may be interested in a Comprehensive Critical Risk Audit.

Who We've Worked With

We have extensive experience developing successful critical risk management and critical control programs for a diverse range of clients, including:

  • Glencore

  • BHP

  • Ampol Australia

  • Local councils

  • Leading construction companies

  • Manufacturing companies

  • NDIS providers

  • Charities and not-for-profits


Our expertise spans industries and sectors, allowing us to tailor solutions to meet the unique challenges faced by our clients. Let us bring this experience to your organisation and help you achieve effective and sustainable risk management outcomes.


What’s Included:

  • Tailored Approach: Customised to your industry and confined space hazards.

  • Comprehensive Bowtie Analysis: A detailed analysis of causes, consequences, and controls.

  • Critical Control Identification and Selection: Structured tools to identify and prioritise critical controls.

  • Critical Control Performance Standard Document Suite: Define objectives, performance requirements, and training needs for each critical control.

  • Critical Control Verification Document Suite: Ensure controls are effective and not at risk of failure through observation and testing tools.

  • Consultation and Implementation Guide: Step-by-step guidance to integrate the package effectively.

  • Worker Toolbox Talk: Equip your team with the knowledge to manage confined space risks.


Tailored to a Single Bowtie Analysis

This package is designed for a single bowtie analysis, focusing on a well-defined grouping of scenarios that form an unwanted event. Selecting an appropriate grouping ensures the analysis is precise, actionable, and effective in managing your critical risks.


By leveraging this comprehensive package, you can streamline your risk management process, ensuring critical controls are in place, effective, and verifiable. Click below to take the first step in managing your confined space critical risks confidently and effectively.



You will be asked in the checkout to provide information on your industry and the activities you'd like included in the confined space critical risk package.


Further customisations will be required including context and scenarios. This package will be delivered via email within 5 business days.


Principal Hazard Management Plan (PHMP) Confined Space Add-On

The Principal Hazard Management Plan (PHMP) is a vital document required by many industries to address high-consequence risks effectively. This add-on complements our Critical Risk Packages by providing a comprehensive framework tailored to your specific industry and operations.


What Is a Principal Hazard Management Plan (PHMP)?

A PHMP is a high-level strategic document that:

  • Identifies specific principal hazards in your operations (e.g., working at heights, confined spaces, or mobile equipment interactions).

  • Outlines your organisation's approach to managing these hazards, ensuring compliance with legislative and regulatory requirements.

  • Provides a clear structure for hazard assessment, risk controls, and ongoing monitoring.


What’s Included in the PHMP Add-On?

When you add the PHMP to your Critical Risk Package, you’ll receive:


Tailored Principal Hazard Management Plan:

  • A detailed plan aligned with your industry and operational requirements.

  • Integration of specific risks and controls identified in your Critical Risk Package.


Hazard Identification and Risk Assessment:

  • Comprehensive identification of principal hazards and associated risks.

  • Strategies to mitigate risks effectively and sustainably.


Compliance Framework:

  • Alignment with relevant industry legislation, standards, and codes of practice.


Monitoring and Review Framework:

  • Procedures for continuous improvement, audits, and periodic reviews.


Actionable Strategies:

  • Specific control measures, implementation steps, and roles/responsibilities.


Why Add a PHMP to Your Package?

  • Regulatory Compliance: Ensure your organisation meets all legislative requirements for managing principal hazards.

  • Customised Solutions: Receive a plan tailored to your operations, ensuring relevance and practicality.

  • Enhanced Risk Management: Build a robust framework to manage high-consequence risks effectively.



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