AMSASHE00003

6 0 0 9 2 0 4 9

AMSASHE00003

Name of document AMSA Confined space procedure

AMSA document
number
AMSA SHE 00003
Version 04 Revision date (every 3 years) 1 Nov 2016
This document
AMSA SHE 00003 rev 03 Confined space procedure
replaces

Reason for revision

Section 10: Replace bi-annual risk assessments with annual risk assessments.
(marked in yellow)
■ AMSAFETYST002: Confined space
Related ArcelorMittal
■ AMSAFETYST012: Gas Hazardous Areas
documents / records ■ AMSAFETYST014: HIRA

Other documents / templates:

■ AMSA SHE 00006: AMSA Gas Hazardous Areas procedure
■ AMSA SHE 00011: AMSA Dangerous and toxic gasses procedure
■ AMSA SHE 00012: AMSA Ventilation procedure
■ AMSA SHE 00013: AMSA Atmosphere tester procedure
Related ArcelorMittal
■ AMSA SHE 00014: AMSA Manhole and similar spaces procedure
South Africa ■ AMSA SHE 00025: AMSA Permit to Work
documents / records ■ AMSA SHE 00028: AMSA Gas monitor procedure
■ AMSA SHE 00030: AMSA Hot work procedure
■ Appointment letter for confined space attendant
■ Appointment letter for confined space atmospheric tester
■ Risk assessment (example)

Effective date 1 Nov 2016 Implementation date 1 Nov 2016

Action Name Date Signature

Compiled by: Jan Le Grange 31-Jan-12

Hilda van der Westhuizen and

Revised by: Jan le Grange
01-Jul-13

Willem Prins
Recommended by: ArcelorMittal South Africa 18-Oct-13
Champion

Francois Bezuidenhout
Approved by: Safety, Health and Wellness 18-Oct-13
Group Manager
1. FACTORS FOR TASK ACCOMPLISHMENT
1.1. CRITICAL OPERATIONS PROCEDURES

Emergency Procedure
Quality procedure

Engineering Procedure Safety Procedure

1.2. CRITICAL FACTORS

QUALITY
Not applicable.

SAFETY
This document contains specific safety instructions regarding confined spaces applicable to all
ArcelorMittal South Africa plants and is in line with the ArcelorMittal global standards. Additional specific
instructions are added in this document that must be applied and adhered to at all times. Failure to comply
with this procedure may result is serious incidents and fatalities.

HEALTH
Certain confined areas may have a negative health impact as described in this document.

ENVIRONMENT
Not applicable.

1.3. PURPOSE
The purpose of this procedure is to set minimum requirements that must be applied for entering and
performing work in confined spaces.

1.4. SAFETY EQUIPMENT

Select the correct safety equipment from the list below as applicable to a specific task within the confined
space.

Overalls
Wool socks
Safety shoes

Safety glasses
Dust mask
PVC overall

Safety / hard hat
Gum boots
Portable gas monitor

BA set
Safety harness
O2 monitor

Ear plugs
Isolation locks
CO monitor

Safety boots
Full length rubber gloves
Face shield

Leather gloves
Mono goggles
Life line

“Copyright ArcelorMittal South Africa Limited. This manual is the property of ArcelorMittal South Africa and
may not, as a whole or in part, be reproduced or alienated without the prior written permission of the
copyright holder.”

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 2 of 24
INDEX

TOPIC PAGE
2 Scope 4
3 Confined space process flow 4
4 Statutory requirements 5
5 AMSA procedures 6
6 Definitions 6
7 Confined space classification 8
8 Confined space identification 9
9 Gas area 11
10 Actions after classification 11
11 Confined space risk assessment 13
12 Entry requirements 13
13 Role players and training 15
13.1 Entrants 15
13.2 Entrants control 16
13.3 Standby persons 16
13.4 Permit issuers 17
13.5 Permit receivers 17
13.6 Permit valid period 18
13.7 Emergency and rescue teams 19
13.8 Test of atmosphere 19
13.9 Reporting of incidents 19
14 Atmospheric entry rules 19
15 Gases – symptoms and consequences 20
16 Audits 20
17 Records 21
18 Communication equipment 21
19 Safety precautions 22
20 Confined space hot work 22
21 Drills 22
22 Training and re-training guidelines 22
23 Conclusion 23
24 Revision details 23

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 3 of 24
2. SCOPE
This procedure is applicable to ArcelorMittal employees, contractors, subcontractors and hired labour
employees performing work for or on behalf of ArcelorMittal on premises owned, rented or otherwise
occupied by ArcelorMittal.
The document serves as a high level generic procedure for working in confined spaces and should not be
viewed as a detailed task by task procedure for working in such environments. Each plant must add value by
compiling detailed safe work procedures and instructions applicable to each confined space.

3. CONFINED SPACE PROCESS FLOW

START

Legal Requirements and standards OHS-Act General safety regulation 5

Risk Assessment according to legal

Identify confined spaces requirements

According to definition of confined

Classify confined spaces space classes

According to AMSA signage

Display symbolic signage standard

Risk assessment on each confined 17 Pager baseline risk assessment

space and not a simple HIRA

Dedicated permit per confined

Develop entry requirements space

- Entrants in confined space

Roll players responsiblities and - Permit Issuer
training - Standby person
- Resque team, etc.

Management audits to ensure

Audits
compliance

Records Documentation to be kept on record

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 4 of 24
4. STATUTORY REQUIREMENTS

General safety regulations par 5 related to confined spaces are listed next and purposely numbered
according to the general safety regulations. This must be understood and will be simplified in the contents
of this procedure.

(1) An employer or a user of machinery shall take steps to ensure that a confined space is entered by an
employee or other person only after the air therein has been tested and evaluated by a person who is
competent to certify the safety thereof, and who has certified in writing that the confined space is safe and
will remain safe while any person is in the confined space, taking into account the nature and duration of
the work to be performed therein.

(2) Where the provisions of sub regulation (1) cannot be complied with the employer or user of machinery,
as the case may be, shall take steps to ensure that any confined space in which there exists or is likely to
exist a hazardous gas, vapour, dust or fumes, or which has or is likely to have, an oxygen content of less
than 20% per cent by volume, is entered by an employee or other person only when:

(a) Subject to the provisions of sub regulation (3), the confined space is purged and ventilated to provide a
safe atmosphere therein and measures necessary to maintain a safe atmosphere therein have been taken;
and

(b) The confined space has been isolated from all pipes, ducts and other communicating openings by
means of effective blanking other than the shutting or locking of a valve or a cock, or, if this is not
practicable, only when all valves and cocks which are a potential source of danger have been locked and
securely fastened by means of chains and padlocks.

(3) Where the provisions of sub regulation (2) (a) cannot be complied with, the employer or user of
machinery shall take steps to ensure that the confined space in question is entered only when the
employee or person entering is using breathing apparatus of a type approved by the chief inspector and,
further, that:

(a) The provisions of sub regulation (2) (b) are complied with;

(b) Any employee or person entering the confined space is using a safety harness or other similar
equipment, to which a rope is securely attached which reaches beyond the access to the confined space,
and the free end of which is attended to by a person referred to in paragraph (c);

(c) At least one other person trained in resuscitation is and remains in attendance immediately outside the
entrance of the confined space in order to assist or remove any or persons from the confined space, if
necessary; and

(d) Effective apparatus for breathing and resuscitation of a type approved by the chief inspector is available
immediately outside the confined space.

(4) An employer or user of machinery shall take steps to ensure that all persons vacate a confined space
on completion of any work therein.

(5) Where the hazardous gas, vapour, dust or fumes contemplated in sub regulation (2) are of an explosive
or flammable nature, an employer or user of machinery shall further take steps to ensure that such a
confined space is entered only if:

(a) The concentration of the gas, vapour, dust or fumes does not exceed 25 per cent of the lower explosive
limit of the gas, vapour, dust or fumes concerned where the work to be performed is of such a nature that it
does not create a source of ignition; or
(b) Such concentration does not exceed 10 per cent of the lower explosive limit of the gas, vapour, dust or
fumes where other work is performed.

(6) The provisions of this regulation shall mutatis mutandis (with the necessary changes) also apply, in so
far as they can be so applied, to any work which is performed in any place or space on the outside of and
bordering on or in the immediate vicinity of, any confined space, and in which place or space, owing to its
proximity to the confined space, any hazardous article, oxygen-deficient atmosphere or dangerous
concentration of gas, vapour, dust or fumes may occur or be present.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 5 of 24
 5. AMSA PROCEDURES
From the global ArcelorMittal standards the ArcelorMittal South Africa (AMSA) procedures document is set up
to include local legislative requirements. The AMSA SHE 00003 procedure document was set up taking into
account the global standards and FPS Protocol and is applicable to all ArcelorMittal South Africa plants.

Take note that some information contained in this procedure may not be discussed in detail. Employees must
ensure that they are familiar with the contents of the global standards. It can be accessed on the ArcelorMittal
South Africa portal [see ArcelorMittal South Africa Fatality Prevention Standards FPS].

The remainder of this document will describe confined spaces in a simplified manner in order for our
employees, contractors and hired labour workers to understand the correct procedures that must be applied
before entering and during execution of work within confined spaces.

6. DEFINITIONS
The terminology and definitions used in this document are as follow:

6.1 Confined space (long definition)

A confined space is an enclosed or partially enclosed space that:
• Has been identified as such in a risk assessment and/or in a local regulatory process;
• Is not intended or designed primarily as place of work;

A confined space may have restricted entry and exit; and,

• May have an atmosphere which contains potentially harmful levels of contaminant;
• May not have a safe level of oxygen e.g. following a nitrogen purge; or
• May contain a material that has the potential to entrap or engulf an entrant
• May contain or has the potential to contain a hazardous atmosphere
• May have walls that converge inward or floors that slope downward and taper into a smaller area
which could trap or asphyxiate an entrant
• May contain any other recognised safety or health hazard, such as unguarded machinery, exposed
live wires or heat stress.

A confined space may include, but is not limited to:

• Storage tanks, silos or areas of storage, process vessels, boilers, pressure vessels, tank-like
compartments that have only a manhole for entry, ceiling and floor spaces, spaces occupied by pipes
and cables (considering galleries in particular);
• Open-topped spaces such as pits, clarifiers or grease traps, or excavations more than 1.5 metres
deep;
• Pipes, pumps, sewers, shafts, ducts, drains, tunnels, cellars, basements and similar structures
• BOF (Best Oxygen Furnace) vessel, EAF (Electric Arc Furnace) vessel etc. since entry / exit is not
easy and / or gas may be present.
• Underground vaults, tanks, storage bins, manholes, pits, silos, process vessels and pipelines.

6.2 Confined space (short definition)

A confined space is large enough and so configured that an employee can bodily enter and perform
assigned work and has limited or restricted means for entry or exit and is not designed for continuous
employee occupancy. Confined spaces include but are not limited to underground vaults, tanks, storage
bins, manholes, pits, silos, process vessels and pipelines. Authorisation is required for entrance. A confined
space has one or more of the following characteristics:
• contains or has the potential to contain a hazardous atmosphere
• contains a material that has the potential to engulf an entrant
• has walls that converge inward or floors that slope downward and taper into a smaller area which could
trap or asphyxiate an entrant
• contains any other recognized safety or health hazard, such as unguarded machinery, exposed live
wires or heat stress.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 6 of 24
6.3 Gas areas: A gas area is an area where gas is used or where gas could be present. It differs to a
confined space in that it is an open area with multiple entrances and exits and that entrapment or
engulfment is not likely. Unlike a confined space where a permit to work (PTW) is required, gas areas
may be entered, after conforming to set entry and work procedures.

6.4 Hazardous atmosphere: This means an atmosphere that may expose employees to the risk of death,
incapacitation and impairment of ability to self rescue, injury, or acute illness from contaminants.

6.5 Contaminant: This is any dust, fume, mist, vapour, gas, or any other substance in liquid or solid form,
the presence of which may be harmful to human health and safety.

6.6 Entry permit: A work permit issued by a competent person, appointed by the 2.7(a) to ensure that the
existing hazards in a confined space have been properly assessed and that the necessary preventative
and protective measures and procedures have been taken to ensure the health and safety of workers
involved in confined entry.

6.7 Breathing apparatus (BA) system: A breathing apparatus used in areas where there is insufficient
oxygen or hazardous levels of gases.

6.8 Standby person: An employee that is trained in handling the hazards associated with the task which is
being conducted. This employee must also be trained in resuscitation and be given the authority to take
the necessary steps to deal with any possible incidents.

6.9 GMR 2.1 Appointee: Person appointed by the General Manager ArcelorMittal South Africa at our
different sites as GMR 2.1 and registered as competent person in terms of the General Machinery
Regulation 2 by the Department of Labour. (Extract from OHS ACT GMR - Supervision of machinery
GMR 2.1). In order to ensure that the provisions of the OHS Act and these Regulations in relation to
machinery are complied with, an employer or user of machinery shall, subject to this regulation, in
writing designate a person in a full-time capacity in respect of every premises on or in which machinery
is being used.

6.10 GMR 2.7(a) Appointee: An employer or user of machinery may designate one or more competent
persons to assist a person designated in terms of sub regulation (1).

6.11 Competent person: Refer to the GMR regulation 1 (a) to (d) for a full description of a competent
person in terms of the GMR regulations. In short:
• A person who has served an apprenticeship in an engineering trade … at least 5 years experience
… not less than one year’s experience …
• An engineering diploma in mechanical or electro-technical fields … at least T3 or T5 … not less than
2 year’s experience …
• A graduate engineer with not less than 2 year’s experience …
• A certified engineer.

6.12 Acceptable entry conditions: An AMSA confined space risk assessment is done on each confined
space to determine the hazards and risks involved, spelling out the mitigation that must be in place
before such a space may be entered. These are referred to as the acceptable entry conditions under
section 10 of the risk assessment.

6.13 Common monitor: This term is used to describe a monitor used inside a confined space in order to
eliminate the necessity for each entrant to wear a personal gas monitor. The “common” monitors may for
example be of permanent installation type used inside the confined space during occupancy. The
detection range and size of the confined space shall determine how many of the monitors should be
used and must be captured in the confined space risk assessment. The monitors must cover the entire
space and must be audible and loud enough for all entrants to hear.

6.14 HIRA: Hazardous identification and risk assessment

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 7 of 24
7 CONFINED SPACE CLASSIFICATION
At AMSA confined spaces are classified for control purposes as follow:

Class 1 confined space

It is a space containing no dangerous gas, vapour, dust or fumes but where there is or may be for example
the possibility of engulfment or entrapment. Prior to entering the air quality must be tested and evaluated by
a competent person to certify the safety thereof, who must certify in writing that the space is safe and will
remain safe. The space atmosphere is to be monitored continuously while people are working in it. At this
point we therefore just test without any actual mitigation, purging or ventilating but may lockout against
engulfment or entrapment. When something goes wrong, vacate and re-evaluate.

Simplified: Is a space without dangerous gases but unsafe level of oxygen may occur and engulfment or
entrapment is possible. Test for safe atmosphere before enter and keep an appropriate mobile gas monitor
in the area at all times.

Another way of a simplified explanation is that ventilation is not required and mitigation of the risk of gases or
oxygen is not required, but a gas monitor in the area must be used at all times.

Class 2 confined space

It is a space in which dangerous gases, vapour, dust or fume is present or may be present, or where the
oxygen content is lower than 20.0% by volume. In such a case the following requirements are to be met
before the space may be entered:
• The space is to be purged and ventilated to provide a safe atmosphere and measures must be taken to
maintain a safe atmosphere;
• All pipes, ducts and communication openings to the confined space are to be effectively blanked off and
locked out; and
• The atmosphere in the confined space is to be monitored continuously to ensure that it remains safe.

Simplified: Is a space where dangerous gases or lack of oxygen is or may be present. Must take steps to
ensure a safe atmosphere before entering and monitor the area constantly. Another way of explaining this is
that mitigating steps are successfully, in other words lockout, ventilation, etc. to make the space safe for
entry and that it will remain safe.

Class 3 confined space:

This is a confined space that, unlike class 1 and class 2 spaces cannot be made safe, or once safe, cannot
be guaranteed that it will remain safe. Such a class 3 confined space may be entered only by persons
wearing breathing apparatus, or having it available for immediate use, and only if the following conditions are
met:
• The breathing apparatus is of a type approved by the chief inspector;
• All pipes, ducts, shafts and other communicating openings to the confined space are positively blanked
off and locked out;
• The person entering the confined space is to wear a safety harness to which is attached a rope which
reaches beyond the access to the confined space and of which the free end is attended to by a standby
person and is tied to a fixed structure;
• A standby person must be present at all times outside the confined space, and when necessary, to
initiate rescue actions. The standby person must have a valid first aid certificate.
• A rescue team must be present at a confined space class 3 during entry. When more that one class 3
confined space must be entered, more rescue teams must be available. This is normally not possible
and the following shall apply:
o Conduct a risk assessment to determine and ensure that the rescue team will be situated centrally
and be able to respond to any confined space in without compromising the safety of entrants,
rescue efforts and response time.
o When the rescue team must respond to a rescue call, all other confined spaces must be vacated
immediately until the rescue team is available again to respond to emergency calls.
• Spare breathing apparatus and resuscitation apparatus is to be available directly outside the access to
the confined space; and
• Persons wearing breathing apparatus must be trained and be competent in its use.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 8 of 24
 Simplified: Dangerous gas or a lack of oxygen is present or may be present and cannot be made safe or be
maintained safe. The use of breathing apparatus to enter is compulsory. Retrieval line, rescue team, etc. are
compulsory. Another way of explaining it is that mitigation is unsuccessful, there is still a harmful
atmosphere present or could be present without warning.
Note: If the atmosphere is harmful, a breathing apparatus must be used. If the atmosphere is safe at the
time, a breathing apparatus must be worn and ready for immediate use should the atmosphere become
unsafe.

8 CONFINED SPACE IDENTIFICATION

The legal requirements, AMSA requirements, definitions and classification of confined spaces were
explained. With this in mind, the first step is that each plant must identify the confined spaces in their area.
The following must be in place at all ArcelorMittal South Africa plants:
o A risk assessment must be done to identify all confined spaces according to the definition and legal
requirements of confined spaces. This is done on section 2 of the generic confined space risk
assessment document used at all AMSA plants.

From the confined space risk assessment, the following questions must be answered. Consider the criteria for
a confined space under normal circumstances when entry into the space is required:
A confined space is:
1. Is an enclosed or partially enclosed space. No  Yes 
2. Is the space above or below atmospheric pressure during occupancy. No  Yes 
3. Is not intended or designed primarily as a place of work (i.e. it is designed to perform a
function with conditions not suitable for human occupancy or to contain materials that are No  Yes 
harmful to people).
4. Has a restricted means of entry and exit. No  Yes 

Blast Furnaces, Coke Ovens and re-heat furnaces are examples of areas where gases are usually present.
However, considering the first 4 questions in the case of a re-heat furnace the answers to these questions are
as follow:

1. No – the area around the furnace is not an enclosed or partially enclosed space. It is completely open
with sufficient ventilation.
2. No – it remains at atmospheric pressure.
3. No – can enter the area and perform work without any problems.
4. No – open with various entries and exits with easy access.

It indicates that the physical composition of the area is not a confined space. Next, consider the following
questions.

And is liable at any time to:

5. Have an atmosphere that contains potentially harmful levels of contaminant. No  Yes 
6. Have an oxygen deficiency or excess. No  Yes 
7. Cause or be at risk of engulfment. No  Yes 
8. Cause or be at risk of entrapment. No  Yes 
For the area to be defined as a confined space at least one of the questions from 5 to 8 must be answered as
‘Yes’. There may be or there is harmful gases around the furnace, thus by definition it is a confined space, but
we classify it as a gas area where entry control measures and procedures must be in place. If gas is detected,
it is easy and quick to vacate the area. A permit is not required.

A “Yes” to one or more of questions 1 to 4 and a “Yes” to one or more questions from 5 to 8 indicates a
confined space where a permit is required.

Is the area a confined space by definition? No  Yes 

Note – The above criteria is a guideline, as there may be other reasons/circumstances that do or do not
define the area as a ‘confined space’, and if so, please list those reasons below in ‘comments’.

Is the area a confined space for other reasons? Refer to the important note on the
No  Yes 
last page of the risk assessment under section 17. It is also explained below.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 9 of 24
Comments:

Confined space for other reasons (section 17)

After answering questions 1 to 8 under section 2, consider “other” reasons why it should be classified as a
confined space. The following examples are used as a guideline to ensure that plant management considers
similar plant specific possibilities.

Gas pockets
By answering questions 1 to 8 under section 2, by definition it may indicate that it is not a confined space.
However, consider “gas pockets” that could develop during a gas leak. In open areas, such areas will be
classified as gas hazardous areas. But, if gas can accumulate and get trapped in certain areas that are
enclosed or partially enclosed, then it becomes a confined space. Remember that you need to state for a
class 2 confined space that the atmosphere is safe and will remain safe for the duration of the work. If you
cannot make such a statement due to possible gas leaks that could turn the space into a confined space, then
it must be classified as a class 3 confined space!

Type of work
Again, when answering questions 1 to 8 under section 2 and by nature (definition) the space is not a confined
space, consider the type of work that will be done. Some of these tasks are listed under section 6 of the
generic risk assessment. If an adequate procedure for the specific (normally hazardous work) is in place that
will not turn the space into a “confined space” then it is sufficient. Steam cleaning may be a hazardous task,
but will not necessarily turn a space into a confined space. Plants must be sensible with tasks such as
welding activities where fumes and argon welding may require ventilation. If the work that must be done in a
specific space normally includes welding or other hazardous activities, such as painting that could cause a
harmful atmosphere, consideration must be given whether it should be permanently classified as a confined
space. If the decision based on this logic is taken to classify it as a confined space, then entrance will
ALWAYS be as for confined space entry, no matter the work activities.

Note: If classified as a confined space, then the risk assessment and permit conditions will spell out the
required mitigation. If not classified as a confined space, then the following examples shall be minimum
requirements:
• Diesel/petrol generators and tools: These are fueled power tools with CO emissions. When operated
in partially enclosed spaces, a multi-cell has monitor with explosive limits, CO and oxygen cell shall
be used at all times.
• Dusts / fibers: Plant specific procedures for the type of fibers or fumes shall be in place, spelling out
mitigation and required PPE. This could be obtained in some cases from the Material Safety Data
Sheet (MSDS).

Metal vessels
It is further important to take into consideration tasks within enclosed metal vessels. Refer to important legal
instructions stipulated in the OHS-Act as follow:
o GSR (General Safety Regulations) 9 and in specific 9(3) – welding in metal vessels (in contact with
large masses of metal).
o EMR (Electrical Machinery Regulations) 11(1) and 11(2) – lighting in enclosed metal vessels.

It is strongly recommended that such spaces be considered for classification as confined spaces, simply
because the correct entry and work procedures including compliance with the above regulations will be
permanently captured in the risk assessment and not be “forgotten” or overlooked at some stage. GSR 9(3)
states that there must be a standby person present, just as for a class 3 confined space. Again, it is the plant
management that must take risk based decisions to ensure that correct procedures are followed to protect our
workforce. If the decision is taken to classify such spaces as confined spaces, then entrance will ALWAYS be
as for confined space entry.

Conclusion
The above are examples to assist plant management in taking correct decisions. There must be 100%
certainty that the atmosphere is safe and will remain safe for the duration of the work. If not, then by default it
becomes a class 3 confined space!

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 10 of 24
 9 GAS AREA
To avoid confusion, it must be explained that a “Gas Hazardous Area” is an area where there is or could be a
presence of gas. However, these areas are not enclosed spaces but open areas with sufficient ventilation,
no possibility of entrapment and without limited entries and exits. Examples of these are found around the
reheat furnace at the mills, areas at Blast Furnaces and at Coke Making.

Different entry requirements and control measures are applicable as per plant specific procedures and is not
part of this confined space document. A permit to work is also not necessarily a requirement.
Question:
Enclosed or partially enclosed space that may
have restricted entry and exit;

NO
Yes or No?

YES

Not a gas hazardous

NO Harmful Harmful NO area so the FPS
atmosphere? atmosphere? standards do not
apply

Not a confined
space so the FPS a) Engulfment YES YES
standards do not b) Entrapment
apply
Gas area: Apply
YES
Confined space: Entry specific procedures to
Permit compulsory enter and work in gas
areas

AMSA SHE 00003 AMSA SHE 00006

10 ACTIONS AFTER CLASSIFICATION

• It is the responsibility of the Plant Manager (GMR 2.7(a) appointee) to classify the confined spaces by
definition as class 1, class 2 or class 3 confined spaces. This is done on section 3 of the confined space
risk assessment document.

• All confined spaces must be on a confined space register, updated continuously. The register shall be
according to the AMSA generic template.

• An annual risk assessment must be conducted for each of the identified confined spaces. If confined space
conditions change, a new risk assessment must be conducted, the permit must be updated and all
entrants’ must be re-trained. Triggers for tracking changes and re-training could be:
o Actions stemming from incident investigations;
o Actions stemming from root cause analysis (RCA) investigations;
o Organisational changes or individual work performance
o Changes to the ArcelorMittal standards and ArcelorMittal South Africa procedures document.

• All confined spaces must have protected entry where practical possible. This can be done through the use
of entrances that can be closed / sealed off and by appropriate signage. However, in the case where the
entrances cannot be closed / sealed off, appropriate signage in correct positions must be used.

• The only signage to be used must be the standard signage developed for the different AMSA sites.
Displayed on the sign will be the confined space name and number (inventory number).

• Manholes on pipes and similar structures high up from ground level that is not readily accessible through
stairways or other means but for example with a scaffold or cherry picker, may be sign-posted with the sign
at ground level. The sign may be flat on ground level indicating a confined pace manhole 4 meters, 5
meters, etc. above. It may also be fitted on a pole with a proper message indicating a confined space
manhole above.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 11 of 24
Vanderbijlpark Works Pretoria Works, Saldanha Works Newcastle Works
Vereeniging Works Special Profiles SB.0065-A SB.0065-G
Tubular Products, AMCC, PTA
AMCC, VDB SB.0065-C
SB.0065-B

Take note that all manholes,

pipelines and spaces where access
is gained through force are
considered confined spaces as
illustrated on this signage posted all
entrances to ArcelorMittal South
Africa sites (signboard SB.0094).

This additional signage is also posted throughout our plants.

(Signboard SB.0065D).

Where a confined space has more than one

entry, the confined space number can be
followed with a dash A, B, C, etc. The example
below is for a space with 3 entrances.
Example: MM-CS-001-A, MM-CS-001-B, MM-
CS-001-C

The picture shows an example of manhole. It is a sump hole of 7.6 meters

deep that is connected to the reheat furnace exhaust gas chamber. It may
have an oxygen deficiency or harmful gases may be present. Only one
entrance at the manhole, thus a very dangerous place to enter that requires
specific entry conditions and procedures which include a retrieval line
attached to a winch.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 12 of 24
The hazards, risks and entry requirements to manholes, sump pumps, water channels, etc. are explained in a
separate document AMSA SHE 00014.

11 CONFINED SPACE RISK ASSESSMENT

With the identification of confined spaces done, on register and signage posted, a risk assessment must be
done. The most important step is this comprehensive risk assessment that must be done on each of the
confined spaces. The generic confined space risk assessment used at all AMSA plants continues from
section 4 with the headings that are listed as:
o Section 4 – Reasons for entry into the confined space.
o Section 5 – Work plan, the scope of work that must be done.
o Section 6 – Work that may be required.
o Section 7 – Isolation that is required. All energy sources taken into account.
o Section 8 – Confined space hazards and risks.
o Section 9 – Other risks.
o Section 10 – Acceptable entry conditions.
o Section 11 – PPE required for entry.
o Section 12 – Rescue and safety equipment requirements.
o Section 13 – Authorised entry points.
o Section 14 – Communication procedures.
o Section 15 – Rescue procedures.

The above details will not be discussed but covered during confined spaces training. The risk assessment
must be used to explain to all entrants the hazards, risks, mitigation, etc. before entering a specific confined
space.

12 ENTRY REQUIREMENTS
The details are captured in the risk assessments of the specific confined space under section 10. Below is an
example from a specific confined space risk assessment.
 Lockout electrical components in the
 Confined space entry permit
space
 Lockout mechanical components in the
 Oxygen 20% – 22.5%
space
 Lockout and blank off all pipes to and
 CO less than 50 ppm.
from the space
Lower explosive level 10% (specify in comments
  No hazardous chemicals or material
for each gas that may be present)
Toxic fumes and vapours less than PEL. (attach
NA  Rescue team available (Section 12)
MSDS for substances and specify in comments)
 No engulfing material in space  Pre-entry brief completed (HIRA)
Minimum internal temperature
 Continuous air monitoring NA
_____________ Celsius
Training verified current for all rescue
 Space drained - flushed 
team members
Maximum internal temperature _____________
NA NA Hot Work Permit
Celsius
Training verified for permit receiver (Supervisor),
 NA Non-sparking tools
entrants and attendants
 Task specific HIRA NA Low voltage lighting

NA Forced ventilation  Fire suppression requirements

 Sign-in and out boards in place  Sign-in and out identification cards issued

NA Standby person required? Other?

The information is captured under section 10 of the risk assessment as illustrated above.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 13 of 24
12.1 Before entry into a class 3 confined space, the internal atmosphere must be tested by a trained and
competent atmosphere tester with a calibrated direct-reading instrument for oxygen content (oxygen-
deficient or oxygen-enriched atmospheres), for flammable gases and vapors and for potential toxic air
contaminants.

Safe entry levels to be tested with a multi-cell gas monitor:

• O2% between 20.0% and 22.5%
• CO concentration level below 50 ppm
• The concentration of gas, dust, fumes or vapour may not exceed 10% of the lower explosive limit of
the gas, dust, fumes or vapour.

Important:
Safe entry levels are required by the OHS Act and are also spelled out in the ArcelorMittal standard as set
out above. However, at ArcelorMittal South Africa we insist that the entry levels shall be that of a normal
atmosphere:
• Oxygen – 20.9%
• Carbon Monoxide (CO) – 0 ppm
• Hydrogen Sulphide – 0 ppm
• Explosive level – 0%
• SO2 – 0% ppm

If a normal atmosphere is not present, the Permit Issuer must insist that mitigation be implemented, such as
ventilation. If the above normal atmosphere levels cannot be achieved after mitigation, specific atmosphere
monitoring instructions must be issued to ensure the safety of all entrants. See section 14 for details.

12.2 If the readings for the gas test indicate that the area is safe, the confined space may be entered.
Continuous gas monitoring must be conducted during the period in which the work is done. This
monitoring can be done as follows:
• The use of permanent gas monitors (common monitors) based on risk assessment. Ensure that
the total area is monitored. Ensure that the alarm is audible (everybody can hear the alarm).
• If a common monitor is not utilised, each person must wear a personal gas monitor.

12.3 If the readings from the gas test are outside the safe entry levels, then the following rules for working
in the area must be followed.
• An approved breathing apparatus system must be worn by all employees entering the confined
space.
• A competent standby person must be made available. If more than one standby person is
required, it must be indicated as such in the risk assessment and must be risk based.
• The standby person/s must be situated outside the confined space and must be attached to the
entrants in such a way that they could rescue the entrants if required. Alternatively a rescue team
must be present.
• Additional fully functioning breathing apparatus systems must be available at the entrance, but
outside of the confined space.
• A standby and rescue person must be present at all times and when necessary, to initiate rescue
actions. The standby person must have a valid first aid certificate.

12.4 Before entering the confined space the team needs to obtain a confined space permit and indicate
that the mitigation steps, identified in the HIRA, have been taken.

12.5 All employees are to leave the confined space upon completion of their tasks. Ensure that the
confined space signage is still in place after completion of the work.

12.6 The open entry permits must be communicated to the next shift

12.7 Atmosphere re-testing is necessary before entry after interrupted work and also during every shift
change for un-interrupted work.

12.8 During interrupted and/or uninterrupted work, a daily Task HIRA shall be done, communicated and
signed by all confined space entrants.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 14 of 24
12.9 The atmosphere within the space must be continuously monitored to ensure no accumulation of a
hazardous atmosphere.

12.10 Written records of the pre-entry atmospheric test results and periodic tests must be recorded and kept
at the work site for the duration of the job.

12.11 Authorised entrants who enter a class 3 confined space must (if possible) wear a chest or full body
harness with a retrieval line attached to the center of their backs near shoulder level or above their
heads. The other end of the retrieval line must be attached to a mechanical device or a fixed point
outside the confined space. Refer to section 14 for detailed entry rules.

12.12 The permit issuer must cancel permits when there are changes in the use or configuration of the
permits. New conditions must be noted on the canceled permits. Alternatively, the permits of all
permit receivers may be suspended, changes and mitigation noted on an annexure that must be
attached to the permits, communicated and signed by all permit receivers and executors, then the
permits can be unsuspended.

12.13 Rescue personnel must perform drills on a regular basis (at least once per year).

12.14 Established confined space HIRA’s. HIRA’s must be reviewed every two years at a minimum.

12.15 Corrective and preventive actions from the lessons learnt of emergency drills must be effectively
implemented and closed out.

12.16 Personnel must evacuate the working area if any working condition changes the safe working limits.
The permit issuer must be notified immediately to asses the work environment.

13 ROLE PLAYERS AND TRAINING

The role players in confined spaces must be trained and competent as set out next.

13.1 Entrants

Entrants (executors) must be trained according to the AMSA training matrix – refer to the AMSA portal.

People expected to work in confined spaces (including contractors) must be trained to:
o recognise characteristics of confined spaces as set out in section 2 of the risk assessment;
o understand the hazards of confined spaces as set out in the risk assessment of each confined space
including plant specific confined spaces training if applicable;
o recognise and understand the health effects of hazardous atmospheres.
o select and use appropriate PPE as set out for each confined space;
o maintain communication with attendants as necessary to enable them to monitor the entrant’s status
and alert the entrants to evacuate when necessary. This is set out for each confined space;
o be aware of or understand the use of confined spaces controls and barriers;
o exit from a confined space if hazardous conditions develop or an alarm sounds.

After completion of training, the plants must ensure that the concerned workers have acquired the
understanding, knowledge and skills necessary to safely perform their duties. This must be done through
tests or assessments and drills.

Additional training must be forecast when:

o the job duties change;
o a change occurs in the confined space program or the confined space operation presents any new
hazard;
o an employee’s job performance shows deficiencies;
o an incident related to confined spaces occurs and re-training if necessary after the investigation and
analysis.

Important note:
Unskilled labourers may enter and work under supervision of the Permit Receiver (competent supervisor) in
a class 1 and class 2 confined space. They undergo level 2 basics training only. However, it is compulsory
AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc
Page 15 of 24
that all entrants into a class 3 confined space must be trained at level 3. This means that any labourer that is
unable to complete such training successfully may not enter a class 3 confined space. Entrance of class 3
manholes requires level 3 training.

13.2 Entrants control

Entrants to a confined space must sign in and sign out every time a confined space is entered. It is not
practical to sign in and sign out every time on a paper permit if the permit will be valid for multiple entries or if
a large number of people have to enter the confined space; the paper will be damaged quickly and the
control will be poor.

At ArcelorMittal South Africa we make use of confined spaces SIGN-IN/SIGN-OUT

boards. The boards are portable and get issued to a confined space Permit
Receiver when a confined space permit is issued. The boards are placed in a
practical position outside the confined space for use by entrants. Entrants hang
their confined space entrant cards on the board every time the confined space is
entered and remove the cards every time the confined space is exited. This
ensures there is accurate tracking of who is in the confined space at any given
time

When an emergency occurs and the confined space is evacuated, the entrants
gather at the confined space SIGN-IN/SIGN-OUT board. Any entrant which has a
card on the board not accounted for is then presumed still to be in the confined
space and the relevant rescue procedure will then be activated.

The confined space entry / exit control board will be placed in a strategic position at the entrance to the
confined space. At confined spaces with more than one entry, clear instructions will be issued to all entrants
where the board will be placed. In the event when the confined space must be vacated, all entrants will exit
and immediately go to the board and remove their entrant cards.

Shown on the right is a contractor identification card. This is a temporary paper card without a photograph
like with permanent employees. The confined space entrant card is used to restrict possibility of
unauthorised entry.

It is necessary to issue entrants with just one card as they can only be in one confined space at a time.

The use of this card and an entrant board is

compulsory when entering confined spaces
(card no G.03280A for employees and G.0328-
B for contractors).

13.3 Standby persons

Standby persons, when required, must be trained according to the training matrix to comply with the
following responsibilities and authority:

o remain permanently outside the confined space during entry operations and full duration of the job
execution unless relieved by another authorised standby person;
o perform non-entry rescues when specified by the rescue procedure of the specific confined space;
o know existing and potential hazards, including information on the mode of exposure, signs or symptoms,
consequences and physiological effects;
o maintain communication with and keep an accurate account of those workers entering the confined

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 16 of 24
 space. This must be stipulated for each confined space;
o order evacuation of the confined space when hazardous conditions develop or an alarm sounds;
o initiate rescue and other services during an emergency. Plants to issue specific instructions regarding
emergency team rescue procedures while waiting for protection services;
o perform no other duties that interfere with the standby person’s primary duties;
o at least one standby person must stay outside the confined space into which entry is authorised for the
duration of entry operations and must have no other duties assigned to him;
o prior to entry, the communication equipment must be made available for the standby person and at least
one authorised entrant and it must be tested for correct operation.
o ensure that unauthorised people stay away from confined space;

Note:
A standby and rescue persons are required for Class 3 confined space. The standby person must have a
valid first aid certificate.

One of the duties mentioned above is to ensure that unauthorised people stay away from confined space.
This is very important because the atmosphere of a class 3 confined space cannot be made safe and may
not remain safe for the duration of the work. Unauthorised entry may be fatal. The following must be in
place:
o The standby person must control people entering the confined space (e.g. name list of entrants, sign-in
and sign-out board, etc.).
o When entrants place their access cards onto the sign-in/sign-out board, the standby person will verify if
they may enter.
o All means must be in place to ensure that no person can enter the space accidentally or without
permission.

13.4 Permit issuers

Permit issuers must be trained according to the training matrix to comply with the following responsibilities
and authority:
o Communicate the confined space risk assessment prior to entering a confined space including the
concerned space specific hazards combined with those coming from the activities to be performed in it.
Alternatively, this communication is done by the Task Initiator. This is the AMSA confined space risk
assessment that is already in place for all confined spaces. Task specific HIRA/s must still be done;
o know space hazards including information on the mode of exposure, signs or symptoms and
consequences;
o know and verify the acceptable atmospheric conditions for entry are defined and in compliance with law
and applied;
o verify emergency plans and specified entry conditions such as permits, tests, procedures and equipment
before allowing entry into the specific confined space;
o ensure that the confined space entry board is in place and that all entrants understand entry and exit
procedures using the confined space entrant identification card;
o terminate or withdraw entry and cancel permits when entry operations are completed or if a new
condition exists;
o verify that rescue services are available and that the means for summoning them are operable;
o take appropriate measures to remove unauthorised entrants;
o ensure that entry operations remain consistent with the entry permit and that acceptable entry conditions
are maintained;
o the identified methodology for completing permits for confined space entry. These are all pre-drawn up
permits for specific confined spaces.

13.5 Permit receivers

Permit receivers must be trained according to the training matrix to comply with the following responsibilities
and authority:
o Must receive permit to work training.
o The permit will ensure it is safe to enter a confined space.
o You must have a permit before entering a confined space.
o You have to apply the one person, one lock one key principle.
o No contractor (as a permit receiver) shall perform lockout of any energy sources. This must be done by
an ArcelorMittal South Africa isolation specialist.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 17 of 24
o Together with the Task Initiator, explain the HIRA to all entrants:
• Explain the hazards and risks with mitigation instructions
• Explain and ensure the use of correct PPE
• Explain and ensure the correct entry and exit procedures
• Explain and ensure correct communication
• Explain the alarm system
• Explain emergency procedures:
o Emergency telephone number and ambulance point
o Rescue procedures
o Sign the confined space HIRA and ensure all team members understand and sign the HIRA
o Conduct and discuss a daily task HIRA and ensure that all team members sign the daily task HIRA
o Ensure that the atmosphere is tested every day and the results recorded when receiving the permit. For
uninterrupted work, it must be done during shift changes.
o When all team members vacate the space (for whatever reason), the atmosphere must be tested before
re-entry. During time of non-occupancy, unauthorised entry must be restricted.
o You must ensure that all team members vacate the confined space during an emergency.
o Ensure use of gas monitors as required by the permit and risk assessment.
o You may not leave the confined space with executors not under direct supervision.
o You must have in your possession:
• The permit
• A copy of the lockout register
• The confined space risk assessment
• The daily task HIRA

13.6 Permit valid period

For frequent, routine tasks of low risk, permits may be issued for periods of maximum 1 year. The permit
shall be issued to a permit receiver that must still apply the entry conditions and checks that are required
each time the space is entered. It must be stressed that this is for low risk routine tasks only that may not
compromise the safety of entrants.

13.7 Emergency and rescue teams

Rescue teams must be trained rescue personnel and in this respect we do not refer to plant emergency
teams.

13.7.1 Emergency teams

• These are plant personnel trained in fire fighting and/or first aid with responsibilities as set out in the
plant specific emergency procedures.
• Internal training is provided.
• Emergency teams may not perform rescue.
• Emergency teams may assist with rescue under direct supervision and instructions of the rescue
teams.
• After completion of training, the plants must ensure that the concerned workers have acquired the
necessary understanding, knowledge and skills to safely perform their duties (mock drills).

13.7.2 Rescue teams

• These are personnel trained in confined space rescue procedures and may be members from Asset
Protection Services at most AMSA sites or Proto Teams such as at Saldanha.
• Must be capable of responding to an emergency in a timely manner;
• Use the PPE and rescue equipment, including respirators and BA sets.
• Rescue service personnel must complete the training as for authorised entrants.
• Rescue teams must be trained according to the rescue team training matrix.

Note: At plant level there is an emergency team available to assist when

necessary. The standby person and emergency team provide no-entry rescue
and assistance for the first 5 to 10 minutes until professional rescue teams
take over. They then may enter according to instructions and under
supervision of the professional rescue team.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 18 of 24
 Important:

When something goes wrong, the rescue team MUST use breathing apparatus to enter the confined space
to rescue workers

No matter what the situation or instructions from anyone, you must be trained to rescue someone in a gas
confined space!

DO NOT use a dust mask or respirator of whatever type to

enter the confined space! It will help absolutely nothing. The
purpose of dust masks and respirators is to catch solid
particles in the air and fumes – not gas!

The details regarding training and competencies of plant emergency teams are captured and explained
under FPS “Emergency preparedness”.

13.8 Test of atmosphere

Persons in charge of testing the atmosphere must be trained according to the training matrix and
“Atmosphere tester” course to know the allowable, the maximum and minimum allowable concentration of:
o flammable gas,
o vapor or mist,
o combustible dust,
o oxygen and
o any atmospheric substance for which a dose or permissible exposure has been defined and assess their
concentration in the atmosphere with the necessary devices prior to the confined space entry.
o The hazards of the specific confined space to be entered will dictate what training is required.

For each confined space it must be spelled out:

o Who must conduct an atmosphere test;
o Monitors to be tested before use (multi-cell monitors);
o At least two monitors must be used.
o Monitors to be lowered into or pushed horizontally into the confined space.
o Speed of entering monitor into the confined space, normally around 5 seconds per meter.
o Gas tester must be given 20 seconds to register a reliable reading.
o Measuring may have to be done at different locations in the confined spaces (geometry, gas type, …
etc.).

13.9 Reporting of incidents

If an incident occurred where confined space entrants were exposed to abnormal / harmful levels of
substances in the confined space the following reporting is mandatory:
o Immediately perform a Dräger pack 7000 test and administer pure oxygen if 40ppm of CO or more
o Registration of the incident on the formal incident reporting system,
o Report to the occupational physician of the Works which lists the:
• Confined space entrants affected
• Type of exposure
• Levels of exposure measured
• PPE used during the incident

14 ATMOSPHERIC ENTRY RULES

Confined space Class 1 rules:
o General Safety Regulation 5(1) states that before entry, a competent person must test the atmosphere
and state in writing that it is safe to enter and will remain safe during occupancy. We are only concerned
about a safe level of oxygen in class 1. At this point we therefore just test without any actual mitigation,

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 19 of 24
 purging, ventilating or lockout that may be necessary. But if something goes wrong, we vacate and re-
evaluate.
o Engulfment or entrapment is possible.
o This MUST be eliminated
o Make space safe and it must remain safe

Confined space Class 2 rules:

o General Safety Regulation 5(2) then continues that if the above in (1) is not possible, steps must be
taken to provide a safe atmosphere (oxygen and harmful gasses) through purging if necessary, closing
off and blanking of openings (which is lockout), etc. It includes elimination of engulfment and
entrapment. In other words, after mitigation of whatever nature, the confined space is safe to enter. (We
state that it will remain safe through our mitigation).
o Something wrong or could be wrong with the atmosphere
o This CAN be eliminated
o Make space safe and must remain safe

Confined space Class 3 rules:

o General Safety Regulation 5(3) is where we get to a stage where the atmosphere can not be made safe
in (2) above (or make it safe but we can not guarantee it will remain safe). It is only now for the first time
that the OHS-Act mention and requires additional measures such as retrieval lines, a person
immediately outside the confined space trained in resuscitation as an attendant (what we call standby
person) including spare breathing apparatus outside the space.
o Something wrong or could be wrong with the atmosphere. Try to make safe and:
(a) Get atmosphere 100% safe – but no guarantee it will remain safe
• BA sets or rescue packs shall be available inside the space
• When gas monitor alarm goes off, use BA set or rescue pack
• Vacate the area

(b) Get atmosphere safe within “acceptable entry conditions”

• BA sets or rescue packs shall be available inside the space
• When gas monitor alarm sounds, use BA set or rescue pack
• Vacate the area
• Based on risks (example Carbon Monoxide (CO) may increase to 3000ppm within a few seconds)
BA sets shall be worn when entering and when gas monitor alarm sounds, vacate

(c) Can not get atmosphere safe within “acceptable entry conditions”
• It must be risk based – according to the OHS Act entry is allowed providing BA apparatus is used
• The plant manager and permit issuer will take risk based decisions whether to allow entry with
compulsory use of BA equipment including whatever other provisions are required
• When gas monitor alarm sounds, vacate the area and re-evaluate
• No entry is allowed for explosive limits exceeding acceptable entry limits!

Important note:
Where a confined space must be entered with a breathing apparatus (BA) there is a very remote possibility
that a detection cell of the gas monitor may go into over range mode. When exiting the confined space, the
monitor may not display reliable readings and you could be unable to tell if it is safe to remove the BA set.
So when entering a confined space with a BA set, the standby person shall remain outside the area with a
gas monitor indicating a safe atmosphere outside the confined space. When exiting, the standby person will
indicate that it is safe to remove the BA set.

15 GASES – SYMPTHOMS AND CONCEQUENCES

People involved in confined spaces must be trained according to the training matrix that includes dangerous
and toxic gases. It should be done to ensure those involved has a proper knowledge of the dangers of
gases, common gas symptoms, treatment, etc.

16 AUDITS
Confined space audits must be conducted to ensure the following:
16.1 Procedural audits by the Plant Manager (or manager responsible for a department) must be done 12
monthly to ensure that:
AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc
Page 20 of 24
 • The PTW procedures are complied with and that all information required by law and the
ArcelorMittal standards have been thoroughly completed.
• That each confined space activity is addressed by SWP’s and an emergency procedure.
• That only authorised / competent persons have received the permits. That is Permit Receivers who
completed PTW training with an official appointment letter.
• That identified corrective and preventive actions from the internal audits relating to confined spaces
be effectively implemented and closed out.
• All persons required to work in a permit required confined space, or to act as a standby person, be
trained and competent.
• Specific safe work procedures were developed for work activities that are more hazardous when
carried out in a confined space than elsewhere. These activities would include hot work (cutting and
welding), chemical cleaning, steam cleaning, and abrasive blasting.

16.2 Inspections by the Plant Manager (or manager responsible for a department) must be done at least
12 monthly on at least one permit when a confined space PTW is issued to ensure:
• Correct execution of the PTW procedures.
• That the requirements as set out in 16.1 are complied with.
• That the standby person may do nothing else but the duties as described in this document.
• Keep records of inspections performed for 12 months (minimum retention period).

16.3 Ensure all confined spaces have been identified, signs are clearly displayed and access is controlled.

16.4 Results of all the audits must be analysed, reviewed and kept on record for audit purposes.

17 RECORDS

• All confined spaces documentation shall be kept for at least 12 months. However, where incidents took
place during the work, all the records shall be kept for a minimum of 3 years.
• An updated list of confined spaces must be kept of each plant until such time as there are no confined
spaces on the plant.
• The HIRA’s for the confined spaces must be kept and updated until such time as the specific confined
space is re-classified.
• Keep records of permits audited during shopfloor and monitoring audits.
• Records of annual confined space reviews shall be kept. The AMSA review template must be used and
is available on the SA portal. This is an annual review that must include the risk assessment of each
confined space.
•

18 COMMUNICATION EQUIPMENT
The Confined Space and Gas Hazardous Areas protocol states that
communication equipment used are “inspected and tested on a
planned and regular basis”.

Communication equipment used in confined spaces must be

inspected and tested. To address the requirement two-way radios
must therefore be inspected for integrity and checked for functionality
before entering a confined space (must clearly transmit and receive).
To ensure that a two-way radio is acceptable for use in a confined
space the following must be checked before entry:

• Check that the aerial is in good condition. The aerial must not be loose, broken or have loose wiring.
• Check that the radio / receiver cover is in good condition. The cover must not be cracked or loose.
• Check that a newly charged battery is used in the radio.
• Check the functionality of the radio with test calls.

If the requirements above are met the radio is fit for use in a confined space. Verify and record the checks
on the permit at the start of each shift for uninterrupted work or before entry after interrupted work.
AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc
Page 21 of 24
19 SAFETY PRECAUTIONS
The following rules apply when testing confined spaces for a safe atmosphere and during occupation of a
confined space.
a) When testing a confined space atmosphere, no cell phones or 2-way radios are allowed into the
confined space.
b) After declaring a confined space safe for entry, no cell phones are allowed inside. Never change the
batteries of radios or gas monitors inside a confined space.

20 CONFINED SPACE HOT WORK

The hot work rules and guidelines as set out in the AMSA hot work procedures AMSASHE00030 shall apply.
The AMSA hot work clearance certificate shall be used when hot work must be done in a confined space.
The issue of a hot work clearance certificate for a class 1 and 2 confined space is risk based as per
AMSASHE00030 procedure. A hot work clearance certificate is compulsory when hot work must be done in
a class 3 confined space.

21 DRILLS
Identify real emergencies per site from baseline risk assessments. Set up emergency plans for the most
probable highest risks. At least one annual drill according to site specific emergency plans must be
conducted according to a plan to ensure effectiveness.

Drills must be conducted in departments where the risks are high. Test the emergency plan. Lessons
learned must be distributed to all applicable departments for communication purposes (e.g. via notice).
Revise emergency plans by using the lessons learned during drills.

Content of drill reports must include the following:

• Date of drill.
• Objective of drill.
• Procedure number tested.
• Attendance list of all stakeholders involved.
• Scenario description and detail with timelines (what happened when?).
• What went wrong and what went well (checklist) as per tested procedure.
• Lessons learned (to be communicated – keep record).
• List of corrective and preventative actions to close gaps (on the incident management system).

22 TRAINING AND RE-TRAINING GUIDELINES

After completion of confined spaces training and being declared competent, the appointment letters and
training remain valid indefinitely. However, re-training and exceptions will take place as follow:

• AMSA generic annual re-training: This will be done on an annual basis with a shortened presentation
that will be presented to all affected at level 2 and 3 respectively. Assessments will be done and kept
on record. Where someone fails the assessment, the full training must be repeated. Plant personnel
such as supervisors, SHERQ administrators and Safety Officers must help the training department with
the shortened re-training sessions.

• Procedural changes: When there are changes to the AMSA confined spaces procedures, re-training
shall be in the form of a one-pager setting out the changes. All those affected must sign
acknowledgement and understanding of the changes. Records of this communication must be kept.

• Incidents: Where incidents took place and the cause is as a result of deviation from the AMSA confined
spaces procedures by a specific individual or individuals, such individuals must undergo full training.
This shall also be registered as one of the corrective actions on the incident investigation report.

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 22 of 24
 • Audit findings: Where audit findings are made and the cause is as a result of deviation from the AMSA
confined spaces procedures by a specific individual or individuals, such individuals must undergo full
training.

• Gas monitor: Workers trained at level 2 basics shall practically demonstrate on an annual basis correct
use of a mobile gas monitor and record of the assessments shall be kept. This practical assessment
shall be done by the direct supervisor of each worker under level 2 basics, as well as direct contractor
supervisors with their executors. Records must be submitted to AMSA.

• Atmosphere tester: Training remains valid indefinitely and changes are communicated as per one-
pagers.

• Ventilation: Training remains valid indefinitely and changes are communicated as per one-pagers.

• Contractor permit receivers: Must repeat training annually and be issued a new appointment letter.

• Permit Issuers: Appointment letters remains valid indefinitely. However, where a Permit Issuer did not
issue a permit within a period of 12 months, full training must be repeated for confined spaces level 3
and level 3 high.

• Plant specific training: Remains valid indefinitely and changes are communicated as per one-pagers.
Where incidents took place or audit findings are made and the cause is as a result of deviation from
plant specific procedures by a specific individual or individuals, such individuals must undergo full
training. This shall also be registered as one of the corrective actions on the incident investigation
report.

23 CONCLUSION
When analysing gas inhalation statistics at AMSA sites and for that matter worldwide at many industries, the
following observations were made.

Reasons for gas inhalation:

• Rescue by untrained so-called rescuers – accounts for up to 60% of fatalities
• Lack of knowledge:
o Unaware of gas dangers
o People not trained (gas training and breathing apparatus)
• Carbon monoxide not monitored
• Incorrect use of gas lines
• Excessive gas amounts at blast furnace cast floor
• Ignoring the dangers of gas

Entering confined spaces is a serious issue and when looking at the reasons why people get gassed, it is
alarming to see words like people not trained, gas not monitored, ignoring gas dangers and lack of
knowledge.

The management of AMSA is serious about the health and safety of our employees. However, every worker
on our premises must take care of his/her own health and safety as well. Workers must be properly trained
on the entry procedures, permit requirements and emergency procedures of the specific confined space that
must be entered. If not, it may result is fatalities and for that reason workers must refuse to enter confined
spaces without the necessary and proper training.

24 REVISION DETAILS

Rev
Date Reason for revision
no
February
00 New procedure applicable to ArcelorMittal South Africa
2012

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 23 of 24
01 Sept 2012 • Rectify spelling and layout errors
• Revise section 10: Actions after classification
• Revise section 12: Entry requirements
• Revise point 13.2: Entrants control
• Revise point 13.3: Standby persons
• Revise point 13.5: Permit receivers
• Revise point 13.6: Standby and rescue teams
• Revise point 13.7: Test of atmosphere
• Include section 14: Atmospheric entry rules
• Revise point 16: Audits
• Revise point 18: Communication equipment
• Include section 20: Drills (with content of drill report)
• Revise section 21: Training and re-training guidelines
• Change layout of confined space entrant card (alignment of card)
• Revise Appendix 1: Training matrix (revision 01)
• Include Appendix 2: Rescue team training matrix (draft matrix)
02 December
• Rectify spelling, grammar, reference numbers and layout errors
2012
• Include point 6.12: Common monitor (definition) and 6.13 HIRA
(abbreviation)
• Revise section 7: Remove standby at class 1 and 2 and add shafts as a
class 3 confined space
• Revise section 10: Signage for elevated confined spaces
• Revise point 10: Identification of all confined space entry points
• Revise section 12: entry requirements (standby person)
• Revise point 13.3: Standby person (remove standby person at Class 1 and
Class 2 confined spaces).
• Include new point 13.6: Permit valid period
• Revise section 14: Atmospheric entry rules (aligned with legislation) and
include important note when entering space with breathing apparatus
• Revise section 17 (annual review records) with Appendix 3
• Revise section 18: Instruction on regular recording of radio tests or checks
• Refer to signboard SB-numbers
• Add section 20 confined space hot work
• Revise Appendix 2 (list target groups)
03 July 2013 • Section 6.1 : This is the long definition
• Section 6.2: New entry for the short definition
• Section 7: confined space class 3. Do not necessarily require a rescue
team at each class 3 confined space. Refer to the explanation as set out in
section 7.
• Section 8: type of work note inserted on fueled equipment and dusts or
fibers.
• Section 12.3: Only one standby person is required. If more than one
standby person is required, it must be indicated as such in the risk
assessment and must be risk based.
• Section 12.12: Included description on permit suspension
• Section 13.1: Removed the training matrix and references to it from the
procedure. Refer to the training matrix on the SA portal.
• Section 13.1: All entrants into class 3 confined spaces shall be trained at
level 3 (not 2 advance as previously).
• Section 17: the confined space annual review template is available on the
SA portal – removed from the procedure.
• Section 17: included the instruction that all confined space risk
assessments must be part of the annual review.
• Section 21: Drills to be conducted in departments with a high risk - not
applicable to every department or plant.
04 October 2013 • Section 10: Replace bi-annual rsik assessments with annual risk
assessments

AMSASHE00003 (AMSA confined spaces procedure)(rev 04).doc

Page 24 of 24