Confined Space Electrical Work in the UK: a Guide for Electricians

Regulation 1(2) of the Confined Spaces Regulations 1997 defines a confined space as "any place, including any chamber, tank, vat, silo, pit, trench, pipe, sewer, flue, well or other similar space in which, by virtue of its enclosed nature, there arises a reasonably foreseeable specified risk". HSE guidance in L101 puts it as two features: the space is substantially (though not always entirely) enclosed, and one or more of the specified risks is present or reasonably foreseeable. The specified risks are:

L101 lists places that can be confined spaces, but only where a specified risk is present or reasonably foreseeable: ducts, culverts, tunnels, manholes, shafts, excavations and trenches, building voids, some enclosed rooms (particularly plant rooms) and compartments within them, and the interiors of plant. It also names rooms kept at reduced oxygen for fire prevention, such as archives and IT server rooms, and stores of gas cylinders or fire suppression material. For electricians these are places to check, not confined spaces by default.

A riser, loft or ceiling void needs the same check. HSE says an enclosed workplace without a specified risk is not a confined space under the Regulations, even if it is cramped; in ceiling voids, lofts and some cellars you assess the other risks instead, such as musculoskeletal disorders or getting someone out after a fall. The same riser could become a confined space if gas could get in from adjoining plant or if hot work would bring a specified risk with it.

Regulation 4(1) of the Confined Spaces Regulations 1997 says: "No person at work shall enter a confined space to carry out work for any purpose unless it is not reasonably practicable to achieve that purpose without such entry." The Regulations do not ban entry outright; they require you first to show the work cannot reasonably be done from outside.

1. Can the work be done from outside the space? HSE examples include testing and sampling from outside with long probes, cleaning from outside, remote devices, and CCTV or remote visual inspection, but only where that gives the same results and safeguards as entry would.
2. Can the source of danger be removed? The ACOP gives priority to eliminating the source of danger before deciding on precautions for entry. HSE guidance says a space may stop being a confined space when the specified risk is removed and the atmosphere is tested as safe, but while it is a confined space the Regulations apply in full, even where the specified risk is controlled.
3. If entry is really needed, follow the Regulations in full: a risk assessment, a safe system of work under regulation 4(2), and rescue arrangements under regulation 5 before anyone goes in.
4. Record the decision on whether to enter, and why. Your RAMS is a sensible place to record it.

The ACOP says that in every situation the dutyholder must consider what measures can be taken to do the work properly without going in, which may mean modifying the space or the way the work is done. If it is reasonably practicable to do the work without entering, regulation 4(1) means you do not enter. Designers and installers should also design out the need for entry where they can.

Where entry is necessary, regulation 4(2) requires a safe system of work, and regulation 5 requires suitable and sufficient rescue arrangements before any person enters. The risk assessment comes from regulation 3 of the Management of Health and Safety at Work Regulations 1999. HSE Approved Code of Practice L101 and HSE leaflet INDG258 set out the practical elements.

Electricity is not one of the specified risks. HSE guidance calls it an "other hazard" covered by other law, chiefly the Electricity at Work Regulations 1989 (for example regulation 6 on hazardous environments, regulation 12 on isolation, regulation 13 on work on equipment made dead and regulation 14 on live work), and says the precautions will almost always be more extensive because of the enclosed space. What L101 and INDG258 say about electrical work in confined spaces:

The ACOP says a safe system of work should be in writing and set out the work to be done and the precautions to be taken, and that it is only ever as good as its implementation. A confined space RAMS should describe the actual space, the hazards, the controls and the rescue plan, and the people doing the work need to understand it before they start.

You can draft the document in the Elec-Mate RAMS Generator, which includes confined space work among its hazards, then check it against the space in front of you. There is also a generic electrical RAMS template if you prefer to start from a blank.

Regulation 5(1) of the Confined Spaces Regulations 1997 says no person at work shall enter or carry out work in a confined space unless "suitable and sufficient arrangements for the rescue of persons in the event of an emergency, whether or not arising out of a specified risk" have been prepared. Regulation 5(2) says they must reduce the risks to the rescuers so far as is reasonably practicable and provide resuscitation equipment where resuscitation is a likely consequence. The test is not "did you have a plan?" but "would the plan have worked, on the day, with the people present?"

If a colleague collapses inside a confined space, do not go in after them. The ACOP says ill-conceived attempts to save others who have collapsed are a major cause of death and injury in confined spaces, and that multiple fatalities have occurred when rescuers were overcome by the same conditions. Raise the alarm and put the rescue plan into action; only trained rescuers protected against the cause of the emergency go in.

The ACOP says records should be kept of atmospheric test results and findings, and HSE guidance says to keep records of testing, inspection and calibration of monitoring equipment. If anything went wrong or nearly went wrong, such as a detector alarm, a communications failure or an unexpected hazard, record it.