The Government of Andhra Pradesh vide its gazette no. G.474 published in its official gazette a notification (G.O.Ms. No.10) issued by the Labour Factories Boilers and Insurance Medical Services Department dated July 06, 2023 (“Notification”), which casts an obligation on the occupiers and managers of the factories operating in the State of Andhra Pradesh under the Factories Act, 1948 (“Factories Act”) to undertake safety measures for the workers who are required to work in confined spaces.
The detailed guidelines/instructions issued under the Notification are applicable to all factories operating in the State of Andhra Pradesh under the Factories Act and are effective from the date of issue or the date of registration of a factory under the Factories Act, whichever is later. For facilitating effective safety management in executing critical activities related to confined space including but not limited to cleaning, clearing, inspection, testing, hot works inside the reactors, boilers, storage tanks etc., a standard operating procedure called “Work Permit System” along with guidelines on “Safe Entry and Work in Confined Space” has been introduced under the Notification.
Under the Work Permit System, a number of definitions including but not limited to ‘Confined Space’, ‘Work Permit’, ‘Confined Space Entry Supervisor’, ‘Receiver/Executor’, and ‘Personal Protective Equipment (PPE)’ have been framed. In addition to this, every worker involved in executing the permit to work systems including the contractors shall be trained adequately to perform their duties and responsibilities as per the procedure enumerated under the guidelines.
Few of the safety precautions to be included, but not limited to, in the training are as follows:
- Before permitting the entry and work in confined spaces, such confined spaces shall be tested properly and before testing such confined spaces, such spaces shall be washed, and cleaned with neutralizing agents and make adequate ventilation arrangements.
- Complete physical isolation of all hazardous energies and utilities shall be done prior to entry into the confined space.
- A permit form as an undertaking shall be signed by the entrants before entering into the confined spaces so that they are made aware of the following things: (i) kind of work that needs to be performed; (ii) hazards and risks associated with the entry; and (iii) abide by the safety rules and the permit conditions.
- Emergency rescue facilities i.e., rescue equipment (tripod/safety harness/rescue rope etc.) shall be kept ready before starting the work.
- Individuals working in the confined space must wear a ‘5-point rescue body harness’. The lanyard should be attached and be held back at the entry point by the ‘stand-by person’ (Attendant). They shall also be provided with appropriate and approved personal protective equipment for carrying out the work under permit to work system.
- Random checks for adherence to permit conditions shall be carried out by the permit initiator, executor, safety representative and heads of respective departments.
Moreover, the duties and responsibilities of each entrant, attendant and supervisor has been enshrined under Annexure II of the Notification with regard to workers working in confined spaces. Furthermore, under the Notification, illustrative images for guidance purposes have been portrayed for better understanding and effective safety management in relation to workers executing the critical activities related to confined spaces.
For ease of reference, the term ‘Confined Space’ means “any space by reason of its construction shall as well as in relation to the nature of the work carried therein and where hazards to the persons entering into or working inside exist or are likely to develop during working”.