Confined Spaces Policy

Imperial College Union is committed to ensuring the health, safety and welfare of its members, staff, customers, suppliers, visitors, and all others who may be affected by its activities and recognises the risks to health and accepts its responsibilities to comply with legislation and its duty under the Confined Spaces Regulations 1997.

The Confined Spaces Regulations 1997 Require employers to undertake a number of key duties. These include avoiding entry to confined spaces in the first instance e.g., by doing the work from outside. If this is unavoidable, a safe system of work will be required. Additionally, an adequate emergency plan will be required prior to the commencing of any work within a confined space.

1. Definition

Under these Regulations a "confined space" must have both of the following defining features: it must be a space which is substantially (though not always entirely) enclosed and one or more of the "specified risks" must be present or reasonably foreseeable. Specified risks include:

  • Flammable substances and oxygen enrichment;
  • Excessive heat;
  • Toxic gas, fumes or vapours can lead to asphyxia or unconsciousness;
  • Oxygen deficiency;
  • Ingress or presence of liquids;
  • Free-flowing solids which can submerge a person, preventing breathing;
  • Risk of structural collapse which could entrap a person.

Imperial College Union is committed in providing, as far as reasonably practicable, a safe and healthy working environment for employees, members, staff, customers, suppliers, visitors, and all others including measures to protect their health and safety when working in confined spaces, it is Union's Policy to:

  • Priority must be given to avoiding work in confined spaces, but, if it is not reasonably practicable to carry out the work without entering the confined space, then the Imperial College London Permit to Work and Safe System for work within the confined space must be implemented;
  • Where there are confined spaces, the Imperial College London Permit to Work and and Safe System of Works must be deployed to control high-risk activities:
    • where the space in question is part of the Estate (part of a building or a component fixed to or within a building) this should be managed through the Imperial College London Permit to Work and and Safe System of Works process;
    • where the space is part of a piece of free-standing equipment or system not connected to a building the this should be managed through the Imperial College London Permit to Work process and and Safe System of Works;
  • Undertake risk assessments to identify any spaces which might be considered to meet the criteria outlined above;
  • Where the need to enter cannot be avoided steps must be taken to reduce the duration of such entry and to ensure that suitable means of escape and /or rescue are in place, and that associate emergency arrangements are documented with the control measures;
  • Control measures must document the Personal Protective Equipment (PPE) (including any harnesses, atmospheric monitoring devices and Breathing Apparatus) which might be required for those entering the space and for the rescue team(s);
  • Risk assessments must include the assessment of substances which might be present within the space and what might come into the space whilst work is underway.

2. Responsibilities

  • ICU Board of Trustees

    The Health and Safety at Work Act 1974 places a statutory duty on organisations to ensure, so far as reasonably practicable, the safety, health, and welfare of its employees at work and other people who may be affected by their activities, e.g., membership, volunteers, members of the public.  

    The Board of Trustees, as the governing body of the Union, has overall and final responsibility for Health and Safety matters within the Union, and for ensuring that Health and Safety legislation is complied with. 

  • Managing Director (MD)

    The Trustee Board has devolved day-to-day responsibility for Health, Safety and Welfare to the Managing Director.  

    The MD, and those acting on their behalf, will ensure:  

    • Ensure that adequate arrangements are in place to achieve compliance with the policy;

    • MD delegates responsibility for undertaking aspects of these duties through line management & identified roles. 

  • Senior Leadership Team

    The Managing Director will delegate to the membership of the leadership team the following responsibility:   

    • Monitoring and reviewing the effectiveness of Health and Safety activities and the Union's Health and Safety Policy and associated policies and procedures, and for ensuring that, at the strategic level, performance standards and timescales are adhered to.  

    • Chairing the Students' Union’s Health and Safety Committee and ensuring it has the time, facilities, and resources to carry out its business effectively.  

    • Keeping under review this Health and Safety Policy and the Health and Safety performance of the Students' Union. 

  • Facilities, Health and Safety Manger (FHSM)

    The FHSM is appointed by the MD to undertake the following: 

    • Ensure that the ICL Permit to Work and Safe System of Works are adhered to with all works in confined space(s).    

    • Ensuring any incidents involving confined spaces are reported and investigated, where necessary, in consultation with the Facilities, Health and Safety Manager.

  • Imperial College Union Line Managers

    Health and Safety is a delegated line management responsibility requiring managers to undertake operational Health and Safety duties identified in this policy. Imperial College Union Line Managers to undertake the following:  

    • Lead by example by following policies and challenging inappropriate behaviours, should check that staff have received information and encourage them encourage new staff to read and follow the guidance provided.

  • ICU Employees are required to:

    Individual members of staff, students and visitors have a legal duty to co-operate and always comply with the ICU Health and Safety Policy, instruction and training provided. Staff and students are responsible for: 

    • Cooperate and enable implementation of this policy;

    • Immediately report to their Supervisor /Line Manager unsafe practices which they believe to be likely to endanger the safety of themselves or others.

  • Imperial College Union - Student Led Groups

    This policy applies to all Imperial College Union - Student Led Groups have a legal duty to co-operate and always comply with the ICU Health and Safety Policy, instruction and training provided. Student Led groups are responsible for:   

    • Cooperate and enable implementation of this policy 

  • Imperial College London

    The Students' Union, whilst an independent charity in its own right, is an integral part of the Imperial College community and could not exist without the College. The Union and College work in partnership to ensure that adequate measures are in place to ensure health, safety, and welfare within the Union. The Union is committed to working with the Imperial College London Safety department and where appropriate, ensuring that the Union's Health and Safety Policy, Codes of Practice and arrangements are in accordance with the College Health and Safety Policy, Codes of Practice, and arrangements. 

    The Union is in an unusual position in that whilst colleagues work directly for the Students' Union their contracts of employment are with the College. Whilst the Union accepts its duty of care and responsibilities, the College also has a duty to ensure, and support, the safe management and operation of the Students' Union.

Further Guidance 

Review date: March 2025