The Impact of Organisational Policies on Confined Space Safety

Confined spaces are among the most hazardous work environments, often concealing silent, deadly risks—low oxygen levels, toxic gases, engulfment, or heat stress. But while the physical risks are well-documented, there’s a deeper, often overlooked layer to safety failures in confined spaces: organisational policy.

Despite the availability of guidance, standards, and legislation, confined space fatalities and injuries continue to occur globally. The reason is often not a lack of awareness or individual error, but a failure of the organisational systems, policies, and culture that govern how work is planned and performed.

In this article, we’ll explore:

• What organisational policies are, and how they influence confined space work

• Common failures in policy implementation

• Real-world case studies and regulatory insights

• How to evaluate and improve your own policies

• Practical strategies for embedding safety into the DNA of your organisation

Understanding the Role of Organisational Policy

An organisational policy is more than just a written document—it is a statement of intent that guides decisions, processes, and behaviour. In confined space work, policies affect everything from how hazards are identified and assessed to how an entry is approved, supervised, and conducted.

Policies should answer fundamental questions:

• Who can authorise entry?

• What defines a confined space in your context?

• How are gas testing, ventilation, and isolation managed?

• What rescue arrangements must be in place?

• What competencies are required to enter, supervise, or stand by?

A strong policy aligns with legal obligations and reflects industry best practice. But most importantly, it must be implementable. A policy without training, leadership support, and accountability mechanisms is just paperwork.

When Policies Fail: Root Causes of Confined Space Incidents

Let’s look at several common failure modes linked to poor or absent organisational policies.

1. Ambiguity in Definitions and Responsibilities

Some organisations don’t clearly define what constitutes a confined space or who is responsible for controlling it. This creates inconsistency across departments and worksites. When roles are unclear, critical tasks like gas testing, lockout, or emergency planning can be missed or poorly executed.

2. Outdated or Generic Policies

A confined space policy copied from a textbook or another company may not reflect your specific hazards. Policies must be tailored to your equipment, processes, and personnel. A boiler room in one facility might be low-risk, while a sump in another is a death trap.

3. Poor Communication and Awareness

Even the best policy is useless if workers and supervisors don’t know it exists. Many incidents stem from frontline workers being unaware of permit requirements or misunderstanding isolation procedures.

4. Failure to Enforce Permitting and Risk Assessments

Permits are the foundation of confined space control. But in many workplaces, they become rubber-stamping exercises—completed after entry, duplicated across jobs, or skipped entirely under time pressure.

5. Inadequate Rescue Plans

Inadequate rescue planning is a tragic hallmark of many fatal incidents. Policies that require rescue drills, detailed pre-plans, and competent teams are rare. Often, “call the fire brigade” is written as the plan—a dangerously inadequate response for time-critical emergencies.

🛑 Case Study: Molasses Tank Fatality (NSW, ~5 years ago)

In a tragic incident documented on SafeWork NSW’s “Incident information releases” page, a worker performing cleaning operations inside a molasses tank at a rural NSW property died from a lack of oxygen, and a second worker who attempted a rescue became unconscious 

🔍 Incident Details:

• The activity: cleaning inside a molasses tank considered a confined space due to its limited access and poor ventilation.

• The cause: oxygen depletion inside the tank, a hazard not properly identified or mitigated.

• The result: one fatality and one serious injury due to unsafe atmospheric conditions.

• Official source: SafeWork NSW report titled “A worker suffered fatal injuries and a second worker attempting a rescue was rendered unconscious … during cleaning operations inside the confined space of a molasses tank” 

📚 Why This Case Is Significant

1. Oxygen depletion is a common but often overlooked hazard in confined spaces—especially those containing organic materials like molasses, sludge, or grain.

2. The incident highlights dual hazards: the initial victim and the would-be rescuer both suffered harm due to inadequate control measures.

3. It underscores the critical need for:

Thorough risk assessments considering atmospheric hazards 

Pre-entry gas monitoring and continuous ventilation 

A trained standby/rescue team equipped to respond safely

✅ Policy Implications & Preventative Measures

• Entry Permits & Risk Assessment Before entry, assess the atmosphere and issue a permit only if controls (e.g., ventilation) ensure safe oxygen levels.

• Atmospheric Monitoring Use calibrated gas monitors to test oxygen—both pre-entry and continuously during operations.

• Rescue Planning Assign a competent standby person with rescue training and equipment; never rely on informal rescue efforts.

Regulatory and Legal Considerations

Across jurisdictions, confined space entry is governed by strict legislation:

• Australia: WHS Regulation 2011, Part 4.3

• United States: OSHA 29 CFR 1910.146

• UK: Confined Spaces Regulations 1997

These regulations outline specific duties for employers, including risk assessment, entry permits, signage, rescue, and worker training.

However, regulators often go beyond the written law when investigating incidents. They examine whether organisational systems—policies, procedures, and safety culture—met the spirit of the law, not just the letter.

Pro tip: In legal reviews, a policy that is “off the shelf,” outdated, or not followed in practice may be viewed as evidence of negligence.

The Policy-to-Practice Gap

Why do organisations struggle to enforce their own policies?

1. Leadership Disconnect

Executives may assume policies are being followed because they exist. But frontline realities may be far different—especially if safety is subordinated to productivity or cost.

2. Lack of Resources

Even well-written policies require investment—in training, personnel, equipment, and time. Without this, procedures become “tick-box” exercises.

3. Cultural Norms

If the informal culture rewards getting the job done “no matter what,” workers will sidestep policy to meet expectations. Leadership must align incentives with safety.

4. Poor Integration

Many safety policies are siloed from operational procedures. They are written by HSE teams but not embedded in planning, procurement, or HR systems.

Evaluating Your Confined Space Policy: A Self-Check

Ask yourself:

• ✅ Is the policy tailored to our operations and risks?

• ✅ Do all workers understand and have access to it?

• ✅ Are roles and responsibilities crystal clear?

• ✅ Does it include specific procedures for identification, isolation, testing, PPE, communication, supervision, and rescue?

• ✅ Are audits conducted to ensure the policy is being followed?

• ✅ Do we review and update it after incidents, near misses, or regulatory changes?

If the answer is “no” to any of the above, your policy may be a hidden hazard.

Embedding Safety: Turning Policy into Practice

To truly improve confined space safety, policies must become operationalised. Here’s how:

1. Leadership Commitment and Visibility

Safety policies must be endorsed—and demonstrated—by senior leaders. This includes walking the floor, participating in audits, and backing safety decisions, even when they cause delay.

2. Training that Mirrors Reality

Generic e-learning won’t cut it. Confined space training must be hands-on, site-specific, and include drills with actual entry and rescue equipment.

3. Live Permit Systems

Digital permit systems, linked with gas detectors and access control, can improve accountability and traceability. They ensure permits can’t be issued or closed without proper steps.

4. Emergency Preparedness

Have you ever tested your rescue plan? Do you have designated teams? Are they physically capable and properly equipped? Confined space rescue is a specialty—not a task you assign to whoever’s available.

5. Learning from Incidents

Treat every near miss as a gift. Analyse it using methodologies like ICAM or bowtie analysis. Update policies based on what you learn—not just after a fatality.

Organisational Culture: The Ultimate Policy Enforcement Tool

Ultimately, the best policy in the world is powerless in the face of a poor safety culture. Consider these principles:

Psychological Safety

Workers must feel comfortable stopping work or raising concerns. A culture of fear, blame, or “get on with it” leads to silence—and disaster.

Just Culture

Create a framework where honest mistakes are treated differently from negligence or sabotage. This encourages reporting and continuous improvement.

Operational Learning

Encourage bottom-up feedback. Ask workers: What’s stopping you from following the procedure? What would make it easier? What risks are we missing?

Conclusion: Safe Entry Begins with Smart Policy

Confined space entry is one of the most dangerous tasks in industry—and also one of the most preventable when policies are fit for purpose and properly applied.

Organisational policies are not just about compliance—they’re about clarity, accountability, and culture. They signal what’s important, what’s expected, and what will not be tolerated.

So, if you’re in a leadership, safety, or operational role, ask yourself:

Would I be confident standing beside our policy at a coronial inquest?

If the answer is “no” or “I’m not sure,” it’s time for a review.

Safety isn’t just what you say in your policies—it’s what your people do when no one is watching.

Author’s Note: If you’re working to improve confined space policies in your organisation, or have experiences to share (good or bad), I’d love to hear your thoughts in the comments. Let’s learn from each other—because behind every statistic is a person who deserved to go home.