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Most teams think they've got it covered. Most of them haven't.
If you're an HSE Manager in petrochemical, gas transmission, or power generation, you've almost certainly told yourself your confined space team is compliant. You've got certificates on file. You've done the toolbox talks. The box is ticked.
But after more than 20 years of delivering specialist confined space training across the UK, we can tell you this: the teams that come to us believing they're fully compliant are almost always the ones with the biggest gaps.
Here are the 5 warning signs we see over and over again.
1. Your Team Can't Name the Specified Risks Without Prompting
Ask your operatives — right now, without warning — to name the specified risks defined under the Confined Spaces Regulations 1997. Not vaguely. Not "it's dangerous." The actual risks: loss of consciousness or asphyxiation from gas, fume, vapour, or oxygen depletion; engulfment by free-flowing solids; drowning from rising liquid levels; fire and explosion; and loss of consciousness from heat stress.
If they hesitate, that's your first red flag. Knowing the hazards by name isn't a nice-to-have — it's the foundation of every risk assessment, every permit to work, and every emergency response. If your people can't articulate what they're being protected from, they're not truly competent. They're just certificated.
2. Nobody Can Demonstrate a Proper Pre-Entry Atmospheric Test
Having a gas detector isn't the same as knowing how to use it. We regularly meet operatives who carry expensive multi-gas monitors but can't explain their bump test procedure, don't know when the instrument was last calibrated, or couldn't tell you the alarm set points for the gases they're monitoring.
The HSE's Approved Code of Practice (L101) is clear: monitoring equipment must be in good working order, properly calibrated, and used by people who understand what the readings mean. A detector that sits in a van untested is worse than no detector at all — it creates a false sense of security.
3. Your Emergency Rescue Plan Has Never Been Practised
Almost every site we visit has a rescue plan written down somewhere. Very few have ever actually rehearsed it.
Here's the reality: approximately 15 people die each year in the UK while working in confined spaces. A significant number of those fatalities are would-be rescuers — colleagues who rushed in without proper training, proper equipment, or a proper plan. Communication failures and unrehearsed casualty handling are where most rescue plans fall apart under pressure.
The Confined Spaces Regulations 1997 require that suitable and sufficient emergency arrangements are in place before any work begins. A document in a filing cabinet is not an emergency arrangement. Your team needs to have physically practised the rescue — using the actual equipment, in conditions that simulate the real entry — or it doesn't count.
4. Your Supervisors Haven't Had Formal Competency Training
There's a common assumption that if someone has been supervising confined space work for years, they're competent. Experience matters — but experience without formal assessment leaves gaps.
Supervisors and entry controllers carry enormous responsibility. They need to understand their legal duties, know how to monitor changing conditions in real time, manage communication with the team inside the space, and make the call to abort an entry or initiate a rescue. That's not something you pick up informally.
If your supervisors haven't been formally trained and assessed for their specific role — not just "attended a course" but actually demonstrated competence against defined outcomes — that's a serious compliance gap.
5. Your Certificates Are More Than Three Years Old
This is the simplest check on this list, and yet it catches people out constantly.
A confined space training certificate typically has a recommended review period of three years. But a valid certificate doesn't automatically equal current competence — particularly if the person hasn't performed the task regularly or if site conditions have changed since they were trained.
The law doesn't set a specific expiry date on competence, but it does require that workers are competent for the work they're doing, at the time they're doing it. If your team's last formal assessment was more than three years ago, you're relying on an assumption, not evidence.
So What Does Compliant Training Actually Look Like?
Genuine compliance means your operatives can demonstrate — not just describe — the skills they need. It means your supervisors are formally assessed. It means your rescue arrangements have been tested in realistic conditions. And it means you're reviewing competence regularly, not just filing certificates and forgetting about them.
At JMS Consultants, we deliver specialist classroom training in gas testing, confined space entry, and nitrogen purging for operators in petrochemical, gas transmission, and power generation across the UK. We come to you, and we focus on real competence — not just attendance.
Not sure where your team stands? We've put together a free Competency Checklist that takes 5 minutes to complete and will show you exactly where the gaps are. [Download it here] or drop me a message — I'm always happy to have a no-pressure conversation about your team's training needs.
