Roco Rescue



NFPA 350 Update - Guide for Safe Confined Space Entry and Work

Thursday, April 23, 2015

Just a couple of weeks ago at a meeting in Florida, the final public comment revisions were made to NFPA’s new Confined Space Guide (NFPA 350). The document now goes before the NFPA Board for final approval. If all goes well, the new standard may be available next year.

Back in August 2013, we first made you aware of the proposed NFPA 350 document regarding working in and around confined spaces. (Read original post here) Designed as a “best practices guide,” it goes further in explaining what needs to be done to protect workers who make entry or work around confined spaces. We also made the draft document available on our website and encouraged your input, which many of you did. 

NFPA 350 will be an excellent resource for larger companies and municipalities with well-established permit systems, as well as smaller organizations that may not totally understand what is needed to safely work in and around confined spaces. Hopefully, this guide will fill-in some of the gaps or questions that arise when deciphering OSHA 1910.146 (Permit-Required Confined Spaces) as well as provide a better understanding of identifying hazards, ventilation, control measures, atmospheric monitoring, rescue requirements and rescue team qualifications, just to mention a few.

So, to all of you who participated by providing public comments, our hats off to you for taking an active role in providing a best practices guide to help protect others that do a dangerous job!

NOTE: Once finalized, we will update you on some of the unique perspectives of the document. Topics such as the practice of considering every space as hazardous; then, either clearing it, or writing the required permits to allow entry. Stand-by for future updates!
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WH Completes Review of OSHA's Confined Spaces in Construction

Friday, April 10, 2015

Washington – On April 3, the Office of Information and Regulatory Affairs (OIRA) completed its review of OSHA's Confined Spaces in Construction Standard, paving the way for the final rule to move forward. The rule (29 CFR 1926.36) has been in the works for more than a decade. An OIRA review is one of the last steps a federal agency must take before it can publish a final rule. According to OSHA's timetable, the confined spaces final rule was originally scheduled for publication in March.

In 1993, OSHA issued a general industry rule to protect employees who enter confined spaces while engaged in general industry work (29 CFR 1910.146). This standard has not been extended to cover employees entering confined spaces while engaged in construction work because of unique characteristics of construction work sites. Pursuant to discussions with the United Steel Workers of America that led to a settlement agreement regarding the general industry standard, OSHA agreed to issue a proposed rule to protect construction workers in confined spaces.

Source: Membership News Alert from National Safety Council

UPDATE: Roco is hearing that a final ruling will be released within the next 6 weeks. As soon as the information is provided, we will be sure to post for you!

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Roco QUICK DRILL #7 - Anchor Selection and Rigging

Wednesday, April 08, 2015

Maintaining proficiency when building rescue systems requires skills and experience – that’s why regular practice is critical!

With continued practice in keeping it safe and simple (KISS), rescuers can learn to be more efficient with their equipment as well as in selecting and setting up rigging anchors. Proficiency with this allows them to get a running start in constructing the foundation of all rescue systems.

1.  Use an area that has a variety of simulated anchor opportunities. Try to create a mix of bombproof, substantial, and inappropriate anchors.

2.  Clearly state the objectives and point out exactly where the lines have to fall in terms of plumb line, and whether it’s to be set up as a lowering system, safety line belay or static line (rappel line).

3.  Have a variety of anchoring material and equipment available, such as utility straps, webbing, extra rope shorts, carabiners, tri-links, etc. Lay out limited amounts of this equipment.

4.  Here are the rules:
  • • For each rotation, define the type of system to be built (lowering, static or belay) and the type of anchor system such as: bombproof, substantial (multi-point) or self-equalizing.
  • • After each rotation, participants must give up a piece of equipment they used (i.e., if they used utility belts as anchors, remove the belts from available equipment for the next rotation).
  • • Repeat as many times as participants can come up with solutions as you switch between anchor types, systems and available equipment.

5. With a little planning, you can come up with an order and number of rotations possible along with an equipment list that should end with just the rope and a device. This drill can be adjusted to help newer team members better understand rigging principles and techniques, or to challenge more experienced team members based on the number and type of rotations and equipment available.

6. Another way to challenge more experienced team members is to limit the knots to be used by providing a master list of knots. Then, eliminate a knot from the list after it has been used.

This drill will help new rescuers better understand their options while taking a good anchor rigger to the next level.

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Dialing 911 for Confined Space Rescue

Thursday, March 19, 2015

By Pat Furr, Roco Chief Instructor/VPP Coordinator 

It is still happening out there, folks. Fatalities are still occurring during permit required confined space entries. Unfortunately, workers are dying because the permit space (or the entrant) was not properly prepared prior to entry. And, tragically, many of these fatalities are the would-be rescuers, who are trying to aid their co-workers! Most often, these would-be rescuers are authorized attendants or passersby that reacted improperly and took heroic, but inappropriate action. Or they may have been professional rescuers, who were not trained or equipped for this type of rescue.

In nearly every case, these fatalities are completely preventable - simply by properly preparing the permit space prior to entry by isolating or if needed, controlling all hazards. However, should an emergency arise, the rescue service must be prepared to respond to these types of emergencies. This includes proper training and equipment to ensure a successful rescue and that everyone involved goes home safe and sound.

Considering Rescue Service Options

In a previous article, we outlined the three primary ways that an employer can ensure there is a proper confined space rescue service in place as part of their written permit required confined space program. These options include:

(1) an in-house rescue team made up of host employees;

(2) a third party contracted rescue service, or

(3) relying on 911 emergency responders.

All three options have their benefits and their shortcomings. However, it is critically important that the employer focus on the entrant’s safety more than any other consideration, be it monetary, personnel, equipment, or any other resource when deciding what type of rescue service to employ.

I get around…(no, not the Beach Boys’ song). I travel extensively visiting a variety of private and governmental sector work sites, and I also do the trade show/lecture circuit. In my travels, I hear all sorts of variations to the “confined space rescue service” theme. Many employers use in-house rescue teams and accept the funding and time commitments required to keep this capability proficient in the needed skills. Some employers rely on a third party professional rescue service to meet this requirement. Sometimes these third party agreements are for the short term such as during turnarounds, or even for sustaining operations as imbedded contractors. Still other employers rely on 911 public safety responders for their confined space rescue needs.

All three options can and do work, but the one option that I hear having only a cursory vetting process in many cases is the 911 option. At times, I have asked an employer to describe the extent of the agreement between their facility and the 911 responders. That’s when I typically hear an answer such as, “Well, all our employees know the phone number to dial.” That’s when I offer to buy coffee so we can have a little chat. This article will focus on using 911 as your confined space program rescue service.

Before I go any further, I want to say that in my view, our 911 emergency responders are true heroes. And many times, I feel they are under-appreciated. Until a major national disaster hits, many of us are guilty of overlooking the risks that these men and women take on a regular basis. I also think it’s important for employers to understand the extensive set of skills, and wide variety of skills, that emergency responders are required to master in order to perform their primary job responsibilities.

Extensive Skill Requirements for Municipal Responders

For example, firefighters are required to maintain a wide variety of special skills, such as pump operations, ventilation, PPE, emergency vehicle driving, along with medical skills such as advanced airway management, pharmacology, advanced cardiac life support and…are you getting the picture? The skills and knowledge required to perform technical rope rescue is a specialty not typically included in a firefighter’s job description unless they are assigned to a heavy technical rescue (HTR) squad.

NFPA 1006 (2013 edition, with next one coming in 2017) lists all the specialty areas that a rescue service may be called on to master. The first set of requirements is established by the department’s authority having jurisdiction (AHJ) and may include such things as a minimum level of physical fitness, HAZMAT training, emergency medical care training, and several other requirements. Then, there is what used to be referred to as “core skills” now known as Job Performance Requirements. These requirements are extensive before even addressing any of the 19 different technical rescue specialty areas such as: swift water rescue, trench rescue, machinery rescue, structural collapse rescue, wilderness rescue, and the list goes on. Also included in this list is confined space rescue.

In Albuquerque, New Mexico, where I live, we are fortunate to have a dedicated HTR squad within our fire department that is trained, equipped, and staffed 24/7. This team is called upon to respond to flash-flood rescues in our many arroyos, mountain rescue in the peaks east of the city, vehicle entrapments on two interstate highways as well as our surface streets, and may also be called to an employer’s work-site to perform a variety of rescues there. This could be anything from trench rescue to – you guessed it – confined space rescue.

CS Emergencies Require Special Skills and Equipment

It is fairly rare that municipal responders are provided the resources (including specialized training and equipment) to safely and effectively respond to confined space rescue emergencies. Rarer still, for these responders to have been afforded the opportunity to practice in the types of confined space rescues that may be required in their local industrial corridors. Any rescue service would need to be trained and equipped in advance to handle the many hazards and obstacles of permit required confined spaces.

It is the employer’s responsibility, both morally and legally, to engage with the 911 service that is being considered as their confined space rescue service.

Appendix F of 1910.146 is a very valuable means to ensure that both the rescuers and the employer know what the requirements are and that proper agreements are in place prior to confined space entry operations. 

Roco has provided a sample for you to download.

Any shortfalls must be addressed. This may include lack of training, equipment, staffing, or many other requirements necessary to ensure a response appropriate for the types and hazards of the spaces onsite.

OSHA states in section (d)(4) of 1910.146 that “the Employer shall provide rescue and emergency equipment needed to comply with paragraph (d)(9) of this section, except to the extent that the equipment is provided by rescue services…” This is where an employer and a public safety agency may enter a cooperative arrangement beyond what is already expected of the 911 responder's normal duties.

Funding through grants and other resources has become very lean in the last several years. As public safety budgets are trimmed down, both career and volunteer fire departments must make budgetary decisions that in many cases result in sacrificing emergency service capabilities beyond firefighting and emergency medical services. This would mean that many of the technical rescue capabilities outlined in NFPA 1006 are not within the means of many fire departments. The impact on an employer may be that they lose a previously established ability to rely on a 911 agency for their confined space rescue needs, or they may not be able to rely on that rescue service option during the development of their permit required confined space program.

However, we also understand that it is becoming more and more common for employers to provide rescue equipment and/or funding for rescue training specific to the needs of the employer’s confined space program. Various state and local requirements may differ, but generally this can be accomplished by having the employer set up a grant with monies being donated for specific training or equipment purchases. Depending on the local ordinances, equipment can be directly transferred from the employer to the 911 agency through a simple agreement that outlines its intended purpose and ownership. There may be tax advantages to the employer while benefiting the community as well. Bottom line...there are critical steps to take before relying solely on a local 911 agency.

Evaluating Rescue Response Capabilities

Appendix F of 1910.146 clearly explains the need for employers to evaluate a prospective rescue service before depending upon their services. It states,

Merely posting the service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

Other critical factors include response time and availability. Response time is generally extended when relying on an offsite rescue service such as 911. According to OSHA, the response time must be appropriate for the types of known or potential hazards affecting the confined spaces at the employer’s facility. Relevant factors include:

(1) Location of the rescue team or service relative to the employer's workplace

(2) Quality of roads and highways to be traveled

(3)  Potential bottlenecks or traffic congestion that might be encountered in transit

(4) Reliability of the rescuer's vehicles, and the training and skill of its drivers

And, what about the availability of the rescue service? Is it unavailable at certain times of the day or in certain situations? What is the likelihood that key personnel of the rescue service might be unavailable at times? If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the entry operation can be aborted immediately?

In fact, these considerations also apply to any of the three means of providing a confined space rescue service, be it an in-house service, a contracted service, or a 911 emergency response. However, response times and availability are typically crucial limitations in relying on 911 for confined space rescue.

Careful Planning Required!

If you have identified 911 as the rescue service written into your confined space program, it is crucial that you take all the necessary steps to vet the agency as being a good fit to protect your employees. 

In addition to all requirements of Appendix F, it is of utmost importance to pay particular attention to the service’s ability to respond in a time appropriate for your needs, and to ensure that reliable two way communications are in place. The 911 dispatch will be notified when entry operations are to commence; and, just as importantly, the 911 dispatch will notify the employer when the service is not able to respond to an emergency so entry operations can be immediately aborted.

With careful planning, thorough communications, and proper training and equipment, relying on 911 response for confined space rescue can work. Unfortunately, in some instances, the outcome is tragic with loss of life not only to the entrants, but also to the unprepared 911 responders who had little clue as to what they were about to encounter. As an employer, it is your responsibility to make sure the rescue service is adequately prepared!

Additional OSHA References:

1910.146(d)(9) Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue;

1910.146(k)(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of 1910.146(k)(1)(i). Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

1910.146(k)(2)(i) Provide affected employees with the personal protective equipment (PPE) needed to conduct permit space rescues safely and train affected employees so they are proficient in the use of that PPE, at no cost to those employees;

1910.146(k)(2)(ii) Train affected employees to perform assigned rescue duties. The employer must ensure that such employees successfully complete the training required to establish proficiency as an authorized entrant, as provided by paragraphs (g) and (h) of this section;

1910.146(k)(2)(iii) Train affected employees in basic first-aid and cardiopulmonary resuscitation (CPR). The employer shall ensure that at least one member of the rescue team or service holding a current certification in first aid and CPR is available; and

1910.146(k)(2)(iv) Ensure that affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

Note to paragraph (k)(l)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

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Roco Safer Way Banner Giveaway

Tuesday, March 17, 2015

One of our awesome customers had a great safety idea, and we wanted to share it with you…a Roco Safer Way banner. Of course, if you’ve ever been a Roco student, you’ve heard it many times…”there’s a safe way and a safer way!” Now you can win a FREE Roco Safety Banner (4-ft x 2-ft) for your workplace.

During a plant turnaround, this customer used the Roco Safer Way banner to keep safety at the forefront – while maybe also offering a subtle reminder for everyone to be grateful for their on-site emergency responders! It is our hope that these banners will encourage someone to think (or re-think) a situation and make it even safer!

Register now to win a Roco Safety banner and remind your personnel of the safer way!

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RTC Expands to Meet Rescuer Needs

Wednesday, February 18, 2015

Construction is well underway on expansions and improvements to the Roco Training Center (RTC.) The goal is to add new confined space shapes and configurations in order to simulate an even wider variety of scenarios that rescuers may face in the real world. 

An additional two-story container configuration is being erected east of the pipe rack module. This will add 10 vertical confined spaces, 2 horizontal confined spaces, and 7 more student platforms for staging rescue equipment and training evolutions. The new area will be under a covered roof, making rescue training on the prop a bit more user-friendly in our south Louisiana climate!

Nearly complete is the new stairway on the south side of the prop that will provide additional access to the structure and more anchor points for rescue students taking courses at RTC. With these new features, the prop is increasing its student capacity by approximately 33 rescuers per day.

Last year a boiler simulator was added which focuses on extremely tight (12" x 15") horizontal confined spaces found at many industrial settings, old and new.

"Roco is constantly surveying our students to find out what their particular problem spaces are," said Dennis O'Connell, Director of Training for Roco. "We try to duplicate those confined spaces at RTC, so students can practice the skills they will need if a problem occurs at their site. This way, they get a more accurate experience."

The anticipated completion date for the additions to RTC is April 15, 2015. It is sure to add a few more challenges for Roco students who are familiar with the prop, as well as a few more conveniences.

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Roco Tech Panel Q&A - Prompt Rescue by Shift

Sunday, February 01, 2015

Our company procedures require an on-site rescue capability for permit- required confined space entry operations during normal Monday-Friday “day shift” operations, but for entries other than during that shift, we rely on an off-site rescue service. Shouldn’t the rescue capability, specifically the rescue response time, be the same no matter when the permit required confined space entries are being made?

Yes; and no, not necessarily.

Yes, if the nature of any known or potential hazards that may affect the entrants in the permit space, and the configuration of the confined space are the same during regular M-F day shift as they would be during off-shift entries, then the answer is yes. The rescue capability regarding response time, manning, equipment, and overall performance capability should be the same.

No, not necessarily. For example, if the nature of the known or potential hazards of a permit space entered during the day shift requires a shorter response time, or if the configuration of the space requires a higher level of rescue expertise, rescuer PPE, number of rescue personnel, or if there is any other factor that may require a different performance capability than the requirements of the day shift entries, then no, the same rescue capability would not necessarily be required.

This is because OSHA 1910.146 is a performance-based standard. For confined space rescue, specifically regarding what would be considered “prompt rescue,” the performance standard will be most influenced by the nature of the potential and known hazards and how quickly the hazards will affect the authorized entrants, as well as the complexity of providing effective rescue from the particular permit-required confined space.

To demonstrate this point, here are some extracts from OSHA 1910.146 Permit Required Confined Space Regulation Section K, the Summary and Explanation of the Final Rule, and also from OSHA 1910.146 Appendix F.

From 1910.146 (k)(1)(i)“Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

Note to paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.”

From the Summary and Explanation of the Final Rule (1910.146) “OSHA has therefore decided to promulgate the requirement it proposed for "timely" rescue, a requirement that was not opposed by any rulemaking participant, rather than to define precisely what is timely. That determination will be based on the particular circumstances and hazards of each confined space, circumstances and hazards which the employer must take into account in developing a rescue plan. OSHA has added a note to paragraph (k)(1)(i) to clarify this point.”

From 1910.146 Appendix F, A. Initial Evaluation, II, 1. “What are the needs of the employer with regard to response time (time for the rescue service to receive notification, arrive at the scene, and set up and be ready for entry)? For example, if entry is to be made into an IDLH atmosphere, or into a space that can quickly develop an IDLH atmosphere (if ventilation fails or for other reasons), the rescue team or service would need to be standing by at the permit space. On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutes might be adequate.”

The response time of the rescue service is also different than the time needed to provide rescue. Response time generally means the time it takes for the rescue service to arrive on scene. From that time forward, the rescue service must perform a size-up, identify and don PPE, set up rescue systems, and perform many other tasks before initiating entry rescue. Any need to provide victim packaging or to deliver breathing air to the victim will add to the total time it takes to complete the rescue.

Therefore, it is imperative that the employer ensures that the measure of “Prompt Rescue” is driven by the nature of the known or potential hazards of the permitted confined space as well as the complexities of the configuration of the space and how those will effect the time required to the setup the rescue system.

Roco provides confined space rescue services for a variety of industries and is confronted with a very wide range of hazards associated with the entry operations and a vast range of space configurations. The determination on the rescue team’s posture is based primarily on the answer to the following questions.

  • 1.  How quickly will the entrants be overcome by the known or potential hazard(s) of the space, and /or how quickly will the entrants suffer permanent injury if exposed to those hazards?

  • 2.  If non-entry retrieval systems are not employed due to the system not contributing to an effective rescue, or the retrieval system creates a greater hazard, how much time would be needed to arrive on scene, set up an entry rescue system to support the entrant rescuer(s) and the victim(s)?

These are just two of the primary questions that we consider for our CSRT operations. If the nature of the known or potential hazards would require a near immediate rescue of the entrant(s), we would assume a “Rescue Standby” posture where the rescue systems are pre-rigged, the entrant rescuers are already in appropriate PPE or have it available to be quickly donned, and the rescue effort can be initiated in a very short time in an effort to meet that “Prompt Rescue” performance benchmark.

It is vitally important that the employer honestly evaluates the nature of the hazards or potential hazards of the permitted confined spaces that they plan on entering. This can be accomplished by reviewing product SDS (Safety Data Sheets), understanding the nature of the hazards that are not included in the SDS, and always considering worst case scenarios. Additionally, the employer must include an evaluation of the time it would take the rescue service to arrive on scene as well as the additional time to safely assess the situation and setup the required rescue systems prior to initiating rescue.

The answer to the question of a different rescue capabilities based on the “day shift” or “night shift/week-ends” can only be answered by performing a thorough assessment of the permitted spaces. And, on a case by case basis, determine if the rescue capability for that particular entry operation does indeed meet the spirit of “Prompt Rescue.” 

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Roco QUICK DRILL #6 - Splitting One Rope Between Two Systems

Wednesday, January 28, 2015

At times, it may be necessary to use a single rope split between two different rescue systems. This can be useful when all ropes are being used for other purposes, such as taglines, extending anchors, etc. Being proficient in using a single rope between two systems helps spread the resources and may be more than just another tool in your toolbox. Someday, it could be crucial to a successful rescue!

Here’s the drill:

1.  Choose an elevated location that is less than one half the length of the rope – plus, allow a good margin of extra rope. For example, if using a 150 ft. rope, you could use a platform that is about 40 feet high.

2.  Select two appropriate anchor points near each other. One will be for the main line; the other for the safety.

3.  Build a lowering system using one end of the rope and the main line anchor. Anchor the descent control device and prepare for a lower.

4.  Build your safety line using the other end of the rope and the second anchor.

5.  Lower the rescuer, package your patient, and recover them both.

6.  Try doing this using different descent control devices and different types of systems (piggy back vs. Z-rig). Play "what if" and problem solve.


•  Pre-measure your lines. We say start where you want to end up! This drill is nothing more than lowering the end knots to the ground to assure you have enough rope to do the lower. It also allows you to inspect the rope for damage before life loading the lines.

•  If you do this with both ends of your rope and you have enough rope to reach from the ground to your two anchor points independently, you now know you have enough rope for both the mainline and safety line system.

•  Any additional line left between the two systems can be used to extend anchor points, rigging or build mechanical advantage systems.

•  Many times we use this technique of splitting rope from a single rope bag as our safety/retrieval line for rescue entrants during confined space rescue. We use rope bags that allow us to work from either end of the rope easily. We take two different color ropes usually 125 ft., tie them together, and load the bag from both ends with the knot in the middle (double fisherman). This allows us to run safety lines to two rescuers out of one bag. Since each rope is a different color it helps with line management, communications, identification and emergency retrieval. If your rescue scenarios require entrants to advance more than 125 ft., then longer ropes can be substituted. The rope can also be used as a single 250 ft. safety line provided you have knot passing capabilities.

  • •  Manage your ropes! Without good rope management, your work area can easily turn into a tangled mess.

This drill forces rescuers to think ahead and “outside the box” in order to allocate appropriate lengths of rope for each system or how to better use limited equipment resources. It is an excellent exercise in efficiency, rope management, and housekeeping – while demonstrating the importance of each when managing this type of system.

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Q&A: Appendix F (1910.146)

Wednesday, January 07, 2015

If Appendix F is non-mandatory, then why is it relevant to my PRCS program?

Questions often arise about the application of Appendix F of OSHA’s Permit Required Confined Spaces standard. Those questions usually focus on the “non-mandatory” characterization of the appendix.

The question most often asked is “If it’s non-mandatory, why should I even bother with it?” The answer is simple: even though Appendix F itself is “non-mandatory,” the methods for compliance in the appendix all relate to mandatory requirements of the standard. Appendix F is simply a non-mandatory method for complying with mandatory requirements.

The trick when evaluating the methods of compliance outlined in Appendix F is to match the particular non-mandatory provision of the appendix with the corresponding mandatory requirement of the standard. Then the employer can either use the method suggested in the appendix, or devise its own method to comply with the mandatory requirement.

For example, with regard to outside rescue services, Appendix F paragraph A(3) asks the question: “If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately?”

This provision does not create a mandatory requirement, but it does prompt the employer to take into account mandatory requirements of the standard. OSHA 1910.146(j)(3) makes it mandatory for the entry supervisor to terminate the entry and cancel the permit as required by paragraph (e)(5) of the standard.

Paragraph (e)(5) requires the entry supervisor to cancel the entry permit when “a condition that is not allowed under the entry permit arises…” If the particular entry requires rescue service availability and the rescue service suddenly becomes unavailable during the entry, that would be “a condition that is not allowed under the entry permit” requiring the entry supervisor to cancel the permit.

So although there is no provision that specifically states that the rescue service notify the employer if it becomes unavailable, from a practical standpoint the employer cannot comply with the requirement that it cancel the permit and terminate the entry when a condition not allowed under the entry permit arises unless such a notification system is in place. This is just one example of how the provisions of non-mandatory Appendix F provide a method to comply with mandatory requirements.

When considering the provisions of non-mandatory Appendix F, the employer would be wise to determine which mandatory provisions the method stated in the appendix addresses. Of course, the employer is free to choose some other method to comply with the mandatory provision and does not necessarily have to follow the method suggested in the appendix. In that sense, the appendix is “non-mandatory.” But, nonetheless, the employer must comply with the underlying mandatory provision, and take any steps necessary to do so.

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Combustible Dust and Confined Spaces

Monday, January 05, 2015

In January 2004, an explosion at the West Pharmaceutical Company in Kingston, NC killed 6 workers and injured 34 others. Two firefighters were injured during the response to the incident.  One month later, an explosion and fire occurred at the CTA Acoustics manufacturing facility in Corbin, KY, killing 7 workers. In February 2008, an explosion at the Imperial Sugar Company facility in Wentworth, GA, killed 13 workers and injured 42 others. Three very different types of facilities with very different products, but with one thing in common—dust!

"A 'safe’ area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations."

The Chemical Safety Board reported that there were 281 explosions of combustible dust in the United States between 1980 and 2005. These explosions resulted in 199 deaths and 718 injuries. And these are just the actual explosions. There are countless more combustible dust environments just waiting for the right (or wrong) conditions to align to become the next fatal explosion. The fact is that with the exception of silicon or sand, every kind of dust is potentially combustible to some degree.

Combustible dusts are measured on a “deflagration index,” (see box) which measures the relative explosion severity compared to other dusts. They range from such seemingly innocuous items such as dust from powdered milk and egg whites that can create “weak explosions,” to dusts from items such as magnesium and aluminum that can result in “very strong explosions.” But I think we can all agree that no explosion, even a “weak” explosion, is a good explosion—especially if it occurs during rescue operations. 

As rescuers, you should already be familiar with the “fire triangle.” To understand the danger of combustible dusts, you should also be familiar with the “dust explosion pentagon.” The dust explosion pentagon consists of the following:

-       Combustible Dust (Fuel)

-       Ignition Source

-       Oxygen

-       Dispersion of dust (suspension)

-       Containment of the dust in a confined or semi-confined area (Enclosures/Building/Confined Space)

Rescuers should be on the lookout for any appreciable accumulation of dust when sizing up a rescue situation. Keep in mind that your atmospheric monitor containing a sensor for combustible gases is not effective for detecting a hazard from combustible dust.  

Always remain aware that in a suspended state, dust becomes explosive. Dust explosions occur when combustible dust is present, forms a dust cloud in an enclosed environment, and is exposed to oxygen and an ignition source. The explosion occurs as a result of the rapid burning of the dust cloud, which creates a rapid pressure rise in the enclosed area or confined space. 

A dust pile that may burn while an ignition source is being applied, then go out immediately or shortly after the ignition source is removed, can become lethally explosive when scattered and suspended in the air. 

Always consider the potential for combustible dust in any rescue situation, particularly when ventilation of an enclosure, building, or confined space is considered. A “safe” area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations.

This article was written by Robert Aguiluz, who is currently an Administrative Law Judge for the State of Louisiana. He is also an attorney who specializes in Occupational Safety and Health Law, and regulatory and compliance issues. He is a former Certified Safety Professional and Roco Rescue Instructor with over twenty years’ experience in both industrial and municipal emergency response and rescue.

Combustible Dust Considerations for Emergency Responders:

1.  Know your response area and the types of industry that may have the potential for combustible dust. If you are performing standby rescue duties, meet with the SH&E management team to learn about any combustible dust hazards at their facility.

2.  Become familiar with the “deflagration index” for various types of materials. See sample Chart below.

Examples of Kst Values for Different Types of Dust


3.  Consider the effect of ventilating a space that has accumulations of combustible dust.

        •  Will you cause the dust to become suspended?
        •  Will the suspended moving dust create a static charge/discharge and become a source of ignition?
        •  Can your ventilation equipment become a source of ignition?

4.  Is there information to review on the SDS (Safety Data Sheet) regarding the material’s potential to become combustible dust?


OSHA Quick Card: Prevent Dust Explosions

“Firefighting Precautions at Facilities with Combustible Dust”

“Hazardous Communication Guidance for Combustible Dust”

“Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions”

“NFPA 654: Standard for the Prevention of Fire and Dust Explosions”


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