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Retired and Dangerous...Mothballed Vessels and Abandoned Equipment

Tuesday, September 16, 2014

In a recent article in ASSE’s Professional Safety magazine, we found some very important points to consider for rescuers. Whether you are preparing for stand-by rescue operations, getting ready to enter an “abandoned in place” vessel, or just found the “perfect” retired vessel to use for your upcoming rescue training…proceed with caution!

The article does a great job of reminding us that not so long ago the emphasis on safety was far less than it is today. This becomes very clear when we compare current safety practices, such as Management of Change (MOC), and how the absence of that particular management tool has left many retired confined spaces and other systems in a potentially dangerous state.


Because of the potential dangers posed to emergency responders, we wanted to share this article with our readers.

Click to download the full article

Here are some key points from the article “Retired and Dangerous, Out-of-Service Equipment Hazards” by Robert Wasileski.

• Management of Change is emphasized more during the design and operational phase of equipment life cycles, but receives little emphasis when it is time to retire the equipment. 

• Older facilities have a high potential to have retired equipment that haven’t had all hazards addressed and may pose serious risks.

• Equipment that has been out of service for an extended period of time often has very little data on record stating how it was prepared to be taken out of service.

• There are many instances of chemical reactions that can change the physical condition of the equipment over time.  

The author provides several case studies that are truly enlightening. It includes some excellent lessons for rescuers when dealing with out-of-service or “moth-balled” vessels. While a couple of the cases delve pretty deeply into chemical reactions, it serves as a critical reminder of how important it is to check with a qualified person. Remember…just because a vessel has been out of service for a long period of time does not mean there are no hazards present!

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Are You Sure You Don't Need On-Air Rescue Practice?

Thursday, August 28, 2014

Reported by Dennis O’Connell, Director of Training

After more than 25 years in the rescue industry, I always cringe a bit when I hear rescue teams say they don’t practice “on-air” rescues because personnel at their facilities are not allowed to do planned work activities in IDLH or low O2 areas. But I always ask, what about the permit spaces that may have the “potential” for atmospheric hazards? What about those spaces that may unexpectedly become IDLH or low O2 – what then?  

"I have raised this flag many times before and according to NIOSH, a little less than half the deaths from atmospheric conditions occurred in spaces that originally tested as being acceptable for entry. Something happened unexpectedly, and something went very wrong."

Remember, OSHA states that a confined space simply has to have the “potential” for a hazardous atmosphere; not that it is actually present as one of the triggers to make a space a “permit required space” and require rescue capabilities.

So, for these unexpected instances, do you really have the appropriate rescue response in place? In our opinion, not training your team to respond to IDLH emergencies is like buying a gun for home protection, but not buying any bullets.

Also, 1910.146 section (k)(1)(i) makes reference to 1910.134 OSHA’s respiratory regulation. Here OSHA talks about respiratory protection being worn by entrants as the trigger for “standby” rescue personnel capable of immediate action. It is not necessarily based on the level of O2. It calls for “rescue standby” not rescue “available.” Immediate action is called for… not just a timely response

OSHA 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.

If that’s not a hint as to how seriously OSHA takes the possibility of an IDLH atmosphere arising in a permit space, I don’t know what would be.

So, if you don’t think you’ll ever need on-air rescue capabilities, take a look at this incident from a few years back. The way this confined space fatality occurred and the possibility of it happening is a real eye opener. It emphasizes the critical importance for considering all possible (or potential) hazards associated with confined space entry and rescue.

Folks what I’m trying to say here is, as rescuers, we need to be prepared for the worst case scenario as well as the unexpected! This is especially true when it comes to confined spaces. When I hear, "We don’t need on-air practice because we don't allow IDLH entries at our facility." Well, neither did these guys...


Fatal Activation of CO2 Fire Protection System in Confined Space

 


Sheffield Forgemasters was ordered to pay heavy fines and costs for safety failings that led to an employee dying of carbon dioxide poisoning after the cellar he was working in filled with the deadly gas. A worker was found unconscious at the South Yorkshire foundry after a confined underground area swiftly flooded with the fire-extinguishing mist. Four of his co-workers desperately tried to reach him but were themselves almost overcome by the fast-acting gas. The worker, who had three grown-up sons, was pronounced dead on arrival at the hospital after the incident at the firm’s plant on 30 May 2008.

The Health and Safety Executive (HSE) investigated and prosecuted the company for serious safety failings. On December 19th 2013 Sheffield Crown Court heard that on the morning of the incident, the worker had carried out part of the cable cutting task in an electrical drawpit and then went to carry out the rest of the job in the switchroom cellar, which was only accessible by lifting a manhole cover and dropping down a ladder. Once underground at the electrical drawpit, the worker used a petrol-driven saw to cut through redundant 33,000 volt cables. At some point, he moved from there to the nearby switchroom cellar with the saw.

Later that morning, colleagues heard the carbon dioxide (CO2) warning alarms sounding from the cellar. A supervisor and other workmates rushed to help, with several of them trying to get down the ladder from the manhole to rescue the worker from the cellar’s confines. However, all attempts were defeated as each worker struggled to breathe and remain conscious when exposed to the debilitating concentrated carbon dioxide. The victim had to be brought to the surface later using slings.

HSE found that use of the petrol-driven saw in the switchroom cellar had likely activated a smoke sensor and prompted the release of the carbon dioxide from the fire extinguishing system.

The court was told Sheffield Forgemasters had failed to provide any rescue equipment for either the cellar or the drawpit. Other issues identified included a lack of a risk assessment by the firm for the cable cutting task and failing to provide a safe system of work in either underground location. In addition, there was no secure way to isolate the carbon dioxide fire system while work was going on in the cellar.

After the hearing, a HSE Inspector said: “This was a very upsetting incident that resulted in the needless death of this employee. It could have been an even worse tragedy as it was pure chance that another four workers who entered the cellar in a desperate bid to save their colleague did not also perish.” 

“Exposure to between 10-15% of CO2 for more than a minute causes drowsiness and unconsciousness. Exposure to 17-30% is fatal in less than one minute. Carbon dioxide is poisonous even if there is an otherwise sufficient supply of oxygen. 

“The risks associated with confined spaces are well known in industry and there is an entire set of regulations dealing with controlling the risks associated with them. Multiple fatalities do occur when one person gets into difficulty in such a space and then the rescuers are similarly overcome.”

“Sheffield Forgemasters had given no thought to the risks associated with the task being undertaken, nor had they provided emergency rescue equipment. This case shows how important it is for companies to effectively risk assess work activities; looking at how the work will be carried out and in what circumstances.” 

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Roco QUICK DRILL #4 - Selecting the Proper Knot and Tying Correctly

Wednesday, August 13, 2014

Being able to tie a knot in the classroom with a rope short vs. selecting the proper knot and tying it correctly in the field during an emergency requires experience. With a little imagination, you can provide your team members numerous scenarios to practice in just a short period of time while they are still within a controlled environment. This practice will help them to gain more experience that should pay off in the long run if needed during a real life emergency.

1.  Identify the knots your team uses, and where they are used in various systems.

2.  Lay out a series of applications where team members would need to tie a knot. Decide in advance what knots are acceptable in these applications since many times more than one knot may get the job done.

3.  Once you have established the acceptable knots, lay out a gauntlet of knot tying stations.

4.  Each team member will go through each station... first, deciding which knot to use, and then tying it as it would be used in the application (examples: end knot in a lower line, vertical bridle knot, lashing a backboard, adjustable anchor, self-equalizing anchor, etc.)

The goal is to have team members choose an appropriate knot, tie it correctly, and apply it properly based on the rescue system presented. Two examples for knot stations are: (1) Backboard lashing - have the lashing complete except for the knot at the end; and (2) Mainline rigged except for the knot attaching it to the anchor.

CHECK OUT OUR RESCUE KNOT VIDEO SERIES!

Download the Rescue Knots PDF
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OSHA Emergency Response Meeting in Washington, DC

Thursday, August 07, 2014

Reported by Jim Breen, Roco Rescue Director of Operations

On July 30 and 31, OSHA held an Emergency Response and Preparedness Stakeholders meeting in Washington, DC for the purpose of discussing the merits and potential content of an emergency response and preparedness standard.

Meeting participants were from a broad range of both public and private industry experts to include two Roco representatives, Jim Breen, Director of Operations, and Dennis O’Connell, Director of Training. Also participating were representatives from NFPA, IAFF, IAFC, USFA, Louisiana Fire Chiefs Association, Phillips 66, BASF Corporation, Chevron Pipeline Company, Chicago Fire Department, and the American Red Cross to name a few.


The discussion allowed participants to highlight their experiences, voice concerns, and provide input to OSHA administrators who are tasked to make a need and content recommendations to OSHA's senior leadership.

The meeting consisted of four main topics:

1.  Which phases of an emergency incident should be included in a standard?

2.  Should the standard be inclusive of all incident types or should it be focused on those types of incidents that have resulted in a line-of-duty deaths (LODDs)?

3.  What content should be included in the standard?

4.  How can OSHA construct a standard that is practical, relevant, and flexible enough to cover all organizations, regardless of size and complexity?

OSHA was particularly mindful of having participants identifying issues that would impede the practical application of an emergency response and preparedness standard. OSHA administrators were very receptive of the views of the participants and stressed that they were not interested in writing a tactical or tactics standard. Although OSHA did not elaborate on any specific course of direction, it is our impression and hope that OSHA will begin drafting an emergency response and preparedness standard that is performance based, with a strong strategic focus, that emphasizes a recognized incident management system, outlines preparation activities inclusive of pre-incident planning, and is structured around the basic functions of command that will apply to all emergency response organizations that are subject to OSHA oversight.  

Emergency response is one of the most hazardous occupations in America. Emergency responders include firefighters, emergency medical service personnel, hazardous material employees, and technical rescue specialists. Also, law enforcement officers usually are considered emergency responders because they often assist in emergency response incidents.
Source: OSHA.gov and NFPA/FEMA 2012 Reports on Firefighter Fatalities

Background Information from OSHA.gov:

OSHA notes that there are no standards issued by the Agency that specifically address occupational hazards uniquely related to law enforcement activities. Many emergency responders have cross training in these specialties, and may serve in multiple roles depending upon the type of emergency incident involved. Skilled support employees are not emergency responders, but nonetheless have specialized training that can be important to the safe and successful resolution of an emergency incident.
 
OSHA issued a Request for Information in September 2007 that solicited comments from the public to evaluate what action, if any, the Agency should take to further address emergency response and preparedness. Recent events, such as the 2013 tragedy in West, Texas, that killed several emergency responders, and an analysis of information provided make it clear that emergency responder health and safety continues to be an area of ongoing concern. For this reason, OSHA conducted the stakeholder meetings to gather additional information.

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A Job Hazard Analysis for Work at Height

Thursday, July 31, 2014

The following article was featured in the June 2014 issue of ISHN, and authored by Roco Chief Instructor Pat Furr.

As part of my safety consulting duties, I have seen many fall protection programs for a wide variety of industries. When I ask about an employer’s fall protection plan, it’s pretty scary to be told, “Well, I can show you our program in two minutes”— and then see no more than a locker with a rag-tag assortment of body belts, harnesses and a few six- foot energy-absorbing lanyards of questionable integrity.

Now, it is rare to come across such an inadequate program. But truth be told, the comprehensiveness, diligence and effectiveness of the programs I have assessed run a fairly wide spectrum from so-so to top notch.

Top-notch programs all had several common elements, but the one element that stands out the most as being consistently included in the best programs is the completion of fall hazard surveys.

A Comprehensive Survey

The fall hazard survey, or what I like to call the fall hazard “walk-about,” is a critical early step in the process of assembling a comprehensive managed fall protection program. And a survey should be conducted again when certain changes occur including, but not limited to, changes in the facility configuration, changes to work processes, changes to legislated requirements, and the emergence of modern fall protection equipment solutions.

Outlined in ANSI Z359.2, the fall hazard survey is an effective means to identify areas where work is performed at height, identify ways to eliminate or control fall hazards, and help determine which hazards require the highest priority when it comes to allocating sometimes limited resources. A comprehensive fall hazard survey is the best way to identify and understand the types of fall hazards that need to be addressed to provide the best protection to your workers at height.

This requires that the Qualified or Competent Person do a top to bottom, left to right, tour of the facility to identify known areas where work at height is currently being performed, and any areas where future work at height may take place.

It may be helpful to have an area foreman or even an Authorized Person with thorough knowledge of the specific work areas available to ask questions regarding the work process and their needs and concerns.

The goal of this survey is to not only identify areas of work at height, but to determine the most protective means of abating the fall hazards.

 
The goal of this survey is to not only identify areas of work at height, but to determine the most protective means of abating fall hazards.

The Qualified/Competent Person must have the “Hierarchy of Fall Protection” in mind at all times. By having the goal of eliminating the fall hazard first and foremost, any opportunities to bring the work to the ground or to perform the work from the ground should present themselves during this survey. This may require a change in the configuration of certain structures, or the retrofitting of systems that allow the work to be performed from the ground. This may incur some significant costs, but in the long run the changes will be more than offset by avoiding a fall from height and the direct and indirect costs of such an accident.

Continuing the survey while still adhering to the Hierarchy of Fall Protection, the Qualified/ Competent Person may have to consider the use of fall restraint measures, either passive measures in the form of guardrails or parapets, or active measures in the form of body belts or harnesses with lanyards anchored in a way that the system prevents the Authorized Worker from reaching the leading edge of a fall hazard. Once active measures are employed, it is critically important to work with the Authorized Persons to understand what their work activities entail to come to a solution that provides the needed protection but also considers their need for mobility.

If the lower echelons of the Hierarchy of Fall Protection cannot be employed, a fall arrest system may be the only feasible solution.
 

A Fall Arrest Solution

If the lower echelons of the Hierarchy of Fall Protection cannot be employed, a fall arrest system may be the only feasible solution. This is where the Qualified/Competent Person’s knowledge of current fall arrest systems and components really shows its value. Lightweight, breathable, multi-function fall protection equipment available today protects workers while also providing the ease of use and freedom of movement that has been missing for many years. This is an important tool that the Competent Person can use to their advantage when faced with any resistance from certain Authorized Persons.

During the fall hazard survey, consider the presence of any environmental factors that may affect the performance of the fall protection equipment or systems as well as an alternate solution, specialized materials, or even a reconfiguration of the structure/process. Environmental factors can include hot objects, sharp edges, slowly engulfing materials, chemicals, weather factors, or any other environmental factor that may render the fall protection equipment ineffective.

Document Findings

Once the entire facility has been surveyed, it’s time to document in writing the findings and the means to abate the identified fall hazards. The Fall Hazard Survey Report becomes a part of the written fall protection program. It should be reviewed periodically and whenever there is a change to legislated requirements or a change in the facility or fall protection equipment.

Plan for Rescue

If any identified areas require the use of fall arrest systems, then that triggers the need to complete a written rescue pre-plan. It is my opinion that rescue

If any identified areas require the use of fall arrest systems, then that triggers the need to complete a written rescue pre-plan.

 
pre-plans should also include anywhere workers are performing work at height, such as elevated platforms that have been accessed by means other than elevators or stairs, with the goal that the rescue plan provides a capability to get the injured or suddenly ill worker to the ground promptly.

Time to Train

Once the Fall Hazard Survey is completed and documented, it is time for the Qualified Competent Person to provide training to the Authorized Persons on the types of equipment, systems, selection of anchor points, clearance requirements, swing fall hazards, and pre-use inspections of their equipment. Training may vary depending on the areas that Authorized Persons are assigned duties, but in all cases the type of training, any required re-training, and the criteria that would trigger the need for retraining must be documented.

A Valuable Tool

The fall hazard survey is a valuable tool that provides a thorough assessment of the entire facility to honestly identify fall hazards and determine the most effective means to protect workers from falls. Look at it as an expanded JHA that focuses specifically on areas of work at height.


About the Author: Pat Furr is a chief instructor and technical consultant for Roco Rescue, Inc. Pat teaches a wide variety of technical rescue classes including Confined Space Rescue, Rope Access, Tower Work/Rescue, Fall Protection, and Suspended Worker Rescue. He is also involved in research and development, writing articles and presenting at national conferences. He is a member of the NFPA 1006 Technical Rescuer Professional Qualifications Standard.

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Confined Space Attendants Play a Crucial Role

Tuesday, July 08, 2014

The following article was featured in the July 2014 issue of ISHN, and authored by Roco's own Chief Instructor Pat Furr.

Have you ever wondered who that person is who hovers around the portal of a permit space while workers are in the space? What does a Confined Space Attendant (often referred to as the “Hole Watch”) do anyway? What may seem like a cushy job is actually a critical safety responsibility. Here’s why:

First, OSHA instituted regulations regarding Permit-Required Confined Spaces (1910.146) due to the high number of serious injuries and deaths in confined spaces. Entering these spaces is dangerous business, and the attendant serves as the “safety watchman” for entrants as well as those who may casually try to enter. This also applies in an emergency situation when others may be tempted (but unqualified) to enter the space to rescue a co-worker.

OSHA requires that the attendant be able to safely and effectively perform the duties required in Section (i) of 1910.146. (See “Duties of the Confined Space Attendant”) Once a permit is issued and work begins, the attendant needs to be aware of his or her surroundings and be diligent in monitoring the space and entrants at all times. This individual is not there to be a “gofer” for workers inside the space.

Get real

If entrants need assistance or an emergency situation develops inside (or outside) the space that requires entrants to be evacuated, the attendant is the “vital link”. Unfortunately, it is common practice to fill the Hole Watch position with the least experienced or greenest person on the crew. Many times, this person has no idea what is expected of them. They also may not be aware of potential hazards inside the space or hazards that may be introduced as work is performed. Often, these individuals are not experienced in industrial environments and are not properly trained in the OSHA-required duties. And, in most cases, they don’t realize how critical their duties could become in an emergency when split-second decisions are required.

Train your attendants

It is unrealistic to expect a new employee to perform these duties without receiving appropriate training and being granted the authority to take action as needed. In 1910.146(d)(8), OSHA is specific in its requirements for the various roles involved in conducting safe permit entry operations. Employers are required to provide adequate training and ensure that personnel are capable of performing their duties. At minimum, the regulation requires employers to ensure that each Hole Watch/Attendant knows and understands the following safety precautions:

(1) Hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure to those hazards;

(2) Possible behavioral effects of hazard exposure for the authorized entrants.

Additional duties and responsibilities include:

(1) Continuously maintaining an accurate count of entrants in the permit space.

(2) Performing non-entry rescues as specified by the employer’s rescue procedure.

One of the most critical duties of the attendant is to be able to effectively communicate with entrants and take appropriate actions in an emergency. Communications are required to monitor the status of the entrants and to ensure that there are no signs of exposure to hazards. The attendant must recognize this need and be able to order evacuation of the space. Most importantly, the confined space attendant can perform NO duties that might interfere with their primary duty to monitor and protect the entrants.

Prevent fatalities

Employers must ask themselves, “Will the person designated as the “Hole Watch” be able to react in an effective manner when the pressure is on? Will they be able to initiate a non-entry rescue in an emergency situation?” Again, we witness too many instances where the “Hole Watch” has little or no knowledge of the responsibilities assigned, while some have had virtually no training whatsoever. Sometimes it seems they are there for no other reason than to fill a square to meet an OSHA requirement.

Many times the lack of understanding regarding confined space hazards, combined with the lack of a clear understanding of emergency actions to be taken (as well as actions to avoid) can lead to confined space fatalities, both for the entrants as well as the attendant.

We urge employers to take a serious look at the selection and training of confined space attendants. These individuals must be capable, responsible and properly trained as spelled out in the OSHA standard. When things go wrong in a confined space, the actions (or inaction) of the attendant can be the difference between life and death for the entrants. They must have the knowledge, the tools and the experience to function as an effective, and ultimately safe, “Hole Watch.”


About the Author: Pat Furr is a chief instructor and technical consultant for Roco Rescue, Inc. Pat teaches a wide variety of technical rescue classes including Confined Space Rescue, Rope Access, Tower Work/Rescue, Fall Protection, and Suspended Worker Rescue. He is also involved in research and development, writing articles and presenting at national conferences. He is a member of the NFPA 1006 Technical Rescuer Professional Qualifications Standard.

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Quick-Connect Harness Buckle Safety

Wednesday, July 02, 2014

Recently, we noticed a story in a leading safety and health magazine that questions the “two-piece, pass-through buckle” that is commonly used on many harnesses. The author, in fact, referred to it as a design flaw. However, we consider it more a matter of improper use than a design flaw. While he does identify some potential user failures, we feel his terming is not quite accurate. Here’s why...

As with any life support equipment, it is imperative to use the equipment in accordance with the manufacturer’s instructions for use and receive the appropriate training as required. The author cites instances where he has observed the mating plate of the two-piece, pass-through buckle being improperly oriented which can lead to the buckle loosening and potentially disconnecting. He also suggests that the pass-through plate have some type of “visual indicator” to warn the user when the buckle is improperly connected. Of course, we’re always in favor of additional safety features!

While this may be viewed as a matter of semantics, consider the following analogy… almost every outboard motorboat has one or sometimes multiple drain plugs in the transom well to provide drainage once the boat is pulled out of the water. If the skipper forgets to re-install the drain plugs the next time the boat is launched, the transom well will fill with water, which could lead to swamping. So, is this a design flaw, or improper use? From an equipment designer/manufacturer’s point of view, the use of this terminology could be very significant.

With the many advances in life safety equipment, we have seen harnesses and other rescue/safety equipment become more convenient, lighter, multifunctional, and overall safer than earlier generations. As with many product advances and improvements, there may be compromise in one area but advances in many others. In this case, the speed and ease of donning and doffing a Class III rescue or fall protection harness by using some type of quick-connect buckle. Of course, the user must ensure that the buckle is used correctly.

The pass-through buckle has been around a very long time. In fact, a Croll sport climbing sit harness that I bought in 1981 had this type buckle. These buckles were also used in the past on the leg loops on Roco harnesses. There are minor variations on the design of the buckle with some having slots to ease the pass-through of the top plate, while others do not have this slot.

There are important requirements for the safe use of these buckles, which include:

1.  Make sure the buckle is adjusted tightly enough to ensure constant tension is applied to the top plate against the fixed plate.

2.  Be sure that the top plate is not inverted.

3.  Double check that the tail end of the webbing does not pass through the “fixed plate” but instead lays parallel with the anchored section of the webbing.

These three user points of performance are easily completed. Our extensive experience with this type of buckle tells us that it’s a convenient and safe buckle when used as it was designed. As always, carefully check and re-check your gear before life-loading!

Information from article by Robert Peterson published by OH&S Online - www.ohsonline.com.


 

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OSHA Seeks Input on Emergency Response Standard

Thursday, June 12, 2014

Prompted by the 2013 fire and explosion that killed 12 firefighters at a Texas fertilizer facility, as well as other recent incidents, OSHA is considering the development of a standard on emergency response and preparedness.

Stakeholders are invited to provide input at an informal OSHA meeting in Washington on July 30 and, if needed, on July 31. Attendees must register by July 2.

OSHA first sought public input on an emergency response and preparedness rulemaking in 2007, when the agency issued a Request for Information. In that request, OSHA noted that although several of its current standards address certain issues emergency responders face (including blood borne pathogens and confined spaces), some of those standards are decades old.

In 2012, 231 deaths occurred in the protective service industry, which includes firefighters and law enforcement personnel, according to Bureau of Labor Statistics data.

Story from The National Safety Council

 

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