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Q&A: What are the Rescue Requirements for Trenches/Excavations?

Tuesday, May 19, 2015

READER QUESTION:
One of our readers recently asked about rescue requirements in excavations. We did some searching and found an interesting Letter of Interpretation (LOI) from OSHA that explains when rescue provisions are required during trenching operations.  

ROCO TECH PANEL ANSWER:
The following is from OSHA LOI in regards to this answer. In regard to whether emergency rescue equipment is required at every trenching job site located near or passing by a gas station, refinery, gas line, sewer main, etc., please be advised by the following:

Emergency rescue equipment is required to be readily available where a competent person determines, based on the conditions at each job site, that hazardous atmospheric conditions exist or may reasonably be expected to develop during work in an excavation. In regard to whether a contractor can rely on a local rescue squad instead of providing the rescue equipment, please be advised that many emergency situations associated with the hazards involved with hazardous atmospheres in trenches would normally require an immediate response within a few minutes or even seconds. A rescue squad would be unable to provide the necessary response and therefore could not be used to comply with 1926.651(g)(2).

As more and more industrial sites realize that just about every day, somewhere on their property, there is an open trench. Trench collapses cause dozens of fatalities and hundreds of injuries each year. Obviously, this creates concerns, especially for the rescue personnel who may be called to the scene during an emergency.

We’ve been getting questions from clients that have effective rescue teams for medical, hazmat, fire, confined space and rope but are realizing that they are lacking if a trench collapse occurs on their site. “Who will do the rescue?” is a question often asked. There is concern by supervisors, who have been given the responsibility for signing trench permits, but have not had adequate training in trench and excavations. Many are not “competent persons” as referenced in OSHA1926.651-652.

After looking at the dozen of questions in the referenced LOI, it should raise a few more:

  1. Are the people you have signing off that a trench is constructed properly and safe for entry, trained to know what to look for and have the authority to act (competent person), or are they assuming that the contractor is “doing the right thing”?
  2. Who will be called if a trench emergency should occur?
  3. Are their local resources that have the training and equipment to respond, or are you an island unto yourself when it comes to trench rescue? 

The link to the referenced LOI is shown below – and the questions are still very relevant : https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=20597

Additional Resources:

OSHA Technical Manual

OSHA Trenching and Excavation Safety

Trench Safety Poster – An Unprotected Trench Is An Early Grave

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It's Final-Confined Spaces in Construction-Effective 8/3/15!

Monday, May 04, 2015

The Occupational Safety and Health Administration today issued a final rule to increase protections for construction workers in confined spaces. 

Confined spaces rule (29 CFR 1926 Subpart AA) could protect nearly 800 construction workers a year from serious injuries and reduce life-threatening hazards…Construction protections now match those in manufacturing and general industry. 

Manholes, crawl spaces, tanks and other confined spaces are not intended for continuous occupancy. They are also difficult to exit in an emergency. People working in confined spaces face life-threatening hazards including toxic substances, electrocutions, explosions and asphyxiation.

Last year, two workers were asphyxiated while repairing leaks in a manhole, the second when he went down to save the first – which is not uncommon in cases of asphyxiation in confined spaces.

“In the construction industry, entering confined spaces is often necessary, but fatalities like these don’t have to happen,” said Secretary of Labor Thomas E. Perez. “This new rule will significantly improve the safety of construction workers who enter confined spaces. In fact, we estimate that it will prevent about 780 serious injuries every year.”

The rule will provide construction workers with protections similar to those manufacturing and general industry workers have had for more than two decades, with some differences tailored to the construction industry. These include requirements to ensure that multiple employers share vital safety information and to continuously monitor hazards – a safety option made possible by technological advances after the manufacturing and general industry standards were created.

“This rule will save lives of construction workers,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Unlike most general industry work sites, construction sites are continually evolving, with the number and characteristics of confined spaces changing as work progresses. This rule emphasizes training, continuous work site evaluation and communication requirements to further protect workers’ safety and health.”

On OSHA's website, it also states than an employer whose workers are engaged in both construction and general industry work in confined spaces will meet OSHA requirements [for 1910.146] if that employer meets the requirements of 29 CFR 1926 Subpart AA - Confined Spaces in Construction.

Five (5) key differences in the construction rule, and several areas where OSHA has clarified existing requirements:

  1. More detailed provisions requiring coordinated activities when there are multiple employers at the work site. This will ensure hazards are not introduced into a confined space by workers performing tasks outside the space. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.
  2. Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces.
  3. Requiring continuous atmospheric monitoring whenever possible.
  4. Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a storm upstream from the workers could cause flash flooding. An electronic sensor or observer posted upstream from the work site could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely.
  5. Allowing for the suspension of a permit, instead of cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space. The space must be returned to the entry conditions listed on the permit before re-entry.

OSHA has added provisions to the new rule that clarifies existing requirements in the General Industry standard. These include:

  1. Requiring that employers who direct workers to enter a space without using a complete permit system prevent workers’ exposure to physical hazards through elimination of the hazard or isolation methods such as lockout/tag out.
  2. Requiring that employers who are relying on local emergency services for emergency services arrange for responders to give the employer advance notice if they will be unable to respond for a period of time (because they are responding to another emergency, attending department-wide training, etc.).
  3. Requiring employers to provide training in a language and vocabulary that the worker understands.

Finally, several terms have been added to the definitions for the construction rule, such as "entry employer" to describe the employer who directs workers to enter a space, and "entry rescue", added to clarify the differences in the types of rescue employers can use.

Host Employers, Controlling Contractors, and Entry Supervisors

The rule makes the controlling contractor, rather than the host employer, the primary point of contact for information about permit spaces at the work site. The host employer must provide information it has about permit spaces at the work site to the controlling contractor, who then passes it on to the employers whose employees will enter the spaces (entry employers). Likewise, entry employers must give the controlling contractor information about their entry program and hazards they encounter in the space, and the controlling contractor passes that information on to other entry employers and back to the host. As mentioned above, the controlling contractor is also responsible for making sure employers outside a space know not to create hazards in the space, and that entry employers working in a space at the same time do not create hazards for one another’s workers.

Click for an update on this ruling

Download 29 CFR 1926 Subpart AA Confined Space in Construction Ruling

Source: www.osha.gov

Frequently Asked Questions: https://www.osha.gov/confinedspaces/faq.html

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Roco Chief Chad Roberson Selected for Leadership Training

Friday, May 01, 2015

St. George Fire Department Assistant Fire Chief Chad Roberson has been accepted into the third year of the Fire Service Executive Development Institute, the International Association of Fire Chiefs announced.

Roberson competed with new fire chiefs and chief officers from across the country to become a member of the 2015 program. Roberson also has been awarded a scholarship to cover the expenses for attending the program, a news release from the St. George Fire Department said.

The Fire Service Executive Development Institute is a yearlong leadership development program created and implemented by the IAFC to provide new and aspiring fire chiefs with the tools needed to have successful and productive tenures, the release said.

The institute will meet in May for its first six-day session, in addition to two other sessions six months apart. The group will communicate between sessions using an online community.

Roberson has 27 years of experience and rose through the ranks of the St. George Fire Department.

He holds an associate degree in fire science, a bachelor’s degree in history and a master’s degree. He also has completed the National Fire Academy’s Executive Fire Officer Program and, in 2011, was awarded professional accreditation as a certified fire officer, the release said.

In addition to being assistant fire chief, Roberson serves as the technical rescue coordinator for the department.

He is a member of the International Association of Fire Chiefs and serves on its Emergency Management Committee. In addition, Roberson is an executive board member of the Louisiana Fire Chiefs Association, the Louisiana Fire Chiefs Foundation and the Louisiana Municipal Association. He served for six years as an executive board member of the States Urban Search & Rescue Alliance.

Roberson is married and the father of two elementary school-aged sons. He is a volunteer coach at his sons’ school, St. Jude, and the YMCA. He is also a member of the St. Jude Catholic Church Men’s Club and a member of the St. Jude Church Fair Core Committee.

The Motorola Solutions Foundation has provided the IAFC with a grant to fund the program.

Story from The Advocate

Photo provided by Eldon Ledoux -- The International Association of Fire Chiefs announced that Assistant Fire Chief Chad Roberson, of the St. George Fire Department, has been accepted into the third year of the Fire Service Executive Development Institute.

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Firefighter Council Releases PPE Guidance Videos

Tuesday, April 28, 2015

The National Volunteer Fire Council has released six new videos on the proper use and maintenance of personal protective equipment for firefighters.

The short videos, available on both NVFC's YouTube channel and its equipment resources webpage, cover the following topics: The importance of PPE during overhaul, PPE cleaning guidelines, Guidance on replacing PPE, Protective clothing and equipment standards, Securing grants for PPE and New PPE regulatory standards. 

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