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OSHA's Confined Space Construction Rule Under OMB Review

Tuesday, November 25, 2014

OSHA's final rule on confined spaces in construction is being reviewed by the Office of Information and Regulatory Affairs. The review is one of the final steps required before OSHA can formally publish the rule.

OIRA, which is a branch of the White House's Office of Management and Budget, received the rule for review on Nov. 14. The office is limited to a 90-day review but can request an extension. The rule has been in the works since at least 2003; the proposed rule was published in 2007.

Several provisions in the proposed rule are similar to those found in the agency's confined spaces standard for general industry. That rule, issued in 1993, mandates specific procedures and includes requirements such as a written program, atmospheric monitoring and training.

Stand by for additional updates on this regulation.

News story from the National Safety Council. 

 

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VFD Acquires Rescue Equipment Through Firehouse Subs Foundation

Monday, November 24, 2014

More than $15,000 in fire rescue equipment was donated to a local volunteer fire department in Washington, WV through the Firehouse Subs Foundation.

The equipment for the Washington Bottom department is for confined areas such as off-road, industrial and water-related accidents. And the department's members are already trained to use it.

"It's nice to know we have the people with the knowledge, the skills, and now, the equipment to use the equipment properly," said Fire Chief K.C. Lindner. "We have the folks who have spent the many hours training and perfecting it. Now, we have the equipment to use."

 


Picture above: Roco Student, Ryan Goldsmith demonstrating the rope rescue equipment.

Money for the donations comes from the purchase of Firehouse's used pickle barrels by its customers.

The chain has been providing equipment to first responders for nearly a decade.

Story source: http://www.thenewscenter.tv/news/headlines/Fighting-Fire-With-Firehouse-283402671.html 

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Atmospheric Monitoring Frequency…Update for Roco Students

Friday, November 07, 2014

One of our very attentive students recently noticed a statement in our Study Guide that was incorrectly attributed to OSHA when it is really a Roco Best Practices Guideline. In the Confined Space chapter of our Study Guide, it states that OSHA requires air monitoring “within 30 minutes of the entry,” and this is not an OSHA requirement. The 30-minute timeline is a Roco recommendation for conducting “baseline” pre-testing prior to entry, but it is not an OSHA requirement.

The revised wording is explained below. You may click here to download and print the corrected pages for your Roco Study Guide. If you have any questions or need assistance, please contact the Roco office at 800-647-7626.


 

CONFINED SPACE CHAPTER

(1) ATMOSPHERIC MONITORING:  (Page 13)
ROCO RECOMMENDATION: Although OSHA does not define a specific timeline to conduct pre-entry atmospheric monitoring, we recommend that a “baseline test” be conducted approximately 30 minutes prior to the entry and then another test conducted immediately prior to entry. A comparison of these readings could indicate that atmospheric changes have occurred inside the space. If a space has been vacated for a period of time, it is recommended that similar baseline testing be repeated.

Also, while OSHA allows for periodic monitoring and sets no exact timespan between testing, Roco recommends continuous air monitoring any time workers are in the space. In addition, pre-entry testing as well as periodic testing should be based on the hazard assessment for a given space to include any previous work activities that may have introduced atmospheric hazards as well as any known history of hazardous atmospheric conditions. Another consideration is how rapidly those hazards can change the atmosphere, which may require additional precautions for safe entry.

(2) MONITORING FREQUENCY:  (Page 15)
OSHA does not define a specific timeline for conducting pre-entry atmospheric monitoring or periodic testing. OSHA 1910.146 (c)(5) refers to testing the internal atmosphere before an employee enters the space and testing as necessary to maintain acceptable entry conditions. Testing should be based on the hazard assessment for a given space as well as how rapidly those hazards could cause a change in the atmosphere, which may require additional action for safe entry.

As a safer way, Roco recommends continuous monitoring while employees are inside a permit-required confined space.


Frequently Asked Questions: PRCS Standard Clarification (OSHA.gov)

How much periodic testing is required?


The frequency of testing depends on the nature of the permit space and the results of the initial testing performed under paragraph (c)(5)(ii)(c). The requirement in paragraph (c)(5)(ii)(F) for periodic testing as necessary to ensure the space is maintained within the limits of the acceptable entry conditions is critical. OSHA believes that all permit space atmospheres are dynamic due to variables such as temperature, pressure, physical characteristics of the material posing the atmospheric hazard, variable efficiency of ventilation equipment and air delivery system, etc. The employer will have to determine and document on an individual permit space basis what the frequency of testing will be and under what conditions the verification testing will be done.

 
What does testing or monitoring "as necessary" mean as required by 1910.146(d)(5)(ii) to decide if the acceptable entry conditions are being maintained?

The standard does not have specific frequency rates because of the performance oriented nature of the standard and the unique hazards of each permit space. However, there will always be, to some degree, testing or monitoring during entry operations which is reflective of the atmospheric hazard. The employer must determine the degree and the frequency of testing or monitoring. Some of the factors that affect frequency are:

* Results of test allowing entry.
* The regularity of entry (daily, weekly, or monthly).
* The uniformity of the permit space (the extent to which the configuration, use, and contents vary).
* The documented history of previous monitoring activities.
* Knowledge of the hazards which affect the permit space as well as the historical experience gained from monitoring results of previous entries.

Knowledge and recorded data gained from successive entries (such as ventilation required to maintain acceptable entry conditions) may be used to document changes in the frequency of monitoring.

OSHA 1910.146 REFERENCES

1910.146(c)(5)(ii)(C)
Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. Any employee, who enters the space, or that employee's authorized representative, shall be provided an opportunity to observe the pre-entry testing required by this paragraph.

1910.146(c)(5)(ii)(F)
The atmosphere within the space shall be periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. Any employee, who enters the space, or that employee's authorized representative, shall be provided with an opportunity to observe the periodic testing required by this paragraph.

1910.146(d)(5)(i)
Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin, except that, if isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), pre-entry testing shall be performed to the extent feasible before entry is authorized and, if entry is authorized, entry conditions shall be continuously monitored in the areas where authorized entrants are working;

1910.146(d)(5)(ii)
Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations;

 

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Who is your Fall Protection MVP?

Wednesday, October 29, 2014

The following article was featured in the September issue of ISHN, and authored by Roco Chief Instructor Pat Furr.
Every team has their most valuable player or person, their MVP. When you consider all the personnel who make up the fall protection team at your facility, who is your MVP?

Chances are it is your Competent Person. OSHA defines a Competent Person as “One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” In order to do their job and become your Fall Protection MVP, it is very important that your Competent Person be.....well, competent.


Understanding Regulations & Standards

Competence can come through formal training, work experience, self-study, or most likely a combination of all three. Areas in which the Competent Person must be well versed include a thorough understanding of legislated requirements pertaining to fall protection. A great deal of time must be spent visiting the applicable OSHA regulations that apply to the type of work activities that the Competent Person will be overseeing.

This can be rather daunting, but there are plenty of resources to help in this effort. OSHA provides clarification through the issuance of letters of interpretation, Safety and Health Information Bulletins (SHIBs) and safety posters, and several training institutions provide formal training covering OSHA regulations as part of their curricula.

In addition to understanding the OSHA legislated requirements, it is also helpful that the Competent Person use consensus standards, BKM, and certainly any company policies that strengthen the OSHA required protections. The ANSI/ASSE Z359 family of standards is a big help, especially Z359.2 titled, “Minimum Requirements for a Comprehensive Managed Fall Protection Program.” This document provides recommended guidance for roles and responsibilities, training, fall hazard surveys, procedures, the hierarchy of fall protection, anchorages, inspection, maintenance and storage of fall protection equipment, rescue procedures, incident investigation, and evaluating program effectiveness.

Meeting the Needs of Authorized Persons

The Competent Person is in a unique position. They must communicate to the Authorized Persons that will be employing the fall protection procedures and systems, and also to the Program Administrator. In many cases, the Competent Person may be the Program Administrator, too. In this position, the Competent Person must strive to understand the needs of Authorized Persons regarding systems and equipment that will not create an unacceptable hindrance to their job.

If the fall protection equipment is so burdensome that workers cannot do their job, or is very uncomfortable, there is a better chance they will be reluctant to use it. So one of the most important aspects of the Competent Person’s education is to stay abreast of the types of fall protection equipment and systems commercially available. With the recent explosion of modern, lightweight, multi-function, easily deployed fall protection equipment and systems, the question of feasibility and overcoming reluctance on the part of the Authorized Person is becoming a concern of the past.

Fall Hazard Survey

The “Fall Hazard Survey” is a great tool for the Competent Person to use to identify existing and potential future fall hazards at the worksite, and to determine means to abate those hazards. This exercise is outlined in ANSI/ASSE Z359.2 and provides a systematic approach to this most valuable step. I refer to it as the fall hazard walk-about — a top-to-bottom, north-to-south, thorough physical review of all areas in which current or future work at height may be performed. The goal is to identify fall hazards by type and to identify one or more means to eliminate or control hazards while keeping the hierarchy of fall protection in mind at all times.

Once the Fall Hazard Survey is completed, it may call for the use of active fall protection equipment and systems if falls cannot be eliminated through engineering controls. In this instance, the Competent Person may have to impose limits on work activities and prescribe specific guidance on equipment and non-certified anchor point selection, and also on equipment use limitations to control swing falls and clearance requirements. Procedures put into place to eliminate or control fall hazards should be documented and included in the fall protection program.


Rescue Planning

One often overlooked duty of the Competent Person is to prepare or ensure that written rescue pre-plans are developed for any identified fall hazard that calls for the use of personnel fall arrest systems. I advocate development of a rescue from height pre-plan anytime employees are performing work at an elevated location that is accessed by means other than a stairwell or elevator. This includes platforms that may be protected by passive restraints such as standard guardrails or parapets. Always consider the possibility that a worker may be injured or become suddenly ill while at this elevated position and will need prompt rescue to get them safely to ground level.


Equipment Inspections & Incident Investigation

There are two primary types of fall protection equipment and system inspections, and the Competent Person plays a role in both types. The Competent Person is tasked with performing OSHA-mandated periodic inspections and any periodic inspections in accordance with the manufacturer’s instructions for use. Pre-use inspections of fall protection equipment will be completed by the Authorized Person, but the training on these pre-use inspections and the person who ensures that these inspections are indeed completed is the Competent Person. If any equipment fails a pre-use or periodic inspection, it is immediately removed from service. In the unfortunate event that there is a fall from height incident, the Competent Person will participate in the investigation.

Role Recap

I’d like to summarize the role of the Competent Person “According to Pat” by saying they:

  • •  Must be very knowledgeable of the OSHA fall protection regulations.

  • •  Identify and understand all areas where work is performed at height and provide solutions adhering to the hierarchy of fall protection by completing a thorough and honest Fall Hazard Survey.

  • •  Have a finger on the pulse of traditional and emerging technologies for fall protection equipment and systems. Provide solutions to the Authorized Persons that are comfortable, convenient, and may be safer than what is currently being used.

  • •  Understand the capabilities and limitations of rescue systems.

I hope you have your own “Fall Protection MVP” at your work site and, if not, maybe it is time to groom one.

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Roco QUICK DRILL #5 - Building Complete Rescue Systems

Thursday, October 16, 2014

Due to time restraints in refresher training, oftentimes individual team members may only get to build a portion of a rescue system – for example, setting up a mainline or performing patient packaging. In order to have maximum team efficiency, it is important to keep all team members proficient in all aspects of the rescue operation.

1. Lay out enough equipment to build a mainline and a safety line system and for a particular type of packaging. Describe which system is to be used and how the patient will be packaged (i.e. vertical stokes raise, or horizontal SKED lower with attendant).

2. Identify what will be used as anchors. If working in a classroom or apparatus floor, a chair leg could be designated as bombproof or substantial anchor depending on the rigging the team member is being asked to do. If you are in the field, use whatever anchors are available.

3. Assign a team member to construct or rig the entire system on their own, including packaging the patient.

This drill allows a Team Leader to identify potential weaknesses in individual performance skills, while improving the team member's understanding of how the systems work. The knowledge gained will also help in planning future training sessions to correct any deficiencies. For the individual team member, this drill will reinforce all aspects of putting systems together and identifying weak points or areas of confusion that need to be corrected.    

 

 

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