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Guidelines for Permanent Marking of Rescue Hardware

Friday, April 29, 2011

One of the most reliable ways to ensure that your rescue team is able to identify, and if needed, prove ownership of its equipment is by marking the gear with some type of visible identification. There are many ways to accomplish this ranging from color-coded paint or vinyl tape to affixing tags. Each has its shortcomings in terms of durability – and tags could potentially interfere with the function of the item. Here are some additional guidelines from our hardware manufacturer, SMC. For more than 40 years, it has been SMC’s goal to design and manufacture innovative gear that sets the standard for quality, reliability, and functionality.

The following information is intended to serve as a clear and simple guide concerning what is acceptable and conversely, what is not acceptable, when permanently marking by engraving into the surface of various types of hardware.

Note: Always adhere to your equipment manufacturer’s instructions.

First of all, it’s very important to note that it is only acceptable to use a “hand-held” electric type engraver to place identifying marks on hardware. Do NOT strike
with a hammer or stamps or ever use other similar methods. Once the marking process has been completed, ALWAYS inspect the product for proper fit and function PRIOR to returning it to service.

Carabiners:
For carabiners, it is recommended to mark along the spine of the frame. Do NOT mark on or near the lock or pivot tabs of the frame and stay away from rope bearing areas. Do NOT mark on the gate! For steel and stainless products, use a medium setting with medium to heavy pressure. For aluminum products, use a low setting with light to medium pressure. Depth of engraving equal to the thickness of a piece of paper should be enough to last the life of the product.

Pulleys:
For pulleys, it is recommended to mark on the flat outside surface around the axle. Do NOT mark ON OR NEAR the carabiner hole at the top of a pulley or anywhere on the becket of a double pulley. It is also important to stay away from all rope bearing areas.

Rappel Racks & Bars, Rigging Plates & Rope Protection:
When marking other hardware, always use caution and stay away from all carabiner holes, rope bearing surfaces and surrounding areas.

Coatings:
Most aluminum products are anodized. Some slight cosmetic oxidation may occur over time and this is a natural occurrence. Alloy steel parts are typically zinc plated. Engraving these products will remove the zinc plating in that particular area. One advantage of zinc plating is that it will move over and protect the exposed base material (self-sacrificing). However, this will eventually lead to the zinc in the area being consumed and may allow rust to begin to form. To help prevent corrosion, periodically wipe down plated products with LPS or a similar product.

As durable as modern rescue hardware is, it is important never to use any permanent identification method that would compromise the structural integrity of the item. With the clear guidelines provided by SMC, it allows the owner to have a reliable means of identifying their rescue hardware, while at the same time maintaining the original integrity of the item.

We remind you that it is important to review the user information and instructions for use for any rescue equipment item to ensure that the procedures outlined above are not conflicting with another manufacturer’s guidelines. Roco strives to provide practical and useful information to the rescue community, and this is one in a series of postings that we hope will help you become a better rescuer.
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5 Thought Starters for Rescue Team Practice Drills

Tuesday, April 19, 2011

If you’re the one who’s responsible for setting up proficiency training for your team, ask your team members to come up with some ideas that are different from your typical drill. You might be surprised with what they come up with. If you’re a team member, approach your training manager with some suggestions to change things up a bit. Once the idea is planted and your team starts to run a variety of training scenarios, the idea will catch on. In fact, team members may try to “outdo” each other on coming up with the next new scenario.

Here are some suggestions to get you started:

1.  Dig deeper into your equipment kits. Is there a piece of gear that is gathering dust? Some of the old tried-and-true pieces still have a lot of value. See if incorporating them into your next training session rekindles the thought that it was good back then and it still has a place today.

2.  Call some of your neighboring plants (or agencies) to see if they have a situation that is different from what you have. Do a little brainstorming over the phone and then re-create the situation during a train up.

3.  Review NIOSH Fatality Assessment and Control Evaluation (FACE) Program Investigations to see if there are lessons to be learned. There will be. Try to identify incidents that have similar space configurations and associated hazards as you may be summoned to.

4.  Do a thorough review of your existing rescue plans. Are they current? Have there been new spaces installed or reconfigured that would make existing rescue plans ineffective? If so, update the plans and practice any new procedures that the new plans may have generated.

5.  Sign up for Roco’s Rescue Challenge. This is a great opportunity to share ideas with other rescuers and learn new ways to approach your rescue response. It also satisfies annual practice requirements for individuals, and rescue teams. 
 
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Rescue I-Plus Class Photo

Friday, April 15, 2011

We had a great group at the March, Rescue I-Plus open-enrollment class in Baton Rouge. With 30 students from Louisiana to Alaska, the class was a great learning experience as well as a lot of fun. Roco Instructors for this class included Chief Instructor Russ Kellar (Austin) , Rob “Soup” Campbell (Baton Rouge); Bob Kauer (New York); Brent Glidden (LaPlace, LA); and Keith Pridgen (El Dorado, Arkansas).

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Rescue Plans…What is required?

Tuesday, April 12, 2011

We had a very interesting inquiry regarding OSHA’s requirements for rescue plans and wanted to share it with you.

Reader’s Question: Does OSHA 1910.146 (k)(1)(v) state that a plan must be developed by a rescue service before an entry can be made? Can entries be conducted with the understanding that a rescue service has the competence to rescue someone without seeing the space prior?


Section (k)(1)(v) of the regulation states that the employer shall…“Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.” [Emphasis added]

First of all, it’s important to note that the term “plan” as used in safety-related regulations and standards such as the Permit-Required Confined Space (PRCS) standard, can have a more general meaning than what rescuers typically think of when they refer to “rescue preplans.” When rescuers refer to “rescue preplans,” what usually comes to mind is a very specific, detailed plan for rescue from a particular space.

Although the regulations do not specifically state that a “plan must be developed by a rescue service before an entry can be made,” the regulation assumes that a properly selected (and evaluated) rescue team or service will develop appropriate rescue plans, and requires that rescuers be given access as necessary to develop those plans. OSHA makes it very clear, however, in Non-Mandatory Appendix F, the Preamble to the Final Rule, Summary and Explanation of the Final Rule, and its Compliance Directive on Permit-Required Confined Space, that it interprets the regulation to require rescue plans. [See links below.]

How specific a “rescue plan” must be in order to meet OSHA requirements can be determined by answering this question…“How detailed must the rescue plan be to enable me to safely perform a timely rescue from the permit-required confined space being entered?” Generally speaking, the simpler and more generic the space and the entry, the simpler and less detailed the plan must be. The more complex the space and the hazards, the more specific and detailed the plan must be. And, the more likely the rescue service should see the space and/or a representative space in advance.

As such, the degree and content of the rescue plan should be determined by the rescue service – and it must be provided access to do so. Ultimately, however, it is the employer’s responsibility to perform an adequate evaluation of the prospective rescue service. The viability of the rescue plan should be demonstrated; therefore, proving that the rescue service is staffed, equipped, available, and proficient in performing timely rescue from that particular space (or representative space). The employer must be confident that the rescue service can “Talk the talk, and walk the walk.”

When evaluating the capabilities of a rescue service, Non-Mandatory Appendix F provides guidelines for doing so and specifically references “rescue plans” for the types of spaces involved. It is also important for employers to note that while it is “not mandatory” that the evaluation is performed in exactly the same way; you still have to reach the same result. In other words, it is a non-mandatory means of meeting the mandatory requirements.

Section B (1) of Appendix F asks…
Does the rescue service have a plan for each of the kinds of permit space rescue operations at the facility?

Is the plan adequate for all types of rescue operations that may be needed at the facility?

Note: Teams may practice in representative spaces, or in spaces that are ‘worst-case’ or most restrictive with respect to internal configuration, elevation, and portal size.

Appendix F also offers recommendations for determining whether a space is “truly” representative of an actual space. [See link below.]

You can also refer to Roco’s Confined Space Types Chart (click here to download) which illustrates various confined space types for rescue practice and planning purposes.

In summary, prior to permit required entry operations, the employer must afford the selected rescue service access to the permit spaces they may respond to for the purposes of rescue planning.  The degree and content of the rescue plan should be determined by the rescue service. The rescue service must be prepared and proficient in rescue from the “same type(s) of confined spaces” in terms of configuration, access, and hazards.

IMPORTANT: The information in Roco Rescue Online is provided as a complimentary service for emergency response personnel. It is a general information resource and is not intended as legal advice. Because standards and regulations relating to this topic are typically performance based, and compliance with those standards and regulation is often dependent on the specific circumstances and conditions at hand, it is always important to carefully review all relevant standards and regulations, and to follow the proper protocols specific to your company or agency.

ONLINE REFERENCES:


OSHA 1910.146 Appendix F.

OSHA CPL 02-00-100, 5/5/1995, Application of the Permit-Required Confined Spaces (PRCS) Standards, 29 CFR 1910.146  Appendix D, V. Rescue, D. Combinations: 1. a.

OSHA 1910.146 Permit-Required Confined Spaces, Section: 2, II. Summary and Explanation of the Final Rule
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Confined Space Stand-by Teams: How many members?

Monday, March 28, 2011

This topic was brought to light by one of our blog participants. Since it may affect many industrial rescue teams in our readership, we are posting the information here to share with the entire community.

In response to a question about manpower requirements for stand-by rescue teams (How many members should be on a standby team?), the Roco Tech Panel has gathered some information which we hope will be helpful. First of all, we will address it from a regulations and standards prospective, and then offer some considerations and practical guidelines that we use here at Roco. 

Of course, your company’s internal policy and safety procedures must always be considered first.

OSHA’s Permit Required Confined Space Regulation (1910.146) is our primary reference for this topic; and, as mentioned, it does not state the specific number of personnel required for stand-by operations. This standard is intended to be “performance based” and a determination of the prospective rescue service’s ability to perform rescue from the types of spaces which they may respond is to be evaluated by the employer. If the evaluated team, regardless of number, can safely and effectively perform rescue from the applicable spaces in a timely manner, then the team would be deemed capable.

However, we must also use a degree of judgment and take into consideration all the particulars of the types of spaces that may be encountered and the types of injuries that the entrants may incur – which will dictate the type of patient packaging that may or may not be required inside the space.  All the factors, such as twists and turns into and out of the space, communications, placement of directionals, and intermediate anchors and haul/lowering systems should all be considered factors in determining the size of the rescue team. As an example, rescuing an entrant from a 24-inch round horizontal portal that is 3-feet off the ground would require a minimum of personnel. But, take this same scenario to 80-feet off the ground, or an on-air IDLH event, and it’s a much different story!

Next, the Respiratory Standard (1910.134), section (g)(3)(i) states that “One employee or, when needed, more than one employee is located outside the IDLH atmosphere;” and Section (g)(3)(iii) adds that…“The employee(s) located outside the IDLH atmosphere are trained and equipped to provide effective emergency rescue” – however, we are given no set number of personnel.

Sometimes we hear the HAZWOPER standard (1910.120) cited regarding IDLH response requirements. This standard requires the use of the “buddy system with stand-by personnel” for emergency response operations involving the release of hazardous substances producing IDLH conditions for employees responding. This regulation specifies a minimum of four personnel, two as a team in the buddy system and two stand-by personnel, to conduct operations in hazardous areas safely. Again, however, this is from the HAZWOPER regulation.

From the National Fire Protection Association, NFPA 1670 (Standard on Operations and Training for Technical Search and Rescue Incidents) states that six (6) rescue technicians shall be the minimum staffing for a “Technician Level” confined space response. This typically means any IDLH condition (breathing air; complexity; elevated or entanglement concerns) that exists in a permit required confined space rescue operation.

Now, we’ll give you an idea of how we address this at Roco with our stand-by rescue services. First of all, our typical (standard) Confined Space Rescue Team is made up of three persons including a Crew Chief and two Rescue Technicians. Keep in mind, that these are experienced, professional emergency responders, who perform stand-by rescue operations and/or train on a regular, if not daily, basis. In addition, the job circumstances and scope of work are carefully evaluated prior to committing a specific number of personnel. As a example, here are some basic guidelines:

Four-person team (minimum) for jobs involving inert entries, other types of IDLH entries, unusual space configurations (i.e., long distances, underground piping or complex obstructions.) As mentioned above, a three-person team made up of experienced rescuers is our standard operational manning requirement. This applies to the majority of our stand-by rescue work. In certain instances, a two-person team may be appropriate. For example, when there is very low potential for atmospheric hazards; large and easily assessable manways; no secondary lowering operations required; strictly horizontal movement, etc.

In closing, we must re-emphasize that OSHA 1910.146 is a performance-based standard that requires safe, timely and capable rescue response for confined space incidents. A realistic, hands-on rescue performance evaluation as referenced in Appendix F of this regulation can be a valuable tool in determining training, equipment and personnel needs based on the circumstances in your response area.

We hope this information has been helpful. Roco Rescue Online and the information herein is provided as a complimentary service for rescuers and emergency response personnel. As always, proper training is required prior to use of any technique described. If we may be of further assistance, please don’t hesitate to contact us at Roco headquarters by calling, 1-800-647-7626.
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RescueTalk (RocoRescue.com) has been created as a free resource for sharing insightful information, news, views and commentary for our students and others who are interested in technical rope rescue. Therefore, we make no representations as to accuracy, completeness, or suitability of any information and are not liable for any errors, omissions, or delays in this information or any losses, injuries, or damages arising from its display or use. All information is provided on an as-is basis. Users and readers are 100% responsible for their own actions in every situation. Information presented on this website in no way replaces proper training!