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OSHA-Required Dockside Rescue

Tuesday, March 06, 2018

Roco now offers marine rescue standby services for the Baton Rouge-New Orleans industrial corridor. As with other Roco services, our personnel are experienced emergency responders trained to provide lifesaving skills when it matters most.

All Roco marine standby personnel are First Responder/ CPR/First Aid trained, and most are EMT’s. Our boats are fully equipped with First Aid kits, AEDs and O2 for prompt emergency care.

For construction work over or near waterways, OSHA 1926.106 requires certain safety precautions – including the timely response of a boat to rescue a fallen worker. In fact, according to one OSHA LOI, the retrieval of an employee from the water is required no more than 3 to 4 minutes from the time they entered the water. And, depending on hazards present, it could be required even sooner.

Section 1926.106(d) states:
At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.

The intent of the paragraph is to ensure prompt rescue of employees that fall into the water, regardless of other precautions taken to prevent this from occurring. Thus, OSHA requires that employers supply a skiff to affect a prompt water rescue. As a skiff supplies a backup to potential failures of fall protection devices, the use of fall protection systems is not a substitute for the skiff.

The requirement in 1926.106(d) addresses the hazard of falls that may occur in the event of a failure of the operation of fall protection devices or a lapse in their use. An employer is also required to comply with all other applicable standards including, but not limited to, the requirements that an injured employee be treated by medical personnel or an employee certified in first aid within 3 to 4 minutes from the time the injury occurred. This could mean that first aid treatment would have to begin in the lifesaving skiff or boat.

For more information on this service, please contact Roco at 800-647-7626 or email info@rocorescue.com.

Resources: OSHA 1926.106 as well as Letters of Interpretation (LOI’s) dated 8/23/04; 12/5/03; 12/6/91; and 06/13/90.

NOTE:  In this article, Roco cites OSHA 1926.106 which applies to construction activities while working over or near water. For other industries such as shipyard (Part 1915), marine terminals (Part 1917), or longshoring (Part 1918), please refer to those standards for specific requirements, particularly for PFDs and rescue skiffs. OSHA does not require rescue skiffs for all industry activities. However, keep in mind, OSHA sets minimum standards. And, remember, there’s a safe way and a safer way!

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The Clock's Ticking on Timely Response

Tuesday, April 25, 2017

By Dennis O'Connell, Roco Director of Training & Chief Instructor

As Director of Training, I get many questions about rescue techniques and regulations from our students and readers. In the past month alone, I have received three inquiries about "timely response for rescue teams" regarding permit required confined spaces (PRCS). So, let's break it down and try to clear the air on this subject. For clarification, we will refer to the General Industry Standard 1910.146; the Construction Standard 1926-1211; and the Respiratory Standard 1910.134.

In 1910.146, OSHA provides guidance on timely response in Subpart K (Rescue and Emergency Services) and again in Non-Mandatory Appendix F (Rescue Team or Rescue Services Evaluation Criteria). Subpart (k)(1)(i) states: "Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified."

This one sentence actually says volumes about response times. The first question to be answered is, "Can the rescue service respond in a timely manner?" It then gives a hint as to what a timely manner should be based on. The second part of the sentence refers to "considering the hazard(s) identified." What this so eloquently says is the response time must be determined based on the possible hazard(s). This means the "known and potential hazard(s)" must be identified for each space to be entered. The hazards discovered -- based on severity, type, how rapidly the hazard could become IDLH or injure the worker, how quickly the need to treat the injury, or how quickly hazards might interfere with the ability to escape the space unaided -- would then be used to determine an acceptable response time. This is why OSHA only alludes to response times and does not set hard and fast times to follow -- it depends on the hazards of that particular space.

Another aspect we need to consider is that "response time" begins when the call for help goes out, not once the team is on scene. It ends when the team is set-up and ready to perform the rescue. So, how long will it take your team to be notified, respond and set-up is a big portion of that acceptable response time calculation. For example, a dedicated onsite fire/rescue team would be able to respond faster than workers who have other responsibilities and need to meet at the firehouse before responding. Or, more quickly than an outside service, such as a municipal department, that would have to respond to the facility, get through the gate, and be led to the scene.

In the note to paragraph (k)(1)(i), it adds: What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA 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.

Here we see OSHA better defining an acceptable response time for IDLH atmospheres -- i.e., immediate action! However, it's important to note this doesn't just refer to low O2...depending on the type of contaminant in the atmosphere, other respiratory equipment such as half- or full-face APRs could be used. It may include a dusty environment where the entrant wears a mask and visibility is less than 5 feet. Technically, that would be considered an IDLH environment. Many people get hung up on the use of SAR/SCBA as the trigger for a standby team, and that is just not the case.

For an IDLH atmosphere where respiratory protection is needed, an adequate number of persons (rescuers) is required to perform a rescue from the type of space involved - ready, trained, equipped and standing by at the space -- ready to take immediate action should an emergency occur. So, when dealing with possible IDLH atmospheres, we are looking at "hands-on" the patient in 3-4 minutes as possibly being an appropriate response time. Basically, this is about how long an entrant can survive without air. The only way to safely make rescue entry in that time frame is to have rescuers standing by, suited up and ready to go!

So, if dealing with an IDLH atmosphere, we revert back to 1910.134. Many people think that that is the only time we need a team standing by ready to take immediate action. I pose the question, "If the hazard is a liquid (engulfment hazard), what would be a reasonable response time?" If the victim is Tarzan or Johnny Weissmuller (okay, Michael Phelps, for you younger people), we may have a longer stay-afloat time. But if a non-swimmer, or in an aerated solution or other engulfment hazard, immediate action may be their only chance of survival! And, what about radiation (time, distance, shielding)? I am sure you can think of a few more possibilities.

And, while OSHA referred to an IDLH atmosphere in this example, it's important to consider other IDLH hazards as well. Here's where we note that the definition of IDLH in the Respiratory Standard (1910.134) differs slightly in Permit-Required Confined Spaces (1910.146). The Respiratory standard specifically refers to an IDLH "atmosphere" while the PRCS standard states the following: Immediately dangerous to life or health (IDLH) means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. This includes more than simply atmospheric hazards! 

OSHA NOTE: Some materials -- hydrogen fluoride gas and cadmium vapor, for example -- may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim feels "normal" until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.

In Non-Mandatory Appendix F (I hate that non-mandatory language), OSHA gives guidance on evaluating response times under Section A - Initial Evaluation. 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 into 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.

Not a bad paragraph for a non-mandatory section of the standard! Here they explain what they are looking for in regards to response times. They even take the OSHA 1910.134 IDLH atmosphere requirement for a team standing by at the space a little further by adding "or into a space that can quickly develop into an IDLH atmosphere." It also states if the hazard is mechanical in nature, 10-15 minutes might be adequate. That’s right, "might" not will be, but might be. Again, it depends on the hazard.

Paragraphs 2-7 in Appendix F goes on to describe other conditions that should be considered when determining response times such as traffic, team location, onsite vs. offsite teams, communications, etc. If you have not done so, I highly recommend that you review the not-so-Non-Mandatory Appendix F. It is also important to note that while it's not mandatory to follow the exact methods described in Appendix F, meeting the requirements are! OSHA also uses the word "should" in Appendix F, not following the OSHA recommendations could certainly lead to some hard questions post incident.

OSHA 1926 Subpart AA Confined Spaces in Construction closely mirrors 1910.146. In this relatively new standard, they simplified the definition of timely response and omitted Non-Mandatory Appendix F, which helps to eliminate the confusion of the "non-mandatory" language, and included the requirements right in the standard, which is good. However, 1910.146 really gives you a better idea of what timely would be for different situations through the notes in Section (k) and Appendix F.

Section 1926.1211 of the Construction Standard for Rescue and Emergency Services (a)(1) states: Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. This is immediately followed by: Note to paragraph 1926.1211(a)(1). What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA1926.103, Respiratory Protection (for construction) 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.

In closing, these regulations are driving you in the same direction for identifying what a timely response would be...THERE IS NO SET TIME FRAME! Each space must be evaluated based on potential hazards and how quickly rescue would need to take place. I hope this will make you take a closer look at "how and what" you consider a timely response. An employer's PRCS program must identify and evaluate the rescue resources to be used. It is then up to the entry supervisor to make sure the identified rescue service is available to respond in a timely manner, which can literally mean life or death for the entrants.

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OSHA Civil Penalties Set to Increase in August

Friday, July 08, 2016

OSHA’s maximum penalty for serious violations will increase from $7,000 to $12,471. The agency’s top penalty for willful or repeated violations will jump from $70,000 to $124,709. OSHA’s maximum penalties have not increased since 1990.

“Civil penalties should be a credible deterrent that influences behavior far and wide,” Secretary of Labor Thomas E. Perez said in a press release. “Adjusting our penalties to keep pace with the cost of living can lead to significant benefits for workers and can level the playing field [for] responsible employers who should not have to compete with those who don’t follow the law.”

OSHA's new penalty levels are scheduled to take effect after August 1, 2016. Any citations issued after this date will be subject to the new penalties if the related violations occurred after November 2, 2015. The interim final rules were announced June 30. Comments on the interim final rules will be due 45 days after the rules are published in the Federal Register. (Source: National Safety Council.)

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Roco's New RescueTalk™ Podcast

Wednesday, June 08, 2016

RescueTalk™ Podcasts explore critical topics for technical, industrial and municipal rescue professionals, emergency responders and safety personnel. Learn about confined space rescue, OSHA compliance, NFPA standards, fall protection, trench rescue, off-shore considerations, rescue equipment, training and more. Get it now.
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New from OSHA: Is 911 your Confined Space Rescue Plan?

Monday, May 16, 2016

OSHA has a new Fact Sheet for “Confined Spaces in Construction” that is designed to keep workers and emergency responders safe in permit-required confined spaces.

The new document from OSHA stresses that employers must select a service that has the ability to respond and conduct rescue in a timely manner based on site conditions and potential hazards specific to the space. It also states that “an employer who relies on local emergency services for assistance is required to meet the requirements of 1926.1211-Rescue and emergency services.”

This Fact Sheet includes information for emergency response providers along with key questions to consider before making a commitment to respond. It also emphasizes the importance of preplanning while encouraging service providers to work closely with employers in order to be properly prepared for the challenges they may face.

Click here to download OSHA Fact Sheet.

“Permit-required confined spaces can present conditions that are immediately dangerous to workers’ lives or health if not properly identified, evaluated, tested and controlled.”

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