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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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Do’s & Don’ts for CS Attendants (Hole Watch)

Thursday, October 19, 2017

There continues to be a misconception that a confined space attendant (or “hole watch”) is a menial task to be assigned to the greenest, most inexperienced personnel on the job. That’s a dangerous assumption, and it has been a contributing factor in many confined space fatalities.

In fact, the attendant or hole watch should have a solid understanding of the permit space to be entered. This includes knowing the particulars of any known or potential hazards as well as other pertinent knowledge and skill sets. If you are assigned this crucial role, I hope you understand that the entrant(s) are relying on you. Your performance may have a significant bearing on the outcome, both good and bad.

Do you know everything you need to know in order to perform your duties as a confined space attendant? Don’t assume that you will learn everything you need to know after a two- or three-minute pre-job briefing.

Being an attendant or "hole watch" is a critically important role and failure to properly perform these duties has led to multiple fatalities – both for the entrants and the attendants themselves.

Do understand the known and potential hazards of the confined space. Do take the time to review the SDS (MSDS) for any and all materials or gasses that may be encountered. Do learn what the signs and symptoms of exposure may be. Then, if you detect any of them in the entrant’s behavior or appearance, you can order immediate evacuation.

Don’t gloss over this valuable and readily accessible information only to wonder what caused the entrant(s) to lose consciousness. The SDS (MSDS) provides information on route of exposure; and very importantly, the signs and symptoms of exposure. Don’t miss the opportunity to save the day, and perhaps a life, by learning these early warning signs. This allows evacuation of the space before entrants are no longer able to do so on their own.

Do learn the proper operation of any testing equipment, such as atmospheric monitors. It is also important to understand the limitations of this equipment as well.

Do keep track of all authorized entrants in the space. For entries with multiple entrants, don’t rely on your memory alone. Do use some sort of log or entry roster as a reliable means to accurately identify who is in the space.

Do make sure that you have a reliable means to communicate with the entrants. Do test that means of communication at the very limits of the space to ensure it works. Don’t wait until there is an incident to learn that you cannot alert the entrants, or you cannot hear that their status has changed. If you haven’t heard from the entrants in a while, it can be tempting to go into the space to check on them. This very situation has led to many fatalities in which the attendant was overcome by the same hazard as the authorized entrant(s). At that point, there is no longer anyone available to call for help.

Don’t accept the job assignment until you have been briefed by the entry supervisor on all the planned activities both inside and outside the space. Do remember that oftentimes activities outside the space can create a hazard for the entrants inside the space. Carbon monoxide and spills of hazardous materials are just a couple of examples.

Don’t allow any activities to take place inside or outside the space that are prohibited and are not consistent with the conditions stated on the entry permit, especially if they may create a hazard to the entrants. If those activities were not coordinated and told to you by the entry supervisor, do evacuate the space and call the entry supervisor for guidance.

Don’t leave the space or perform other duties that may interfere with your primary duty of monitoring and protecting the entrants.

Do remain diligent, remember that you are the critical link between the entrants and the rescue service.

Do know how to contact rescue services should they be needed. Don’t wait until it is too late to call for help. Do summons rescue as soon as you determine that the entrants may need assistance escaping from the space. Just remember, you can’t turn back the clock and buy back the time that entrants may have needed to survive. It’s a whole lot easier to turn around the rescue service if it is not needed.

Don’t allow unauthorized persons to approach or enter the permit space. If you are unable to warn them away, do order the evacuation of the authorized entrants. Do immediately inform the entry supervisor of the situation.

Do perform non-entry rescue (retrieval) when needed and if authorized by your employer. Do perform a thorough pre-entry inspection on the retrieval rescue equipment. Do make sure it is appropriate for the type of rescue that may be needed. Do learn and practice the proper operation of the retrieval equipment. Don’t wait until there is an emergency to try and figure it out. Don’t attempt entry rescue unless you are authorized, trained and equipped to do so. Don’t attempt entry rescue until you are relieved by another authorized attendant. Remember, you cannot leave the space unattended!

Don’t take your responsibilities lightly. Do ask the right questions of the entry supervisor and your authorized entrants. Do realize that they are all counting on you. Do ask to be briefed by the entry supervisor regarding any coordination that has been made with other work groups in the area. Do remember that many attendants have perished attempting heroic but ill-advised and unauthorized rescue attempts.

Do remember that your authorized entrants are relying on you. Do take the initiative to learn everything you need to know and how to operate any equipment in support of your entrants. As the hole watch, you are the critical link that can make or break a successful entry operation.

Click picture to download Safety Requirements for Confined Space Attendants.

 Written by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

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Planning for Successful Confined Space Rescue

Thursday, September 21, 2017

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

I am often asked by plant managers or rescue team supervisors about getting their team on the right track as far as training and competency is concerned. Here are a few tips for doing just that…

First of all, I always recommend that they choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) adds to the confusion of team members as to what techniques and equipment are being used – especially during a real rescue!

I then suggest that the team’s training records be reviewed in order to determine what level of training has been completed. I also strongly recommend getting everyone to the same level; especially if your facility is what I refer to as an “island unto itself.” In other words, do you have nearby facilities or other local agencies who can offer additional manpower, equipment, etc. in an emergency – or, are you fairly isolated?

Same Page, Same Language
If your facility is somewhat isolated, getting all your rescue team members on the same page, talking the same language, and at the same level of training is extremely important. You may have some experienced rescuers who have completed a variety of courses from different providers and are trained to different levels. Is this previous training properly documented should you be asked about it and to what levels? Having everyone on the same level – with the same basics under their belt – is key to performing a timely and successful rescue
And, do you have a particular goal or level you want your team to strive for, achieve, and maintain? Determining your overall goal for the team is significant in planning for and achieving results. Haphazard training “just for the sake of training” is not necessarily a good thing, and it tends to generate complacency among team members. Besides the obvious, your team “needs to be able to perform a rescue should the need arise.”

Is It Documented?
Take a look at how the training was conducted, documented and what standards were met, if any. And, if you have permit spaces or personnel working at height, I’m assuming that OSHA compliance is a given, but what about meeting requirements of the National Fire Protection Association (NFPA) for rescuers; namely, NFPA 1006 and 1670.

If there is an incident and OSHA or some other regulatory organization were to investigate, how would you provide the documentation that your team is capable of doing what is required of them? Remember, if it can’t be documented, it doesn’t exist!
Using NFPA 1670 (“team” standards) and NFPA 1006 (“individual rescuer” standards) as a basis for the team’s training level will help to provide the needed documentation and add to the credibility of your team’s capabilities. Ideally, all your team members should be certified to the Confined Space Rescue Technician level (NFPA 1006) along with the documentation to back it up.

Because NFPA’s Confined Space Rescue Technician includes confined space and high angle (elevated) rope techniques, I don’t necessary suggest that industrial clients be required to achieve “Rope Rescue Technician.” The added skills of Rope Rescue Technician include less-seldom-used techniques in industrial rescue such as rope ascension and traverse. Do make sure, however, that the course you choose for Confined Space Rescue Technician incorporates some (not all) of the high angle skills you would need to perform elevated rescue at your site.

A Mix of Confined Space and Rope Rescue

If you have a variety of experience and training levels among your team members, it’s important to get them consistently trained and all trained to the same level. Of course, I would recommend Roco’s Fast Track 80™ course, which includes a two-year certification. This course was designed to meet the needs of industrial facilities with a mix between “confined space” and “rope” technician skills needed. The class is geared for confined space rescue with some of the additional rope technician skills needed for elevated or high angle rescue. The class efficiently gets the rescuer to the Confined Space Rescue Technician level in only 80 hours using both performance-based and written testing.

Of course, the next challenge is getting the entire team trained to the same level. It’s not going to be easy to get an entire team released for training all at once – thus compromising the availability of rescue personnel onsite should an emergency arise. Therefore, you may have to run a couple of classes to get everyone certified – or send some of your team (or new team members) to an open-enrollment course.

Testing to the NFPA 1006 Professional Qualifications standard is conducted on the last day of the Fast Track 80™ class. Note: If some of your personnel have already completed this class, they can join the class for the last four days in order to be recertified. This will allow the new members and more experienced team members to work together in realistic practice scenarios. It will help get everyone on the same page as far as techniques plus give the experienced personnel a 3-day refresher and practice time before re-certification testing.

Training Cycle for Compliance
Once all team members are trained to the same level, I recommend going to a two-year rotation. For example, once everyone is certified, the next year would be a Roco Team Performance Evaluation (TPE) where we come for two-to-three days and run teamed-based evaluations using multiple rescue scenarios. Each scenario is critiqued by evaluators to adjust any problems found along the way. The TPE would be followed by a written report to document the scenarios conducted as well as discrepancies found and corrected. The following year would be Re-certification to NFPA 1006 (three-to-four-day session) that includes Individual Performance Evaluations (IPE) where team members would refresh personal skills as well as run several scenarios before testing for re-certification to Confined Space Technician level.
This rotation will help with OSHA compliance by meeting the minimum annual practice requirements as well as by providing a performance evaluation of rescue services as stated in Note to paragraph (k)(1) from 1910.146: “Non-mandatory Appendix F contains examples of criteria which employers can use in evaluating prospective rescuers as required by paragraph (k)(1) of this section.”
In addition, both OSHA 1910.146 and 1926.1211 require timely and capable rescue services for permit spaces. They also require minimum annual rescue practice in the applicable types of confined spaces as well as proficiency for team members. This cycle of training works well in documenting that you have met these minimum requirements while also meeting the requirements of NFPA.

The TPE supporting documentation also provides a “snapshot” of where your team and its individual rescuers stand in terms of competency. This information can then be used as a tool to design internal drills that correct any discrepancies while getting the most from your “all too limited” practice time.

I hope these recommendations are helpful in planning for the success of your rescue team – especially when it’s all on the line during an emergency situation. If you have any questions, don’t hesitate to call me at 800-647-7626 or send an email to info@rocorescue.com.
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Trench Collapses…one of the most dangerous hazards in construction

Wednesday, July 19, 2017

A month after a 33-year-old worker died while working in an unprotected trench, OSHA inspectors found another employee of the same Missouri plumbing contractor working in a similarly unprotected trench at another job site. OSHA determined that, in both cases, the company failed to provide basic safeguards to prevent trench collapse and did not train its employees to recognize and avoid cave-in and other hazards. OSHA issued 14 safety violations found during both inspections, and proposed penalties totaling $714,142.

Trench collapses are among the most dangerous hazards in the construction industry.

Twenty-three deaths from trench and excavation operations were reported in 2016. In the first five months of 2017, at least 15 fatalities have been reported nationwide.

Gain knowledge, develop skills, and learn to recognize trench hazards by registering for Roco's Trench Rescue course. Our desire is for everyone to return home safely each day, and for this fatality number to not continue to increase.

Source: OSHA QuickTakes July 2017

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Cal/OSHA Cites Two Companies After CS Death

Tuesday, May 30, 2017

On Oct. 21, 2016, a D&D Construction employee entered a drainage shaft to clean out mud and debris. No personal fall protection was utilized as the worker descended via bucket 10 ft. into the shaft, which was 4.5 ft. in diameter and lined with concrete.

At some point, the worker lost consciousness due to the oxygen deficient atmosphere in the confined space and fell 40 ft., then drowned in a foot of water.

“Cal/OSHA launched a confined space educational program to bring attention to the dangers and preventable deaths that occur in confined spaces,” said Cal/OSHA Chief Juliann Sum in a statement. “The program helps employers identify hazards and create effective safety plans that include air monitoring, rescue procedures and training before work begins.”

General contractor Tyler Development was constructing a single-family residence in the Bel Air area and hired subcontracted D&D Construction to install and service reinforced concrete posts known as caissons on the property, according to the agency’s report.

The state-run occupational safety unit cited Tyler Development and D&D Construction Specialties Inc. a combined $352,570 for ten serious and willful health and safety violations following an investigation. Cal/OSHA said neither company was in compliance with required confined space procedures.

D&D Construction previously was cited in 2012 for similar safety violations at a different job site.

In total, D&D has to pay a proposed $337,700 for 13 violations, including two willful serious accident-related, one willful serious, one serious accident-related, six serious, and three general in nature.

According to Cal/OSHA, the company failed to:
• ensure safe entry into the confined space
• have an effective method to rescue the worker in the confined space in an emergency
• test the environment to determine if additional protective equipment, such as a respirator or oxygen tank, were required to work safely in the shaft.

Tyler Development was cited $14,870 for five violations, three of them serious, for a failure to:
• evaluate the worksite for possible permit-required confined spaces
• ensure that the subcontractor meets all requirements to comply with a permit space program
• protect workers from the hazard of impalement by guarding all exposed reinforced steel ends that extend up to six feet above the work surface with protective covers

A full copy of the report is available here.

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