Roco Rescue



Q&A: Is a construction manhole considered a permit required confined space?

Wednesday, August 28, 2013

Is a new construction manhole considered a permit required confined space with the following activities being performed inside the space: overhead rigging, cutting welding, working off of six foot (6') step ladders? The task being performed is installation of new steam and condensate piping. Entry into the manhole vault is through a thirty six inch (36") round manhole opening into a vault. The vault is sixteen feet (16') deep. Entry is made by descending a twenty foot (20') extension ladder placed into the manhole opening. No other entry holes or exit holes. A 2000 cfm air mover is also in use for ventilation of the space. The area inside is congested with piping and valves being installed. Would this be considered a permit required confined space and would a rescue team be required?


The answer to this question is complicated, and without actually seeing the space and without having familiarity of all the specifics surrounding the construction of the space, we cannot give you a definitive answer. However, there are several things you must consider when evaluating the situation.

You must determine whether the space falls under General Industry (29 CFR 1910) or Construction (29 CFR 1926) requirements. If the work is considered “maintenance,” the General Industry standards are applicable. If it is considered “Construction,” the Construction standards are applicable. OSHA generally considers any work that entails “keeping equipment in its existing state, i.e. preventing its failure or decline,” as “maintenance” work covered by the General Industry standard, even if the work is construction “type” work.

From your description, it appears that the installation of new steam and condensate piping is part of the initial “construction” of the vault. However, other factors could affect that determination, such as whether the new steam and condensate lines are actually part of maintenance of an already existing piece of equipment. In that case, the vault itself may be new, but the work on the lines might be maintenance.

If the General Industry standard applies, OSHA takes the position that the PRCS standard (29 CFR 1910.146) does not apply to welding, cutting, and brazing activities as long as the hazards introduced by the welding are the only hazards in the space, and the protective measures of Subpart Q - Welding, Cutting and Brazing, are adequate to prevent a hazard from developing.

The protective measures of the welding standard would be applicable to the work in this space, specifically the following paragraphs of Subpart Q: 1910.252(a)(4)(i), 1910.252(b)(4)(i) to 1910.252(b)(4)(vii), 1910.252(c)(4), 1910.252(c)(9), and 1910.252(c)(10). All other hazards must be considered when making the determination of whether the PRCS standard applies. For example, if piping or other equipment will be lowered into the vault from overhead while workers are in the space, there would be a potential physical hazard not covered by Subpart Q that might require the space to be classified as a PRCS.

The General Industry standard for welding, cutting, and brazing activities does have certain requirements that are similar to some of the PRCS requirements. 

For example, it requires that where a welder enters a confined space through a manhole or other small opening means shall be provided for "quickly" removing him in case of an emergency. If harnesses or "safety belts" are used for this purpose, they have to be attached so that the welder's body cannot be jammed in a small exit opening. It also requires that "an attendant with a preplanned rescue procedure shall be stationed outside to observe the welder at all times and be capable of putting rescue operations into effect."

The General Industry welding standard also has certain specific ventilation requirements for spaces that are less than 10,000 cubic ft per welder, or in confined spaces where there are partitions or other obstructions that would obstruct cross ventilation. The minimum rate for such ventilation is 2,000 cfm per welder. It is important to keep in mind that the 2,000 cfm per welder is the actual air movement provided by the air mover, not the rated air movement. The ventilation must be configured to ensure that the air mover is not recirculating contaminated air back into the space. This would usually involve moving the air mover away from the entry point when there is a single opening, and ducting the air into the space. However, the use of ducting reduces the actual air movement. For example, an air mover rated at 2,000 cfm maximum will not actually be moving 2,000 cfm with 50’ of ducting having a 90 turn into the space. Each foot of ducting and each turn in the ducting reduces airflow. You stated that a 2,000 cfm air mover is being used. It is important to conduct the calculations for your ventilation configuration to determine whether you are actually moving the minimum 2,000 cfm.

Until OSHA issues its final rule on confined space safety for the construction industry (ruling is expected in 2013), there is no detailed standard at this time. However there is a construction standard for welding that has specific requirements for welding, cutting, and brazing in confined spaces (29 CFR 1926.353). The rescue requirements are the same as for the General Industry welding standard. Additionally, the Construction welding standard requires that if sufficient ventilation cannot be obtained without blocking the means of access, the employees in the confined space must be provided with airline respirators, and there must be an employee outside the space assigned to maintain communication with the employees in the space and to provide assistance in an emergency.

Obviously, to us, rescue capabilities are always at the top of the list. If the decision is made to follow the General Industry standard and consider the vault to be PRCS, then rescue capabilities and a plan need to be put in place. Depending on the conditions that exist in and around the space, rescue retrieval may be an option, such as a tripod and winch system with retrieval line attached to the entrant. In your description, however, you mention that internal elements that may hinder the ability to do external retrieval. If this is the case, then some type of internal rescue capability will be needed.

When it comes to the response time, we think Appendix F 1910.146 explains it best… 

"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 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."

Thank you for your question, and we hope this information has been helpful. If we may be of further service, please don’t hesitate to contact us.

The information provided on our website or by our Tech Panel is a complimentary service for our readers. It is a general information resource for rescuers and is not intended as legal advice in any way. Because standards and regulations 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.

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Get In and Get Out: Confined Space Rescue Teams

Monday, May 06, 2013

Is your confined space rescue team prepared for the worst?

Roco Chief Pat Furr is published in the APRIL 2013 issue of ISHN. Here's the article.
If you are tasked with administering the “permit required confined space” (PRCS) program at your workplace, you know that it can be a daunting job. There are several considerations regarding safe confined space entry operations. Paramount amongst all these considerations is preparation prior to ever entering the space.

Preparations for entering these spaces come in many forms. First is properly preparing your confined space entry team (Authorized Entrants, Attendants, and Entry Supervisors) by providing proper training and equipping them with appropriate PPE, communications and management’s support. Another is preparing the permit space for safe entry by eliminating or controlling known or potential hazards. These preparations are all logical and well comprehended by most PRCS program administrators.

The preparation often misunderstood (or inadequately addressed) is PRCS rescue. One reason is that most confined space program administrators don’t have a background in confined space rescue procedures, especially if there is a need for “entry rescue” if non-entry rescue is infeasible. The need for sometimes complex rescue techniques and the use of specialized equipment required for safe entry rescue is indeed difficult to evaluate unless the evaluator has a strong background in the field.

How skilled is the team?

I have witnessed first-hand rescue teams performing very well in rehearsed and scripted demonstrations. However, some of these are more of a “dog and pony show” than a true demonstration of the team’s capabilities. I’ve also seen rescue teams tasked with performing very complex confined space rescues during actual emergencies or during a “no-notice” evaluation with outstanding results. The level of a rescue team’s capabilities in terms of training, teamwork, equipment, performance under pressure, and all factors that would provide the best outcome is critical during actual confined space emergencies. I have seen it run the spectrum — from top notch as good as it gets, to the team is not only a hazard to the victim(s) but a hazard to themselves as well.
Therefore, one of the most important preparations for a complete PRCS entry program is a thorough evaluation of prospective and selected rescue teams to ensure an appropriate level of capability for the worst-case situation. In fact, OSHA not only requires the rescue team practice for the worst-case event based on the representative types of spaces, but also for all confined space types to which they may be summoned. This includes rescue from an elevated structure if necessary.

Resources for evaluating rescue teams

A great starting point for “evaluating” a prospective confined space rescue team can be found in OSHA 1910.146-Appendix F. However, unless the confined space administrator knows the right questions to ask of the team or knows a great deal about proper rescue procedures, the evaluation may not reveal a true picture of the team’s capabilities. The performance demonstration must confirm that the team is indeed capable of providing safe and effective rescue for the site’s worst-case confined space rescue scenario.

Another helpful tool is a “Confined Space Types Chart” that can be used in identifying potential worst-case situations for a responding rescue team. Click to download your copy here.

Taking advantage of OSHA’s 1910.146 Appendix F guidance and the “Confined Space Types Chart” will arm the confined space program administrator with tools to adequately vet a prospective or selected rescue team. These same tools can be used to determine appropriate “training levels” for the confined space rescue team as well.

For example, with “Confined Space Types 1-6,” you’ll notice that for each pairing of numbers, CS Types 1 & 2 are “side entry” portals; Types 3 & 4 are “top entry” portals; and Types 5 & 6 are “bottom entry” portals. Then, for portal dimensions, the odd numbers (Types 1, 3 and 5) are more restricted portals that are less than 24-inches in diameter. The even numbers (Types 2, 4 and 6) are portals greater than 24 inches.

Why is it important to consider these confined space types and portal sizes when evaluating the rescue team? Well, it has to do with the rescue team’s ability to get in and out of the portal with any required PPE — most likely affecting the need for airline respirators versus backpack SCBAs — and also the need to get a packaged victim out of the space. Generally, a rigid Stokes type litter will not fit through a portal that is 24 inches or less, especially once the victim is loaded into the litter.

The internal configuration of the space also has to be evaluated to determine if any obstacles would impede rescue or limit the types of patient packaging that may be required. Does the internal configuration require the need for rigging directional pulleys inside the space? Are there any other training or equipment shortfalls? There are many other internal physical configuration considerations such as sharp edges, sensitive equipment, exposed leading edges, hot surfaces, limited patient packaging and more.

Then, elevated locations must be considered. Is the portal elevated above grade by four feet or more? It’s one thing to provide rescue from the confined space only to find out that the rescue team is ill-equipped or does not possess the skills required to safely move the victim to ground level. This often requires specialized training and techniques in order to maneuver a packaged victim over handrails, or to statically load the lowering system without causing a shock load to the rope system or to the victim, or in providing an attendant or tag lines to guide the rescue package through or around any obstacles.
Effective evaluation is essential

Whether it’s an in-house rescue team, a team of municipal emergency responders, or a third-party contracted rescue team, simply hearing the rescue team “talk the talk” is only the beginning of the evaluation process. It is essential to confirm that they can also “walk the walk.” That’s why it is so important for the evaluator to have a solid technical rescue background or be qualified to effectively use the tools described in this article. These tools will help provide the right questions for a program administrator to ask.

About the Author:
Pat Furr is a chief instructor and technical consultant for Roco Rescue, Inc. As a chief instructor, Pat teaches a wide variety of technical rescue classes including Confined Space Rescue, Rope Access, Tower Work/Rescue, Fall Protection, and Suspended Worker Rescue. In his role as technical consultant, he is involved in research and development, writing articles, and presenting at national conferences. He is also a new member of the NFPA 1006 Technical Rescuer Professional Qualifications Standard. Prior to joining Roco in 2000, Pat served 20 years in the US Air Force as a Pararescueman (PJ)
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Update: Question to OSHA on Individual Retrieval Lines

Tuesday, September 18, 2012

Report submitted by John Voinche', Sr. Vice President/COO, Roco Rescue

In July, a group of Roco instructors conducted a Confined Space Rope Rescue demonstration for OSHA representatives from Washington, DC. These agency officials represented both General Industry and Construction. This demo was used to clarify our concerns about a pending Letter of Interpretation (LOI) concerning Individual Retrieval Lines in confined spaces that was brought to our attention last year. Here is a little background…

Last July (2011), we brought you a story entitled, “What’s the talk about individual retrieval lines?”  At the heart of the issue was a pending LOI from OSHA regarding how retrieval lines are used inside confined spaces. [Note: This LOI is pending and has not been published in the Federal Register.]

Here’s the question to OSHA from a gentleman in Maryland which initiated the LOI…

“Does OSHA 1910-146 (k)(3) require that each individual entrant, including workers and/or rescuers, entering into a confined space be provided with an independent retrieval line or can more than one entrant be connected to a single retrieval line?”

The proposed answer from OSHA stated that each entrant should have an “individual” retrieval line, despite the fact that the word “individual” is not included in this section of the standard [1910.146 (k)(3)(i)].
Roco then wrote a letter to OSHA requesting clarification about the forthcoming LOI. A portion of our letter stated that, “This pending interpretation is different from our understanding of what’s required by the regulation. While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.”

One of the techniques being used is a “single retrieval line” for multiple entrant rescuers. The first rescuer to enter the space is attached to the retrieval line via an end-of-line Figure 8 on a Bight. Any subsequent rescuers enter the space attached to the same retrieval line using mid-line Butterfly knots. In our opinion, this satisfies the intent of the regulation in that each entrant is attached to a retrieval line.

However, in the case of multiple entrants, requiring “individual” lines as mentioned in the proposed LOI may represent an entanglement hazard. This, in effect, may cause entrants to opt out of using retrieval lines due to potential entanglement hazards (which is allowed by the standard if entanglement hazards are a concern). So, in our opinion, this effort to bring more clarity to the issue may further complicate the matter.
Again, we believe the single retrieval line method described above is one way to rescue entrants while satisfying the intent of the standard at the same time. More background is available by reading our original story.

Fast-forward back to July 2012… the demonstration lasted about four hours. During this time, Roco demonstrated numerous retrieval line techniques as well as the “pros and cons” for each system. There was a great deal of discussion back and forth on how this pending letter of interpretation could affect rescuers and entrants – and their ability to perform their jobs safely and efficiently.
We would like to thank OSHA for allowing us to offer our feedback concerning this topic. We also want to say a special thanks to the Baltimore Fire Department for allowing us to use their training facilities. We don’t know when a final LOI will be issued, but we will keep you posted!
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LAFD promotes Confined Space Awareness

Tuesday, June 26, 2012

“It is our experience that the victims, would-be rescuers, and co-workers either fail to adhere to their emergency plans or simply do not have a plan in place, with catastrophic results... In the last year alone, we have responded to three confined space rescues.”- Battalion Chief Jack Wise of the Los Angeles Fire Department

Joint Effort for Confined Space Awareness Education

The California Department of Industrial Relations' Division of Occupational Safety and Health (Cal/OSHA) joined forces March 28 with the Los Angeles Fire Department to urge employers and employees to prepare properly for working in confined spaces. Officials from both agencies participated in a news conference where LAFD personnel gave a confined space rescue demonstration and potential hazards were explained.

Cal/OSHA launched a statewide confined space education and awareness campaign in February after seven confined space deaths and numerous injuries in 2011. Illustrating the variety of industries where confined spaces are common, those deaths occurred at a Fortune 500 pharmaceutical facility, a winery, a paint manufacturing plant, and a recycling center.

“Today's event with the Los Angeles Fire Department helps raise awareness of the hazards associated with working in confined space environments and the need for employers to have an effective emergency response plan in place before a critical situation arises,” DIR Director Christine Baker said. “As a national leader in workplace safety, Cal/OSHA is working with labor, employers, and public safety officials to eliminate this type of preventable fatality in the workplace.”

Some of the 2011 fatalities involved potential rescuers attempting to aid someone who had collapsed in a confined space. “These confined space deaths and serious injuries were all preventable had safety practices been in place. It is even more tragic that, in many cases, workers attempting to rescue their co-workers also fall victim,” said Cal/OSHA Chief Ellen Widess. “Confined spaces can be deceptively dangerous. Employers need to assess if they have such a hazard, identify and mark those spaces, [and] provide employee and supervisor training and on-site rescue plans and equipment.”

Cal/OSHA has posted extensive information about confined space hazards on its website at
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New Study: Relying on Municipal Rescuers for Confined Space Response

Tuesday, May 22, 2012

A study on the “reliance of municipal fire departments for confined space response” has been funded by a legal settlement following the deaths of two workers in a confined space incident in California.Research by the University of California, Berkeley, indicates that employers may be relying too heavily on local fire departments for confined space rescue.

These findings indicate that local fire departments may not have the resources to provide the specialized training needed for confined space rescue, especially when "response and rescue" times are such critical factors.

Key Points from Study

•  Confined space incidents represent a small but continuing source of fatal occupational injuries;

•  A sizeable portion of employers may be relying on public fire departments for permit-required confined space response; and,

•  With life-threatening emergencies, fire departments usually are not able to effect a confined space rescue in a timely manner.

Municipal Response Statistics

The study includes some very interesting statistics about fire department response times, rescue times, and capabilities. It also shows that rescue times increase dramatically when hazardous materials are present. For example, according to the report, fire department confined space rescue time estimates ranged from 48 to 123 min and increased to 70 and 173 min when hazardous materials were present.

According to the report, “estimates made by fire officers show that a worker who experiences cardiac arrest, deprivation of cerebral oxygen, or some other highly time-critical, life-threatening emergency during a confined space entry will almost certainly die if the employer’s emergency response plan relies solely on the fire department for rescue services.”

Researchers proposed that a more appropriate role for fire departments would be to support a properly trained and equipped on-site rescue team and to provide life support following a rescue.

Information excerpted from, “Confined Space Emergency Response: Assessing Employer and Fire Department Practices,” by Michael P. Wilson, Heather N. Madison & Stephen B. Healy (2012). This study was published in the Journal of Occupational and Environmental Hygiene (Feb 2012) and is available for purchase from Taylor & Francis Online.

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