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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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Atmospheric Monitors: “Calibration vs. Bump Testing”

Friday, January 21, 2011

“The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal, should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.”

Here at Roco, we’re often asked for an explanation of the difference between “calibration” and “bump testing” of portable atmospheric monitors. There seems to be some confusion, specifically regarding bump testing. Some folks believe that bump testing and calibration are the same thing. Others think that bump testing is no more than allowing the monitor to run its “auto span function” during the initial startup sequence – or by running a “manual auto span” in order to zero out the display if there is any deviation from the expected values.

To preface this explanation, it is important that the user maintain and operate the monitor in accordance with the manufacturer’s instructions for use. There are some general guidelines that apply to all portable atmospheric monitors and some of the information in this article is drawn from an OSHA Safety and Health Information Bulletin (SHIB) dated 5/4/2004 titled “Verification of Calibration for Direct Reading Portable Gas Monitors.”

Considering that atmospheric hazards account for the majority of confined space fatalities, it is absolutely imperative that the instruments used to detect and quantify the presence of atmospheric hazards be maintained in a reliable and ready state. Environmental factors such as shifts in temperature, humidity, vibration, and rough handling all contribute to inaccurate readings or outright failure of these instruments. Therefore it is critical to perform periodic calibration and pre-use bump testing to ensure the instruments are capable of providing accurate/reliable information to the operator.

Calibration of the monitor involves using a certified calibration gas in accordance with the manufacturer’s instructions. This includes exposing the instrument sensors and allowing the instrument to automatically adjust the readings to coincide with the known concentration of the calibration gas. Or, if necessary, the operator will manually adjust the readings to match the known concentration of the calibration gas.

In addition to using a certified calibration gas appropriate to the sensors being targeted, do not ever use calibration gas that has passed its expiration date. The best practice is to use calibration gas, tubing, flow rate regulators, and adapter hoods provided by the manufacturer of the instrument.

The frequency of calibration should also adhere to the manufacturer’s instructions for use; or, if more frequent, the set protocol of the user’s company or facility. Once the monitor has been calibrated, it is important to maintain a written record of the results including adjustments for calibration drift, excessive maintenance/repairs, or if an instrument is prone to inaccurate readings.

Each day prior to use, the operator should verify the instrument’s accuracy. This can be done by completing a full calibration or running a bump test, also known as a functional test. To perform a bump test, use the same calibration gas and equipment used during the full calibration and expose the instrument to the calibration gas. If the readings displayed are in an acceptable range compared to the concentrations of the calibration gas, then that is verification of instrument accuracy. If the values are not within an acceptable range, then a full calibration must be performed and repairs/replacement completed as necessary.

Modern electro-mechanical direct reading atmospheric monitors have come a long way in recent years in terms of reliability, accuracy, and ease of use. But they are still relatively fragile instruments that need to be handled and maintained with a high degree of care. The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.

For more information on this subject, please refer to the November 20, 2002 ISEA position Statement “Verification of Calibration for Direct Reading Portable Gas Monitors Used In Confined Spaces”; “Are Your Gas Monitors Just expensive Paperweights?” by Joe Sprately, and James MacNeal’s article as it appears in the October 2006 issue of Occupational Safety and Health magazine.
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Industrial Rescue I/II…Practical Skills, Industrial Focus

Monday, January 03, 2011

New for 2011! Practical skills training with a focus on compliance, but without the certification testing.

We’ve had many requests for a course that provides the skills, techniques and problem-solving scenarios for industrial rescue without the NFPA certification testing. Focusing on OSHA compliance, Roco’s new Industrial Rescue I/II will prepare rescuers and rescue teams for industrial confined space and elevated rescue as well as “rescue from fall protection.” Here’s more…

INDUSTRIAL RESCUE I/II (50 Hours)

This course offers a very practical, hands-on approach to industrial rescue that will provide the skills necessary to meet OSHA compliance guidelines for a competent rescue team or rescue team member.

Participants will be taught safe, simple and proven techniques that will allow them to effectively perform confined space and elevated rescues from towers, tanks, vessels and other industrial structures. Rescues from simulated IDLH atmospheres requiring the use of Supplied Air Respirators and SCBA will also be practiced. This course is designed for all rescuers, both industrial and municipal, who may be required to handle confined space rescues in industrial settings. It also includes Rescue from Fall Protection (rescue of suspended workers) as well as OSHA Authorized Entrant, Attendant and Supervisor training.

The problem-solving scenarios can be used to document annual practice requirements in representative spaces as required by OSHA 1910.146 and as referenced in NFPA 1006. For training conducted at Roco’s training facility, scenarios will be completed in all six (6) types of confined spaces. At other sites, the number of types completed will depend on the availability of practice spaces.

OSHA 1910.146(k)(2)(iv)
Ensure that affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

NFPA 1006 A.3.3.38 Confined Space Type
Figure A.3.3.38* shows predefined types of confined spaces normally found in an industrial setting. Classifying spaces by “types” can be used to prepare a rescue training plan to include representative permit spaces for simulated rescue practice as specified by OSHA. (*Roco Confined Space Types Chart)
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What does it mean when my atmospheric monitor gives negative or minus readings?

Thursday, December 02, 2010

At some point, most atmospheric monitors will display a “negative” or minus reading for a flammable gas or toxic contaminant. First of all, it is not actually possible for an atmosphere to contain a “negative amount” of a substance. These negative readings usually result from improper use of the monitor.

Most monitors will “Field Zero” or “Fresh Air Calibrate” its sensors when powered on. Because of this, it is very important to power on the unit in a clean, fresh air environment away from confined spaces, running equipment or other possible contaminants. Otherwise, the monitor may falsely calibrate based on the contaminant that is present.For example, a monitor that is powered on in an atmosphere that contains 10 ppm of a contaminant and then moved to fresh air may display a reading of minus 10 ppm. Even more troublesome, if that same monitor is then brought to a confined space that actually contains 25 ppm of the contaminant, it may display a reading of only 15 ppm. As you can see, this could easily lead to the improper selection of PPE for the entrant and result in a confined space emergency.

As always, it is very important to consult with the manufacturer of your particular atmospheric monitor in order to determine how to use it properly. Don’t take any chances with this critical part of preparing for confined space entry or rescue operations.
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Is there a regulation requiring rescuers to use respiratory protection that is “one level higher” than that required for the entrants?

Thursday, November 18, 2010

To our knowledge, there is no regulatory requirement. However, we’ve heard this before and have used it as well when stressing the importance of proper PPE for rescuers, particularly when IDLH atmospheres may be involved. Here’s our thinking… if the entrant’s PPE did not provide adequate protection and he or she is now requiring rescue assistance, then using their “same level of protection” isn’t going to protect you either!

What triggers the use of a greater level of protection? This comes from the rescuer’s assessment of the hazards – including the use of an independent atmospheric monitor from that used by the entrant(s). That’s why it’s so important for the rescue team to provide their own atmospheric monitoring equipment. It also illustrates why written rescue preplans are so important – you need to preplan what equipment and techniques will be required well in advance of an emergency. It’s critical; the PPE selected must be adequate to protect the rescuers.

When preparing rescue preplans, you must also take into consideration any unusual hazards or circumstances that may arise from any work being done inside or near the space. For example, special cleaning solvents might be used or other hazards may be introduced into the space by the workers. Referencing and understanding the MSDS as well as “listening to what your monitor is telling you” are key factors in PPE determination.

OSHA does mention, however, if the atmospheric condition is unknown, then it should be considered IDLH and the use of positive pressure SCBA/SAR must be used. This will protect you from low O2 levels and other inhalation dangers; however, you must also consider LEL/LFL levels. Other factors include non-atmospheric conditions as well. For example, have you considered “skin absorption” hazards and what precautions must be taken?

So, the bottom line, the decision to go with breathing air for rescuers can be determined from your hazard assessment; or, in some cases, by company policy; and even required by OSHA when there’s an unknown atmosphere involved. Remember, it’s much better to be safe than sorry!
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