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Municipal Response to Permit-Required Confined Spaces

Tuesday, November 16, 2010

A blog reader, who is a member of a municipal rescue team assigned to an airport, expressed concern about fulfilling “timely response” obligations for permit-required confined space entries within his district. Here are some suggestions from our Tech Panel…

First of all, the departments and agencies involved must carefully consider the obligations in providing rescue response for permit-required confined spaces.

Obviously, we cannot advise on departmental policy concerning response and notification, this must be determined by management officials. However, for you as an emergency responder, we cannot stress enough the importance of preplanning and conducting a hazard analysis for all confined spaces within your response area. The information gained by the analysis will help you determine what level of “timely response” may be required for a particular type of entry.

OSHA does not set a specific response time because there are too many variables involved – plus, they don’t want to set requirements that might cause a rescue team to “rush” into entering a space to attempt a rescue. OSHA does reference how long a person might survive an IDLH atmosphere (such as an oxygen deficient atmosphere) before becoming incapacitated (4 to 6 minutes). However, even this is up to interpretation depending on the level of oxygen present. For example, an 18% O2 level vs. a 6% O2 level, both are O2 deficient but have very different response requirements for successful rescue.

Another important consideration is when an entrant is entering an IDLH environment. In this case, having a team standing by the portal, fully equipped and ready to go may be the only way to meet a timely response for that situation. OSHA’s 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.”

Most entries, however, are not IDLH. This means that other forms of “external” rescue (vs. internal rescue) may be appropriate. Many times, in the rush of the moment, rescuers forget about external retrieval. Guessing that many of the spaces around the airport are manholes or vaults, these can most often be handled by the confined space attendant with an external retrieval system. This would include a mechanical winch attached to a tripod with a cable attached to the entrant’s high-point dorsal connection. Of course, this decision would be based on a prior hazard analysis.

NOTE: It’s important to note that ALL entrants are required to have “an immediate means of retrieval.” Reference OSHA 1910.146 [note to paragraph (k)(1)(i)] concerning timely response: “What will be considered timely will vary according to the specific hazards involved in each entry…”

As a final note, if hazard analysis and rescue preplans have not been conducted on your potential sites as required by OSHA, we encourage you to do so. Taking the time to do so will better enable you to determine what would be considered an appropriate “timely response” for a particular type of entry. It will also better prepare you as an emergency responder should the need arise.
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Is a “tailboard briefing” enough prior to a confined space entry?

Monday, November 08, 2010

We had this question from a reader and wanted to post for all to read.

Would a proper tailboard briefing conducted before a confined space entry be sufficient for identifying hazards that may be encountered by the entrants or the rescue team?

It’s true that a tailboard briefing should be an integral part of the larger overall preplanning for a confined space entry. However, well in advance of the entry, a detailed “hazard analysis” of the space should be performed.

A hazard analysis is used to identify the types of hazards, lock-out/tag-out needs, PPE required for entry, method of entry and important rescue considerations. In fact, OSHA requires these written assessments to be completed prior to an entry being made and the confined space permit acts as a secondary written assessment performed at the time of the entry. Here are some OSHA references concerning this topic…

1910.146(c)(5)(ii)(H)
The employer shall verify that the space is safe for entry and that the pre-entry measures required by paragraph (c)(5)(ii) of this section have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification shall be made before entry and shall be made available to each employee entering the space or to that employee’s authorized representative.

1910.146(d)(2)
Identify and evaluate the hazards of permit spaces before employees enter them;

1910.146(d)(3)
Develop and implement the means, procedures, and practices necessary for safe permit space entry operations;

The tailboard briefing should be used to confirm or reinforce the information already gathered in the hazard analysis. Because it deals with an individual space at the time of entry, the tailboard briefing is also a very useful tool in finding out if conditions have changed since the hazard analysis was completed.

So, the bottom line… having a detailed hazard analysis for each space that includes a detailed rescue preplan allows a rescue team to review and prepare for potential problems well in advance. Reviewing this information at a tailboard briefing just prior to the entry helps to remind everyone of the possible hazards, the proper precautions, and the potential solutions should an emergency occur.
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Retrieval vs. Entry Rescue

Monday, October 25, 2010

There’s no doubt about it, confined space entry is risky business. A first consideration should always be to try and eliminate the known and potential hazards – or, even better, “engineer out” the need for entry when possible. If it’s not possible (or feasible), and entry must be made, then as part of OSHA’s Permit-Required Confined Space standard (1910.146), the employer must take action to protect its workers. This regulation requires employers to develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, and for preventing unauthorized personnel from attempting a rescue.
Planning for rescue of the entrant should always be approached in a logical hierarchy. The first choice for rescue should always be “self-rescue.

However, there are too many lads named “Murphy” lurking about to be able to rely on this as the only means of rescue. That leads to the next option, which is “retrieval rescue.” This means that retrieval (or rescue) of the entrant(s) can be made without anyone else having to enter the space.

NOTE: It’s important to note that the hierarchy of rescue needs to be followed even when an “entry rescue team” is located on site. For example, when an entry is made into a simple vertical vault, a retrieval system must be used even if a trained rescue team is standing by – again, preventing rescuers from having to enter the space unless necessary.

To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. The retrieval system shall include a chest or full body harness, with a retrieval line attached at the center of the entrant’s back near shoulder level, above the entrant’s head, or in such a way to present a small enough profile for successful removal of the entrant. In certain instances wristlets may be used. The retrieval line shall be attached to a fixed point outside the space or to a mechanical device. For vertical entries more than 5 feet in depth, a mechanical device such as a retrieval winch or mechanical advantage rope system shall be available.

Relying on non-entry retrieval rescue requires a thorough and honest assessment of the retrieval system’s ability to function as intended should the need arise. Are there any entanglement issues within the space that would cause the retrieval line to fail? If the entrant must travel around any 90 degree corners or between levels, will the retrieval line work? Any and all potential causes of retrieval system failure would require the need to plan for entry rescue.

One of the advantages of non-entry retrieval rescue is that oftentimes it can be performed by the attendant. Modern retrieval equipment may utilize powerful gear reductions or rope mechanical advantages and are usually quite easy for the attendant to learn to operate. It is encouraged and quite common for the attendant to be trained and capable of performing non-entry rescue. The attendant is prohibited, however, from entering the space to perform rescue unless properly trained and equipped for ”entry rescue,” which is the last option in the hierarchy of rescue.

NOTE: Even if the attendant is trained and equipped for entry rescue, he or she must be relieved by another authorized attendant before abandoning their attendant duties.

Entry rescue requires the rescuer(s) to enter the confined space, thus possibly exposing them to the same hazards as the victim. That’s why it is critical for rescuers to be trained and equipped with the proper PPE to protect themselves from the hazards involved. In fact, OSHA states that if you don’t have the proper PPE or training, DO NOT ATTEMPT THE RESCUE!

This warning is driven by the great number of “would be” rescuers dying in confined spaces while attempting to save a life. Safe, successful entry rescue requires sufficient training in the proper techniques, a proficiency in the use of the appropriate PPE and rescue equipment, and the ability to recognize and identify the hazards and potential hazards in confined spaces.

Again, it’s important to keep in mind that there are many permit required confined spaces where non-entry retrieval is a viable option – and it should be used whenever possible. Vertical utility vaults with no entanglement hazards, horizontal entries with no corners or elevation changes are just a few. The proper course is to always perform a thorough assessment of the space to determine which type of rescue will be needed and to make sure the appropriate rescue response is in place should the entrants need assistance.
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To Pre-rig, or not to Pre-rig?

Monday, September 27, 2010

We received an interesting question about pre-rigged systems from one of our subscribers. The TechPanel had some helpful comments to share, so we have re-posted the info here. It’s a great topic.

Here are some things to consider about leaving systems pre-rigged.First of all, whether to pre-rig systems or not depends a lot on the types of rescues you will be doing.

Pre-rigged systems make sense for most industrial and municipal teams who have rope equipment designated specifically for rescues. However, it makes less sense for climbers and wilderness personnel who will be using the same equipment for multiple uses and putting systems together based on a specific need. This also reduces the amount and weight of equipment they must carry, which is a big concern. However, it also requires a high level of proficiency in a variety of systems in order to build systems safely and in a timely manner.

Next, let’s clarify what we mean by “pre-rigged systems.”

“Plug-n-Play” – These are systems that come pre-built and seem to require little training to operate. These “Plug-n-Play” systems may work for a specific location or type of rescue but may not work in every situation. Training for these systems should address what to do if the device/system malfunctions, or if it will not work for the type of scenario you may be faced with.

“Customized Pre-rigged Systems” – These are customized pre-rigged systems that rescuers build for site-specific needs and their team’s needs using existing equipment and training.

Confined space and rope rescue can be broken down to three core tasks… (1) Lowering, (2) Safety line Belay, and (3) Mechanical Advantage/Retrieval systems. You can build pre-rigged systems that make sense for your specific needs. Many of the teams we work with have adopted a three bag system.

For example, one rope bag is designated for “Lowering” along with the typical equipment needed for a lowering system (i.e. descent control device, carabiners, anchor straps, padding). This will provide a pre-rigged system that will handle most of your lowering needs. You may decide to supplement that with another anchor strap and a pulley for a high-point directional, etc.

Your “Safety line/Belay” bag can be set up the same way with enough carabiners and shock absorbers attached to the rope bag to allow for at least two rescuers and a victim. The third bag of rope (“Mechanical Advantage/Retrieval”) with a simple, pre-built Block-n-Tackle hauling system and its own anchor straps will give your team an “immediate means of retrieval” for either the main line or a safety line retrieval. With a few additional pieces of hardware, you will be able handle the vast majority of urban rope/confined space rescue scenarios.

We find that for industrial rescue teams or municipal fire and police rescue squads, these pre-rigged systems make sense. They save set-up time and get a rescuer to the victim as quickly as possible, which is especially critical for an IDLH emergency.

Many times teams will arrange their equipment so that it’s easier to inventory rather than what’s the fastest way to deploy it. For example, if you have twenty carabiners, why not have them attached to a rapid deployment bag type system rather than in a hardware bag that a team member will have to go through and pick out what is needed?

Our best advice would be to look at your team’s response area and consider the types of rescues that may be needed. You can then customize and build pre-rigged systems that make sense for your team. “Plug-n-Play” systems may handle most of your rescue situations or they may be part of a larger pre-rigged rescue system like the one above. Using a “pre-rigged systems” approach saves time, cuts down on confusion, and uses equipment more efficiently – especially when the pressure is on.
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Firefighter and Worker Die in Confined Space Incident

Thursday, September 09, 2010

TARRYTOWN, NY (WABC) — A fire department official says oxygen levels were dangerously low in a manhole where a sewer worker and a firefighter died.

No cause of death has been established in Monday’s deaths of sewer worker Anthony Ruggiero and Tarrytown firefighter John Kelly. At firehouses throughout Tarrytown, there are the ceremonial displays that no department ever wants to have to put up: black and purple bunting and flags at half staff.

Inside the headquarters there’s a memorial for one of the fallen men, John Kelly. “Our prayers all go out to the families of these two men, who were doing their jobs,” Tarrytown Mayor Drew Fixell said. “One of them a firefighter, acting heroic and trying to save the other one.”

Ruggerio was trying to clear a backup of sewage as part of his full time job in the village’s Public Works Department. He was overcome by fumes and collapsed. Kelly had tried to save Ruggiero, but also the fumes overwhelmed him as well.

Assistant Fire Chief John McGee said Tuesday that a hazardous materials team measured the oxygen level at 14 percent. The normal amount of oxygen in air is about 21 percent. He said he did not know if other, deadly gases were detected. Those are life threatening conditions that may have taken the men by surprise.

Village Administrator Michael Blau said neither of the men who died had put on a protective masks before entering the manhole. He said autopsies were planned. The deaths were being investigated by federal, state and local agencies.

“It’s very, very sad,” resident Susie Poore said. “I’m speechless, because…I don’t know even what to say. I don’t know what to say, other than I must have said ‘Oh my God’ 100 times already.”

Both victims spent over 20 years as volunteer firefighters. Ruggerio was a supervisor in the DPW by trade. Kelly worked as a state Department of Transportation worker.
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