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NEW 2014: ProBoard & IFSAC Option in Roco's Fast-Track 80™

Friday, September 20, 2013

Roco is excited to announce that beginning in 2014, we will offer a ProBoard/IFSAC option conducted by the Carrol L. Herring Fire & Emergency Training Institute for select Roco courses at the Roco Training Center (RTC) in Baton Rouge. Students choosing the ProBoard option will complete both a written and skills exam. Upon successful completion of this certification process, they are then eligible to be entered into the ProBoard’s certification registry.

The first Roco course to offer FETI’s accredited certification testing will be our Fast-Track 80™ course to be held on February 20-22 & 24-28, 2014. There is an additional charge of $100.00 per student, and advance registration is required. Call us at (800) 647-7626 to register and reserve spaces or get more information.

The ProBoard is an internationally recognized professional organization that represents the fire service and related emergency response fields. The ProBoard accredits organizations, such as the Carrol L. Herring Fire & Emergency Training Institute, that provide certification testing to the National Fire Protection Association’s (NFPA) professional qualification standards. The International Fire Service Accreditation Congress (IFSAC) is a peer driven, self-governing system that accredits both public fire service certification programs and higher education fire-related degree programs.

Visit ProBoard's WEBSITE  or CLICK HERE to watch a video about the benefits of seeking fire service certifications through a ProBoard accredited entity.

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Proposed NFPA 350 Confined Space Guide: Approved for Comments

Saturday, August 31, 2013

NOTICE: If you are involved in any kind of confined space work or rescue, you need to read this document and offer your comments. This applies to anyone who may work in or near confined spaces, both industrial and municipal.

At a meeting earlier this month, NFPA’s Guide for Safe Confined Space Entry and Work (Draft) was approved for public comment by the NFPA Standards Council.

This document is designed as a “best practices” guide for those who work in and around confined spaces. As with any document that attempts to be all inclusive, it may work well for some while negatively affecting others. Therefore, it is very important that "WE" the public, the people who will be using this type of document in real world applications, offer our feedback. Now is the time to offer comments and suggestions. Comments as to what may or may not be feasible for your organization or what may have been overlooked in this document are a vital part of this NFPA process.

As contributing members for this document, we are encouraging you to take the time to make your suggestions in order to create a practical guide that will be user friendly and provide for greater safety when working in confined spaces. As you read it, please keep in mind that it is currently listed as a “Best Practices Guide.” However, this does not mean that at some point in the future it won’t possibly become an NFPA Standard.

This document could eventually affect the way you do your job, so it’s very important to all of us for it to be a safe, practical best practices guide. Every comment or suggestion must be addressed by the sub-committees. So, whether you agree or disagree, the time to offer your input is NOW!

Public comment will be accepted online until January 3, 2014. Go to www.nfpa.org/350. In order to comment, you must log in with your email and password – or you can quickly create an account.

Click here to download the PDF version. (Note: Download may take up to 3 minutes depending on your computer.)

 

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

Wednesday, August 28, 2013

READER QUESTION:
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?

ROCO TECH PANEL RESPONSE:

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.


NOTICE:
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 http://ohsonline.com/articles/2012/03/30/la-fire-department-boosts-confined-space-awareness.aspx
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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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Multiple Confined Space Entries

Tuesday, May 08, 2012

QUESTION: What is required for making multiple confined space entries, and can an Attendant/Hole Watch monitor more than one entry at a time?

ANSWER: Good question! And, the answer is YES according to OSHA 1910.146. However, each space must be evaluated on its own merits with all regulations and requirements applying to each individual entry. Here we will provide some tips when considering one Attendant for multiple entries. This is also where preparing comprehensive rescue preplans becomes essential, and we'll start there.

Suggestions for Writing Rescue Preplans

1.  One of the first things is to identify and categorize the space as “permit-required” or “non-permit required.” You’ll need to carefully consider the possible hazards based on the information gathered.

2.  Once you’ve identified the hazards, you’ll want to consider what actions might be taken to eliminate or control the hazard to allow for a safe entry. OSHA 1910.146 defines "acceptable entry conditions" as the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.

3.  Next, you would need to consider the type of work that is going to take place inside the space. A very important question to ask... could the work create its own hazard? (An example would include hot work being performed inside the space.) Then, what about rescue capabilities and requirements? Next, you’ll need to determine whether the entry should be considered “Rescue Available” or “Rescue Stand-by?”

Roco uses the terms “Rescue Available” or “Rescue Stand-by” to better prepare for safe entry operations and in determining more specific rescue needs for that particular entry. Here’s the way we use these distinctions...Rescue Available would be your normal entry that is NOT considered an IDLH (Immediately Dangerous to Life and Health)entry. In this case, a 10-15 minute response time for a rescue team would generally be sufficient to satisfy OSHA regulations and is typical during turnarounds where multiple entries are taking place.

On the other hand, we use Rescue Stand-by when a more immediate need is anticipated, such as with a hazardous atmosphere or potentially hazardous atmosphere. For example, with an IDLH entry, it may require the team to be standing by just outside the space in order to reach the patient in a timely manner (i.e., how long can you live without air...3 to 4 minutes?)  Or, how quickly can the entrant be engulfed where there is a potential engulfment hazard?  OSHA 1910.134 requires a standby person or persons capable of immediate action with IDLH atmospheres. (See reference below.)

OSHA Reference Note to Paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §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.

Regarding multiple entries, this Rescue Stand-by status could certainly limit the number of entries that could take place due to the availability of qualified responders and equipment. You must also consider that if you’re doing an entry that requires Rescue Stand-by and are called to respond to a rescue from a Rescue Available space, the entrants at the Rescue Stand-by entry must be evacuated before the team can respond. And, if there is only one rescue team, all other entries must stop during a rescue, as the team is no longer available.
Can an Attendant cover more than one confined space entry at the same time?

According to OSHA (see below), attendants can cover multiple spaces as long as they meet the responsibilities and duties at each entry site. If the spaces are “Rescue Available” and are in close proximity, this may be possible. However, without seeing the spaces and if they are on different levels as you mentioned, it could be very difficult for an Attendant to meet all of the requirements OSHA defines for Attendants.

OSHA Notes regarding Attendants and Multiple Entries...
NOTE to 1910.146(d)(6): Attendants may be assigned to monitor more than one permit space provided the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored. Likewise, attendants may be stationed at any location outside the permit space to be monitored as long as the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored.

1910.146(d)(7) If multiple spaces are to be monitored by a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendant's responsibilities under paragraph (i) of this section;

Once all these critical factors have been reviewed, you will need to consider the following when writing a rescue plan for an identical space:

    Internal configuration
    Elevation
    Portal Size

For hazards and LOTO procedures, you may be able to use the same rescue plan to cover those spaces. An example would be in doing ten (10) ground-level entries into 6-ft deep manholes, each with a 24” round, horizontal portal with a valve at the bottom. The rescue plan may be identical for all of these entries with the same description and hazards. However, on the rescue plan, you would need to allow for any unexpected hazards such as a possible change in atmosphere. This would be needed to be detected and properly handled by the responders at the time of the incident.

So, these are some of the basics you need to consider when writing a rescue preplan for confined spaces and for determining if (and when) an Attendant can effectively monitor multiple spaces.

If you have questions concerning these topics, please feel free to contact Roco at 800-647-7626.
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Can your Rescue Team “Walk-the-Walk?” The Value of Performance Evaluations

Tuesday, January 31, 2012

As an employer with permit-required confined spaces, you’ll need to determine if your rescue team or selected rescue service can truly “walk-the-walk” when it comes to confined space rescue. OSHA’s Permit Required Confined Space Standard (1910.146) is “performance-based” – meaning it’s all about capabilities when the stakes are high.Conducting a performance evaluation of your rescue service is a vital component in determining their true capabilities as well as fully meeting the performance requirements of 1910.146.

The Dilemma

Determining the adequacy of the team’s rescue capability can present a dilemma for many employers. That is, does the employer have the depth of understanding in technical rescue required to administer an accurate, meaningful performance evaluation? Do they know what to look for in terms of proper equipment use, efficiency, compliance with industry standards, and required safety systems – just to name a few. If not, is it then possible that the team may not be able to affect rescue when the need arises?

As we know, it’s quite easy to demonstrate a rescue capability for a very “straight forward” situation. This is what we call a “Dog and Pony Show.” They tend to be very controlled and scripted to ensure that everything goes smoothly. Unfortunately, when there’s an actual emergency, it seems the victims never get a copy of the script. Unless the rescue team or service is prepared for the “other than straight forward” rescue, the operation has little chance of going smoothly. There are still way too many incidents involving injury or death to would-be rescuers that can be directly attributed to lack of proficiency in the type of rescue being attempted.

The Guidance

Fortunately, Appendix F (Non-Mandatory) of 1910.146 provides guidance for employers in choosing an appropriate rescue service. It contains criteria that may be used to evaluate the capabilities both of prospective and current rescue teams. For all rescue teams or services, the evaluation should consist of two components:

An initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform permit space rescues of the kind needed at the facility and whether such rescuers can respond in a timely manner.

A performance evaluation, in which employers measure the performance of the team or service during an actual or practice rescue.

Another way to break down these two evaluation components is something like this… 
(1) The initial evaluation is to determine if the rescue service can “talk-the-talk”; and, (2) the performance evaluation is to determine if the rescue service can “walk-the-walk.”

During the initial evaluation the employer should interview the prospective rescue service or team to determine response times, availability, a means to summons in the event of an emergency, reciprocal communications should the service/team become unavailable, whether they meet the requirements 1910.146 paragraph (k)(2), and whether they are willing to perform rescue at the employer’s workplace.

Additionally during the initial evaluation the employer should determine if the rescue service/team has the necessary equipment to perform rescues. This includes both technical rescue equipment and if a space may pose a significant atmospheric hazard which requires entry rescue, does the team/service have adequate supplies of SCBA [or SAR].

ROCO NOTE:  Another aspect often overlooked is HazMat capabilities… does the team have the proper training and PPE to protect themselves from the particular hazards they may face? Can they deal with de-con issues that may result from exposure? Or, as the employer, will you provide the appropriate PPE and decon?

Finally, the employer should evaluate if the rescue team/service has the technical knowledge for vertical rescues in excess of five feet, the knowledge of rope work or elevated rescue, if needed, and the necessary skills for medical evaluation and patient packaging. Other than the visual and/or physical review of the rescue equipment; and, if necessary, emergency breathing air, the initial evaluation of the team/service is primarily completed through interviews and a review of training documents. In other words, can the team or service “talk-the-talk”?

Therefore, it is simply not enough for an employer to rely on the initial evaluation. While it’s a good start in narrowing the field of prospective rescue team/services, it is incumbent on the employer to determine if the rescue service can indeed walk-the-walk.  And the only way to ensure that is to complete a performance evaluation during an actual or practice rescue from the actual or representative types of spaces that they may be summoned to.

The Third Party Advantage

Performance evaluations can be administered to a prospective rescue service, or as a periodic evaluation of current rescue services. As an option, an employer may choose to use a third party that has extensive experience in this type of rescue.

This is especially beneficial when employers may not have the in-house expertise necessary to administer an accurate evaluation, or for employers who are more comfortable with having a third party evaluation as a documented, independent, and unbiased record of the rescue service/team’s capabilities.

As an independent evaluator, Roco has conducted these team (TPE) and individual (IPE) performance evaluations for many years using specific grading criteria. It is a valuable tool for the employer to ensure and document that the selected rescue team/service (whether an outside service or in-plant team) has the required proficiencies for rescue at their facility. These TPE/IPEs also provide a degree of refresher training that will help bring the team/individual up to the level they need to be.

In rare instances, our recommendation may be that the team requires more than spot training in order to meet an acceptable level of proficiency. Another benefit of third party TPE/IPEs is that it may be an opportunity for the evaluator to recommend minor changes in equipment or techniques that would enhance the capability of the team. In fact, Section B of Appendix F states,

“As part of each practice session, the service should perform a critique of the practice rescue, or have another qualified party perform the critique, so that deficiencies in procedures, equipment, training, or number of personnel can be identified and corrected.”

Another area where third party evaluations are beneficial is when contractors will be providing their own rescue capability. Some host employers mistakenly believe that theyare relieved of all responsibility when the contractor’s employees are performing the entries. But 1910.146(c)(8) and (9) place reciprocal responsibilities on both employers to each other. This includes the host employer informing the contractor that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146, and the contractor informing the host employer of the permit program it will be following.

Although this paragraph of the standard lacks specific direction, it certainly contemplates that the host employer cannot turn a “blind-eye” to deficiencies in the program presented by the contractor – including insufficient rescue capabilities. A team performance evaluation would be helpful in determining the contractor’s ability to provide rescue services for their employees. While some host employers may be qualified to evaluate contractor’s technical rescue capabilities, that is usually not the case.

Keeping Skills Fresh

Employers must also realize that technical rescue skills are very perishable. While a team or individual can successfully complete rescue training and attain a high degree of proficiency, regular practice is crucial to maintaining these skills. Unfortunately, all too often, the time and resources required to maintain this level of proficiency are not provided. How quickly these skills erode will vary. However, even with the most experienced rescuers, they will eventually lose their edge if practice time is not provided. For newer rescuers that complete their training but don’t the chance to practice fairly soon, their skills can erode at an incredibly fast rate.

The degree of difficulty for the anticipated rescues must also be considered. When more complex rescues are involved, teams may require even more training and practicetime to maintain their level of expertise. And, while a training certificate is good to have, the only way an employer can truly know if the rescue team/service meets the OSHA performance requirement for confined space rescue is by completing a properly administered performance evaluation.

For all those employers who have workers entering confined spaces to work, we hope that you will carefully consider this rescue evaluation process – it could save a life or even prevent multiple fatalities. For you rescuers out there, we hope that you will do everything you can to maintain and increase your proficiencies – so when the time comes, you can walk-the-walk with pride in a job well done.

If you would like additional information on a documented Team Performance Evaluation for your rescue service, please contact Roco at 800-647-7626.
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INVISIBLE HAZARD KILLS AGAIN

Wednesday, January 18, 2012

Roco Director of Training/Chief Instructor, Dennis O’Connell reviews the importance of following OSHA safety standards for confined space entry, no matter how many times workers have entered the space. The take away? With confined spaces…It’s NEVER old hat! The importance of preplanning confined space entries and identifying “potential hazards ”should be old hat by now. Yet every year we are still killing entrants and rescuers in confined spaces.

In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

Atmospheric Hazards Continue to Claim Lives in Confined Space Entry Scenarios

The importance of preplanning confined space entries and identifying “potential hazards” should be old hat by now. Yet every year we are still killing entrants and rescuers inconfined spaces.  In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

It’s always important to remember that each entry stands alone. Each and every time a space is entered, we need to:

(a) identify potential hazards;

(b) eliminate or control them, when possible;

(c) use proper PPE; and,

(d) have an EFFECTIVE Rescue Plan.

Otherwise, as in this story, we will lose or injure workers as well as those attempting the rescue.

Start from scratch and treat each entry like it’s the first time you’re entering the space – it could save your life.

Keep in mind, the history of a space really has nothing to do with the current entry. We’ve all heard people say, “We do this all the time, and we’ve never had a problem!” Or, “We’ve entered this space a thousand times and the air is always good!” Remember this… IT DOES NOT MATTER!! This entry has nothing to do with the last.

As you read of yet another unfortunate incident, let it be a reminder to those of us who make entries or do rescues from confined spaces – do not let your guard down, do not get complacent…it could be deadly. Atmospheric hazards are still one of the leading ways that people are dying in confined spaces. Because humans are visually oriented by nature, if we can see a hazard, we’ll protect ourselves from it. However, if we can’t see it, we tend to assume it’s safe. OSHA’s 1910.146 PRCS standard and others were developed for a reason… people were making tragic mistakes and dying in confined spaces. These standards and guidelines are written so we don’t make the same mistakes.

OSHA FINES UTILITY FIRM $118,580 FOLLOWING WORKER’S DEATH

OSHA has cited a contracting and utilities company for two willful and two serious safety and health violations following the death of a worker at the company’s Texas facility. Proposed penalties total $118,580. An inspection was initiated by OSHA on June 28 in response to a report that employees working on a new sewer line were exposed to inhalation of a hazardous chemical. One employee who entered a manhole to remove a plug in order to flush out accumulated debris became overwhelmed by toxic fumes and died. Another employee was hospitalized after attempting to rescue his co-worker.

The willful violations are for failing to test for atmospheric conditions and provide adequate ventilation and emergency retrieval equipment prior to entry into a manhole.

The serious violations are failing to provide or require the use of respirators as well as conduct an assessment to determine the potential for a hazardous atmosphere where oxygen deficiency, methane, and/or hydrogen sulfide were present or likely to be present.

“The company failed to ensure that proper confined space entry procedures were followed,” said Jack Rector, OSHA’s area director in Fort Worth. “If it had followed OSHA’s safety standards, it is possible that this tragic incident could have been prevented.”
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