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RESCUE IV-ADVANCED SCENARIOS

Wednesday, December 07, 2011

We’ve had so many requests for “advanced-level scenario training” that we’ve added Rescue IV to our 2011 schedule. You can add new techniques to your rescue toolbox while putting your problem-solving skills to the test.Challenging confined space and high-angle evolutions, including Roco’s“Yellow Brick Road” multi-station scenario, will give rescuers and rescue teams the most realistic rescue experience possible. This 40-hour course will challenge participants in a wide variety of confined space and high angle rescue scenarios.

RESCUE IV – ADVANCED SCENARIOS (40 hours)
Prerequisite: Rescue I-Plus or Industrial I/II

Challenging confined space and high-angle evolutions, including Roco’s “Yellow Brick Road” multi-station scenario, will give rescuers and rescue teams the most realistic rescue experience possible. This 40-hour course will challenge participants in a wide variety of confined space and high angle rescue scenarios.Advanced problem-solving skills and additional techniques will equip rescuers to function more effectively in time-critical emergency situations. This 40-hour course will challenge individual rescuers and rescue teams in a wide variety of confined space and high angle rescue scenarios. These scenarios will increase in complexity to include simulated IDLH and non-IDLH atmospheres, using both SCBA and SAR air equipment. For training conducted at Roco’s training facility, practice scenarios will be completed in all six (6) types of representative confined spaces. At other sites, the number of types completed will depend on the availability of practice spaces.This course will provide documented confined space practice scenarios in accordance with OSHA 1910.146 and as referenced in NPFA 1006.

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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Confined Space Fatalities…a closer look at the numbers

Tuesday, November 01, 2011

At some point during just about every Roco CSRT Rescue Stand-By job, someone will ask us why we are there. After we tell them that we’re there to make sure all the workers go home safely (and explain some of the basic requirements of OSHA’s 1910.146 regulation), they will normally add, “Well, we’re glad you’re here!”When asked how often we have to do a rescue, we’ll tell them that it’s not often – because our goal is to make sure a rescue never has to happen. With careful pre-planning and proper entry procedures, an entry rescue should not be needed. 

As we all know, however, things go wrong – especially in a confined space. And that’s when a Stand-by Rescue Team can make all the difference in the world – especially to the worker(s) in the hole.

With a facility that plans for confined space entry and routinely follows all safety precautions, employees just might not realize how common these confined space emergencies can be. With that in mind, we decided to do some very basic analyses of statistics from the Department of Labor. In looking at permit-required confined space incidents from 2005 through 2009, we found some of these statistics to be surprising.

Here’s what we found… during the 5-year period (2005-2009), there were a total of 481 fatalities. This averages to about 96.2 fatalities per year (or 1.85 fatalities per week). If you carry this logic forward, it equates to 1 fatality about every 4 days. And keep in mind that this data only covers incidents with at least one fatality or death, so these numbers don’t include all of those incidents that resulted in serious injuries or illnesses.

These fatalities occurred in 28 states…with just about every age group other than the very young and the very old equally represented. Over 61% (or 298) of these incidents occurred during construction, repairing or cleaning activities. For 203 of the fatalities, the victim worked in the construction industry regularly; however, 17% (or 83) of the victims were in management positions.

Over 61% of confined space entry fatalities occurred during construction, repairing or cleaning activities.

One of the most surprising statistics had to do with the causes of these fatalities. Generally, you would assume that the most common cause of confined space emergencieswould be atmospheric hazards. However, during this particular period, that was not the case. The largest cause by a significant measure was “Physical Hazards.” This broad term encompasses a lot of territory including, “struck by”; “caught in”; “collapses”; and “falls.” Physical hazards accounted for 294 or 61% of the fatalities. Atmospheric hazards (including fires) accounted for 160 or 33% of the incidents.

These numbers serve to remind us how important proper safety precautions are when it comes to confined spaces. For emergency responders, atmospheric hazards are always on our minds – however, from this, we also must consider the many physical hazards that are often found in confined spaces – especially when construction or maintenance activities are in process.
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Is relying on my local fire department in compliance with OSHA 1910.146?

Tuesday, September 13, 2011

Often the question comes up about using a local fire department for confined space rescue coverage in an industrial facility; and if it would be in compliance with OSHA 1910.146? In addition to the proper evaluation of the prospective rescue service, we always stress the need for “reciprocal communications” between the rescue service and the employer. For example, if the rescue service becomes unavailable at any time during a PRCS entry, the rescue service agrees to contact the employer so that the entry can be immediately suspended until the rescue service is once again available to respond in a timely manner.


The following is from an OSHA Letter of Interpretation dated 5/23/08.

Scenario: An employer evaluates and selects a local fire department using the guidance provided in Appendix F of the PRCS standard, Rescue Team or Rescue Service Evaluation Criteria (Non- mandatory). The employer has determined that the local fire department is adequately trained and equipped to perform permit space rescues of the kind needed at the facility. The employer has also made a performance evaluation of the service in which the employer has measured the performance of the team or service during an actual or practice rescue. However, the local fire department cannot guarantee that the rescue team will not be sent on another call during the employer’s permit-space entry operations. In other words, they have the ability to respond in a timely basis, unless another call prevents them from doing so.

Question: If the employer selects this local fire department as its off-site rescue service, would the employer be in compliance with 1910.146(k)(1)?

29 CFR 1910.146(k)(1) provides:

(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of his section, shall:

(i) Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

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.

(ii) Evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified;

(iii) Select a rescue team or service from those evaluated that:

(A) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;

(B) Is equipped for and proficient in performing the needed rescue services;

(iv) Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and

(v) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

Note to paragraph (k)(1): Non-mandatory appendix F contains examples of criteria which employers can use in evaluating prospective rescuers as required by paragraph (k)(1) of this section.

The employer must evaluate and select an off-site rescue service that has the capability to respond in a timely manner to the particular hazards at issue and to the types of emergencies that may arise in the employer’s confined spaces. The criteria employers can use in evaluating and selecting a service include determining whether the service is unavailable at certain times of the day or in certain situations, the likelihood that key personnel of the rescue service might be unavailable at times, and, if the rescue service becomes unavailable while an entry is underway, whether the service has the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately.

Compliance may require the employer to be in communication with the off-site rescue service prior to each permit space entry. In the scenario described, the employer must ensure close communication with the rescue service during entry operations so that if the rescue service becomes unavailable while an entry is underway, the employer can instruct the attendant to abort the entry immediately. Entry operations cannot resume until the entry supervisor verifies that the rescue service is once again able to respond in a timely manner.

ROCO COMMENTS:

It’s important to note that the off-site service must be willing to perform rescues at the employer’s workplace. As referenced in Appendix F (5)… For off-site services, is the service willing to perform rescues at the employer’s workplace? (An employer may not rely on a rescuer who declines, for whatever reason, to provide rescue services.)

Also, while a written agreement with the local agency is not necessarily required by the regulation, it certainly would make it easier to document that an agreement to respond was in place – and that the department had an understanding of the scope of services to be provided at the employer’s site (i.e., confined space rescue).
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Confined Space Fatality Follow-up

Monday, August 29, 2011

Here’s a follow up to a Confined Space Fatality story we published earlier this year. One of the injured persons (a “would be” rescuer and co-worker of the initial victim) remains hospitalized since January. According to a Cal/OSHA Chief, “it is unfortunately common for other employees to be injured or killed while attempting impromptu rescue of the initial victim.” In fact, NIOSH states that prior to enactment of the permit-required confined space regulation, 60% of all fatalities in confined space incidents where multiple fatalities occurred were “would-be” rescuers.

This article also addresses the importance of proper planning for confined space operations. These incidents continue to happen all too often when workers aren’t properly trained to deal with the hazards of confined spaces and the appropriate actions to take prior to entering a space – especially if a co-worker is already down. Keep in mind, most likely, there’s something very wrong in the space! As a rescuer, or a “would be” rescuer/co-worker, don’t rush into a confined space. You must protect yourself first!

Cal/OSHA fines prominent pharmaceutical firm $371,000 for safety violations leading to worker fatality

Los Angeles – Cal/OSHA issued eleven citations totaling $371,250 to Baxter Healthcare Corporation dba Baxter Bioscience this week for deliberate and willful workplace safety violations which resulted in the death of one of their technicians and serious injury of two others. The violations included four willful citations, indicating intentional violation or knowledge of a violation. Baxter has 15 business days to appeal or pay the citations. “We will not tolerate employers who intentionally sacrifice the safety of their workers,” said DIR Acting Director Christine Baker. “Our goal is to prevent these needless tragedies and ensure employers live up to their responsibility of protecting their workers.”

On January 21, Baxter technician Henry Astilla, 33, collapsed when he entered a seven foot deep, 6,000 liter tank in which nitrogen gas was being bubbled through plasma as part of a protein extraction process. Air in the tank had been displaced by the nitrogen gas resulting in an oxygen deficient atmosphere in the tank. Cal/OSHA regulations require employers to have special protective procedures in place prior to the entrance by employees into these types of confined spaces. In this case, the employer had not tested the atmosphere prior to entrance to insure there was sufficient oxygen, which led to Astilla’s death.

Cal OSHA’s investigation further revealed that when Astilla was discovered, a supervisor ordered two other employees to enter the tank and retrieve him, without testing the atmosphere of the tank or providing proper equipment and other safeguards necessary for a safe rescue. As a result, Astilla died and the two employees sent to retrieve him were seriously injured. One remains hospitalized since January.

“The hazards of working in confined spaces are well documented and this is a classic example of the kind of injury that occurs when employers fail to adequately protect their employees,” said Cal/OSHA Chief Ellen Widess. “When confined space operations are not properly planned, it is unfortunately common for other employees to be injured or killed while attempting impromptu rescue of the initial victim.”

Cal/OSHA determined that Baxter’s confined space program failed to comply with all requirements, including appropriate atmospheric testing, protective equipment as well as rescue equipment and procedures. Baxter Bioscience is a multi-national pharmaceutical company with a Los Angeles plant located in Atwater Village. The facility is the largest of its kind in the nation, utilizing advanced technology to produce plasma proteins.

The citations Cal/OSHA issued this week included one classified as general and ten classified as serious, four of which were classified as willful. Willful classifications are issued when an employer either commits an intentional violation and is aware that it violates a safety law, or when an employer is aware that an unsafe or hazardous condition exists and makes no reasonable effort to eliminate the hazard.
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What’s the talk about individual retrieval lines?

Wednesday, July 20, 2011

Because it is important to keep our readers and students updated, we wanted to share the following information with you. Please note that this issue is not resolved as of this time, and we have a letter submitted to OSHA for clarification. However, we wanted to keep you in the loop so that you can make better decisions when it comes to your rescue preplanning and operations.

It has recently come to our attention that there is a pending OSHA Letter of Interpretation (LOI) regarding the requirement for an “individual retrieval line” for each entrant. This pending interpretation is different from our understanding of what’s required by the regulation (1910.146). While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.

As mentioned above, Roco has submitted a detailed letter to OSHA for a clarification, stating our position that the use of individual lines for entrants in all cases is problematic for a number of reasons. Although OSHA’s response in its letter of interpretation is ambiguous as to its applicability to entry rescue operations, in our commitment to follow the intent of all OSHA standards, Roco is assuming that OSHA’s response was intended to apply to all entries, including rescue entries. Therefore, we will teach and use “individual lines” for the time being until we get further clarification from OSHA.

Question to OSHA:
In a request for clarification, a gentleman from Maryland had asked this question, “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?”

OSHA’s Response:
OSHA’s response in the LOI states, “OSHA 1910.146(k)(3)(i) requires that each authorized entrant into a permit-required confined space must have a chest or full-body harness attached to their ‘individual’ retrieval line or life line to ensure immediate rescue of the entrant.”

Roco Note: It is important to note that “individual” retrieval line is not used in (k)(3)(i); it simply refers to “a” retrieval line. The standard states, “Each authorized entrant shall use 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 at another point….”

Additional Roco Comments:
First of all, OSHA’s Permit-Required Confined Spaces Standard is, for the most part, a “performance-based” standard, meaning that it generally provides a result that is to be met, but leaves the manner by which that result is to be obtained to the judgment of the employer. This is particularly true of the rescue and retrieval requirements, as the specific circumstances and conditions of each entry or rescue will dictate what equipment and techniques may be required. However, this pending Letter of Interpretation (LOI) regarding the use of retrieval lines in Confined Spaces crosses over into the area of specific equipment and techniques that must be used.

Consistent with the performance-based nature of the standard, Roco has taught for years a technique that uses a single retrieval line for multiple entrants as an option to reduce line entanglement hazards during a rescue. The use of this technique was based on testimony given to OSHA prior to the Permit Required Confined Spaces Standard (29CFR 1910.146) being published, and indeed our interpretation of the intent of the standard. The particular technique in question is a common practice for rescuers in which one retrieval line is used and multiple entrant/rescuers are attached at different intervals with butterfly knots to reduce entanglement hazards during a rescue (see example below.)


This pending interpretation would put restraints on techniques used by rescuers when entanglement issues could be a problem. It would result in the management of multiple retrieval lines in the space which could affect the effectiveness of the rescue or result in an increased danger to the entrants and/or rescuers. In effect, this OSHA interpretation could cause an “all or nothing” response regarding the use of retrieval lines for rescuers and entrants. This LOI would eliminate the opportunity of using an external rescue technique for certain situations.

Paragraph (k)(3)  allows entrants to forgo using a retrieval line in certain situations –
“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 technique in question is an option that falls between each individual having an “individual” retrieval line, and having to opt out of using a retrieval line at all, and it allows for external retrieval to still be an option in many cases. And, as most of you know from personal experience, for most confined space portals only one individual can pass through at a time anyway. Even with multiple retrieval lines, it is still a “one at a time” event.  A shared retrieval line allows the same to take place.

It is Roco’s position that the rescue and retrieval techniques used in rescue should be performance based to allow for the ever-changing conditions and problems that are unique to rescue. We also feel this pending LOI could affect the safety and ability of rescuers to adjust to these situations. However, until this issue is clarified, Roco will not teach or use the technique of having multiple rescuers/entrants attached to the same retrieval line in consecutive order using midline knots as their attachment points.
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1910.147 LOTO vs. 1910.146 Isolation

Wednesday, July 06, 2011

Question:  If I close and Lockout/Tagout the main valve on the natural gas line supplying a boiler unit – does this satisfy OSHA’s requirement for eliminating the hazard of a permit required confined space?

Answer:  No, it does not. You are asking a question that we address quite often and it reveals some misconceptions regarding “eliminating” or “isolating” the permit space from hazards. Lockout/Tagout (LOTO) procedures are covered in OSHA’s 1910.147 “Control of Hazardous Energy (Lockout/Tagout).

” Many times this regulation is incorrectly referenced when addressing permit space hazards that are not covered by this regulation.
OSHA’s 1910.147 LOTO regulation applies to the control of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. It does not apply to engulfment hazards (liquid or flowable solids), flammable gasses, or other gasses that may be toxic or oxygen displacing.

It is important to understand this distinction because the use of isolation procedures appropriate for the hazards addressed in 1910.147 may not be effective in eliminating other hazards.  “Isolation,” as defined in the Permit Required Confined Space regulation (1910.146) spells out the various measures required to eliminate hazardous energies as covered in the LOTO regulation as well as the types of hazards that are not addressed in that regulation.  You will note that 1910.146 cites LOTO as a means to isolate all sources of energy (emphasis added), but outlines other methods used to isolate the other hazards such as hazardous materials. These isolation procedures include the process by which a permit space is “removed from service” and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

By closing and placing a LOTO device on a single valve of a natural gas feed line, you may have controlled the hazard but you have not eliminated it. To provide true isolation (elimination), you will have to employ such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; or a double block and bleed system.

Download the LOTO tip sheet from NIOSH.
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How to Haul a Victim in Half the Time: Part 2

Tuesday, June 28, 2011

Well, maybe not half the time, but certainly some fraction of the time.

In How to Haul a Victim in Half the Time: Part 1, we covered ways to reduce the time needed to haul a rescue package by taking advantage of changes of direction.

Here, we want to address OSHA and ANSI guidance regarding retrieval systems – specifically mechanical devices used for rescue.

OSHA 1910.146(k)(3) states “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.

Additionally, OSHA follows the ANSI Z117-1-1989 approach that was in effect at the time of OSHA 1910.146 promulgation, which states, “A mechanical device shall be available to retrieve personnel from vertical type PRCS’s greater than 5 feet in depth.” It also adds, “In general, mechanical lifting devices should have a mechanical advantage adequate to safely rescue personnel.”

Subsequent revisions to ANSI Z117 included the recommendation that “The mechanical device used should be appropriate for rescue service.” The revised standard adds,“Mechanical lifting devices should have a mechanical advantage of at least four to one and the capacity to lift entrants including any attached tools and equipment.”

Two key points that must be considered: (1) OSHA follows the ANSI approach that was in effect at the time 1910.146 was promulgated which did not recommend a minimum mechanical advantage ratio; and, (2) The rule makers intended to leave a degree of latitude for the rescue service to select a lifting device that is most appropriate for the particular situation encountered.

Roco’s rule of thumb is… the mechanical device used should be appropriate for rescue service – and the employer should not use any mechanical device that could injure the entrant during rescue, which would include a mechanical device with too great a mechanical advantage (MA) for the number of people operating the system. Here’s a guideline we use for determining the proper number of rescuers for a particular system – it should take some effort to haul the victim, but not so much effort that it wears the rescuers completely out. And, it should not be too easy, or you won’t as readily feel if the victim gets hung-up.

Because 1910.146 is a performance-based regulation, it does not specify the rescue procedures that are most appropriate for any given PRCS. It leaves this to the responding rescue service based on their assessment of the PRCS in terms of configuration, depth, and anticipated rescue load. Current ANSI Z117 recommends that the MA “should” be at least four to one. Notice that it does not state “shall” and thus the discretion of the rescue service is taken into account. A generic recommendation of a 4:1 is a good start but should not be considered as a catch-all answer to the problem of lifting the load. Even a 4:1 may not be enough if the person doing the hauling is not strong enough and may require a greater M/A in order to remove the load from the space.

Must we always use a minimum MA of 4:1, or could there be justification in using an MA below the 4:1 ratio when there is a need to provide a faster means of hauling the rescue package? Consider the possibility of reducing the mechanical advantage ratio when there is plenty of haul team members. If you have 4 haul team members for a 250 pound rescue package, do you really need that 4:1 MA? Consider going with a 3:1 or even a 2:1, especially if the throw is short and the haul is long. However, keep in mind that the package will be traveling much faster by reducing the MA – so it is imperative that a “hole
watch” be assigned to monitor the rescue package and be ready to call an immediate “STOP” should the package become hung up.

Caution: If you’re using a piggyback system, make sure the haul team does not outpace the individual taking in the mainline slack through a ratchet device. Should a lot of slack build up in the mainline and the haul team lose control of the haul line, the resulting free-fall of the load could spell disaster. Of course we always encourage the use of a safety (belay) line, but on rare occasions the urgency of the rescue may warrant not using a safety line on the victim.

Ultimately it is the employer’s responsibility to evaluate the selected rescue service’s ability to provide prompt and effective rescue. If the rescue service is able to demonstrate their capability using an MA that is less than the current ANSI recommendation, then that would meet the performance-based nature of the standard. In reality, by using a reduced MA, the time required to extricate the rescue package can be cut by 1/3 to 1/2 depending on the situation. In certain emergencies, that saved time could very easily mean the difference between a successful rescue and a body recovery.
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How to Haul a Victim in Half the Time: Part 1

Thursday, May 12, 2011

As anyone who has ever been summoned to an industrial site for a confined space rescue, or has taken the opportunity to practice rescue drills in these facilities knows, sometimes the working area for the rescue team can be a tad cozy.  By “cozy” we mean cramped.  If there is the need for a haul of the rescuers or victim after a lower, these cramped conditions can cause multiple problems.  Consider it a challenge to overcome, and use your rope rescue know-how to come up with an efficient solution that will not only reduce congestion at the working area, but will most likely provide for a much faster haul of the rescue package.

First of all, if the space lends itself to a vertically mounted block and tackle, the problem is greatly reduced.  However, if there is no overhead anchor available and the use of a portable overhead anchor such as a tripod is not feasible then a “lane” for the haul team may be necessary.  At times, even the use of a vertically mounted block and tackle may require a solution to a congested working area.

Sometimes we are confronted with a very short throw between the mechanical advantage anchor point and the edge of the portal.  This may cause multiple resets of the haul system, be it a piggyback system or a Z-Rig.  These short throws with multiple resets will really slow down the progress of hauling the rescue package and can become a significant hazard when the need for rapid retrieval is needed.

If the opportunity presents itself, take advantage of a simple change of direction on the haul system.  At times, a single 90-degree change of direction can convert a short 3-4 foot throw into a throw many times longer.  We see this all the time on catwalks, yet it is often overlooked by our rescue teams when we throw scenario-based training evolutions at them.  Yes, it does require some extra equipment which typically amounts to a single sheave pulley, a carabiner, and a utility strap.  It also adds some frictional losses at that directional pulley, but the advantage gained by extending the throw from 3-4 feet to 20 or more feet, far outweighs the disadvantages of extra equipment, added friction, and time needed to make the change.

If a single change of direction doesn’t quite solve the short throw problem, consider two, or even more changes of direction in order to position the haul team in an area thatthey can “walk the haul” using their leg strength instead of being bunched up and using their arm strength only.  Of course, it gets to a point where too many changes of direction exhausts the equipment cache or creates so much friction that any advantage is lost.

As in any rescue situation, a good cohesive team is a great benefit.  If the situation causes the team to be bunched up on top of each other, remember to scan the area for an opportunity to open things up a bit.  Sometimes that change of direction does wonders for the ability of the team to take full advantage of their strength in numbers, and creates a situation where if needed, speed can be a lifesaver.

About the Author:
Patrick Furr, employed with Roco since 2000, has been actively involved with technical rescue since 1981. Pat is a Chief Instructor/Technical Consultant for Roco and currently resides in Albuquerque, New Mexico. He has also been an On-Site Safety Services Team Leader for Roco at a major semiconductor company in New Mexico for the past ten years. As a Chief Instructor, Pat teaches Confined Space Rescue, Rope Access, Tower Work/ Rescue and Fall Protection programs across North America. Prior to Roco, he served 20 years in the U.S. Air Force as a Pararescueman (PJ). His background includes eight years as a member of the 71st Pararescue team in Anchorage, Alaska, where he specialized in mountain and glacier rescue. Pat was a team leader of the 1986 and 1988 PJ teams that summited Mt. McKinley and augmented the National Park Service mountain rescue team. He also spent two tours of duty in Iceland where he put in multiple “first ascent” ice routes.
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Rescue Plans…What is required?

Tuesday, April 12, 2011

We had a very interesting inquiry regarding OSHA’s requirements for rescue plans and wanted to share it with you.

Reader’s Question: Does OSHA 1910.146 (k)(1)(v) state that a plan must be developed by a rescue service before an entry can be made? Can entries be conducted with the understanding that a rescue service has the competence to rescue someone without seeing the space prior?


Section (k)(1)(v) of the regulation states that the employer shall…“Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.” [Emphasis added]

First of all, it’s important to note that the term “plan” as used in safety-related regulations and standards such as the Permit-Required Confined Space (PRCS) standard, can have a more general meaning than what rescuers typically think of when they refer to “rescue preplans.” When rescuers refer to “rescue preplans,” what usually comes to mind is a very specific, detailed plan for rescue from a particular space.

Although the regulations do not specifically state that a “plan must be developed by a rescue service before an entry can be made,” the regulation assumes that a properly selected (and evaluated) rescue team or service will develop appropriate rescue plans, and requires that rescuers be given access as necessary to develop those plans. OSHA makes it very clear, however, in Non-Mandatory Appendix F, the Preamble to the Final Rule, Summary and Explanation of the Final Rule, and its Compliance Directive on Permit-Required Confined Space, that it interprets the regulation to require rescue plans. [See links below.]

How specific a “rescue plan” must be in order to meet OSHA requirements can be determined by answering this question…“How detailed must the rescue plan be to enable me to safely perform a timely rescue from the permit-required confined space being entered?” Generally speaking, the simpler and more generic the space and the entry, the simpler and less detailed the plan must be. The more complex the space and the hazards, the more specific and detailed the plan must be. And, the more likely the rescue service should see the space and/or a representative space in advance.

As such, the degree and content of the rescue plan should be determined by the rescue service – and it must be provided access to do so. Ultimately, however, it is the employer’s responsibility to perform an adequate evaluation of the prospective rescue service. The viability of the rescue plan should be demonstrated; therefore, proving that the rescue service is staffed, equipped, available, and proficient in performing timely rescue from that particular space (or representative space). The employer must be confident that the rescue service can “Talk the talk, and walk the walk.”

When evaluating the capabilities of a rescue service, Non-Mandatory Appendix F provides guidelines for doing so and specifically references “rescue plans” for the types of spaces involved. It is also important for employers to note that while it is “not mandatory” that the evaluation is performed in exactly the same way; you still have to reach the same result. In other words, it is a non-mandatory means of meeting the mandatory requirements.

Section B (1) of Appendix F asks…
Does the rescue service have a plan for each of the kinds of permit space rescue operations at the facility?

Is the plan adequate for all types of rescue operations that may be needed at the facility?

Note: Teams may practice in representative spaces, or in spaces that are ‘worst-case’ or most restrictive with respect to internal configuration, elevation, and portal size.

Appendix F also offers recommendations for determining whether a space is “truly” representative of an actual space. [See link below.]

You can also refer to Roco’s Confined Space Types Chart (click here to download) which illustrates various confined space types for rescue practice and planning purposes.

In summary, prior to permit required entry operations, the employer must afford the selected rescue service access to the permit spaces they may respond to for the purposes of rescue planning.  The degree and content of the rescue plan should be determined by the rescue service. The rescue service must be prepared and proficient in rescue from the “same type(s) of confined spaces” in terms of configuration, access, and hazards.

IMPORTANT: The information in Roco Rescue Online is provided as a complimentary service for emergency response personnel. It is a general information resource and is not intended as legal advice. Because standards and regulations relating to this topic 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.

ONLINE REFERENCES:


OSHA 1910.146 Appendix F.

OSHA CPL 02-00-100, 5/5/1995, Application of the Permit-Required Confined Spaces (PRCS) Standards, 29 CFR 1910.146  Appendix D, V. Rescue, D. Combinations: 1. a.

OSHA 1910.146 Permit-Required Confined Spaces, Section: 2, II. Summary and Explanation of the Final Rule
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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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