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Combustible Dust and Confined Spaces

Monday, January 05, 2015

In January 2004, an explosion at the West Pharmaceutical Company in Kingston, NC killed 6 workers and injured 34 others. Two firefighters were injured during the response to the incident.  One month later, an explosion and fire occurred at the CTA Acoustics manufacturing facility in Corbin, KY, killing 7 workers. In February 2008, an explosion at the Imperial Sugar Company facility in Wentworth, GA, killed 13 workers and injured 42 others. Three very different types of facilities with very different products, but with one thing in common—dust!

"A 'safe’ area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations."

The Chemical Safety Board reported that there were 281 explosions of combustible dust in the United States between 1980 and 2005. These explosions resulted in 199 deaths and 718 injuries. And these are just the actual explosions. There are countless more combustible dust environments just waiting for the right (or wrong) conditions to align to become the next fatal explosion. The fact is that with the exception of silicon or sand, every kind of dust is potentially combustible to some degree.

Combustible dusts are measured on a “deflagration index,” (see box) which measures the relative explosion severity compared to other dusts. They range from such seemingly innocuous items such as dust from powdered milk and egg whites that can create “weak explosions,” to dusts from items such as magnesium and aluminum that can result in “very strong explosions.” But I think we can all agree that no explosion, even a “weak” explosion, is a good explosion—especially if it occurs during rescue operations. 

As rescuers, you should already be familiar with the “fire triangle.” To understand the danger of combustible dusts, you should also be familiar with the “dust explosion pentagon.” The dust explosion pentagon consists of the following:

-       Combustible Dust (Fuel)

-       Ignition Source

-       Oxygen

-       Dispersion of dust (suspension)

-       Containment of the dust in a confined or semi-confined area (Enclosures/Building/Confined Space)

Rescuers should be on the lookout for any appreciable accumulation of dust when sizing up a rescue situation. Keep in mind that your atmospheric monitor containing a sensor for combustible gases is not effective for detecting a hazard from combustible dust.  

Always remain aware that in a suspended state, dust becomes explosive. Dust explosions occur when combustible dust is present, forms a dust cloud in an enclosed environment, and is exposed to oxygen and an ignition source. The explosion occurs as a result of the rapid burning of the dust cloud, which creates a rapid pressure rise in the enclosed area or confined space. 

A dust pile that may burn while an ignition source is being applied, then go out immediately or shortly after the ignition source is removed, can become lethally explosive when scattered and suspended in the air. 

Always consider the potential for combustible dust in any rescue situation, particularly when ventilation of an enclosure, building, or confined space is considered. A “safe” area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations.

This article was written by Robert Aguiluz, who is currently an Administrative Law Judge for the State of Louisiana. He is also an attorney who specializes in Occupational Safety and Health Law, and regulatory and compliance issues. He is a former Certified Safety Professional and Roco Rescue Instructor with over twenty years’ experience in both industrial and municipal emergency response and rescue.
 

Combustible Dust Considerations for Emergency Responders:

1.  Know your response area and the types of industry that may have the potential for combustible dust. If you are performing standby rescue duties, meet with the SH&E management team to learn about any combustible dust hazards at their facility.

2.  Become familiar with the “deflagration index” for various types of materials. See sample Chart below.

Examples of Kst Values for Different Types of Dust

 

3.  Consider the effect of ventilating a space that has accumulations of combustible dust.

        •  Will you cause the dust to become suspended?
        •  Will the suspended moving dust create a static charge/discharge and become a source of ignition?
        •  Can your ventilation equipment become a source of ignition?

4.  Is there information to review on the SDS (Safety Data Sheet) regarding the material’s potential to become combustible dust?


HELPFUL LINKS:

OSHA Quick Card: Prevent Dust Explosions

“Firefighting Precautions at Facilities with Combustible Dust”

“Hazardous Communication Guidance for Combustible Dust”

“Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions”

“NFPA 654: Standard for the Prevention of Fire and Dust Explosions”

 



















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Tips for Using Roco’s Confined Space Types Chart

Thursday, December 11, 2014

Is your rescue team (or service) truly capable of rescuing workers from the various types of confined spaces on your site?

What about rescue services for the contractor who’s working on your site with personnel entering permit spaces?

As a rescue team, have you considered all the angles in preparing for confined space rescue?

Refineries, plants and manufacturing facilities have a wide range of confined spaces – some having only a few, where others may have hundreds. In OSHA’s 1910.146, a big consideration is allowing rescue teams the opportunity to practice and plan for the various types of confined spaces they may be required to respond for rescue.

Obviously, it would be impossible to practice in each and every one of the spaces – from a time standpoint as well as most times the spaces are operating and functioning units within the plant. That’s why section (k) of 1910.146 also allows practice from “representative” spaces.

Using OSHA’s guidelines for determining representative spaces, Roco’s Confined Space Types Chart was developed to assist rescue teams in planning and preparing for the various types of spaces in their response area. Our CS Types Chart allows you to categorize permit spaces into one of six types – which can be used to prepare rescue plans, determine rescue requirements and practice drills or evaluate a prospective rescue service.

While there may be hundreds of permit spaces on site, many of them will fit into one of these six types and require the same (or similar) rescue plan. Of course, there are always unique situations in addition to physical characteristics, such as space-specific hazards or specialized PPE requirements, but we feel this chart is a valuable tool that can be used for critical planning and preparation for confined space rescue operations.

Over the decades here at Roco, we have seen just about every type of confined space configuration there is. We’ve also learned that it is imperative to understand the physical limitations of the space access and internal configuration and how this affects the choice of equipment and techniques in order to provide a viable, safe rescue capability.

During an emergency is NOT the time to learn that your backboard or litter will not fit through the portal once the patient is packaged. By referring to the Types Chart and practicing simulated rescues from the relevant types of spaces will help identify these limitations in a controlled setting instead of during the heat of an emergency.

Here’s an example


Most backboards are 16 to 20-inches wide. With an 18-inch round portal, the backboard will only fit through the “widest” part (or diameter) of the opening. In effect, this cuts the size of the opening in half (see illustration). If the thickness of the backboard is approximately 1-inch, then you only have about 7 or 8-inches of space remaining to clear the patient. This is one example where all the rescue equipment components may fit into the space but cannot be removed once the patient is packaged.

 


On the Roco Types Chart, you will note that there are six (6) general types identified, which are based on portal opening size and position of portal. For example, Types 1 and 2 are “side entries”; Types 3 and 4 are “top entries”; and Types 5 and 6 are “bottom entries.” There are two types of each due to portal size as discussed above. Openings greater than 24-inches will allow packaged patients on rigid litters or rescuers using SCBA to negotiate the opening. Spaces less than 24-inches will require a higher level of expertise and different packaging and patient movement techniques.
Confined Space Portal Types defined by OSHA

Because OSHA 1910.146 requires employers to allow access for rescue planning and practice purposes, here’s an opportunity to be better prepared and practiced on thetypes of spaces in the response area. So, get out your clipboard, tape measure, some sketch paper, and a flashlight (if safe to do so) in order to view as much of the interior of the space as you can. Gaining access to architectural or engineering drawings may also be helpful in determining the internal configuration of the space for the times that actual entry is not feasible. Armed with this information, it is time to “type” the spaces in your response area using the Roco CS Types Chart.

Once this is completed, pay particular attention to spaces that have been identified as Types 1, 3, or 5. These spaces have restrictive portals (24-inches or less) and are considered “worst case” regarding entry and escape in terms of portal size. As mentioned, this is very important because it will greatly influence the types of patient packaging equipment and rescuer PPE that can be used in the space.

Another critical consideration is accessibility to the space – or “elevation” of the portal. While the rescue service may practice rescues from Top, Side and Bottom portals – if it’s from ground level, that’s very different from a portal that’s at a 100-ft elevation. Here’s where high angle or elevated rescue techniques normally are required for getting the patient lowered to ground level. This is important! Rescue practice from a representative space needs to be a “true” representation of the kind of rescue that may be required in an emergency.

In Appendix F, OSHA offers guidelines for determining Representative Spaces for Rescue Practice. OSHA adds that “teams may practice in representative spaces that are ‘worst case’ or most restrictive with respect to internal configuration, elevation, and portal size.” These characteristics, according to OSHA, should be considered when deciding whether a space is truly representative of an actual permit space.

Roco Note: Practice in portals that are greater than 24-inches is also important so that rescuers can practice using all proper patient packaging protocols that may be allowed with larger size openings.

(1) Internal Configuration – If the interior of the space is congested with utilities or other structural components that may hinder movement or the ability to efficiently package a patient, it must be addressed in training. For example, will the use of entrant rescuer retrieval lines be feasible? After one or two 90 degree turns around corners or around structural members, the ability to provide external retrieval of the entrant rescuer is probably forfeited. For vertical rescue, if there are offset platforms or passageways, there may be a need for directional pulleys or intermediate haul systems that are operated inside the space.

What about rescues while on emergency breathing air? If the internal configuration is so congested that the time required to complete patient packaging exceeds the duration of a backpack SCBA, then the team should consider using SAR. Will the internal configuration hinder or prevent visual monitoring and communications with the entrant rescuers? If so, it may be advisable to use an “internal hole watch” to provide a communication link between the entrant rescuers and personnel outside the space.

What if the internal configuration is such that complete patient packaging is not possible inside the space? This may dictate a “load and go” type rescue that provides minimal patient packaging while providing as much stabilization as feasible through the use of extrication-type short spine boards as an example.

(2) Elevation – If the portal is 4 feet or greater above grade, the rescue team must be capable of providing an effective and safe high angle lower of the victim; and, if needed, an attendant rescuer. This may require additional training and equipment. For these situations, it is important to identify high-point anchors that may be suitable for use, or plan for portable high-point anchors, such as a “knuckle lift” or some other device.

(3) Portal Size – The magic number is 24 inches or less* in diameter for round portals or in the smallest dimension for non-round portals. It is a common mistake for a rescue team to “test drive” their 22-to-23-inch wide litter or backboard on a 24-inch portal without a victim loaded and discover that it just barely fits. The problem arises when a victim is loaded into the litter. The only way the litter or backboard will fit is at the “equator” of the round portal. This will most likely not leave enough room between the rigid litter or backboard and the victim’s chest, except for our more petite victims.

And, it’s already difficult to negotiate a portal while wearing a backpack SCBA. For portals of 24 inches or less, it is nearly impossible. DO NOT under any circumstances remove your backpack SCBA in order gain access to a confined space through a restricted portal or passageway. If the backpack SCBA will not fit, it is time to consider an airline respirator and emergency escape harness/bottle instead.

By using the Roco Types Chart in preplanning these “worst case” portals and the spaces that fall into the type 1, 3, or 5 categories, the rescue team will be able to determine in advance that different equipment or techniques may be required in order to effect rescue through these type portals.

*ROCO NOTE: In Appendix F, OSHA uses “less than 24-inches” in Section B (#8); however, in (3) Portal Size (a) Restricted, it uses “24-inches or less,” which we are using in our Types Chart.

(4) Space Access – Horizontal vs. Vertical? Most rescuers regard horizontal retrievals as easier than vertical. This is not always the case. If there are floor projections, pipe work or other utilities, or just a grated floor surface, it may create an incredible amount of friction or an absolute impediment to the horizontal movement of an inert victim. In this case, the entrant rescuers may have to rely on old-fashioned arm and leg strength to maneuver the victim. Once the victim is moved to the portal, it may become an incredibly difficult task to lift a harnessed victim up and over the lower edge of the portal. Even if the portal is as little as three feet above the level of the victim, it is very difficult to lift a victim’s dead weight up and over the portal lower edge. Sometimes using a long backboard as an internal ramp may do the trick. For vertical access, there may be a need for additional training or equipment to provide the lifting or lowering capability for both the victim and the entrant rescuer.

Appropriate rescue pre-plans and realistic rescue practice can be one of the best ways to be prepared for confined space rescues – and allow rescuers to operate more safely and effectively in an emergency situation. Roco CS Types Chart can be used as a quick reference when doing an initial assessment of confined spaces and permit-required confined spaces. It helps in designing rescue training and practice drills that will truly prepare rescuers for the particular spaces on site. The information can also be used when conducting performance evaluations for your team, a contracted stand-by rescue service, a local off-site response team, or a contractor who supplies their own rescue services while working in your plant.

In section (k), OSHA requires employers to evaluate the prospective rescue service to determine proficiency in terms of rescue-related tasks and proper equipment. If you are relying on a contracted rescue service or if an on-site contractor is providing their own rescue capabilities, we encourage you to have them perform a simulated rescue from a representative type space. Otherwise, if an incident occurs and the “rescuers” you are depending on are not capable of safely performing a rescue, your company could be culpable.
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Confined Space Attendants Play a Crucial Role

Tuesday, July 08, 2014

The following article was featured in the July 2014 issue of ISHN, and authored by Roco's own Chief Instructor Pat Furr.

Have you ever wondered who that person is who hovers around the portal of a permit space while workers are in the space? What does a Confined Space Attendant (often referred to as the “Hole Watch”) do anyway? What may seem like a cushy job is actually a critical safety responsibility. Here’s why:

First, OSHA instituted regulations regarding Permit-Required Confined Spaces (1910.146) due to the high number of serious injuries and deaths in confined spaces. Entering these spaces is dangerous business, and the attendant serves as the “safety watchman” for entrants as well as those who may casually try to enter. This also applies in an emergency situation when others may be tempted (but unqualified) to enter the space to rescue a co-worker.

OSHA requires that the attendant be able to safely and effectively perform the duties required in Section (i) of 1910.146. (See “Duties of the Confined Space Attendant”) Once a permit is issued and work begins, the attendant needs to be aware of his or her surroundings and be diligent in monitoring the space and entrants at all times. This individual is not there to be a “gofer” for workers inside the space.

Get real

If entrants need assistance or an emergency situation develops inside (or outside) the space that requires entrants to be evacuated, the attendant is the “vital link”. Unfortunately, it is common practice to fill the Hole Watch position with the least experienced or greenest person on the crew. Many times, this person has no idea what is expected of them. They also may not be aware of potential hazards inside the space or hazards that may be introduced as work is performed. Often, these individuals are not experienced in industrial environments and are not properly trained in the OSHA-required duties. And, in most cases, they don’t realize how critical their duties could become in an emergency when split-second decisions are required.

Train your attendants

It is unrealistic to expect a new employee to perform these duties without receiving appropriate training and being granted the authority to take action as needed. In 1910.146(d)(8), OSHA is specific in its requirements for the various roles involved in conducting safe permit entry operations. Employers are required to provide adequate training and ensure that personnel are capable of performing their duties. At minimum, the regulation requires employers to ensure that each Hole Watch/Attendant knows and understands the following safety precautions:

(1) Hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure to those hazards;

(2) Possible behavioral effects of hazard exposure for the authorized entrants.

Additional duties and responsibilities include:

(1) Continuously maintaining an accurate count of entrants in the permit space.

(2) Performing non-entry rescues as specified by the employer’s rescue procedure.

One of the most critical duties of the attendant is to be able to effectively communicate with entrants and take appropriate actions in an emergency. Communications are required to monitor the status of the entrants and to ensure that there are no signs of exposure to hazards. The attendant must recognize this need and be able to order evacuation of the space. Most importantly, the confined space attendant can perform NO duties that might interfere with their primary duty to monitor and protect the entrants.

Prevent fatalities

Employers must ask themselves, “Will the person designated as the “Hole Watch” be able to react in an effective manner when the pressure is on? Will they be able to initiate a non-entry rescue in an emergency situation?” Again, we witness too many instances where the “Hole Watch” has little or no knowledge of the responsibilities assigned, while some have had virtually no training whatsoever. Sometimes it seems they are there for no other reason than to fill a square to meet an OSHA requirement.

Many times the lack of understanding regarding confined space hazards, combined with the lack of a clear understanding of emergency actions to be taken (as well as actions to avoid) can lead to confined space fatalities, both for the entrants as well as the attendant.

We urge employers to take a serious look at the selection and training of confined space attendants. These individuals must be capable, responsible and properly trained as spelled out in the OSHA standard. When things go wrong in a confined space, the actions (or inaction) of the attendant can be the difference between life and death for the entrants. They must have the knowledge, the tools and the experience to function as an effective, and ultimately safe, “Hole Watch.”


About the Author: Pat Furr is a chief instructor and technical consultant for Roco Rescue, Inc. Pat teaches a wide variety of technical rescue classes including Confined Space Rescue, Rope Access, Tower Work/Rescue, Fall Protection, and Suspended Worker Rescue. He is also involved in research and development, writing articles and presenting at national conferences. He is a member of the NFPA 1006 Technical Rescuer Professional Qualifications Standard.

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Ready, Set, Go to Challenge!

Friday, May 23, 2014

Don't Miss the Rescue Team Event of the Year!

2014 Roco Rescue Challenge
October 8-9, 2014 
RTC - Roco Training Center

Rescue teams from across the country will participate in realistic confined space rescue exercises designed by Roco’s top instructors. And, although Challenge is more of a learning event than a competition, trophies will be awarded to the teams with top scores for individual skills proficiency and the infamous “Yellow Brick Road” rescue-relay scenario.

Roco Rescue Challenge meets the annual rescue practice requirements of 1910.146 while providing realistic practice drills in all six confined space types. Written documentation will be provided to each team following the event.

All rescue teams are welcome and observer registration is available.This two-day event definitely puts industrial rescue teams to the test! The event is limited to six (6) teams only, so reserve space NOW!

To register your team, join us as an observer, or receive more information CALL 800-647-7626.

CHECK OUT THE 2013 Roco Rescue Challenge Video

Benefits
- Learn from participating in realistic rescue scenarios.
- Gain confidence in your skills and teamwork abilities.
- Enjoy excellent training while interacting with rescue pros.

- Share ideas, experiences, and techniques with teams from across the nation.

OSHA Compliance
- Document your team’s confined space response capabilities.
- Meet annual practice requirements in varying confined spaces types.
- Confirm individual skills proficiency. 

This photo gallery has no pictures.

Download Challenge Site Sheet 2014 

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Confined Space Rescue: Non-entry or Entry Rescue?

Monday, April 14, 2014

The following article was featured on the cover of the March 2014 issue of ISHN, and authored by Roco's own Chief Instructor Pat Furr.

It’s a Saturday night December 21st and the plant is running on a skeleton crew. Operations wants to get a head start on annual preventative maintenance and decides to knock out several permit required confined space entries before the majority of the work is to be done when the regular shifts return after the New Year. Randy has just finished the third of five vessels that are identical in configuration. His authorized attendant and good friend Hector have been working together for over 15 years and they both know the drill. They have changed out the stainless steel bolt sets on the agitator blades of these vessels every year at about this same time. The entry supervisor just closed out the permit for the third vessel and after reviewing the permit for the fourth vessel and helping with the pre-entry atmospheric monitoring; he signs the permit authorizing entry.

Hector checks Randy’s harness and the attachment of the non-entry rescue retrieval cable to his dorsal D-ring, and double checks the davit arm and the mounting point of the self-retracting lifeline with the built in retrieval winch. As Randy climbs 25 feet down the rope ladder to access the bottom of the vessel, all is going according to plan. As he steps off the ladder and begins to loosen the first bolt set, he slips on the concave floor of the stainless steel vessel. Before he can react, he strikes his head on the agitator blade which causes a 5 inch gash to his left temple and knocks him unconscious. He falls between two of the agitator blades and then slides to the bottom of the vessel with his retrieval line wrapped over one of the blades and under another. Hector tries to winch his friend out of the space only to find that Randy’s limp body gets wedged under the agitator blade. You can probably guess what happened next.

Realizing there is no entry rescue capability on this shift; Hector’s gut reaction is to enter the space to help his friend. In his rush, he slips from the rope ladder and falls 20 feet to his death. When the entry supervisor arrives 30 minutes later to close the permit and initiate the last entry, he sees two bodies at the bottom of the space.

Understand OSHA rescue requirements  

Are there permit required confined spaces at your worksite? Are employees allowed to enter these spaces? If you answered yes to these two questions, it is critically important to understand the OSHA requirements for rescue. As part of a written permit space program, the employer must “Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue”.

When considering what methods should be used for rescuing authorized entrants, the safety of the rescuer(s) should be considered as important as the effectiveness of the rescue technique. If it is possible to perform non-entry rescue of the entrant(s), that should always be the first choice. It’s always a given – keep additional personnel (even rescuers) out of the space unless absolutely necessary. It is important to consider potential scenarios that could arise when determining if non-entry (or retrieval) rescue is sufficient.

Non-entry rescue

What are the requirements for non-entry rescue? OSHA 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.”

Let’s examine this further. What conditions would preclude the use of non-entry retrieval systems? Here are some guidelines that OSHA will use to make this determination:

• A permit space with obstructions or turns that prevent pull on the retrieval line from being transmitted to the entrant does not require the use of a retrieval system.
• A permit space from which an employee being rescued with the retrieval system would be injured because of forceful contact with projections in the space does not require the use of a retrieval system.
• A permit space that was entered by an entrant using an air supplied respirator does not require the use of a retrieval system if the retrieval line could not be controlled so as to prevent entanglement hazards with the air line.


Assess the space

The ONLY way to determine if a non-entry retrieval system will provide adequate safety for entrants and satisfy OSHA’s requirement is to perform an honest and thorough assessment. This assessment should provide careful consideration for the capabilities and limitations of the retrieval system for any planned or unplanned condition that may arise during entry. We have all heard of “Murphy’s Law” and most of us have experienced the effects of that particular law. I encourage you to remember that Murphy is always lurking close by.

So when evaluating these spaces to determine if non-entry or entry rescue is the appropriate choice, always ask yourself “what if?” For the fictitious accident that opened this article, the plan was to do all the work on the near side of the agitator blade directly below the top portal. In that case, it would have been safe to assume non-entry retrieval was the only plan needed for rescue. Enter Murphy…… Was the rescue plan developed with the assumption that the planned work activities would always ensure the successful use of the retrieval system, but failed to consider the “what ifs”? Some might say that we can “what if” things to death. Let’s turn that around; we SHOULD “what if” these questions in an effort to PREVENT death.

When evaluating permit spaces to determine the appropriate rescue capability, please explore those “what ifs”. This is not to say that in the case cited above that the only option would have been entry rescue. That may not be necessary and if the non-entry retrieval system would have worked, then there is no need to expose rescuers to the hazards of entering the permit space. But there was a potential for the condition to change, and it sure did. So recognizing that potential, an entry rescue capability should have been planned in the event that the change in conditions rendered the non-entry rescue system ineffective.

Backup plan

The point of this article is to consider non-entry rescue as the default for assisted permit space rescue unless the conditions cited by OSHA are present. At that point, entry rescue must be planned. But this isn’t necessarily a one or the other choice. As we can see from this story, it is sometimes best to plan for non-entry rescue as the primary technique, but if there is any reasonable potential for an unplanned change in conditions, then an entry rescue capability must be in place as a back-up.


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 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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