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Using Hazard Controls to Prevent Worker Deaths

Monday, June 15, 2015

Despite progress made over the past several decades in reducing the number of occupational deaths, an average of 12 workers are still killed on the job every day, Mary Vogel, executive director with the National Council for Occupational Safety and Health, said during the press conference.

The National COSH recently reported that broader use of hazard prevention strategies and threats of stiffer consequences for workplace safety violations will help reduce the number of annual worker deaths, a group of safety advocates stated during an April 23 press conference in Longmeadow, MA.

Criminal prosecution of employers for workplace violations is extremely rare. Vogel said that although increasing prosecutions would not eliminate all workplace fatalities, the strategy should be used "when appropriate."


Hazard prevention strategies based on the Hierarchy of Controls are another effective method for ending workplace deaths, according to Peter Dooley, senior consultant with National COSH. During the press conference, Dooley listed several recent workplace fatalities he claims could have been prevented with such strategies.

National COSH also announced the release of its annual report, "Not an Accident: Preventable Deaths, 2015." The report includes case studies of recent worker deaths, prevention strategies and National COSH's policy platform.

It was released in advance of Workers Memorial Day, which will take place April 28. On that day, National COSH plans to release a database detailing the circumstances of 1,500 worker deaths.

Article Source – National Safety Council News Alert (www.nsc.com)

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It's Final-Confined Spaces in Construction-Effective 8/3/15!

Monday, May 04, 2015

The Occupational Safety and Health Administration today issued a final rule to increase protections for construction workers in confined spaces. 

Confined spaces rule (29 CFR 1926 Subpart AA) could protect nearly 800 construction workers a year from serious injuries and reduce life-threatening hazards…Construction protections now match those in manufacturing and general industry. 

Manholes, crawl spaces, tanks and other confined spaces are not intended for continuous occupancy. They are also difficult to exit in an emergency. People working in confined spaces face life-threatening hazards including toxic substances, electrocutions, explosions and asphyxiation.

Last year, two workers were asphyxiated while repairing leaks in a manhole, the second when he went down to save the first – which is not uncommon in cases of asphyxiation in confined spaces.

“In the construction industry, entering confined spaces is often necessary, but fatalities like these don’t have to happen,” said Secretary of Labor Thomas E. Perez. “This new rule will significantly improve the safety of construction workers who enter confined spaces. In fact, we estimate that it will prevent about 780 serious injuries every year.”

The rule will provide construction workers with protections similar to those manufacturing and general industry workers have had for more than two decades, with some differences tailored to the construction industry. These include requirements to ensure that multiple employers share vital safety information and to continuously monitor hazards – a safety option made possible by technological advances after the manufacturing and general industry standards were created.

“This rule will save lives of construction workers,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Unlike most general industry work sites, construction sites are continually evolving, with the number and characteristics of confined spaces changing as work progresses. This rule emphasizes training, continuous work site evaluation and communication requirements to further protect workers’ safety and health.”

On OSHA's website, it also states than an employer whose workers are engaged in both construction and general industry work in confined spaces will meet OSHA requirements [for 1910.146] if that employer meets the requirements of 29 CFR 1926 Subpart AA - Confined Spaces in Construction.

Five (5) key differences in the construction rule, and several areas where OSHA has clarified existing requirements:

  1. More detailed provisions requiring coordinated activities when there are multiple employers at the work site. This will ensure hazards are not introduced into a confined space by workers performing tasks outside the space. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.
  2. Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces.
  3. Requiring continuous atmospheric monitoring whenever possible.
  4. Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a storm upstream from the workers could cause flash flooding. An electronic sensor or observer posted upstream from the work site could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely.
  5. Allowing for the suspension of a permit, instead of cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space. The space must be returned to the entry conditions listed on the permit before re-entry.

OSHA has added provisions to the new rule that clarifies existing requirements in the General Industry standard. These include:

  1. Requiring that employers who direct workers to enter a space without using a complete permit system prevent workers’ exposure to physical hazards through elimination of the hazard or isolation methods such as lockout/tag out.
  2. Requiring that employers who are relying on local emergency services for emergency services arrange for responders to give the employer advance notice if they will be unable to respond for a period of time (because they are responding to another emergency, attending department-wide training, etc.).
  3. Requiring employers to provide training in a language and vocabulary that the worker understands.

Finally, several terms have been added to the definitions for the construction rule, such as "entry employer" to describe the employer who directs workers to enter a space, and "entry rescue", added to clarify the differences in the types of rescue employers can use.

Host Employers, Controlling Contractors, and Entry Supervisors

The rule makes the controlling contractor, rather than the host employer, the primary point of contact for information about permit spaces at the work site. The host employer must provide information it has about permit spaces at the work site to the controlling contractor, who then passes it on to the employers whose employees will enter the spaces (entry employers). Likewise, entry employers must give the controlling contractor information about their entry program and hazards they encounter in the space, and the controlling contractor passes that information on to other entry employers and back to the host. As mentioned above, the controlling contractor is also responsible for making sure employers outside a space know not to create hazards in the space, and that entry employers working in a space at the same time do not create hazards for one another’s workers.

Click for an update on this ruling

Download 29 CFR 1926 Subpart AA Confined Space in Construction Ruling

Source: www.osha.gov

Frequently Asked Questions: https://www.osha.gov/confinedspaces/faq.html

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Roco Chief Chad Roberson Selected for Leadership Training

Friday, May 01, 2015

St. George Fire Department Assistant Fire Chief Chad Roberson has been accepted into the third year of the Fire Service Executive Development Institute, the International Association of Fire Chiefs announced.

Roberson competed with new fire chiefs and chief officers from across the country to become a member of the 2015 program. Roberson also has been awarded a scholarship to cover the expenses for attending the program, a news release from the St. George Fire Department said.

The Fire Service Executive Development Institute is a yearlong leadership development program created and implemented by the IAFC to provide new and aspiring fire chiefs with the tools needed to have successful and productive tenures, the release said.

The institute will meet in May for its first six-day session, in addition to two other sessions six months apart. The group will communicate between sessions using an online community.

Roberson has 27 years of experience and rose through the ranks of the St. George Fire Department.

He holds an associate degree in fire science, a bachelor’s degree in history and a master’s degree. He also has completed the National Fire Academy’s Executive Fire Officer Program and, in 2011, was awarded professional accreditation as a certified fire officer, the release said.

In addition to being assistant fire chief, Roberson serves as the technical rescue coordinator for the department.

He is a member of the International Association of Fire Chiefs and serves on its Emergency Management Committee. In addition, Roberson is an executive board member of the Louisiana Fire Chiefs Association, the Louisiana Fire Chiefs Foundation and the Louisiana Municipal Association. He served for six years as an executive board member of the States Urban Search & Rescue Alliance.

Roberson is married and the father of two elementary school-aged sons. He is a volunteer coach at his sons’ school, St. Jude, and the YMCA. He is also a member of the St. Jude Catholic Church Men’s Club and a member of the St. Jude Church Fair Core Committee.

The Motorola Solutions Foundation has provided the IAFC with a grant to fund the program.

Story from The Advocate

Photo provided by Eldon Ledoux -- The International Association of Fire Chiefs announced that Assistant Fire Chief Chad Roberson, of the St. George Fire Department, has been accepted into the third year of the Fire Service Executive Development Institute.

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WH Completes Review of OSHA's Confined Spaces in Construction

Friday, April 10, 2015

Washington – On April 3, the Office of Information and Regulatory Affairs (OIRA) completed its review of OSHA's Confined Spaces in Construction Standard, paving the way for the final rule to move forward. The rule (29 CFR 1926.36) has been in the works for more than a decade. An OIRA review is one of the last steps a federal agency must take before it can publish a final rule. According to OSHA's timetable, the confined spaces final rule was originally scheduled for publication in March.

In 1993, OSHA issued a general industry rule to protect employees who enter confined spaces while engaged in general industry work (29 CFR 1910.146). This standard has not been extended to cover employees entering confined spaces while engaged in construction work because of unique characteristics of construction work sites. Pursuant to discussions with the United Steel Workers of America that led to a settlement agreement regarding the general industry standard, OSHA agreed to issue a proposed rule to protect construction workers in confined spaces.

Source: Membership News Alert from National Safety Council

UPDATE: Roco is hearing that a final ruling will be released within the next 6 weeks. As soon as the information is provided, we will be sure to post for you!

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RTC Expands to Meet Rescuer Needs

Wednesday, February 18, 2015

Construction is well underway on expansions and improvements to the Roco Training Center (RTC.) The goal is to add new confined space shapes and configurations in order to simulate an even wider variety of scenarios that rescuers may face in the real world. 

An additional two-story container configuration is being erected east of the pipe rack module. This will add 10 vertical confined spaces, 2 horizontal confined spaces, and 7 more student platforms for staging rescue equipment and training evolutions. The new area will be under a covered roof, making rescue training on the prop a bit more user-friendly in our south Louisiana climate!

Nearly complete is the new stairway on the south side of the prop that will provide additional access to the structure and more anchor points for rescue students taking courses at RTC. With these new features, the prop is increasing its student capacity by approximately 33 rescuers per day.

Last year a boiler simulator was added which focuses on extremely tight (12" x 15") horizontal confined spaces found at many industrial settings, old and new.

"Roco is constantly surveying our students to find out what their particular problem spaces are," said Dennis O'Connell, Director of Training for Roco. "We try to duplicate those confined spaces at RTC, so students can practice the skills they will need if a problem occurs at their site. This way, they get a more accurate experience."

The anticipated completion date for the additions to RTC is April 15, 2015. It is sure to add a few more challenges for Roco students who are familiar with the prop, as well as a few more conveniences.

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OSHA's Confined Space Construction Rule Under OMB Review

Tuesday, November 25, 2014

OSHA's final rule on confined spaces in construction is being reviewed by the Office of Information and Regulatory Affairs. The review is one of the final steps required before OSHA can formally publish the rule.

OIRA, which is a branch of the White House's Office of Management and Budget, received the rule for review on Nov. 14. The office is limited to a 90-day review but can request an extension. The rule has been in the works since at least 2003; the proposed rule was published in 2007.

Several provisions in the proposed rule are similar to those found in the agency's confined spaces standard for general industry. That rule, issued in 1993, mandates specific procedures and includes requirements such as a written program, atmospheric monitoring and training.

Stand by for additional updates on this regulation.

News story from the National Safety Council. 

 

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VFD Acquires Rescue Equipment Through Firehouse Subs Foundation

Monday, November 24, 2014

More than $15,000 in fire rescue equipment was donated to a local volunteer fire department in Washington, WV through the Firehouse Subs Foundation.

The equipment for the Washington Bottom department is for confined areas such as off-road, industrial and water-related accidents. And the department's members are already trained to use it.

"It's nice to know we have the people with the knowledge, the skills, and now, the equipment to use the equipment properly," said Fire Chief K.C. Lindner. "We have the folks who have spent the many hours training and perfecting it. Now, we have the equipment to use."

 


Picture above: Roco Student, Ryan Goldsmith demonstrating the rope rescue equipment.

Money for the donations comes from the purchase of Firehouse's used pickle barrels by its customers.

The chain has been providing equipment to first responders for nearly a decade.

Story source: http://www.thenewscenter.tv/news/headlines/Fighting-Fire-With-Firehouse-283402671.html 

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Atmospheric Monitoring Frequency…Update for Roco Students

Friday, November 07, 2014

One of our very attentive students recently noticed a statement in our Study Guide that was incorrectly attributed to OSHA when it is really a Roco Best Practices Guideline. In the Confined Space chapter of our Study Guide, it states that OSHA requires air monitoring “within 30 minutes of the entry,” and this is not an OSHA requirement. The 30-minute timeline is a Roco recommendation for conducting “baseline” pre-testing prior to entry, but it is not an OSHA requirement.

The revised wording is explained below. You may click here to download and print the corrected pages for your Roco Study Guide. If you have any questions or need assistance, please contact the Roco office at 800-647-7626.


 

CONFINED SPACE CHAPTER

(1) ATMOSPHERIC MONITORING:  (Page 13)
ROCO RECOMMENDATION: Although OSHA does not define a specific timeline to conduct pre-entry atmospheric monitoring, we recommend that a “baseline test” be conducted approximately 30 minutes prior to the entry and then another test conducted immediately prior to entry. A comparison of these readings could indicate that atmospheric changes have occurred inside the space. If a space has been vacated for a period of time, it is recommended that similar baseline testing be repeated.

Also, while OSHA allows for periodic monitoring and sets no exact timespan between testing, Roco recommends continuous air monitoring any time workers are in the space. In addition, pre-entry testing as well as periodic testing should be based on the hazard assessment for a given space to include any previous work activities that may have introduced atmospheric hazards as well as any known history of hazardous atmospheric conditions. Another consideration is how rapidly those hazards can change the atmosphere, which may require additional precautions for safe entry.

(2) MONITORING FREQUENCY:  (Page 15)
OSHA does not define a specific timeline for conducting pre-entry atmospheric monitoring or periodic testing. OSHA 1910.146 (c)(5) refers to testing the internal atmosphere before an employee enters the space and testing as necessary to maintain acceptable entry conditions. Testing should be based on the hazard assessment for a given space as well as how rapidly those hazards could cause a change in the atmosphere, which may require additional action for safe entry.

As a safer way, Roco recommends continuous monitoring while employees are inside a permit-required confined space.


Frequently Asked Questions: PRCS Standard Clarification (OSHA.gov)

How much periodic testing is required?


The frequency of testing depends on the nature of the permit space and the results of the initial testing performed under paragraph (c)(5)(ii)(c). The requirement in paragraph (c)(5)(ii)(F) for periodic testing as necessary to ensure the space is maintained within the limits of the acceptable entry conditions is critical. OSHA believes that all permit space atmospheres are dynamic due to variables such as temperature, pressure, physical characteristics of the material posing the atmospheric hazard, variable efficiency of ventilation equipment and air delivery system, etc. The employer will have to determine and document on an individual permit space basis what the frequency of testing will be and under what conditions the verification testing will be done.

 
What does testing or monitoring "as necessary" mean as required by 1910.146(d)(5)(ii) to decide if the acceptable entry conditions are being maintained?

The standard does not have specific frequency rates because of the performance oriented nature of the standard and the unique hazards of each permit space. However, there will always be, to some degree, testing or monitoring during entry operations which is reflective of the atmospheric hazard. The employer must determine the degree and the frequency of testing or monitoring. Some of the factors that affect frequency are:

* Results of test allowing entry.
* The regularity of entry (daily, weekly, or monthly).
* The uniformity of the permit space (the extent to which the configuration, use, and contents vary).
* The documented history of previous monitoring activities.
* Knowledge of the hazards which affect the permit space as well as the historical experience gained from monitoring results of previous entries.

Knowledge and recorded data gained from successive entries (such as ventilation required to maintain acceptable entry conditions) may be used to document changes in the frequency of monitoring.

OSHA 1910.146 REFERENCES

1910.146(c)(5)(ii)(C)
Before an employee enters the space, the internal atmosphere shall be tested, with a calibrated direct-reading instrument, for oxygen content, for flammable gases and vapors, and for potential toxic air contaminants, in that order. Any employee, who enters the space, or that employee's authorized representative, shall be provided an opportunity to observe the pre-entry testing required by this paragraph.

1910.146(c)(5)(ii)(F)
The atmosphere within the space shall be periodically tested as necessary to ensure that the continuous forced air ventilation is preventing the accumulation of a hazardous atmosphere. Any employee, who enters the space, or that employee's authorized representative, shall be provided with an opportunity to observe the periodic testing required by this paragraph.

1910.146(d)(5)(i)
Test conditions in the permit space to determine if acceptable entry conditions exist before entry is authorized to begin, except that, if isolation of the space is infeasible because the space is large or is part of a continuous system (such as a sewer), pre-entry testing shall be performed to the extent feasible before entry is authorized and, if entry is authorized, entry conditions shall be continuously monitored in the areas where authorized entrants are working;

1910.146(d)(5)(ii)
Test or monitor the permit space as necessary to determine if acceptable entry conditions are being maintained during the course of entry operations;

 

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Rescue Challenge 2014 - Huge Success!

Friday, October 10, 2014

Congrats to the 7 excellent teams who participated in 2014 Roco Rescue Challenge this week. There was plenty of learning, and lots of doing, and these guys and gals represent some of the finest industrial rescuers in America.

Thanks to all who made this year's event a success, and to the hard working emergency responders who dedicate their lives to saving others!



Rescue Challenge 2014 Video


Visit Roco Rescue's Facebook for a full photo gallery of Challenge 2014!

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