Reported by Jim Breen, Roco Rescue Director of Operations
On July 30 and 31, OSHA held an Emergency Response and Preparedness Stakeholders meeting in Washington, DC for the purpose of discussing the merits and potential content of an emergency response and preparedness standard.
Meeting participants were from a broad range of both public and private industry experts to include two Roco representatives, Jim Breen, Director of Operations, and Dennis O’Connell, Director of Training. Also participating were representatives from NFPA, IAFF, IAFC, USFA, Louisiana Fire Chiefs Association, Phillips 66, BASF Corporation, Chevron Pipeline Company, Chicago Fire Department, and the American Red Cross to name a few.
The discussion allowed participants to highlight their experiences, voice concerns, and provide input to OSHA administrators who are tasked to make a need and content recommendations to OSHA's senior leadership.
The meeting consisted of four main topics:
1. Which phases of an emergency incident should be included in a standard?
2. Should the standard be inclusive of all incident types or should it be focused on those types of incidents that have resulted in a line-of-duty deaths (LODDs)?
3. What content should be included in the standard?
4. How can OSHA construct a standard that is practical, relevant, and flexible enough to cover all organizations, regardless of size and complexity?
OSHA was particularly mindful of having participants identifying issues that would impede the practical application of an emergency response and preparedness standard. OSHA administrators were very receptive of the views of the participants and stressed that they were not interested in writing a tactical or tactics standard. Although OSHA did not elaborate on any specific course of direction, it is our impression and hope that OSHA will begin drafting an emergency response and preparedness standard that is performance based, with a strong strategic focus, that emphasizes a recognized incident management system, outlines preparation activities inclusive of pre-incident planning, and is structured around the basic functions of command that will apply to all emergency response organizations that are subject to OSHA oversight.
Emergency response is one of the most hazardous occupations in America. Emergency responders include firefighters, emergency medical service personnel, hazardous material employees, and technical rescue specialists. Also, law enforcement officers usually are considered emergency responders because they often assist in emergency response incidents.
Source: OSHA.gov and NFPA/FEMA 2012 Reports on Firefighter Fatalities
Background Information from OSHA.gov:
OSHA notes that there are no standards issued by the Agency that specifically address occupational hazards uniquely related to law enforcement activities. Many emergency responders have cross training in these specialties, and may serve in multiple roles depending upon the type of emergency incident involved. Skilled support employees are not emergency responders, but nonetheless have specialized training that can be important to the safe and successful resolution of an emergency incident.
OSHA issued a Request for Information in September 2007 that solicited comments from the public to evaluate what action, if any, the Agency should take to further address emergency response and preparedness. Recent events, such as the 2013 tragedy in West, Texas, that killed several emergency responders, and an analysis of information provided make it clear that emergency responder health and safety continues to be an area of ongoing concern. For this reason, OSHA conducted the stakeholder meetings to gather additional information.
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 VideoBenefits
- Share ideas, experiences, and techniques with teams from across the nation.
- Document your team’s confined space response capabilities.
- Meet annual practice requirements in varying confined spaces types.
- Confirm individual skills proficiency.
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Imagine donning a Class III harness in as little as 8 seconds!
That’s just one of the many features of the new CMC/Roco Work-Rescue Harness.
Because of its innovative “no-step” donning, comfort fit and lightweight design, this new harness will appeal to rescuers, rope access technicians, tower climbers, and other professionals working in the vertical environment.
Our design team (aka Roco instructors) joined up with CMC’s engineering and fabrication team to create this new Class III harness with a “no-step-through” design. The harness literally wraps around your body as you don it. After the initial webbing adjustment, it is then fitted to the user with no need to re-adjust the various straps when you re-don the harness. This unique feature allows a user to don the harness and be ready to go in as little as 8 seconds. Compare this to donning a standard Class III where the user has to step through the waist and leg loops, then tighten the buckles and stow the straps. Not to mention when a “dreaded half twist” is discovered in one of the straps requiring the wearer to start all over again.
The CMC/Roco Work-Rescue Harness features comfortable wear especially while suspended. The lightweight proprietary CMC alloy D-Rings reduce the overall weight of the harness, while the addition of a rated attachment point at the back of the waist belt allows for a convenient connection to a fall restraint lanyard.
The harness has many advantages for work-at-height professionals. For rope access technicians, the top of the A-Frame lift is designed to accept a variety of connectors for anchoring chest ascenders. It also includes a closed loop on the chest H-Frame to mount a chest ascender adjustable tow strap.
Tower climbers will benefit from the vertical orientation of the sternal D-Ring, which eliminates binding of ladder safety system cable grabs during down climbs. The sternal D-Ring has a quick release stowage strap that keeps the ring tucked neatly against the chest when not in use.
The harness features ergonomic curves and pre-formed moldings for user comfort and durability while maintaining a modern look. It also incorporates breathable padding on the interior surfaces to reduce heat retention. The dorsal and shoulder pads are a one-piece design created by a vacuum molding process, making it comfortable without sacrificing form for ease of donning.
The Fall Arrest Indicator is another great safety feature available on this harness. The visual on the tag alerts the user if the harness has had a previous fall.
"Creating a harness that is easier and quicker to don provides a great advantage for rope professionals. The new CMC/Roco Work-Rescue Harness literally wraps around the user's body…once donned and adjusted, it’s then ‘custom fit’ to your body,” according to Chief Instructor Pat Furr, who led Roco’s design team.
For more information on the CMC/Roco Work-Rescue Harness, or to place your order now, click here.
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.
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.
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.
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.
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).