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What does ASTM say about Rope Inspection?

Monday, June 06, 2011

ASTM F1740 provides very comprehensive guidelines for users of rescue rope.  The title “Standard Guide for Inspection of Nylon, Polyester, or Nylon/Polyester Blend, or Both Kernmantle Rope” indicates it is specifically intended to guide the user in the inspection of these rescue ropes, and is not intended to be a guide in the selection and use of rescue ropes.

However, the information included in F1740 is not to be considered the only criteria for evaluating the serviceability of rescue rope.

One of the first considerations the user needs to address is the selection of an experienced individual who is deemed qualified to perform and document the rope inspections.

While F1740 does provide excellent guidelines, the user and/or the Authority Having Jurisdiction (AHJ) may feel it necessary to augment the information in F1740 with additional training.

Fortunately, our friends at PMI Rope have produced a very comprehensive webinar on Rope Care which includes specific information on  rope inspections. This 61 minute webinar is presented by Mr. Steve Hudson, president of PMI Rope. Steve has an unsurpassed background and knowledge base regarding the manufacture and use of rescue rope and his presentation should more than satisfy your need to augment F1740.

Click here for a link to PMI’s webinars. Use the scroll down on the left and select the 3/2/10 presentation titled “Rope Care.” The information that addresses rope inspection begins at the 24:30 time mark of the presentation.

RocoRescue.com offers PMI rescue rope for rescue professionals. Please contact Roco at 800-647-7626 if you have any further questions.
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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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How often should I replace my rescue harness?

Tuesday, March 15, 2011

We get many calls asking about the “life expectancy” of rope, harnesses and other nylon products. Of course, there are many factors involved and no one “set in stone” answer, but a lot depends on how much you use your harness and the ways you use it. Even where you store your gear is a factor. 

For example, for emergency responders working in industrial environments, atmospheric exposures may be a key consideration for nylon products even while in storage. Another consideration is “when” the harness or rope was made… manufacturing parameters change as technology improves and you may just want a product that’s been tested to the latest standards. However, as with all of your rescue equipment, it’s important to account for its use as well as to follow the manufacturer’s instructions.


Never take chances when there’s any doubt about the serviceability of a life safety product. For more details on the service life of nylon products, our harness manufacturer, CMC Rescue, has provided the following information:

The service life of a rescue harness is closely related to the life of a rescue rope – both are used in the same environments, both are made from nylon or polyester, and both receive similar levels of inspection and care. Since harnesses are worn on the body, they are generally better protected than the ropes. On the other hand, harnesses rely on the stitching to hold them together, and due to its small diameter, the thread can be more susceptible to abrasion, aging, and chemical damage than web or rope.

The fall protection industry recommends 2 to 3 years as a service life for a harness or belt in use. They recommend 7 years for the shelf life. The military was using 7 years as a service life for nylon products. The Climbing Sports Group of the Outdoor Recreation Coalition of America says that a climbing harness should last about two years under normal weekend use. At this time, the rescue industry does not have a recommended service life for harnesses.

Through the ASTM consensus standards process, the rescue industry set 10 years as the maximum service life for a life safety rope, see ASTM Standard F1740-02 Guide for Inspection of Nylon, Polyester, or Nylon/Polyester Blend, or both Kernmantle Rope. The guide stresses that the most significant contributing factor to the service life of a rope is the history of use. A rope that is shock loaded or otherwise damaged should be retired immediately. Hard use would call for a shorter service life than would be acceptable for a rope that sees very little use.

If we apply the same analysis to the rescue harness, then the actual use and the conclusions drawn from inspection would be the significant criteria for retirement. We do know that with any use, a rope will age, and thus a harness is likely to do the same, so a 10-year maximum service life may well be appropriate for harnesses as well assuming inspection has not provided any reason for early retirement.

As with ropes, if the harness has been subjected to shock loads, fall loads, or abuse other than normal use, the harness should be removed from service. If there is any doubt about the serviceability of the harness for any reason, it should be removed from service.
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What does it mean when my atmospheric monitor gives negative or minus readings?

Thursday, December 02, 2010

At some point, most atmospheric monitors will display a “negative” or minus reading for a flammable gas or toxic contaminant. First of all, it is not actually possible for an atmosphere to contain a “negative amount” of a substance. These negative readings usually result from improper use of the monitor.

Most monitors will “Field Zero” or “Fresh Air Calibrate” its sensors when powered on. Because of this, it is very important to power on the unit in a clean, fresh air environment away from confined spaces, running equipment or other possible contaminants. Otherwise, the monitor may falsely calibrate based on the contaminant that is present.For example, a monitor that is powered on in an atmosphere that contains 10 ppm of a contaminant and then moved to fresh air may display a reading of minus 10 ppm. Even more troublesome, if that same monitor is then brought to a confined space that actually contains 25 ppm of the contaminant, it may display a reading of only 15 ppm. As you can see, this could easily lead to the improper selection of PPE for the entrant and result in a confined space emergency.

As always, it is very important to consult with the manufacturer of your particular atmospheric monitor in order to determine how to use it properly. Don’t take any chances with this critical part of preparing for confined space entry or rescue operations.
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Is there a regulation requiring rescuers to use respiratory protection that is “one level higher” than that required for the entrants?

Thursday, November 18, 2010

To our knowledge, there is no regulatory requirement. However, we’ve heard this before and have used it as well when stressing the importance of proper PPE for rescuers, particularly when IDLH atmospheres may be involved. Here’s our thinking… if the entrant’s PPE did not provide adequate protection and he or she is now requiring rescue assistance, then using their “same level of protection” isn’t going to protect you either!

What triggers the use of a greater level of protection? This comes from the rescuer’s assessment of the hazards – including the use of an independent atmospheric monitor from that used by the entrant(s). That’s why it’s so important for the rescue team to provide their own atmospheric monitoring equipment. It also illustrates why written rescue preplans are so important – you need to preplan what equipment and techniques will be required well in advance of an emergency. It’s critical; the PPE selected must be adequate to protect the rescuers.

When preparing rescue preplans, you must also take into consideration any unusual hazards or circumstances that may arise from any work being done inside or near the space. For example, special cleaning solvents might be used or other hazards may be introduced into the space by the workers. Referencing and understanding the MSDS as well as “listening to what your monitor is telling you” are key factors in PPE determination.

OSHA does mention, however, if the atmospheric condition is unknown, then it should be considered IDLH and the use of positive pressure SCBA/SAR must be used. This will protect you from low O2 levels and other inhalation dangers; however, you must also consider LEL/LFL levels. Other factors include non-atmospheric conditions as well. For example, have you considered “skin absorption” hazards and what precautions must be taken?

So, the bottom line, the decision to go with breathing air for rescuers can be determined from your hazard assessment; or, in some cases, by company policy; and even required by OSHA when there’s an unknown atmosphere involved. Remember, it’s much better to be safe than sorry!
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Municipal Response to Permit-Required Confined Spaces

Tuesday, November 16, 2010

A blog reader, who is a member of a municipal rescue team assigned to an airport, expressed concern about fulfilling “timely response” obligations for permit-required confined space entries within his district. Here are some suggestions from our Tech Panel…

First of all, the departments and agencies involved must carefully consider the obligations in providing rescue response for permit-required confined spaces.

Obviously, we cannot advise on departmental policy concerning response and notification, this must be determined by management officials. However, for you as an emergency responder, we cannot stress enough the importance of preplanning and conducting a hazard analysis for all confined spaces within your response area. The information gained by the analysis will help you determine what level of “timely response” may be required for a particular type of entry.

OSHA does not set a specific response time because there are too many variables involved – plus, they don’t want to set requirements that might cause a rescue team to “rush” into entering a space to attempt a rescue. OSHA does reference how long a person might survive an IDLH atmosphere (such as an oxygen deficient atmosphere) before becoming incapacitated (4 to 6 minutes). However, even this is up to interpretation depending on the level of oxygen present. For example, an 18% O2 level vs. a 6% O2 level, both are O2 deficient but have very different response requirements for successful rescue.

Another important consideration is when an entrant is entering an IDLH environment. In this case, having a team standing by the portal, fully equipped and ready to go may be the only way to meet a timely response for that situation. OSHA’s 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.”

Most entries, however, are not IDLH. This means that other forms of “external” rescue (vs. internal rescue) may be appropriate. Many times, in the rush of the moment, rescuers forget about external retrieval. Guessing that many of the spaces around the airport are manholes or vaults, these can most often be handled by the confined space attendant with an external retrieval system. This would include a mechanical winch attached to a tripod with a cable attached to the entrant’s high-point dorsal connection. Of course, this decision would be based on a prior hazard analysis.

NOTE: It’s important to note that ALL entrants are required to have “an immediate means of retrieval.” Reference OSHA 1910.146 [note to paragraph (k)(1)(i)] concerning timely response: “What will be considered timely will vary according to the specific hazards involved in each entry…”

As a final note, if hazard analysis and rescue preplans have not been conducted on your potential sites as required by OSHA, we encourage you to do so. Taking the time to do so will better enable you to determine what would be considered an appropriate “timely response” for a particular type of entry. It will also better prepare you as an emergency responder should the need arise.
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Is a “tailboard briefing” enough prior to a confined space entry?

Monday, November 08, 2010

We had this question from a reader and wanted to post for all to read.

Would a proper tailboard briefing conducted before a confined space entry be sufficient for identifying hazards that may be encountered by the entrants or the rescue team?

It’s true that a tailboard briefing should be an integral part of the larger overall preplanning for a confined space entry. However, well in advance of the entry, a detailed “hazard analysis” of the space should be performed.

A hazard analysis is used to identify the types of hazards, lock-out/tag-out needs, PPE required for entry, method of entry and important rescue considerations. In fact, OSHA requires these written assessments to be completed prior to an entry being made and the confined space permit acts as a secondary written assessment performed at the time of the entry. Here are some OSHA references concerning this topic…

1910.146(c)(5)(ii)(H)
The employer shall verify that the space is safe for entry and that the pre-entry measures required by paragraph (c)(5)(ii) of this section have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification shall be made before entry and shall be made available to each employee entering the space or to that employee’s authorized representative.

1910.146(d)(2)
Identify and evaluate the hazards of permit spaces before employees enter them;

1910.146(d)(3)
Develop and implement the means, procedures, and practices necessary for safe permit space entry operations;

The tailboard briefing should be used to confirm or reinforce the information already gathered in the hazard analysis. Because it deals with an individual space at the time of entry, the tailboard briefing is also a very useful tool in finding out if conditions have changed since the hazard analysis was completed.

So, the bottom line… having a detailed hazard analysis for each space that includes a detailed rescue preplan allows a rescue team to review and prepare for potential problems well in advance. Reviewing this information at a tailboard briefing just prior to the entry helps to remind everyone of the possible hazards, the proper precautions, and the potential solutions should an emergency occur.
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To Pre-rig, or not to Pre-rig?

Monday, September 27, 2010

We received an interesting question about pre-rigged systems from one of our subscribers. The TechPanel had some helpful comments to share, so we have re-posted the info here. It’s a great topic.

Here are some things to consider about leaving systems pre-rigged.First of all, whether to pre-rig systems or not depends a lot on the types of rescues you will be doing.

Pre-rigged systems make sense for most industrial and municipal teams who have rope equipment designated specifically for rescues. However, it makes less sense for climbers and wilderness personnel who will be using the same equipment for multiple uses and putting systems together based on a specific need. This also reduces the amount and weight of equipment they must carry, which is a big concern. However, it also requires a high level of proficiency in a variety of systems in order to build systems safely and in a timely manner.

Next, let’s clarify what we mean by “pre-rigged systems.”

“Plug-n-Play” – These are systems that come pre-built and seem to require little training to operate. These “Plug-n-Play” systems may work for a specific location or type of rescue but may not work in every situation. Training for these systems should address what to do if the device/system malfunctions, or if it will not work for the type of scenario you may be faced with.

“Customized Pre-rigged Systems” – These are customized pre-rigged systems that rescuers build for site-specific needs and their team’s needs using existing equipment and training.

Confined space and rope rescue can be broken down to three core tasks… (1) Lowering, (2) Safety line Belay, and (3) Mechanical Advantage/Retrieval systems. You can build pre-rigged systems that make sense for your specific needs. Many of the teams we work with have adopted a three bag system.

For example, one rope bag is designated for “Lowering” along with the typical equipment needed for a lowering system (i.e. descent control device, carabiners, anchor straps, padding). This will provide a pre-rigged system that will handle most of your lowering needs. You may decide to supplement that with another anchor strap and a pulley for a high-point directional, etc.

Your “Safety line/Belay” bag can be set up the same way with enough carabiners and shock absorbers attached to the rope bag to allow for at least two rescuers and a victim. The third bag of rope (“Mechanical Advantage/Retrieval”) with a simple, pre-built Block-n-Tackle hauling system and its own anchor straps will give your team an “immediate means of retrieval” for either the main line or a safety line retrieval. With a few additional pieces of hardware, you will be able handle the vast majority of urban rope/confined space rescue scenarios.

We find that for industrial rescue teams or municipal fire and police rescue squads, these pre-rigged systems make sense. They save set-up time and get a rescuer to the victim as quickly as possible, which is especially critical for an IDLH emergency.

Many times teams will arrange their equipment so that it’s easier to inventory rather than what’s the fastest way to deploy it. For example, if you have twenty carabiners, why not have them attached to a rapid deployment bag type system rather than in a hardware bag that a team member will have to go through and pick out what is needed?

Our best advice would be to look at your team’s response area and consider the types of rescues that may be needed. You can then customize and build pre-rigged systems that make sense for your team. “Plug-n-Play” systems may handle most of your rescue situations or they may be part of a larger pre-rigged rescue system like the one above. Using a “pre-rigged systems” approach saves time, cuts down on confusion, and uses equipment more efficiently – especially when the pressure is on.
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Are safety lines required in an actual rescue?

Friday, September 24, 2010

This question was submitted by Thomas Vitti from the Chevron Fire Dept. in Salt Lake City, Utah.

In the event of an actual rescue is a safety line necessary?

Good question… the answer is YES and NO. This question falls into somewhat of a gray area. Much depends on what type of rescue you’re doing; who the safety line is for; and, most importantly, the function of the safety line. Here, we’ve put together our ideas in relation to OSHA regulations, interpretations and our own rescue experience. Then, of course, there’s our motto… “There’s a safe way and a SAFER way,” which we always keep in mind.

Most of the time, the answer for rescuers is YES. Again, one of the most important questions in determining the answer is the function of the safety line during the particular rescue. In most instances, the safety line functions as fall protection, and OSHA requires that all employees be protected from fall hazards. That includes employees performing rescue.

As a rescuer, it is expected that you would be capable of designing a rescue system that maintains two points of contact and meets all fall protection requirements. For example, if you (the rescuer) are being lowered into or out of a space, you would be on a single system (one point of contact) and will therefore need another point of contact (safety line) to act as your second point of contact and fall protection. In this instance, your safety line functions as your fall protection. Once you’ve been lowered to the bottom of a confined space, and you move away from the portal, your safety line then functions as an external retrieval line. However, if it will not contribute to your rescue (or will make it more hazardous), according to OSHA 1910.146, the line is not necessary.

Is a safety line required for the person being rescued (i.e., the victim)? For the most part, YES – it should be part of the preplan for that particular type of rescue. While OSHA requires that all employees be protected from fall hazards, if the patient’s condition is critical (heart attack, suspended unconscious, IDLH atmosphere, etc.) and set-up time for the safety line would cause a delay in getting the proper medical treatment, the rescue team may be justified in not using a safety line for the victim/patient. Additionally, certain circumstances may not require the application of a safety line system for the victim. For instance, if an employee falls and is suspended by a fall arrest system, you don’t need to add another safety line to do the rescue.

Roco’s recommendation…  YES, a safety line is always required for a rescuer – even in a confined space,  where it can also be used for communication purposes. Safety lines for the victim/patient are also highly recommended when the victim will be suspended. But we also realize that there may be life or death circumstances when “quickness of rescue” is more important than the added precaution of using a safety line on the patient. Because Fed OSHA does not specifically address this issue, in certain circumstances, it may be justifiable not to do so.

It is understood that there are unexpected emergency events with many possible mitigating factors to deal with – making it impossible to regulate every potential scenario. So, this leaves some room for judgment based on the circumstances. But if your “justification” is that you did not have sufficiently trained personnel or sufficient equipment to employ a safety line (fall protection) system, OSHA is likely to conclude that you were not properly prepared to perform rescue for your particular work environment.

OSHA does not dictate how a rescue is to be performed. OSHA’s only performance standard for a rescue team is that they are capable of performing rescues in a safe, efficient and timely manner. That’s why we emphasize preplanning, preparing and practicing for the most likely scenarios at your site. Rescue preplans allow teams to plan for safe, effective rescue systems that would include fall protection as part of the plan – in fact, the safety line system could be pre-rigged, bagged and ready to go. The importance of preplanning for rescue is also addressed in OSHA 1910.146(k)(1)(v), which refers to providing 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. (Of course, “representative spaces” are also acceptable.)

As a final note, where OSHA does not have a specific regulation that addresses a particular hazard or means of protection, it may cite an employer for violating the General Duty clause – which requires an employer to provide a workplace free of recognized hazards. In citing under the General Duty clause, OSHA can reference national consensus standards, such as ANSI and NFPA, to establish a recognized hazard and acceptable means of protection. These consensus standards can also be invaluable resources for compliance guidance.

Note: It is always important to follow your company’s policies and procedures concerning emergency response operations as well as all relevant standards and regulations for your industry.
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