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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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How much training is needed for attendants on air monitoring equipment?

Wednesday, September 01, 2010

Reader Jeff Machen had a question concerning how much training to give attendants on air monitoring equipment; especially when they may only be working a week long shut down? Here’s our reply from CSRT Manager Bryan Rogers.

When you’re dealing with temporary labor, it is difficult to ensure that they are well trained on something as complex as atmospheric monitoring. We checked with several equipment manufacturers, and they don’t set a specific amount of training required, but leave it up to the customer’s internal company policy and/or person(s) issuing the monitor.

We also spoke to a few of our instructors who work at different plants and refineries. The majority of these companies require a company employee to perform the initial monitoring and then again after a break in work greater than 30 minutes. In addition, they review with the attendant what to look for and what to do if there are changes in the readings or an alarm sounds. One company provides a four-hour PowerPoint presentation on monitoring and attendant responsibilities.

OSHA does not indicate a time frame for this training either. However, it does require that persons be capable of safely performing the tasks assigned. Therefore, I would say your best bet would be to cover as much of the manufacturer’s instructions as possible along with reviewing the most common problems such as…

    - Calibration conversions
    - Turning on the monitor (or “field zeroing”) in the presence of contaminates
    - Negative LEL or negative toxic readings
    - Contaminated sampling hoses
    - Clogged filters

Lastly, I would stress to the attendants the importance of contacting a supervisor if they have any questions or concerns - and, if they get any unusual results from the monitor… “Do not hesitate to have everyone exit the space while the results are investigated!”
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Why does my Petzl ID snag and prevent me from taking up slack to the load prior to a lower?

Thursday, August 26, 2010

"Most likely the loaded section of the line is catching on the anti-error catch where the load line enters the body of the ID. This is a safety feature of the ID to prevent free-falling loads if the ID is loaded backwards. To prevent the rope from jamming, consider positioning yourself between the ID and the load facing the anchor. Hold both sections of rope oriented towards the load. Pull on the left section of rope while allowing the right section to drag through your hand. This will keep the rope clear of the anti-error catch." ~Roco Chief Instructor Pat Furr.

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Why does my trusty old Petzl ID allow rope to continue feeding during a lower or rappel even after I have locked it off in work positioning mode?

Wednesday, August 25, 2010

The answer may be in the description “trusty old”. The ID has a wear indicator cast into the friction bobbin. It is located at the top of the bobbin on the side of the bobbin that the swinging side plate is on. When in usable condition the wear indicator is visible as a slightly raised ridge about a half-inch long. If the wear indicator is not visible the bobbin is worn out and the ID needs to be taken out of service.

 Smart answer courtesy of Pat Furr

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