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1910.147 LOTO vs. 1910.146 Isolation

Wednesday, July 06, 2011

Question:  If I close and Lockout/Tagout the main valve on the natural gas line supplying a boiler unit – does this satisfy OSHA’s requirement for eliminating the hazard of a permit required confined space?

Answer:  No, it does not. You are asking a question that we address quite often and it reveals some misconceptions regarding “eliminating” or “isolating” the permit space from hazards. Lockout/Tagout (LOTO) procedures are covered in OSHA’s 1910.147 “Control of Hazardous Energy (Lockout/Tagout).

” Many times this regulation is incorrectly referenced when addressing permit space hazards that are not covered by this regulation.
OSHA’s 1910.147 LOTO regulation applies to the control of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. It does not apply to engulfment hazards (liquid or flowable solids), flammable gasses, or other gasses that may be toxic or oxygen displacing.

It is important to understand this distinction because the use of isolation procedures appropriate for the hazards addressed in 1910.147 may not be effective in eliminating other hazards.  “Isolation,” as defined in the Permit Required Confined Space regulation (1910.146) spells out the various measures required to eliminate hazardous energies as covered in the LOTO regulation as well as the types of hazards that are not addressed in that regulation.  You will note that 1910.146 cites LOTO as a means to isolate all sources of energy (emphasis added), but outlines other methods used to isolate the other hazards such as hazardous materials. These isolation procedures include the process by which a permit space is “removed from service” and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

By closing and placing a LOTO device on a single valve of a natural gas feed line, you may have controlled the hazard but you have not eliminated it. To provide true isolation (elimination), you will have to employ such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; or a double block and bleed system.

Download the LOTO tip sheet from NIOSH.
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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.


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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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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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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Myths and Misunderstandings

Thursday, July 01, 2010

How often have you heard the statement “I will just call 911 if we have a confined space emergency”?  Let’s dispel some common myths and misunderstandings regarding confined space rescue compliance.

In accordance with OSHA 1910.146 (d)(9) an employer that will have personnel entering Permit Required Confined Spaces at their workplace 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.

Meeting this requirement can be accomplished in several ways…

    - Develop an in-house rescue team made up of host employees.
    - Contract with an outside third party rescue team.
    - Coordinate with local emergency services (“911”).

Whatever way an employer chooses, there are specific evaluation criteria that must be met according to 1910.146 (k)…

The rescue team must be capable of responding in a timely manner and reaching the victim(s) within an appropriate amount of time based on the hazards of the confined space.  On-site teams (in-house or third party contracted teams) are generally better able to meet this requirement.

The team must be equipped and proficient in performing the type(s) of rescue that may be encountered.  Can they walk the walk, or just talk the talk?

The employer shall ensure at least one member of the rescue team is currently certified in CPR/First Aid.

The employer shall also ensure that the designated rescue team practices making permit space rescues at least once every 12 months from the actual spaces or representative spaces in regards to opening size, configuration, and accessibility. Representative spaces shall simulate the types of permit spaces from which rescue is to be performed.

Non-Mandatory Appendix F – Rescue Team/Rescue Service Evaluation Criteria

These are some but not all of the requirements of an initial and periodic performance evaluation of the rescue team:

At a minimum, if an offsite rescue team is being considered, the employer must contact the service to plan and coordinate the evaluation of the team based on 1910.146 (k).  Merely posting the service’s phone number or planning to rely on “911” to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

Can the rescue team respond in an appropriate amount of time based on the hazards of the space?  For known IDLH hazards or hazards that can quickly develop into IDLH conditions, on scene rescue standby is required.  For non- IDLH hazards, a response time of 10-15 minutes may be adequate.

Will the offsite rescue team be available to respond to a confined space incident or is there a potential they will be out of service on a separate incident and unable to respond?

If necessary, can the rescue service properly package and retrieve victims from a permit space that has a limited size opening (less than 24 inches in diameter) or from a space that has internal obstacles or hazards? Does the service have the capability to provide rescue from an elevated location using high angle rescue techniques?

About the Author:
Patrick Furr, employed with Roco since 2000, has been actively involved with technical rescue since 1981. He is a Roco Chief Instructor as well as a Team Leader for our on-site safety services in New Mexico. Pat teaches Confined Space Rescue, Rope Access, Tower Work/Rescue and Fall Protection programs across North America. He is a retired U.S. Air Force MSgt/Pararescueman.
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