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Grain Storage: Rescuers Beware!

Monday, February 21, 2011

“Two teenagers (ages 14 and 19) were killed in a tragic incident involving a grain elevator in Illinois. Both young workers suffocated after being engulfed in a grain bin they had entered to help clear. A third young worker was pulled out of the storage bin alive, and was hospitalized after being trapped for 12 hours.”

Unfortunately, this is not a rare occurrence. Researchers at Purdue University documented 38 grain entrapments in 2009 alone. (*)

During recent months, OSHA has issued strong warnings concerning the dangers of grain storage facilities. This article is intended to remind emergency responders, in particular rural firefighters/rescuers, of the special hazards and other rescue considerations when called to the scene of a grain bin or silo accident.

In our rural communities, especially in the “Bread Basket of America,” we continue to see too many accidents involving farm-based and commercial grain bins and silos. The causes of these accidents run the gamut from machinery entanglement to atmospheric/ respiratory hazards and engulfment, just to name a few. However, these same hazards also pose potential threats to the responders who must exercise caution in order to protect themselves and their victim(s) when attempting a rescue.

In fact, OSHA 1910.272 Appendix A recommends that grain handling facility employers coordinate with local Fire Departments for the purpose of preplanning for emergencies. This standard (1910.272) also provides guidance to the facilities to help ensure a safe work environment for employees. Unfortunately, these accidents continue to happen.

So what are some of the hazards and considerations for responders when summoned to this type of rescue? First of all, as with any emergency situation, a thorough “size-up” must be made prior to committing any rescue personnel. Of course, any time confined spaces are involved, an understanding and evaluation of atmospheric hazards is critical to rescuer safety. Don’t allow your responders to become additional victims!

Depending on the product, atmospheric hazards may include airborne combustible dust, oxygen depletion, oxides of nitrogen, fumigants, and in some instances hydrogen sulfide. Therefore, one of the first considerations should be to ventilate the space in an attempt to eliminate the atmospheric hazard(s). If ventilation is not possible or effective, then appropriate PPE or intrinsically safe equipment must be employed. It is also critical for all machinery to be shut down and locked out/tagged out (LO/TO), especially discharge augers and any equipment that may cause vibration.

Let’s look at the scenario where a worker becomes engulfed while working on top of the grain. OSHA requires that workers walking on grain wear a body harness that is tied off with a restrain line unless it can be demonstrated that there is no engulfment hazard. It is also recommended that the worker be attached to a winch to aid in retrieval should they become engulfed. Unfortunately, there are many instances where these provisions are neglected and thus the worker becomes partially or fully engulfed with no immediate means of rescue.

Engulfment can occur due to a number of conditions. Walking down grain while the outlet auger is running is a recipe for disaster. It is shocking how quickly moving grain can engulf a worker. The funneling effect of moving grain is just something that a worker will not be able to outrun. It is forbidden for employees to walk down grain with the auger running and not using LO/TO.

A second situation that may lead to engulfment is breaking through “grain bridges.” Grain bridges develop when the top layer of grain becomes encrusted or freezes and the outlet of the grain below forms a pocket or void below the bridge. Employees and rescuers should always probe the surface of the grain with a rod to detect the presence of bridging to prevent this type of engulfment. Even wearing a harness and restraint line can lead to an engulfment if the bridge collapses while the individual is several feet laterally from their tie-off point.

A third way workers or rescuers may become engulfed is due to product avalanche. This occurs when product builds up on the walls of the bin and releases while the worker or rescuers are in the bin. For the responder that is called to a grain bin engulfment, one option of rescue is to cut outlet holes in several places on the outside wall of the structure just below the level of the victim. This will rapidly drain the product out and away from the victim. However, this may prove difficult if access to the required level of the bin is not readily available.

Another option is to remove the material from around the victim by using whatever means possible, including vacuum hoses, shovels, scoops, or buckets. Keep in mind that if rescuers enter the bin and are working on the surface, they also need to wear harnesses and restraint, preferably with a means of immediate retrieval. Avoid using self-retracting lifelines (SRL) as the quicksand effect of the grain may not cause a fast enough drop to activate the brake of the SRL.

To distribute the weight of the rescuer(s) and help prevent sinking into the product, consider using ladder sections placed on the surface of the grain. It is also imperative to use some type of cofferdam structure either manufactured specifically for this type of rescue or improvised using sheets of plywood or even backboards to prevent the material from filling back in around the victim as you dig them out. For a victim that is engulfed in a vertical or near vertical posture, a “rescue tube” (see video below) is a great option and comes in sections that are easily passed through the bin opening and can be assembled right at the victim’s location.

Typically, once a victim is buried mid-thigh to waist deep, they cannot escape without assistance. Fatalities from engulfment are usually suffocation due to blockage of the breathing passages with grain – even the partially engulfed victim may succumb to mechanical asphyxiation due to restricted movement of their chest walls and diaphragm.

In the case of cold grain engulfment, consider treating the victim for hypothermia as the material draws body warmth through conduction instead of convection. For the victim that is rescued after being engulfed in cold grain, continue resuscitation efforts even if they have no signs of life, similar to treating cold water drowning. In fact, OSHA reports of a near tragedy that occurred in February when a worker was trapped in soybeans up to his chest in 25 degree weather. Fortunately, he was ultimately rescued after a four-hour ordeal.

The bottom line for emergency responders… these types of rescues are time and labor intensive; it’s a slow and tedious process. What’s more, the probability of accessing the victims through elevated portals will often require the use of a ladder truck or high angle rope rescue once the victim is removed from the engulfment unless they are able to climb down on their own.

Also, take heed when performing the initial scene assessment. One of the first things to try to determine is “what happened to the victim?” (i.e., mechanism of injury). Stop and ask, “What do I need to do to keep this from happening to me?” Don’t end up in the same predicament as the victim – your personal safety and that of other responders is always paramount.

To summarize, rural firefighters/rescuers should be prepared by paying a visit to representative grain handling facilities in their response area. Become familiar with the types of hazards, equipment and machinery that may be encountered and the types of rescues that may be required. This preplanning may reveal the need for specialized training or equipment to help ensure that responders are capable, and most importantly adequately protected, when the emergency call for assistance is received.

(*) Excerpt from OSHA letter, dated August 4, 2010. Click here to read entire letter with additional incidents.
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Hands-On Training Most Effective in Hazardous Jobs

Monday, February 07, 2011

“Hands-on safety training for workers in highly hazardous jobs is most effective at improving safe work behavior, according to psychologists who analyzed close to 40 years of research.”

At jobs where the likelihood of death or injury was highest, the findings showed that more engaging training (e.g., behavioral modeling, simulation and hands-on training) was considerably more effective than less engaging training (such as lectures, films, reading materials and videos) for both learning about and demonstrating safety on the job.

Less engaging training, meanwhile, was just as effective in regard to improving these outcomes when the risk for death or injury was low.

“The primary psychological mechanism we can offer as an explanation for these results is something called the ‘dread factor,’” said the study’s lead author, Michael Burke, Ph.D., of Tulane University. “In a more interactive training environment, the trainees are faced more acutely with the possible dangers of their job and they are, in turn, more motivated to learn about such dangers and how to avoid them.”

For example, when hazardous events and exposures are extreme (e.g., fires, explosions, exposure to toxic chemicals or radiation), the action, dialogue and considerable reflection that takes place in more interactive training would be expected to create a sense of dread and realization of the dangers of the job. This analysis offers practical implications for employers who may be hesitant to invest in the more expensive interactive training programs.

“Distance learning and electronic learning may appear to be more cost effective. But our findings point to the value of investing in more hands-on training to help prevent the enormous financial and human costs associated with disasters like the Upper Big Branch mine explosion,” said Burke.

Excerpt from EHS Today, The Magazine for Environment, Health and Safety Leaders (ehstoday.com)  Jan 28, 2011 11:39 AM, By Laura Walter
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Atmospheric Monitors: “Calibration vs. Bump Testing”

Friday, January 21, 2011

“The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal, should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.”

Here at Roco, we’re often asked for an explanation of the difference between “calibration” and “bump testing” of portable atmospheric monitors. There seems to be some confusion, specifically regarding bump testing. Some folks believe that bump testing and calibration are the same thing. Others think that bump testing is no more than allowing the monitor to run its “auto span function” during the initial startup sequence – or by running a “manual auto span” in order to zero out the display if there is any deviation from the expected values.

To preface this explanation, it is important that the user maintain and operate the monitor in accordance with the manufacturer’s instructions for use. There are some general guidelines that apply to all portable atmospheric monitors and some of the information in this article is drawn from an OSHA Safety and Health Information Bulletin (SHIB) dated 5/4/2004 titled “Verification of Calibration for Direct Reading Portable Gas Monitors.”

Considering that atmospheric hazards account for the majority of confined space fatalities, it is absolutely imperative that the instruments used to detect and quantify the presence of atmospheric hazards be maintained in a reliable and ready state. Environmental factors such as shifts in temperature, humidity, vibration, and rough handling all contribute to inaccurate readings or outright failure of these instruments. Therefore it is critical to perform periodic calibration and pre-use bump testing to ensure the instruments are capable of providing accurate/reliable information to the operator.

Calibration of the monitor involves using a certified calibration gas in accordance with the manufacturer’s instructions. This includes exposing the instrument sensors and allowing the instrument to automatically adjust the readings to coincide with the known concentration of the calibration gas. Or, if necessary, the operator will manually adjust the readings to match the known concentration of the calibration gas.

In addition to using a certified calibration gas appropriate to the sensors being targeted, do not ever use calibration gas that has passed its expiration date. The best practice is to use calibration gas, tubing, flow rate regulators, and adapter hoods provided by the manufacturer of the instrument.

The frequency of calibration should also adhere to the manufacturer’s instructions for use; or, if more frequent, the set protocol of the user’s company or facility. Once the monitor has been calibrated, it is important to maintain a written record of the results including adjustments for calibration drift, excessive maintenance/repairs, or if an instrument is prone to inaccurate readings.

Each day prior to use, the operator should verify the instrument’s accuracy. This can be done by completing a full calibration or running a bump test, also known as a functional test. To perform a bump test, use the same calibration gas and equipment used during the full calibration and expose the instrument to the calibration gas. If the readings displayed are in an acceptable range compared to the concentrations of the calibration gas, then that is verification of instrument accuracy. If the values are not within an acceptable range, then a full calibration must be performed and repairs/replacement completed as necessary.

Modern electro-mechanical direct reading atmospheric monitors have come a long way in recent years in terms of reliability, accuracy, and ease of use. But they are still relatively fragile instruments that need to be handled and maintained with a high degree of care. The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.

For more information on this subject, please refer to the November 20, 2002 ISEA position Statement “Verification of Calibration for Direct Reading Portable Gas Monitors Used In Confined Spaces”; “Are Your Gas Monitors Just expensive Paperweights?” by Joe Sprately, and James MacNeal’s article as it appears in the October 2006 issue of Occupational Safety and Health magazine.
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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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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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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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Confined Space Attendants – More than just a “Hole-Watch”

Wednesday, August 04, 2010

Whenever I go out into the field for a rescue stand-by job, I always take note of the attendant.  I will always talk to them in order to try and gauge this person’s level of knowledge about confined spaces in general as well as the particular entry that is being made.  Unfortunately, more often than not, I discover that this worker has very little experience or very little training in confined spaces.  Most of these workers tend to be the “low-man” on the work crew and seem to just be “thrown” in to that position.  A lot of the facilities and contractors seem to have the attitude that anyone can be the “hole-watch.”  This can be the major ingredient in a recipe for disaster.

When OSHA created the Confined Space Regulation (29 CFR 1910.146) they included a list of the “roles and responsibilities” of the Entrant, Attendant and Entry Supervisor.  A cursory glance at the responsibilities of the attendant paints a picture of someone who is acutely tied to the overall safety of the operation.

These are some of the highlights of the attendant’s duties:

    - Know the hazards that may be faced during the entry, as well as the effects of those hazards
    - Monitor conditions inside and outside of the space
    - Call for the evacuation of the space in the event of an emergency or the detection of a prohibited condition

When you look closely at these duties, you’ll see that this is a lot more than just some “body” standing outside of the space.  For example, in order to monitor the conditions inside a space, most attendants are handed a two- or four-gas air monitor and sent out to the space to “sniff” the air inside.  The untrained or inexperienced “hole-watch” will likely not be aware of the numerous things that can affect the atmospheric testing results. Things such as the techniques used to calibrate the monitor, or the oxygen content of the air, or the concentration of certain gases can all skew the readings of a monitor.  I have also seen, on at least two occasions, a ventilation fan being placed within a few feet of a bank of gas-powered welding machines.  In one case, the carbon monoxide readings inside the space reached a high enough level to actually set off the alarms on the atmospheric monitor.  These are things that unqualified workers are simply not going to know about.

Not only do the attendants out in the workforce need to be better trained, they also should be brought into the planning phase of the entry operation.  The attendant should attend pre-job meetings as well as assist in the process of making the space safe for entry.  In one entry that I witnessed about 10 years ago, a very well qualified attendant was present.  The entry was into an underground vault that housed a large water main.  The entrants were installing a new valve into the system.  Because the attendant had helped shut down and isolate the space, he was familiar with the system in general.  Once the repairs to the valve were completed, a call was made to re-pressurize the line in order to make sure there were no leaks present.  The attendant ordered the entrants to exit the space while the pipe was brought up to pressure.  The entrants argued that they needed to be there to tighten up any leaks that might develop, but the attendant was adamant that they leave the space.  As the pressure in the line climbed higher, it ruptured and the entire vault filled with water in about 30 seconds.  It happened so fast that no amount of pre-rigging for rescue would have saved the two entrants.

A well-qualified attendant can have a definite impact on the entire project.  It is unfortunate that many times they are looked at as just some person standing outside the space – instead of a key component in the overall safety of the entry operation.

Author:
Bryan Rogers
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Safety Inspection of the Sked Basic System

Friday, July 30, 2010

As with all rescue equipment, it’s extremely important to inspect your equipment before and after each use according to the manufacturer’s recommendations. Here are some tips from Skedco for inspecting your Sked Stretcher.

For the Sked Body: Do a visual inspection of the plastic. If there are cuts that go completely through the plastic (especially at the edges or the grommets), it should be   taken out of service and replaced. This is a very rare occurrence. If the plastic is wearing thin and preventing the Sked from retaining its shape, take it out of service.

Check all brass grommets.
If they are badly bent or coming apart, they should be changed. This may also require sewing a new strap into it. Grommets can be replaced inexpensively by parachute riggers or any awning shop. When it is done, be sure the grommeting tools do not cut the inside of the grommet. Grommets that are sharp inside can cut webbing or rope.

Check all straps for broken stitching, discoloring (usually white), and fraying. If straps are badly frayed, discolored or if ten (10) or more stitches are broken, replace the straps.

Horizontal lift slings: Check for excessive wear, broken stitches or severe discoloration. If these conditions are found, replace the slings.

Vertical lift slings (3/8 static kernmantle rope): Check for severe discoloration and soft or thin spots. Thin spots that are soft indicate damaged core. If found, cut the rope at that point and take it out of service.

All other webbing products should be inspected in the same way as the slings and Sked straps.

The carabiner should work smoothly when the gate is opened and closed. Check for alignment. Check the hinge pin for looseness. The lock nut should work smoothly without hanging up at any point. Failure at any of these points requires replacement. A poorly functioning carabiner should be broken or destroyed to prevent others from using it by mistake.

If you have any doubts, call Skedco for assistance.
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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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