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Trench/Excavation Competent Person Training

Monday, October 15, 2018

If you are supervising an excavation/trench job or are signing off on a permit for excavation work…YOU NEED THIS CLASS!

This 8-hour course from Roco is intended for Owners, Supervisors, Managers, Operators, and Safety personnel who are required to oversee Excavation and Trench work.

OSHA has recently updated its National Emphasis Program (NEP) on preventing trenching and excavation collapses in response to a recent spike in trenching fatalities. According to a study by OSHA1, the primary reason trenches collapse is that they are not properly protected. Protective systems were properly employed in only 24% of the trench collapse fatalities. In the remainder, a protective system was either improperly used (24%), available but not in use (12%) or simply unavailable (64%).

Despite the fact that environmental conditions were a contributing factor in 68% of the fatalities, the Competent Person2 was not onsite when the fatality occurred 86% of the time.
Most of the time (65%) the employer (Competent Person’s responsibility) had not identified the soil type even though soil type is a factor in trench cave-ins.

Because of the extreme hazards involved, OSHA 29 CFR 1926.650 Subpart P (Excavations) requires at least one person be trained as a Competent Person for excavation sites, which includes trenching activities. Trenching and excavation compliance and safety is dependent on these specialized employees, and OSHA has recognized that a higher level of training and experience is required than a normal worker would possess. OSHA relies on the Competent Person for certain activities or safety procedures at a construction site such as design, daily inspections, and supervision.

Tasks performed by the Competent Person include:
• Monitoring water removal equipment and operations.3
• Inspecting excavations subject to runoff from heavy rains to determine need for suitable protection.4
• Determining cave-in potential and need for protective systems.5
• Examining damaged material or equipment used for protective systems.6
• Classifying soil, by both visual analysis and by testing, to determine appropriate protection; re-classifying, if necessary.7
• Determining the appropriate slope of an excavation to prevent collapse due to surcharge loads, operating equipment, adjacent structures, or traffic, and assuring that  such slope is achieved.8
• Designing structural ramps that are used solely by employees as a means of access or egress.9
• Authorizing immediate removal of employees from the hazardous area where evidence of possible cave-in, failure of protective systems, hazardous atmospheres, or other hazardous conditions exists.10

Course Topics Include:
• Scope, Application, and Definitions of OSHA 1926.650, 1926.651 & 1926.652
• Specific Requirements of an Excavation Competent Person
• Identifying Existing and Potential Hazards
• Soil Classification
• Protective Systems – Requirements, Options, Installation and Inspection
• Sloping and Benching – Requirements
• Aluminum Hydraulic and Timber Shoring
• Shoring Alternatives (Trench Boxes)
• Using Tabulated Data: OSHA, Manufacturer’s and Engineer’s Tabulated Data
• Protective Systems Selection
• Rescue Considerations

This Roco class is available as a privately scheduled event. To schedule, email us at info@RocoRescue.com or call 800-647-7626.

1 Results of OSHA’s 2003 investigation are still useful in understanding why trench fatalities occur and how they can be avoided.
2 Competent person is defined by OSHA “as an individual, designated by the employer, who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous or dangerous to workers, and who is authorized to take prompt corrective measures to eliminate them.”

3 [29 CFR 1926.651(h)(2)]
4 [29 CFR 1926.651(h)(3)]
5 [29 CFR 1926.652(a)(1)]
6 [29 CFR 1926.652(d)(3)]
7 [29 CFR 1926 Subpart P Appendix A]
8 [29 CFR 1926 Subpart P Appendix B (c)(3)(iii)]
9 [29 CFR 1926.651(c)(1)(i)]
10 [29 CFR 1926.651(k)(2)]
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Host a Roco Course - Get FREE Training!

Monday, October 01, 2018

Has your Fire Department ever thought about hosting a Roco Confined Space Rescue course?

It just might be easier than you think! If your municipal department needs this kind of training, and you have a training site that would be adequate – it could be that simple.

We will be offering this opportunity for up to four (4) municipal fire departments in 2019. All we ask is help from you in promoting the class to local agencies and industries so that we can get a minimum of eight (8) paying students. Then your department would receive two (2) FREE spots in the 5-day class. The more paying students, the more FREE slots your department would earn. It’s a great way to get the training you need at no cost to your organization.

Details:

One of the first things we need is to determine if you have a site that will work for the training. So, you’ll need to send us a few photos of your training site. Then, we will need a signed letter from your Fire Chief (or other authority) providing permission to conduct a Roco course at your training site and invite participants from other organizations. In turn, your department would promote the class in your local area. Roco would provide the instructors and rescue equipment at no charge to you.

If you are interesting in hosting a course next year, please email your site photos along with a letter from your Fire Chief authorizing the use of your facility for the training and for allowing other personnel to attend. Send all information to us at info@RocoRescue.com.

Note: Limited to municipal agencies within the continental United States. Class to be Level I/I-II program. All course participants must be 18 or older, physically fit, and sign waivers prior to participation.
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Using a Crane in Rescue Operations

Sunday, September 30, 2018

We’re often asked, “Can I use a crane as part of my rescue plan?”

If you’re referring to using a crane as part of moving personnel or victims, the answer is “No, except in very rare and unique circumstances.” The justification for using a crane to move personnel, even for the purposes of rescue, is extremely limited. Therefore, it is very important to understand the do’s and don’ts for using a heavy piece of equipment in a rescue operation.

On the practical side, the use of a crane as a “stationary, temporary high-point anchor” can be a tremendous asset to rescuers. It may also be part of a rescue plan for a confined space; for example, a top entry fan plenum. The use of a stationary high-point pulley can allow rescue systems to be operated from the ground. It can also provide the headroom to clear rescuers and packaged patients from the space or an elevated edge.

Of course, the security of the system's attachment to the crane and the ability to “lock-out” any potential movement are a critical part of the planning process. If powered industrial equipment is to be used as a high-point, it must be treated like any other energized equipment with regard to safety. Personnel would need to follow the Control of Hazardous Energy [Lockout/Tagout 1910.147]. The equipment would need to be properly locked out – (i.e., keys removed, power switch disabled, etc.). You would also need to check the manufacturer’s limitations for use to ensure you are not going outside the approved use of the equipment.

Back to using a crane for moving personnel – because of the dangers involved, OSHA severely limits its use. In order to utilize a crane, properly rated “personnel platforms or baskets” must be used. Personnel platforms that are suspended from the load line and used in construction are covered by 29 CFR 1926.1501(g). There is no specific provision in the General Industry standards, so the applicable standard is 1910.180(h)(3)(v).

This provision specifically prohibits hoisting, lowering, swinging, or traveling while anyone is on the load or hook.
OSHA prohibits hoisting personnel by crane or derrick except when no safe alternative is possible. The use of a crane for rescue does not provide an exception to these requirements unless very specific criteria are met. OSHA has determined, however, that when the use of a conventional means of access to any elevated worksite would be impossible or more hazardous, a violation of 1910.180(h)(3)(v) will be treated as “de minimis” if the employer complies with the personnel platform provisions set forth in 1926.1501(g)(3), (4), (5), (6), (7), and (8).

Note: De minimis violations are violations of standards which have no direct or immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way as any other violation, but are not included on the citation.

Therefore, the hoisting of personnel is not permitted unless conventional means of transporting employees is not feasible. Or, unless conventional means present even greater hazards (regardless if the operation is for planned work activities or for rescue). Where conventional means would not be considered safe, personnel hoisting operations meeting the terms of this standard would be authorized.

OSHA stresses that employee safety, not practicality or convenience, must be the basis for the employer's choice of this method.
However, it’s also important to consider that OSHA specifically requires rescue capabilities in certain instances, such as when entering permit-required confined spaces [1910.146]; or when an employer authorizes personnel to use personal fall arrest systems [1910.140(c)(21) and 1926.502(d)(20)]. In other cases, the general duty to protect an employee from workplace hazards would require rescue capabilities.

Consequently, being “unprepared for rescue” would not be considered a legitimate basis to claim that moving a victim by crane was the only feasible or safe means of rescue.

This is where the employer must complete written rescue plans for permit-required confined spaces and for workers-at-height using personal fall arrest systems – or they must ensure that the designated rescue service has done so. When developing rescue plans, it may be determined that there is no other feasible means to provide rescue without increasing the risk to the rescuer(s) and victim(s) other than using a crane to move the human load. These situations would be very rare and would require very thorough documentation. Such documentation may include written descriptions and photos of the area as part of the justification for using a crane in rescue operations.

Here’s the key… simply relying on using a crane to move rescuers and victims without completing a rescue plan and very clear justification would not be in compliance with OSHA regulations.
It must be demonstrated that the use of a crane was the only feasible means to complete the rescue while not increasing the risk as compared to other means. Even then, there is the potential for an OSHA Compliance Officer to determine that there were indeed other feasible and safer means.

WARNING: Taking it a step further, if some movement of the crane (or fire department aerial ladder, for example) is required, extreme caution must be taken! Advanced rigging techniques may be required to prevent movement of the crane from putting undo stress on the rescue system and its components. Rescuers must also evaluate if the movement would unintentionally “take-in” or “add” slack to the rescue system, which could place the patient in harm’s way. Movement of a crane can take place on multiple planes – left-right, boom up-down, boom in-out and cable up-down. If movement must take place, rescuers must evaluate how it might affect the operation of the rescue system.

Of course, one of the most important considerations in using any type of mechanical device is its strength and ability (or inability) to “feel the load.” If the load becomes hung up on an obstacle while movement is underway, serious injury to the victim or an overpowering of system components can happen almost instantly. No matter how much experience a crane operator has, when dealing with human loads, there is no way he can feel if the load becomes entangled. And, most likely, he will not be able to stop before injury or damage occurs.

Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is completely lost when energized devices are used to do the work.
For rescuers, a crane is just another tool in the toolbox – one that can serve as temporary, stationary high-point making the rescue operation an easier task. However, using a crane that will require some movement while the rescue load is suspended should be a last resort! There are simply too many potential downfalls in using cranes. This also applies to fire department aerial ladders. Rescuers must consider the manufacturer’s recommendations for use. What does the manufacturer say about hoisting human loads? And, what about the attachment of human loads to different parts of the crane or aerial?

There may be cases in which a crane is the only option. For example, if outside municipal responders have not had the opportunity to complete a rescue plan ahead of time, they will have to do a “real time” size-up once on scene. Due to difficult access, victim condition, and/or available equipment and personnel resources, it may be determined that using a crane to move rescuers and victims is the best course of action.

Using a crane as part of a rescue plan must have rock-solid, written justification as demonstration that it is the safest and most feasible means to provide rescue capability. Planning before the emergency will go a long way in providing options that may provide fewer risks to all involved.

So, to answer the question, “Can I include the use of a crane as part of my written rescue plan?” Well, yes and no. Yes, as a high-point anchor. And, no, the use of any powered load movement will most likely be an OSHA violation without rock-solid justification. The question is, will it be considered a “de minimis" violation if used during a rescue? Most likely it will depend on the specifics of the incident. However, you can be sure that OSHA will be looking for justification as to why using a crane in motion was considered to be the least hazardous choice.

NOTE: Revised 9/2018. Originally published 10/2014.


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Q&A: Energy Absorber Systems and Safety Lines

Friday, September 28, 2018

READER QUESTION: 
Is an energy absorber system needed on the safety line to help limit the impact forces should the belay system be engaged to arrest the falling load?

ROCO TECH PANEL ANSWER: 

Thank you for your question. Roco uses traditional untensioned safety lines in most all of our rescue systems, and we do indeed incorporate an energy absorber (shock) in those belay systems. While OSHA does not address specifics when it comes to rescue systems, there is some overlap from the OSHA as well as the ANSI standards that is helpful when considering the belay system during rescue. 

NFPA 1006 Standard for Technical Rescue Personnel Professional Qualifications, sections 5.2.9 through 5.2.11, provides guidance for the construction of a belay (safety line) system. Specifically, the 5.2.11 objective statement calls for the belay system to ensure “the fall is arrested in a manner that minimizes the force transmitted to the load.” The annex information to 5.2.9 adds: “A.5.2.9 Belay systems are a component of single-tensioned rope systems that apply a tensioned main system on which the entire load is suspended and a non-tensioned system with minimal slack (belay) designed, constructed, and operated to arrest a falling load in the event of a main system malfunction or failure. 

While these traditional systems used for lowering and raising are in common use, two-tensioned rope systems can also be used to suspend the load  while maintaining near equal tension on each rope, theoretically reducing the fall distance and shock force in the event of a singular rope failure. To be effective, two-tensioned rope systems must utilize devices that will compensate appropriately for the immediate transfer of additional force associated with such failures.”

Additionally the NFPA 1006 definition of belay is “3.3.9* Belay. The method by which a potential fall distance is controlled to minimize damage to equipment and/or injury to a live load.” And Annex information “A.3.3.9 Belay. This method can be accomplished by a second line in a raise or lowering system or by managing a single line with a friction device in fixed-rope ascent or descent. Belays also protect personnel exposed to the risk  of falling who are not otherwise attached to the rope rescue system."

So, where can OSHA help in all of this? OSHA requires the maximum force of a fall arrest system not to exceed 1,800 pounds. ANSI is more protective and requires arresting forces not to exceed 900 pounds. NFPA does not state what the arresting forces need to be limited to, but the performance measurement is to “minimize damage to equipment and/or injury to a live load.” OSHA and ANSI have already done the homework on this and stated their performance requirements. One proven way to meet NFPA 1006 as well as OSHA and ANSI requirements is to incorporate an energy absorber in the belay (fall arrest) system. Whether 1,800 pounds or the ANSI required 900 pounds is appropriate, or if you use a two tensioned system, this is up to your AHJ. 

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Safe Confined Space Entry - A Team Approach

Wednesday, September 26, 2018

Having been involved in training for 30 years, I have had the opportunity to observe how various organizations in many different fields approach confined space entry and rescue. And, when it comes to training for Entrants, Attendants and Entry Supervisors, the amount of time and content varies greatly.

Roco Rescue CS EntryMost often, training programs treat the three functions as separate, independent roles locked into a hierarchy based on the amount of information to be provided. However, it’s critical to note, if any one of these individuals fails to perform his or her function safely or appropriately, the entire system can fail – resulting in property damage, serious injury or even death in a confined space emergency.

Before I go any further, I have also seen tremendous programs that foster cooperation between the three functions and use more of a confined space “entry team” approach. This helps to ensure that the entry is performed safely and efficiently.

It also allows all parties to see the overall big picture of a safe entry operation.
In this model, all personnel are trained to the same level with each position understanding the other roles as well. This approach serves as “checks and balances” for confirming that:

• The permit program works and is properly followed;
• The permit is accurate for the entry being performed;
• All parties are familiar with the various actions that need to occur; and,
• The team knows what is expected of each other to ensure a SAFE ENTRY!

However, I am often surprised to find that Entrant and Attendant personnel have little information about the entry and the precautions that have been taken. They are relying solely on the Entry Supervisor (or their foreman) to ensure that all safety procedures are in place. If you have a well-tuned permit system and a knowledgeable Entry Supervisor, this may be acceptable, but is it wise? As the quality of the permit program decreases, or the knowledge and experience of the Entry Supervisor is diminished, so is the level of safety.


Roco CS Entry Supervisor & AttendantIn my opinion, depending exclusively on the Entry Supervisor is faulty on a couple of levels. First of all, the amount of blind trust that is required of that one person. From the viewpoint of an Entrant, do they really have your best interest in mind? And, we all know what happens when we “ass-u-me” anything! Plus, it puts the Entry Supervisor out there on their own with no feedback or support for ensuring that all the bases are covered correctly. There are no checks and balances, and no team approach to ensuring safety.

Looking at how 1910.146 describes the duties of Entrant, Attendant and Entry Supervisor tends to indicate that each role requires a diminishing amount of information. However, we believe these roles are interrelated, and that a team approach is far safer and more effective. To illustrate this, we often pose various questions to Entrants and Attendants out in the field. Here is a sample of some of the feedback we get.

We may ask Entrants…Who is going to rescue you if something goes wrong? Has the LOTO been properly checked? At what point do you make an emergency exit from the space? What are the acceptable entry conditions, and have these conditions been met? How often should the space be monitored? Typically, the answer is, “I guess when the alarm goes off, or when somebody tells me to get out!”

When we talk to Attendants about their duties, we often find they only know to “blow a horn” or “call the supervisor” if something happens, or if the alarm on the air monitor goes off. We also ask…What about when the Attendant has an air monitor with a 30 ft. hose, and there is no pump? Or, if you have three workers in a vertical space and the entire rescue plan consists of one Attendant, a tripod and a winch, plus no one in the space is attached to the cable – what happens then?
  
These are very real scenarios. Scary, but true. It often shows a lack of knowledge and cooperation between the three functions involved in an entry. And, that’s not even considering compliance!
We ask, would it not be better to train your confined space entry team to the Entry Supervisor level? Wouldn’t you, as an Entrant, want to know the appropriate testing, procedures and equipment required for the entry and specified on the permit? Would it not make sense to walk down LOTO with the Attendant and Entrant? This would better train these individuals to understand non-atmospheric hazards and controls; potential changes in atmosphere; or, how to employ better air monitoring techniques. All crucial information.

More in-depth training allows the entry team to take personal responsibility for their individual safety as well as that of their fellow team members. It also provides multiple views of the hazards and controls including how it will affect each team member’s role. Having an extra set of eyes is always a good thing – especially when dealing with the hazards of permit spaces. Let’s face it, we’re human and can miss something. Having a better-trained workforce, who is acting as a team, greatly reduces this possibility.

Roco Rescue Remote MonitoringMany times, we find that the role of Attendant is looked upon as simply a mandated position with few responsibilities. They normally receive the least amount of training and information about the entry. However, the Attendant often serves as the “safety eyes and ears” for the Entry Supervisor, who may have multiple entries occurring at the same time. In reality, the Attendant becomes the “safety monitor” once the Entry Supervisor okays the entry and leaves for other duties. So, there’s no doubt, the better the Attendant understands the hazards, controls, testing and rescue procedures – the safer that entry is going to be!

As previously mentioned, training requirements for Entrant, Attendant and Supervisor are all over the board with little guidance as to how much training or how in-depth that training should be. Common sense tells us that it makes better sense to train entry personnel for their jobs while raising expectations of their knowledge base.

OSHA begins to address some base qualifications in the new Confined Spaces in Construction standard (1926 Subpart AA) by requiring that all confined spaces be identified and evaluated by a “competent person.” It also requires the Entry Supervisor to be a “qualified person.” Does the regulation go far enough? We don’t think so, nor do some of the facilities who require formal, in-depth training courses for their Entrant, Attendant and Entry Supervisor personnel.

OSHA 1926.32 DEFINITIONS:
• Competent person: “One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.” 
• Qualified person: “One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” 

So, do yourself a favor…go out and interview your Entrants and Attendants on a job.
Find out how much they do (or don’t) understand about the entry and its safety requirements. Do not reprimand them for not knowing, as it may not be their fault. It may be a systemic deficiency and the training mentality of distributing a hierarchy of knowledge based on job assignment.

Simply put, we believe that arming the entry team with additional information results in safer, more effective confined space operations. After all, isn’t that what it’s all about? GO TEAM!

Additional Resources:
• Download our Confined Space Entry Quick Reference Checklist. This checklist reiterates the value of approaching permit-required confined space entries as a team. In addition to OSHA-required duties and responsibilities for the three primary roles, we have included our recommendations as well. These are duties that we feel are important for the individual(s) fulfilling that role to be knowledgeable and prepared to perform if need be.

Safe Entry Workshop: Entrant, Attendant & Entry Supervisor is now available. See the full course description for details.

Roco Rescue - Dennis O'Connell

Author's Bio: Dennis O'Connell has been a technical rescue consultant and professional instructor for Roco Rescue since 1989. He joined the company full-time in 2002 and is now the Director of Training and a Chief Instructor. He currently is responsible for Roco's training curriculum to include Confined Space & High Angle, Trench Rescue, Structural Collapse and Instructor Development. Dennis has played a key role in the development of Roco's Rescue Technician certification programs to NFPA 1006. Prior to joining Roco, he served on the NYPD Emergency Services Unit (ESU) for 17 years. He was a member of NY's Task Force 1 and has responded to numerous national disasters such as the World Trade Center and the Oklahoma City bombing.

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