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Roco QUICK DRILL #10 - Tripod Quick Drill

Monday, February 08, 2016

Rescue tripods provide a mobile and rapidly deployable high-point anchor option for confined space emergencies. Like any piece of equipment, however, it has its limitations. It is important that your team becomes proficient with this tool in training to ensure fluid deployment during a live rescue. 

There are two primary topics to review regarding rescue tripod operations: Set-Up and Rigging. Here’s a quick drill to help you and your team become more proficient in its use.

Set-Up

1. Find an area to review your tripod operations. Ideally, train over a potential rescue space, keeping in mind safety around any open spaces. As with any training exercise, always use proper PPE and take proper fall protection precautions. If you don’t have access to potential spaces or are training in a municipal environment, improvise with a closed street manhole or create a mock-up opening with wood or cardboard.

2. Deploy your tripod. While you are deploying it, discuss the following with your team:

a. When do you setup the tripod in a rescue operation? Prior to rescuer entry? During packaging stage? During extrication stage?

b. Do we setup the tripod over the space or in a safe area, then move the tripod over the space?

c. What type of patient packaging will be done and at what height will the tripod need to be in order to clear packaging out of space?

d. Tripod strengths at different height settings. Is height more important or strength?

e. Can the legs of the tripod be different lengths or rest on different elevated surfaces?

f. Should the tripod be tied down so it won’t tip?

g. Keeping resultant forces within the legs of the tripod to prevent tipping.

h. Insure correct assembly, including the use of the tripod’s chain to prevent overspreading the legs of the tripod.

Now that your tripod is assembled, move on to rigging.

Rigging

Rig each of the following systems and raise and lower a load/weight. This shows the pros and cons of operating each system. Show how the resultant forces can be applied by the haul position or by patient movement outside the tripod footprint. In most cases, there are three rigging options for tripod operations. Rig each, while discussing each method’s strengths and weaknesses.

1. Block and Tackle System

a. Often pre-rigged and therefore rapid to deploy.

b. Will the length of the collapsed system create height constraints to remove the victim from the space?

c. Does the height of the tripod create any issues operating the cam of the system?

d. Rope length vs depth of space; what strength M/A will you be able to build?

e. Can the haul team keep resultant haul forces within the legs or footprint of the tripod to prevent tipping, or do we need to have a change of direction pulley?

2. Single Main Line with COD (change of direction) within the Tripod’s Footprint

a. Better option when the tripod’s height and victim clearance are concerns.

b. Enables the lower/haul team to operate remote of the space.

c. Necessitates an anchor point within the tripod’s footprint and an anchor point for the main line.

d. Allows for reaching greater depths than a block and tackle system.

e. Single line entering the space and allows for attachment of patient air bottle.

f.  Takes more time to rig.

3. Pass-Through Method

a. A solution when the block and tackle or single main line techniques will not work (no anchor point within footprint of tripod available).

b. Increased Mechanical Advantage (6x1).

c. Requires two remote in-line anchor points on opposite sides of the space.

d. Two traveling lines in the space.

e. Eliminates concerns with haul-resultant forces.

f. Most complicated of the three systems.

A properly deployed rescue tripod can be a game changer for a confined space rescue. As with any piece of equipment, continuous training with the device and its associated techniques is necessary to maintain “proficiency,” which translates into safety and efficiency! Always, train hard so that your team will perform when the call comes!

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Service Life Guidelines for Rescue Equipment

Wednesday, January 20, 2016
Regardless of the stated service life, the condition of equipment–as determined through inspection by a qualified party – is a key factor in determining whether or not a piece of equipment is fit for service.

THIS INSPECTION PROCESS OFFERS GUIDELINES FOR KEEPING EQUIPMENT IN SERVICE OR RETIRING IT.

Depending on the manufacturer, you will find varying specifications for service life of rescue equipment. For example, Petzl specifically defines the “potential” service life of plastic or textile products to be no longer than 10 years. It states indefinite for metallic products. CMC, on the other hand, does not give specified times for their equipment stating, “The service life of equipment used for rescue depends greatly on the type of use and the environment of use. Because these factors vary greatly, a precise service life of the equipment cannot be provided.” However, in reference to harnesses, CMC’s cites ASTM F1740-96 as the industry standard for service life. SMC follows along the lines of CMC when stating the amount of time a product can stay in service.

Although the definition of “equipment lifespan” is very broad depending on the manufacturer, each will provide specific instructions on proper inspection of equipment and detailed explanations on when to the retire service item.

Most manufacturers follow the same general guidelines for removing equipment from service. Several general identifiers that pertain to all equipment are shown below. 

Download Roco's Quick Checklist for your convenience. →

REASONS FOR EQUIPMENT RETIREMENT INCLUDE:

  •   Item fails to pass any pre/post use or competent person inspection.
  •   Item has been subjected to a major fall or load.
  •   Item is constructed of plastic or textile material and is older than 10 years.
  •   You cannot determine the complete full-use history of item.
  •   You are not certain or have lost confidence in the equipment.

Most manufacturers will provide service for equipment items that are repairable. However, most caution against this because the cost of repair typically exceeds the cost of replacement. Any repairs attempted outside of the manufacturer may void any warranty and will release the manufacturer from any liability or responsibility. In addition, all manufacturers recommend destroying equipment once it has been retired from service to prevent items from inadvertently being recycled back into active service gear.

Manufacturers also provide indicators for different types of equipment that require it to be retired from service. These are not only capturing the general conditions mentioned above, but also bring in conditions that are specific to each category of equipment. It is important to identify these specific conditions as they are vital to the dependability and functionality of each component.

Harnesses:

Harnesses are one of the most vital components of life safety equipment. Without a certified harness in serviceable condition, the best life safety rope and hardware in pristine condition will do little to protect the user. All individuals who are required to wear harnesses to perform duties should be trained and authorized in the inspection process. Harnesses should be inspected before and after use as well as once annually by an individual deemed a competent person by the facility or department.

Since harnesses are a nylon product, they fall under the guidelines set forth by ASTM consensus standard F1740-96 and have a service life of 10 years. Manufacturers also state that hard or excessive use – as well as the conditions when a harness is used – may significantly reduce its service life. It is important to conduct routine inspections as well as keep records of harness use. This “usage” history could indicate signs that would require the equipment to be retired early.

Here are some conditions to help identify when it’s time to retire your life safety harness:

  •   The harness has surpassed 10 years since the manufacture date.
  •   Webbing shows signs of cuts, significantly worn or frayed areas, soft or hard spots.
  •   Webbing shows signs of discolored or melted fibers.
  •   Stitching shows signs of pulled threads, abrasion or breaks.
  •   Hardware shows signs of damage, sharp edges, excessive wear or improper function.
  •   If the harness has been subjected to shock loads, fall loads, or abuse.
  •   If there is any doubt about the integrity of the harness.
  • If the harness demonstrates any of these conditions, it should be removed from service and destroyed.

  • Life Safety Rope, Webbing, Anchor Straps, Accessory Cord:
       

Since these products are nylon or textile based as well, they fall under the same inspection process as harnesses. A complete inspection of life safety rope and associated products includes not only a visual inspection but a tactile (or touch) inspection as well. The tactile inspection should be done with tension on the rope, webbing or strap. 

The inspector is looking to identify any of the following conditions:

  •   Chafed, glazed or discolored surfaces (these areas should receive a more thorough inspection).
  •   Abrasions or cuts in the sheath where the core is exposed.
  •   Variation of diameter of the rope that could indicate potential damage to the core fibers.
  •   Soft or hard spots that could indicate core damage or that the fibers have been over stressed.
  •   If the rope has been subjected to shock loads, fall loads or abuse.

If any of these conditions are noted, then the item should be retired and destroyed immediately. It is important to remember that an accurate history should be maintained for all life safety rope products. The date of manufacture should be identified and recorded as products are being put into service. Equipment inspectors or users should ensure that these products do not exceed their service life. As with harnesses, the amount, type and conditions of use can drastically reduce the service life of these products.

Carabiners:

Since carabiners are metallic, they do not fall under the ASTM service life recommendation of 10 years. As long as these products are in serviceable condition and properly maintained, they have an infinite service life. Even though they do not have a dedicated service life term, it is still important to conduct the same pre/post use and annual inspections. 

Some conditions that would require the equipment, such as carabiners, to be retired from service include:

  •   Carabiner has been dropped a significant distance.
  •   Exposed to heat sufficient enough to alter the surface appearance.
  •   Cracks, distortion or deep gouges.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Gate does not line up when closed.
  •   Gate action does not return to closed position when opened and released.
  •   Locking mechanism does not fully engage.
  •   Complete history of use cannot be determined.
  • If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items even though the service life of the product is infinite.
Pulleys:

Pulleys, as with carabiners, are metallic in construction and do not have a service life recommendation. They will also have an infinite service life as long as they are in serviceable condition and are properly maintained. Pulleys fall under the same inspection requirements as carabiners. 

Below are some conditions that would require such equipment to be removed from service:

  •   Pulley has been dropped a significant distance.
  •   Exposed to heat sufficient enough to alter the surface appearance.
  •   Cracks, dents or elongation at the carabiner hole on side plates.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Deep scratches or gouges to side plates or sheave(s).
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Side plates that do not line up at the carabiner hole.
  •   Elongation of the side plates at the sheave pin.
  •   Side plates that do not move freely.
  •   Sheave does not turn freely or significantly rubs against side plate.
  •   If the item has been subjected to shock loads, fall loads or abuse.
  •   If the history of use or manufacture date cannot be determined.

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items even though the service life of the product is infinite.

DeScent control devices:

Descent control devices, if metallic, do not have a service life recommendation. If the device is constructed of plastic or other textile material, it will have a service life not to exceed 10 years. 

Below are some conditions that would require this equipment to be removed from service:

  •   Cracks, deformations or elongation to any portion of the device.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Deep scratches or gouges to any portion of the device.
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Excessive wear to friction surfaces or cam (see wear indicator on some devices).
  •   If the device has been subjected to shock loads, fall loads or abuse.
  •   If the history of use or manufacture date cannot be determined.

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items throughout their service life.

Ascenders:

As with previously mentioned equipment, the same inspection procedures apply to ascenders. 

Below are some of the conditions that would require ascenders to be removed from service:

  •   Cracks, deformations or elongation to any portion of the device.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Deep scratches or gouges to any portion of the device.
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Fouled teeth on cam (handled type ascenders).
  •   Excessive wear to surface of cam.
  •   Damage to rivets (if applicable).

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items throughout their service life.

Service history is an extremely important part of ensuring life safety equipment is properly maintained and that service life is not exceeded. Not only does this help rescue teams control inventory and operational capability of equipment by documenting each use and inspection, it also assists the teams in forecasting budget costs for the replacement of items that are nearing the end of their service life.

Maintaining records of the manufacturer’s information received when purchasing new equipment is vital to identifying and keeping track of the manufacture date. It is also important to keep this information on file for the exact procedures for inspecting and removing equipment from service. If the manufacture date of equipment, such as life safety rope and harnesses, cannot be identified; it poses extreme liability for agencies or facilities whose teams may potentially be operating with equipment that has passed its service life. It could also create a compromise in the safe operation of the equipment. Also, if record-keeping of equipment inspection and use is not a primary focus, it could potentially expose team members to operating with unsafe equipment due to abuse or excessive/extreme conditions that go undetected.

All team members should be qualified and knowledgeable enough to perform pre- and post-use inspections of equipment. It is crucial that all members document each use of equipment, denote any deficiencies, and report to the proper person. One person should be designated to perform the competent person annual inspection. This person should have complete knowledge of the equipment and inspection procedures as well as the authority to keep or remove equipment from service as they see fit. If team members are unable to fill this role, a qualified third party with applicable manufacturer certifications in competent person inspection should be brought in to assist in determining the condition and estimated service life of rescue equipment. For assistance from our rescue equipment professionals, call us at 800-647-7626.

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NFPA Issues New Guide for Confined Spaces

Thursday, January 07, 2016
“Up until now, requesting or researching OSHA Letters of Interpretation or checking with other safety professionals was the means to get a clearer picture of ‘how’ to accomplish safe and compliant confined space entry. NFPA's Guide for Safe Confined Space Entry (NFPA350) helps to bridge that area from regulation to compliance. It is a ‘must have’ resource for safety professionals, confined space owners/workers and rescuers as well,”  states, Dennis O'Connell, Director of Training for Roco Rescue, who served as an alternate committee member for NFPA 350.

Here's more from NFPA on their new guide...

Every year, confined space incidents result in worker deaths, injuries, and serious illnesses. The danger is widespread because all facilities can have confined spaces - from commercial buildings and hospitals to public works, utilities, and chemical/industrial facilities. By U.S. law, employees must comply with applicable regulations such as OSHA's 29 CFR 1910.146 and 29 CFR 1926 Subpart AA to ensure personnel safety. However, these regulations tell you 'what' to do, not 'how' to identify, evaluate, and control confined space hazards or conduct rescue response.

NFPA has just introduced NFPA 350: Guide for Safe Confined Space Entry and Work. This all-new guide is essential for anyone who enters confined spaces, along with facility managers, code officials, and safety personnel. NFPA 350 explains how to protect workers who enter into confined spaces for inspection or testing, or to perform associated work. Provisions address the full range of special hazards, including those present in water treatment, petrochemical, and agricultural facilities. It provides information to assist companies that need to comply with OSHA's Permit-Rquired Confined Spaces (29 CFR 1910.146) among other standards. In addition, NFPA 350 helps fire service and emergency services personnel develop and evaluate plans for confined space rescue in conjunction with NFPA 1670: Standard on Operations and Training for Technical Search and Rescue Incidents.

This guide will help you be prepared to recognize, evaluate, and control confined space entry hazards. Follow practices developed by experts for: 

    • • Identification of Confined Spaces
    • • Evaluation of Hazards
    • • Atmospheric Monitoring
    • • Hazard Elimination and Control
    • • Ventilation
    • • Rescue and Rescue Planning
    • • Confined Space Personnel Duties, Responsibilities, and Competencies
    • • Pre-Entry Evaluation Forms and Permits
    • • Management of Change
    • • Prevention Through Design
    • • OSHA Alternate Entry Procedures and Reclassification (Annex C)

As an added note, NFPA 350 looks at all confined spaces from a different prospective- i.e., all spaces are treated as "permit required" until it is proven that entry is safe or the proper precautions have been taken. This guide's impact in confined space work and rescue will be significant in reducing risk and meeting compliance issues. For more information, visit NFPA.org.

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Gravedigger Engulfed In Cave-in of Unguarded Grave

Monday, January 04, 2016
“A Trench is a Trench is a Trench”

An employee of a cemetery in Farmingdale, New York, was seriously injured on May 7, 2015, when the walls of the grave opening in which he was working collapsed and buried him up to his waist.

An inspection by the Long Island Area Office of the U.S. Department of Labor’s Occupational Safety and Health Administration found that the excavation and its support systems lacked adequate protection against cave-ins and the excavation had not been inspected to identify such deficiencies. Other hazards included damaged equipment and the placement of excavated soil on the edge of the unprotected trench. These conditions exposed employees to the hazards of cave-in, engulfment and struck-by injuries.

This worker literally came close to an early grave because the cemetery failed to provide proper excavation protections. 

“This cave-in could have been prevented if proper and legally required trenching safety procedures had been followed by the employer,” said Anthony Ciuffo, OSHA’s Long island (NY) area director. “It is imperative that cemeteries ensure that workers at all its cemeteries are protected against cave-in hazards and ensure that an incident such as this does not happen again in the future.”

OSHA cited the company on Nov. 5, 2015, for two willful and three serious violations of workplace safety standards.

Roco Comments from Dennis O’Connell, Director of Training:

You may think of this is an unusual circumstance, a once in a lifetime event. Sorry, but you’re wrong. During my tenure as a rescuer in NYC, I responded to a number of these jobs, and they present some additional hazards that are not associated with most trench rescue jobs.

You can call it what you want, but a grave is a trench. And the location can make a big difference in terms of hazards presented. For example, I have a house in NY and one in Louisiana – in South Louisiana, we try to bury people above ground, if possible! However, in places like NY, cemetery space is so limited. It’s like high-rises in the city, our cemetery family plots bury multiple family members usually 3 on top of the other, which is referred to as a triple depth grave. This pushes the grave depth to about 8 feet for the first entombment.

So, no matter what you call it – a trench is a trench, and we need to follow OSHA 1926.651-652 requirements for protecting workers. Let’s look at some of the grave/trench basics before we move on to the specific grave hazard. If we dig an excavation that is longer than it is wide, it is a considered a trench – if it is 4’ or deeper, you need to have a ladder or other means of egress for workers; if it is 5’ or deeper, you need to install a protective system.

You must have a Competent Person, as defined by OSHA, to determine what system is adequate and that it is installed properly. They must also inspect the trench and surrounding area for hazards before workers can enter the trench. Of course, there’s a lot more to digging a trench and the responsibilities of the competent person but you get the idea.

Also, just because a trench is only 7’ long and 3’ wide, this does not change the rules or responsibilities associated with digging a trench. If you’re digging a trench, you need to have that competent person; you need to understand the requirements of 1926.651-652; and you need to know who will respond if you have a trench emergency. Keep in mind, most municipal departments, especially volunteer departments, do not have the training or equipment to respond to a trench collapse.

Ok, the added hazard to a grave collapse rescue is the headstone at the end of the grave – depending on the size, they can weigh over 1,000lbs. If it has fallen in the grave on top of the victim, then you will need to use technical rescue techniques and equipment to lift and free the victim. If it is still on the edge, you will need to support, stabilize or remove it before rescuers can work under it. So, even an innocent grave, can be the scene of a complicated technical trench rescue.

Bottom line… if you are digging trenches for whatever reason, or you have contractors digging trenches on your property, you need to be aware of the requirements of 1926.651-652, have a “competent person,” and identify who you are going to call if a collapse happens.

FYI, you need to have 2.9 feet of soil above the casket top. Some say that it’s a public health law. Between you and me, I think it’s to keep Zombies from escaping!

Here is an OSHA fact sheet to help you better understand some of the requirements. OSHA Fact Sheet - Trenching and Excavation Safety

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Worth the Wait...OSHA’s Confined Space Standard for Construction

Tuesday, December 15, 2015

In our opinion, the new OSHA regulation for Confined Spaces in Construction (Subpart AA of 1926) was worth the wait! This new standard is well thought out and includes some significant as well as subtle differences from the General Industry Permit Required Confined Space Standard 1910.146.

In this article, we will point out additional requirements for compliance for construction activities involving confined spaces. With the exception of residential construction, the final rule became fully enforceable as of October 2, 2015.   

These additional requirements instituted by OSHA are due to the dynamic nature of the construction environment. Dynamic in terms of the continuously evolving configuration of the workplace, and also in the diverse and ever-changing makeup of employers and employees depending on the phase of construction. We feel the most significant differences are not complete shifts in an administrative or operational approach to conducting safe permit required confined space operations, but more of an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.

“We believe the new standard offers an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.”

Please pay particular attention and review 1926 Subpart AA for requirements to ensure clear communication and coordination between the varied entities that work in or adjacent to the construction areas that have confined spaces. The lack of accurate communication and coordination continues to be a cause of confined space fatalities.

The need to communicate with the controlling contractor and entry employers regarding any operations that may have introduced a hazard into a confined space is of paramount importance. The failure to do so has repeatedly led to disaster for unsuspecting follow-on entrants into those confined spaces. Likewise, understanding and communicating the types of operations adjacent to, or in the proximity of confined spaces that may negatively affect that entry operation, must be coordinated and communicated.

Also, several new roles and responsibilities have been added to the confined space regulations. One of the most important new roles is that of the “competent person” for confined spaces.

Having a dedicated individual (Competent Person) who has the expertise and background to perform this critical function will undoubtedly result in lives saved.

OSHA has also added clarification to the need to ensure that the designated confined space rescue service is not only available at the time entry operations commence, but also that rescue service must now agree to notify the entry employer if a situation arises that renders them unable to respond to an emergency.


So let’s take a look at some of the particulars of these new requirements and clarifications.

1. Allows an Entry Permit to be suspended, instead of cancelled in the event of changes from the entry conditions list. Ref: 1926.1205(e)(2)

This differs from 1910.146(e)(5) which requires an employer to terminate entry and cancel the entry permit. This change has specific requirements and limits. Suspending a permit is only allowed when a condition that is not allowed under the entry permit arises in or near the permit space and that condition is: (a) temporary in nature; (b) does not change the configuration of the space; and/or, (c) does not create any new hazards within it.

The first action of the entry supervisor must be to terminate entry and ensure all authorized entrants have safely evacuated the space. At that point, the entry supervisor can suspend or cancel the entry permit. Prior to authorizing reentry, the entry supervisor must fully reassess the space before allowing reentry.

2. Includes more detailed provisions requiring coordinated activities when there are multiple employers at the worksite.

This is an important difference compared to the General Industry regulation. It is required due to the ever-changing makeup of the construction workforce and most especially when the need for workers from multiple employers must enter permit spaces at the same time, or perform work activities in the vicinity of the permit space – thus, the potential to introduce new hazards to the space that all employers on site must be aware of and prepare for.

This final provision differs from 1910.146(d)(11) by specifically addressing the need to coordinate work activities through the controlling contractor, as well as with employers working outside the permit space when their work could foreseeably affect conditions within a confined space. The new construction industry standard goes far beyond by outlining the need for coordinated activities between multiple employers by identifying specific roles – host employer, controlling contractor and the entry employer. (Refer to Chart.)

OSHA 1926.1203 General Requirements paragraph (h) includes specific communication and coordination requirements between the various employers and contractors. The host employer must provide certain information they may have about confined spaces to the controlling contractor.

Required information includes items such as:
(a) The location of known permit spaces;
(b) The nature of hazards in those identified permit spaces;
(c) The reason for classifying the space as permit required; and,
(d) Any additional precautions that the host employer, any other controlling contractor, or entry employer have previously employed to protect their employees must be provided.

It is also incumbent upon the controlling contractor to obtain information from the host employer regarding the hazards associated with the permit spaces and any information on previous entry operations into that permit space.

The controlling contractor is responsible for passing information to any entry employer that may authorize entry into that permit space as well to any other entity at the worksite that could foreseeably create a hazard that may affect that confined space.

The entry employer must obtain from the controlling contractor all the information regarding the particular permit space hazards and entry operation information. Additionally, the entry employer must inform the controlling contractor of the provisions of their permit required confined space program and any hazards they expect to confront or create during their entry operations.

It is also very important that the controlling contractor and all entry employers coordinate their activities when multiple entry employers have entrants in the same space, or when other activities around the permit space may create a hazard that affects the confined space entry operation.

At the completion of entry operations, it is equally important that all entities including entry employers and controlling contractors communicate information regarding the particulars of any given entry. This information must include the permit space program followed during the entry operation as well as any hazards confronted or created during entry. Of particular importance is to communicate any hazards created within the confined space that may still be in place. The controlling contractor in turn communicates all of this information to the host employer.

3. Requires a Competent Person to evaluate the work site and identify confined spaces, including permit spaces.

Along with the increased need for strong communications and coordination, the addition of the role of competent person for confined spaces may be one of the most important differences between the general industry standard and the construction standard.

It may seem to be a subtle difference in the two standards’ requirements, but now there is a specific role, or an identified position for conducting an evaluation of the worksite to determine the presence of confined spaces, a determination of the known or potential hazards associated with those confined spaces, and that has the authority to eliminate the identified hazards.

The competent person for confined spaces must have a high degree of expertise in identifying confined spaces and to make an accurate determination of the nature of any known or potential hazards associated with the confined space that would trigger it to be classified a permit space. In the event that the configuration or use of a non-permit required confined space changes, or a new hazard is introduced, the entry employer must have the competent person reevaluate that space to determine if it has become a permit required confined space. This is also true for any confined space that may not have initially been adequately evaluated to identify any known or potential hazards that would require that space to be classified a permit required confined space.

4. Designated rescue service must agree to notify the entry employer immediately if it becomes unavailable.

Although it has always been implied in the general industry standard that the entry supervisor would ensure the designated rescue service is available during entry operations, 1926.1211 explicitly requires an employer to designate a rescue service – in turn, the rescue service agrees to notify the entry employer immediately if they become unavailable to respond.

5. Provide an early warning system for non-isolated engulfment hazards.

This is primarily for sanitary and storm drain entry operations, but is equally important for any entry operations of a similar nature. The type of early warning systems can be as simple as posting an individual as an “upstream watch” to more complex systems such as electronic sensors or camera systems. Whatever system is used to detect an impending engulfment hazard, it must include a means of communications to provide advanced warning to the downstream entrants in time to safely evacuate the space.

We encourage our readers to spend time studying the new regulation, and in particular understanding the points we have highlighted in this article as well as in our downloadable Confined Spaces in Construction Safety Poster. If you have questions, or if we may be of service, please contact us at 800-647-7626.

 

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