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Successful Engulfment Rescue in Iowa

Monday, November 26, 2018

Our congratulations to the Burlington (Iowa) Fire Department on a successful grain bin rescue that happened in their community back in May of this year (2018). The incident was reported on Firehouse.com.

The Burlington Fire Department responded to an incident with a man trapped up to his neck inside a corn grain bin in a rural area. Upon arriving at the scene, the initial ambulance unit spoke with the victim’s son who told them that his father was buried up to his armpits inside the bin. The son had thrown a rope down to his father to prevent slipping further down into the corn. Fortunately, the victim remained calm and was able to communicate with the responders.

The bin, designed to hold up to 30,000 bushels of corn, was two thirds full on that morning.
Responders used a Res-Q-Throw Disc typically used in water rescue to lower an O2 bag with an attached non-rebreather mask to the victim.

As additional response vehicles arrived on scene, proper positioning of the apparatus was critical in assisting the rescue. The department’s aerial truck was positioned in a narrow lane between two grain bins and a barn where the aerial was deployed by the crew. The aerial was initially raised to the roof level where crews (two firefighters and two deputies) had assembled including the victim’s son.
To reduce weight on the roof of the structure, one of the deputies and the son came down from the structure.
Crews soon realized that the only way to rescue the gentleman was to set up a rope system and lower a responder into the bin. The aerial was put in place to assist this operation. An incident command vehicle was set up a short distance behind the aerial, offering excellent visibility to the Incident Commander.

Rescue equipment was gathered from various apparatus to include main and secondary life safety ropes as well as other needed gear. Pulleys were attached to the manufactured anchor points on the bottom of the aerial platform. A change-of-direction pulley was fixed to the front of the aerial truck directing the pulling action of the rope to a large grassy area in front of the truck. The main line was rigged with a 5:1 system while the secondary line was rigged with a 2:1 system. CMC MPDs were used as the descent-control device for both lines. On-scene personnel reportedly highly praised these devices.

A firefighter donned a Class III-harness to be lowered through a small opening in the top of the bin to the surface level of the corn, which was approximately 25 feet below. The aerial platform was positioned above the opening and remaining personnel on the room tended the lines. These personnel also assisted in lowering equipment down to the rescuer via a rope.

As part of the equipment being lowered were several milk crates and soda bottom flats, which became an essential part of the operation by distributing the rescuer’s weight on the corn. These crates, positioned in a horse-shoe pattern around the victim, allowed the rescuer to walk across the surface of the corn. A truck belt was lowered into the bin and was positioned around the victim’s chest. It remained attached to the secondary line to prevent the victim from slipping down further into the corn.

Finally, a six-paneled grain rescue tube was lowered into the bin panel by panel. Each panel was placed around the victim and then hammed into place with a TMT Rescue tool. The panels were fastened together to form a solid tube. When secured, the tube protected the victim from shifting corn and relieved some of the pressure being exert on him.
Throughout the process, the ground team kept the rescuer on a short leash to prevent him from falling into the grain himself.

A 4-gas atmospheric monitor with an extra-long sampling tube was used to test the air inside the bin to make sure the rescuer and victim were not in an IDLH atmosphere. The meter was monitored continuously throughout the rescue operation by fire personnel who was positioned on an extension ladder on the exterior of the bin near the opening. He also functioned as a safety officer for operations inside the bin and on the roof and relayed communications for the rescuer inside the space.

A neighboring fire department had brought a special grain rescue auger that was lowered into the bin. The rescuer inserted the auger inside the rescue tube and slowly removed the corn from around the victim’s chest. After the tube was secured around the victim, the IC had called for two relief cuts to be made in the bin – one cut near the victim and the other directly opposite it on the other side of the bin, which was used to empty the bin of corn. Crews used K-12 saws to cut a large triangular opening in the bin wall. The second opening was made by forcing open a door in the side of the bin near the victim. These doors, which swung inward, could only be opened after a significant amount of grain spilled from the cut made on the other side of the bin.

Local road crews which had been on site brought a large-end loader and a smaller skid loading to the scene and used them to push large amount of corn away from the openings in the walls, which enabled a continuous flow of corn.

In approximately 2-1/4 hours after crews arrived on scene, the victim was able to walk from the bin. He refused air transport but consented to ground ambulance transport where he was treated for minor injuries.

Again, our congratulations to the Burlington Fire Department as well as all the agencies involved in making this a successful rescue.

Notes:
The department noted several lessons learned which include:

• Grain bin rescue is a high hazard, low frequency event. The department recognized the importance of its training in ropes and rope operations as well as training with specialized rescue equipment.
• It was determined that the roofs of the grain bins hold far less weight than originally surmised.
• The aerial platform was a key factor in the rescue operation. It was used as an anchor point and for staging equipment. Physical limitations and maximum load-bearing capability must be carefully considered and even more especially when ropes are being utilized. Weight and angles of the aerial must be factored into the operation.

Source: www.Firehouse.com

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Safe Confined Space Entry - A Team Approach

Wednesday, September 26, 2018

by Dennis O'Connell, Director of Training/Chief Instructor

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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Know When NOT to Enter a Confined Space!

Friday, August 17, 2018

There are countless injuries and deaths across the nation when workers are not taught to recognize the inherent dangers of permit spaces. They are not trained when "not to enter" for their own safety. Many of these tragedies could be averted if workers were taught to recognize the dangers and know when NOT to enter a confined space.

While this incident happened several years ago, it emphasizes the senseless loss of life due to a lack of proper atmospheric monitoring and confined space training. Generally, the focus for training is for those who will be entering spaces to do the work. However, we also must consider those who work around confined spaces – those who may be accidentally exposed to the dangers. Making these individuals aware of the possible hazards as well as to stay clear unless they are properly trained.

Note: This case summary from the New York State Department of Health goes on to say that the DPW had a confined space training program but stopped the training after the last trainer retired.

CASE SUMMARY - TWO (2) FATALITIES
A 48-year-old male worker (Victim I) employed by the Department of Public Works (DPW) and a 51-year-old male volunteer firefighter (FF Victim II) died after entering a sewer manhole located behind the firehouse. In fact, the Fire Chief was on scene because he had been called by the DPW general foreman to unlock the firehouse and move the firetruck so it would not be blocked by the DPW utility truck working at the manhole. Another firefighter also arrived to offer assistance, he later became FF Victim II.

The manhole was 18 feet deep with an opening 24-inches in diameter (see photo above). Worker Victim I started climbing down the metal rungs on the manhole wall wearing a Tyvek suit and work boots in an attempt to clear a sewer blockage. The DPW foreman, another firefighter and FF Victim II walked over to observe. They saw Victim I lying on the manhole floor motionless. They speculated that he had slipped and fallen off the rungs and injured himself. The Fire Chief immediately called for an ambulance.

Meanwhile, FF Victim II entered the manhole to rescue Victim I without wearing respiratory protection. The other firefighter saw that FF Victim II fell off the rungs backwards while he was half way down and informed the Fire Chief. The Fire Chief immediately called for a second ambulance and summoned the FD to respond. FD responders arrived within minutes.

The Assistant Fire Chief (AFC) then donned a self-contained breathing apparatus. He could not go through the manhole opening with the air cylinder on his back. The cylinder was tied to a rope that was held by the assisting firefighters at the ground level. The AFC entered the manhole with the cylinder suspended above his head. He did not wear a lifeline although there was a tripod retrieval system. He secured FF Victim II with a rope that was attached to the tripod.

FF Victim II was successfully lifted out of the manhole. The AFC exited the manhole before a second rescuer entered the manhole and extricated Victim I in the same manner. Both victims were transported to an emergency medical center where they were pronounced dead an hour later. The cause of death for both victims was asphyxia due to low oxygen and exposure to sewer gases.

Contributors to the Firefighter's Death:
• Firefighters were not trained in confined space rescue procedures.
• FD confined space rescue protocol was not followed.
• Standard operating procedures (SOPs) were not established for confined space rescue.

The DPW had developed a permit-required confined space program but stopped implementing it in 2004 when the last trained employee retired. They also had purchased a four-gas (oxygen, hydrogen sulfide, carbon monoxide and combustible gases) monitor and a retrieval tripod to be used during the training. It was reported that a permit-required confined space program was never developed because DPW policy “prohibited workers” from entering a manhole. However, the no-entry policy was not enforced. Numerous incidents of workers entering manholes were confirmed by employee interviews.

This incident could have been much worse. Training is the key, whether it’s just an awareness of the dangers in confined spaces or proper entry and rescue procedures. In this case, the victims had no C/S training even though they may have to respond to an incident, and the worker had not had on-going training through out his career. Periodic training to keep our people safe and aware of proper protocols is key to maintaining a safe work force.

Unfortunately, training is usually one of the first things to be cut when the budget gets tight; however, after an incident, it usually becomes the primary focus. Often the lack of training is determined to be a key element in the tragedy.
Investing in periodic training for the safety of your workforce includes spending the time and money to keep your trainers and training programs up to speed and in compliance. The old saying, “closing the barn doors after the horses escaped,” is no way to protect your people – a little investment in prevention goes along way in preventing these tragedies.

One last comment on my biggest pet peeve – proper, continuous air monitoring. This one step can reduce the potential of a confined space incident by about 50%! Don’t take unnecessary chances that can be deadly.

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. Prior to joining Roco, he served on the NYPD Emergency Services Unit (ESU) for 17 years.

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Do’s & Don’ts for CS Attendants (Hole Watch)

Thursday, October 19, 2017

There continues to be a misconception that a confined space attendant (or “hole watch”) is a menial task to be assigned to the greenest, most inexperienced personnel on the job. That’s a dangerous assumption, and it has been a contributing factor in many confined space fatalities.

In fact, the attendant or hole watch should have a solid understanding of the permit space to be entered. This includes knowing the particulars of any known or potential hazards as well as other pertinent knowledge and skill sets. If you are assigned this crucial role, I hope you understand that the entrant(s) are relying on you. Your performance may have a significant bearing on the outcome, both good and bad.

Do you know everything you need to know in order to perform your duties as a confined space attendant? Don’t assume that you will learn everything you need to know after a two- or three-minute pre-job briefing.

Being an attendant or "hole watch" is a critically important role and failure to properly perform these duties has led to multiple fatalities – both for the entrants and the attendants themselves.

Do understand the known and potential hazards of the confined space. Do take the time to review the SDS (MSDS) for any and all materials or gasses that may be encountered. Do learn what the signs and symptoms of exposure may be. Then, if you detect any of them in the entrant’s behavior or appearance, you can order immediate evacuation.

Don’t gloss over this valuable and readily accessible information only to wonder what caused the entrant(s) to lose consciousness. The SDS (MSDS) provides information on route of exposure; and very importantly, the signs and symptoms of exposure. Don’t miss the opportunity to save the day, and perhaps a life, by learning these early warning signs. This allows evacuation of the space before entrants are no longer able to do so on their own.

Do learn the proper operation of any testing equipment, such as atmospheric monitors. It is also important to understand the limitations of this equipment as well.

Do keep track of all authorized entrants in the space. For entries with multiple entrants, don’t rely on your memory alone. Do use some sort of log or entry roster as a reliable means to accurately identify who is in the space.

Do make sure that you have a reliable means to communicate with the entrants. Do test that means of communication at the very limits of the space to ensure it works. Don’t wait until there is an incident to learn that you cannot alert the entrants, or you cannot hear that their status has changed. If you haven’t heard from the entrants in a while, it can be tempting to go into the space to check on them. This very situation has led to many fatalities in which the attendant was overcome by the same hazard as the authorized entrant(s). At that point, there is no longer anyone available to call for help.

Don’t accept the job assignment until you have been briefed by the entry supervisor on all the planned activities both inside and outside the space. Do remember that oftentimes activities outside the space can create a hazard for the entrants inside the space. Carbon monoxide and spills of hazardous materials are just a couple of examples.

Don’t allow any activities to take place inside or outside the space that are prohibited and are not consistent with the conditions stated on the entry permit, especially if they may create a hazard to the entrants. If those activities were not coordinated and told to you by the entry supervisor, do evacuate the space and call the entry supervisor for guidance.

Don’t leave the space or perform other duties that may interfere with your primary duty of monitoring and protecting the entrants.

Do remain diligent, remember that you are the critical link between the entrants and the rescue service.

Do know how to contact rescue services should they be needed. Don’t wait until it is too late to call for help. Do summons rescue as soon as you determine that the entrants may need assistance escaping from the space. Just remember, you can’t turn back the clock and buy back the time that entrants may have needed to survive. It’s a whole lot easier to turn around the rescue service if it is not needed.

Don’t allow unauthorized persons to approach or enter the permit space. If you are unable to warn them away, do order the evacuation of the authorized entrants. Do immediately inform the entry supervisor of the situation.

Do perform non-entry rescue (retrieval) when needed and if authorized by your employer. Do perform a thorough pre-entry inspection on the retrieval rescue equipment. Do make sure it is appropriate for the type of rescue that may be needed. Do learn and practice the proper operation of the retrieval equipment. Don’t wait until there is an emergency to try and figure it out. Don’t attempt entry rescue unless you are authorized, trained and equipped to do so. Don’t attempt entry rescue until you are relieved by another authorized attendant. Remember, you cannot leave the space unattended!

Don’t take your responsibilities lightly. Do ask the right questions of the entry supervisor and your authorized entrants. Do realize that they are all counting on you. Do ask to be briefed by the entry supervisor regarding any coordination that has been made with other work groups in the area. Do remember that many attendants have perished attempting heroic but ill-advised and unauthorized rescue attempts.

Do remember that your authorized entrants are relying on you. Do take the initiative to learn everything you need to know and how to operate any equipment in support of your entrants. As the hole watch, you are the critical link that can make or break a successful entry operation.

Click picture to download Safety Requirements for Confined Space Attendants.

 Written by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

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The Clock's Ticking on Timely Response

Tuesday, April 25, 2017

By Dennis O'Connell, Roco Director of Training & Chief Instructor

As Director of Training, I get many questions about rescue techniques and regulations from our students and readers. In the past month alone, I have received three inquiries about "timely response for rescue teams" regarding permit required confined spaces (PRCS). So, let's break it down and try to clear the air on this subject. For clarification, we will refer to the General Industry Standard 1910.146; the Construction Standard 1926-1211; and the Respiratory Standard 1910.134.

In 1910.146, OSHA provides guidance on timely response in Subpart K (Rescue and Emergency Services) and again in Non-Mandatory Appendix F (Rescue Team or Rescue Services Evaluation Criteria). Subpart (k)(1)(i) states: "Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified."

This one sentence actually says volumes about response times. The first question to be answered is, "Can the rescue service respond in a timely manner?" It then gives a hint as to what a timely manner should be based on. The second part of the sentence refers to "considering the hazard(s) identified." What this so eloquently says is the response time must be determined based on the possible hazard(s). This means the "known and potential hazard(s)" must be identified for each space to be entered. The hazards discovered -- based on severity, type, how rapidly the hazard could become IDLH or injure the worker, how quickly the need to treat the injury, or how quickly hazards might interfere with the ability to escape the space unaided -- would then be used to determine an acceptable response time. This is why OSHA only alludes to response times and does not set hard and fast times to follow -- it depends on the hazards of that particular space.

Another aspect we need to consider is that "response time" begins when the call for help goes out, not once the team is on scene. It ends when the team is set-up and ready to perform the rescue. So, how long will it take your team to be notified, respond and set-up is a big portion of that acceptable response time calculation. For example, a dedicated onsite fire/rescue team would be able to respond faster than workers who have other responsibilities and need to meet at the firehouse before responding. Or, more quickly than an outside service, such as a municipal department, that would have to respond to the facility, get through the gate, and be led to the scene.

In the note to paragraph (k)(1)(i), it adds: What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA 1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

Here we see OSHA better defining an acceptable response time for IDLH atmospheres -- i.e., immediate action! However, it's important to note this doesn't just refer to low O2...depending on the type of contaminant in the atmosphere, other respiratory equipment such as half- or full-face APRs could be used. It may include a dusty environment where the entrant wears a mask and visibility is less than 5 feet. Technically, that would be considered an IDLH environment. Many people get hung up on the use of SAR/SCBA as the trigger for a standby team, and that is just not the case.

For an IDLH atmosphere where respiratory protection is needed, an adequate number of persons (rescuers) is required to perform a rescue from the type of space involved - ready, trained, equipped and standing by at the space -- ready to take immediate action should an emergency occur. So, when dealing with possible IDLH atmospheres, we are looking at "hands-on" the patient in 3-4 minutes as possibly being an appropriate response time. Basically, this is about how long an entrant can survive without air. The only way to safely make rescue entry in that time frame is to have rescuers standing by, suited up and ready to go!

So, if dealing with an IDLH atmosphere, we revert back to 1910.134. Many people think that that is the only time we need a team standing by ready to take immediate action. I pose the question, "If the hazard is a liquid (engulfment hazard), what would be a reasonable response time?" If the victim is Tarzan or Johnny Weissmuller (okay, Michael Phelps, for you younger people), we may have a longer stay-afloat time. But if a non-swimmer, or in an aerated solution or other engulfment hazard, immediate action may be their only chance of survival! And, what about radiation (time, distance, shielding)? I am sure you can think of a few more possibilities.

And, while OSHA referred to an IDLH atmosphere in this example, it's important to consider other IDLH hazards as well. Here's where we note that the definition of IDLH in the Respiratory Standard (1910.134) differs slightly in Permit-Required Confined Spaces (1910.146). The Respiratory standard specifically refers to an IDLH "atmosphere" while the PRCS standard states the following: Immediately dangerous to life or health (IDLH) means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. This includes more than simply atmospheric hazards! 

OSHA NOTE: Some materials -- hydrogen fluoride gas and cadmium vapor, for example -- may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim feels "normal" until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.

In Non-Mandatory Appendix F (I hate that non-mandatory language), OSHA gives guidance on evaluating response times under Section A - Initial Evaluation. What are the needs of the employer with regard to response time (time for the rescue service to receive notification, arrive at the scene, and set up and be ready for entry)? For example, if entry is to be made into an IDLH atmosphere, or into a space that can quickly develop into an IDLH atmosphere (if ventilation fails or for other reasons), the rescue team or service would need to be standing by at the permit space. On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutes might be adequate.

Not a bad paragraph for a non-mandatory section of the standard! Here they explain what they are looking for in regards to response times. They even take the OSHA 1910.134 IDLH atmosphere requirement for a team standing by at the space a little further by adding "or into a space that can quickly develop into an IDLH atmosphere." It also states if the hazard is mechanical in nature, 10-15 minutes might be adequate. That’s right, "might" not will be, but might be. Again, it depends on the hazard.

Paragraphs 2-7 in Appendix F goes on to describe other conditions that should be considered when determining response times such as traffic, team location, onsite vs. offsite teams, communications, etc. If you have not done so, I highly recommend that you review the not-so-Non-Mandatory Appendix F. It is also important to note that while it's not mandatory to follow the exact methods described in Appendix F, meeting the requirements are! OSHA also uses the word "should" in Appendix F, not following the OSHA recommendations could certainly lead to some hard questions post incident.

OSHA 1926 Subpart AA Confined Spaces in Construction closely mirrors 1910.146. In this relatively new standard, they simplified the definition of timely response and omitted Non-Mandatory Appendix F, which helps to eliminate the confusion of the "non-mandatory" language, and included the requirements right in the standard, which is good. However, 1910.146 really gives you a better idea of what timely would be for different situations through the notes in Section (k) and Appendix F.

Section 1926.1211 of the Construction Standard for Rescue and Emergency Services (a)(1) states: Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. This is immediately followed by: Note to paragraph 1926.1211(a)(1). What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA1926.103, Respiratory Protection (for construction) requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

In closing, these regulations are driving you in the same direction for identifying what a timely response would be...THERE IS NO SET TIME FRAME! Each space must be evaluated based on potential hazards and how quickly rescue would need to take place. I hope this will make you take a closer look at "how and what" you consider a timely response. An employer's PRCS program must identify and evaluate the rescue resources to be used. It is then up to the entry supervisor to make sure the identified rescue service is available to respond in a timely manner, which can literally mean life or death for the entrants.

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