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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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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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Is Your Rescue Team Ready?

Monday, July 23, 2018

Guidance for improving and maintaining rescue team proficiency...

We all want to succeed, no matter what we are doing. And success is always better than the alternatives…whether a mediocre performance or worse yet, failure. When it comes to rescue, all of a sudden, the difference between success and failure takes on much greater significance.Not only are the lives of the rescue subjects held in the balance, but also the rescuers. Multiple risks are involved with technical rescue and failure may cost the rescuers mightily, and this has been proven too many times. There are many things, however, that rescuers can do to help improve their chances of success, and that's what we will talk about here. 

We have found that the one thing that seems to be a lagging factor is a "lack of proficiency" in performing the required skills either as individuals or as a team. Having rescue preplans, the newest and best equipment, sufficient manning, and reliable communications are all pieces of the puzzle. But all of that becomes nothing more than window-dressing if the team or individuals on the team are unable to perform their duties safely and effectively. This is such an important consideration that several regulations and standards make a point to remind us that proficiency is a high-interest issue. 

For instance, OSHA 1910.146 paragraph K and Appendix F, as well as 1926.1211, require designated rescuers to practice making permit space rescues at least once every 12 months by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. It is our position that this does not even come close to the training time needed to maintain an appropriate level of proficiency. 

Additionally, NFPA 1006 requires rescuers to demonstrate competency on an annual basis. One of NFPA’s recommendations is to attend workshops and seminars, read professional publications, and participate in refresher training as ways technical rescue personnel can update their knowledge and skills. 

I am routinely asked how often a rescue team should practice. And they're always a bit surprised when I do not give them a hard and fast answer such as quarterly or monthly for a minimum of 4 hours. My answer is and will always be, “as often as it takes to ensure you are proficient, as individuals and as a team, to safely and effectively rescue potential victims from any situation you may be called to respond.”

You would be amazed at the spectrum of training schedules that are out there. Some teams practice on a bi-weekly basis and mix in different scenarios to ensure they will not miss any opportunities to improve their skills or to identify any gaps they may have in technique or equipment. Whereas other teams may feel that once a year is all that they need. Knowing how perishable these skills are, we tend to disagree.

It has been our experience that the teams who practice on a very regular basis and really mix it up when they design their training scenarios are the ones who perform best when they come to our facility or we go to theirs for a team performance evaluation (TPE), which can also include an individual performance evaluation (IPE), if desired. The teams and individuals that struggle most during our TPE/IPE visits are the ones that seldom train. And, even though we all call these TPE/IPE visits, we do provide tips and spot training to help correct any deficiencies observed. 

But frequency is no guarantee of excellent performance. It isn’t just about the quantity of training; it must be the quality of training as well. One of the best ways to supplement in-house training is to attend third party refresher training. Or, if it has been a while since a full-on training class, by all means a more extensive and complete training package may be a great option. Roco's annual Rescue Challenge provides an excellent learning experience as well as a way to confirm the true rescue capabilities of your team. 

Technical rescue skills are one of the most perishable skills I have known. Without regular practice and quality training, it is not long before the individual and team skills erode to the point of becoming a liability to the victim and to other team members.

Again, none of us wants to fail - especially on a rescue mission. A good way to avoid this is to dedicate adequate resources to training along with regular refreshers and practice drills. Prepare and practice for your "worst case" scenarios because you just never know when your team may be put to the test. Be ready!

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

About the Author:
Pat Furr has been employed with Roco since 2000 and has been actively involved with technical rescue since 1981. Pat is a Chief Instructor for Roco as well as its VPP Coordinator and Safety Officer. He is also a presenter at national conferences such as ASSE and VPPPA. Prior to Roco, Pat served 20 years in the USAF as a Pararescueman (PJ). His background includes eight years as a member of the 71st Pararescue team in Anchorage, Alaska, where he specialized in mountain and glacier rescue. Pat was a team leader of the 1986 and 1988 PJ teams that summited Mt. McKinley and augmented the National Park Service mountain rescue team. He also spent two tours of duty in Iceland where he put in multiple “first ascent” ice routes.


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Why Use a High-Point Dorsal Connection Point?

Friday, July 06, 2018

We recently had a Facebook inquiry about attaching a rappeler's belay line (safety line) to their high-point dorsal connection on their harness. We choose to do this for a number of reasons including: (a) compliance with applicable regulations; (b) adherence to safe and practical rescue procedures; and, (c) the physiological effects of falls – how the body absorbs an impact force. Let’s take a general look at these considerations.

Compliance

OSHA considers our rappel/lower main lines as “work positioning” lines and our belay or safety lines as “fall protection.” The fact that they and we, as rescuers, consider the safety line as fall protection, or more accurately as our Personal Fall Arrest System (PFAS), kicks in a few requirements and considerations for all private sector responders and for municipal responders governed by OSHA-approved State Plans. These responders are required to comply with applicable OSHA regulations.

However, keep in mind, these regulations are designed to protect workers (and rescuers) from harm and injury. During training, since it is not a real rescue, we should be following the applicable regulations and standards for safety as well as liability reasons. Even during actual rescues, it is important to adequately protect our people from injury. The days of “rescue at all costs” are gone. We are responsible for designing training, systems and SOPs/SOGs that protect our people in a rescue situation.

Note the following key points from OSHA 1926.502(d):

• Limiting the free fall distance (max free fall 6 feet)
“…be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level”

• Deceleration distance of 3.5 feet (41 inches)
“…bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m)”

• Maximum allowable impact load 1,800lbf.
“…limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness”

• Improvised anchorage strengths of 5,000lbf or twice the anticipated load.

“Anchorages used for attachment of personal fall arrest equipment shall be…capable of supporting at least 5,000 pounds (22.2 kN) per employee attached…”
“Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.”

• Harness attachment should be to the high-point dorsal connection point.

“The attachment point of the body harness shall be located in the center of the wearer's back near shoulder level, or above the wearer's head.”

You may have heard the statement, “Firefighters/rescuers don't need fall protection or need to follow OSHA.” This is not true for the 27 State Plan states where OSHA regulations do apply to public sector employees including emergency responders. It puts the burden on the employer, agency or department to establish fall protection and rescue protocols that would adequately protect their people.

To illustrate this, here is an excerpt from an article written by Stephen Speer, a NY career firefighter, for “Fire Rescue” magazine which deals with potential OSHA violations during rescue operations and training exercises. (Note: New York is a State-Plan state.)

“I spoke to a New York State Public Employee Safety & Health (PESH) supervisor about the following scenario and asked if there were areas that could be potential violations.

Scenario: A firefighter operating from a roof ladder is cutting a ventilation hole on a pitched roof. The firefighter falls from the roof and is injured.

In what areas, if any, could an incident commander or company officer be cited? In response, I received 12 pages of documentation. The documents showed that in evaluating potential violations of the general duty clause to see if anyone is responsible, the following four elements must be met:

1. The employer failed to keep the workplace free from a hazard to which employees of that employer were exposed.
2. The hazard was recognized.
3. The hazard was causing or likely to cause death or serious physical harm.
4. There was a reasonable and adequate method to correct the hazard.

NFPA 1500, chapter 8.5.1.1, states that operations should be limited to those that can be completed safely. In this scenario, there is the potential for citation if all four elements apply. As the above scenario illustrates, whether or not you have an aerial apparatus, you must consider fall arrest protection.”

Practicality

When rescuers are sent into a vertical confined space, we use the safety line (PFAS) to protect them as they are being lowered and raised from the space. It is also used as “an immediate means of retrieval” should something go wrong inside the space. Having the safety/retrieval line attachment point at the high-point dorsal position allows us to attempt an emergency retrieval with the victim being extracted in a low profile to fit through a narrow portal.

Physiological Effects

There have been numerous studies on the effects on the body when subject to a fall and arrest while in a harness. They generally come to the same conclusion that high-point dorsal attachment is the most survivable and provides for the greatest injury reduction. Here are excerpts from two studies.

1) Excerpt from a study conducted by Dr. M. Amphoux entitled, “Exposure of Human Body in Falling Accidents,” which he presented at the International Fall Protection Seminar in 1983:

In experiments on the position of the attachment point on the harnesses, Amphoux found that a high attachment point was preferable because “it gave a better-disposed suspension” and that it was “especially effective when the attachment is on the back. When the falling stops, the neck flexes forward. If the attachment point is in the front of the sternum, the neck flexes backwards and the lanyard may strike the face.”

Amphoux continued that it would be better for the compression to be localized on the body of vertebrae and not on the posterior joints, which were too fragile. “Therefore,” he said, “the attachment point would be better on the back than pre-sternal and should be high enough to reduce the potential neck injury. In addition, the forward flexion would be stopped by the thrust of the chin on the chest.”

This was why Amphoux and his colleagues strictly recommended attachment high on the back. It also protected the face from the lanyard when falling. In the case of falling head first, regaining a feet-first position would involve flexion of the head, whereas if the attachment were pre-sternal, the head would more often be projected backwards [whiplash effect].

However, it was accepted that a front attachment might be preferred in a few working situations. This was only acceptable when the height of the potential fall was very short. Whatever the choice of body support, it should not be forgotten that it was only a compromise and not a guarantee of absolute security.

2) Excerpt from “Survivable Impact Forces on Human Body Constrained by Full Body Harness,” HSL/2003/09 by Harry Crawford:

The one-size-fits-all policy of some harness manufacturers may not be suitable for the range of body weight 50kg to 140kg. Although it may be possible for those in the wide range of body weight/size to don such a harness, the position of the harness/lanyard attachment is of paramount importance. For best performance and least risk of injury, the attachment should be as high as possible between the shoulder blades.

Note: They also concluded that the shorter the fall, the less impact and less chance of injury no matter which type of harness or where the connection point was.

Conclusion

Like any rescue or work safety technique, you need to look at all the variables and decide which technique and equipment will best protect you or your co-workers. We choose the high-point back connection because of the variety of situations and locations we might face during a rescue based on the three considerations mentioned earlier in this article.

Thanks for a great question and taking the time to look into the reasons why systems or techniques are used. I hope this answers your question. If you have additional questions, please contact me at 800-647-7626.

By Dennis O'Connell, Roco Director of Training

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