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NEW 2014: ProBoard & IFSAC Option in Roco's Fast-Track 80™

Friday, September 20, 2013

Roco is excited to announce that beginning in 2014, we will offer a ProBoard/IFSAC option conducted by the Carrol L. Herring Fire & Emergency Training Institute for select Roco courses at the Roco Training Center (RTC) in Baton Rouge. Students choosing the ProBoard option will complete both a written and skills exam. Upon successful completion of this certification process, they are then eligible to be entered into the ProBoard’s certification registry.

The first Roco course to offer FETI’s accredited certification testing will be our Fast-Track 80™ course to be held on February 20-22 & 24-28, 2014. There is an additional charge of $100.00 per student, and advance registration is required. Call us at (800) 647-7626 to register and reserve spaces or get more information.

The ProBoard is an internationally recognized professional organization that represents the fire service and related emergency response fields. The ProBoard accredits organizations, such as the Carrol L. Herring Fire & Emergency Training Institute, that provide certification testing to the National Fire Protection Association’s (NFPA) professional qualification standards. The International Fire Service Accreditation Congress (IFSAC) is a peer driven, self-governing system that accredits both public fire service certification programs and higher education fire-related degree programs.

Visit ProBoard's website  or watch their video about the benefits of seeking fire service certifications through a ProBoard accredited entity.

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Proposed NFPA 350 Confined Space Guide: Approved for Comments

Saturday, August 31, 2013

NOTICE: If you are involved in any kind of confined space work or rescue, you need to read this document and offer your comments. This applies to anyone who may work in or near confined spaces, both industrial and municipal.

At a meeting earlier this month, NFPA’s Guide for Safe Confined Space Entry and Work (Draft) was approved for public comment by the NFPA Standards Council.

This document is designed as a “best practices” guide for those who work in and around confined spaces. As with any document that attempts to be all inclusive, it may work well for some while negatively affecting others. Therefore, it is very important that "WE" the public, the people who will be using this type of document in real world applications, offer our feedback. Now is the time to offer comments and suggestions. Comments as to what may or may not be feasible for your organization or what may have been overlooked in this document are a vital part of this NFPA process.

As contributing members for this document, we are encouraging you to take the time to make your suggestions in order to create a practical guide that will be user friendly and provide for greater safety when working in confined spaces. As you read it, please keep in mind that it is currently listed as a “Best Practices Guide.” However, this does not mean that at some point in the future it won’t possibly become an NFPA Standard.

This document could eventually affect the way you do your job, so it’s very important to all of us for it to be a safe, practical best practices guide. Every comment or suggestion must be addressed by the sub-committees. So, whether you agree or disagree, the time to offer your input is NOW!

Public comment will be accepted online until January 3, 2014. Go to www.nfpa.org/350. In order to comment, you must log in with your email and password – or you can quickly create an account.

Click here to download the PDF version. (Note: Download may take up to 3 minutes depending on your computer.)

 

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Q&A: Is a construction manhole considered a permit required confined space?

Wednesday, August 28, 2013

READER QUESTION:
Is a new construction manhole considered a permit required confined space with the following activities being performed inside the space: overhead rigging, cutting welding, working off of six foot (6') step ladders? The task being performed is installation of new steam and condensate piping. Entry into the manhole vault is through a thirty six inch (36") round manhole opening into a vault. The vault is sixteen feet (16') deep. Entry is made by descending a twenty foot (20') extension ladder placed into the manhole opening. No other entry holes or exit holes. A 2000 cfm air mover is also in use for ventilation of the space. The area inside is congested with piping and valves being installed. Would this be considered a permit required confined space and would a rescue team be required?

ROCO TECH PANEL RESPONSE:

The answer to this question is complicated, and without actually seeing the space and without having familiarity of all the specifics surrounding the construction of the space, we cannot give you a definitive answer. However, there are several things you must consider when evaluating the situation.

You must determine whether the space falls under General Industry (29 CFR 1910) or Construction (29 CFR 1926) requirements. If the work is considered “maintenance,” the General Industry standards are applicable. If it is considered “Construction,” the Construction standards are applicable. OSHA generally considers any work that entails “keeping equipment in its existing state, i.e. preventing its failure or decline,” as “maintenance” work covered by the General Industry standard, even if the work is construction “type” work.

From your description, it appears that the installation of new steam and condensate piping is part of the initial “construction” of the vault. However, other factors could affect that determination, such as whether the new steam and condensate lines are actually part of maintenance of an already existing piece of equipment. In that case, the vault itself may be new, but the work on the lines might be maintenance.

If the General Industry standard applies, OSHA takes the position that the PRCS standard (29 CFR 1910.146) does not apply to welding, cutting, and brazing activities as long as the hazards introduced by the welding are the only hazards in the space, and the protective measures of Subpart Q - Welding, Cutting and Brazing, are adequate to prevent a hazard from developing.

The protective measures of the welding standard would be applicable to the work in this space, specifically the following paragraphs of Subpart Q: 1910.252(a)(4)(i), 1910.252(b)(4)(i) to 1910.252(b)(4)(vii), 1910.252(c)(4), 1910.252(c)(9), and 1910.252(c)(10). All other hazards must be considered when making the determination of whether the PRCS standard applies. For example, if piping or other equipment will be lowered into the vault from overhead while workers are in the space, there would be a potential physical hazard not covered by Subpart Q that might require the space to be classified as a PRCS.

The General Industry standard for welding, cutting, and brazing activities does have certain requirements that are similar to some of the PRCS requirements. 

For example, it requires that where a welder enters a confined space through a manhole or other small opening means shall be provided for "quickly" removing him in case of an emergency. If harnesses or "safety belts" are used for this purpose, they have to be attached so that the welder's body cannot be jammed in a small exit opening. It also requires that "an attendant with a preplanned rescue procedure shall be stationed outside to observe the welder at all times and be capable of putting rescue operations into effect."

The General Industry welding standard also has certain specific ventilation requirements for spaces that are less than 10,000 cubic ft per welder, or in confined spaces where there are partitions or other obstructions that would obstruct cross ventilation. The minimum rate for such ventilation is 2,000 cfm per welder. It is important to keep in mind that the 2,000 cfm per welder is the actual air movement provided by the air mover, not the rated air movement. The ventilation must be configured to ensure that the air mover is not recirculating contaminated air back into the space. This would usually involve moving the air mover away from the entry point when there is a single opening, and ducting the air into the space. However, the use of ducting reduces the actual air movement. For example, an air mover rated at 2,000 cfm maximum will not actually be moving 2,000 cfm with 50’ of ducting having a 90 turn into the space. Each foot of ducting and each turn in the ducting reduces airflow. You stated that a 2,000 cfm air mover is being used. It is important to conduct the calculations for your ventilation configuration to determine whether you are actually moving the minimum 2,000 cfm.

Until OSHA issues its final rule on confined space safety for the construction industry (ruling is expected in 2013), there is no detailed standard at this time. However there is a construction standard for welding that has specific requirements for welding, cutting, and brazing in confined spaces (29 CFR 1926.353). The rescue requirements are the same as for the General Industry welding standard. Additionally, the Construction welding standard requires that if sufficient ventilation cannot be obtained without blocking the means of access, the employees in the confined space must be provided with airline respirators, and there must be an employee outside the space assigned to maintain communication with the employees in the space and to provide assistance in an emergency.

Obviously, to us, rescue capabilities are always at the top of the list. If the decision is made to follow the General Industry standard and consider the vault to be PRCS, then rescue capabilities and a plan need to be put in place. Depending on the conditions that exist in and around the space, rescue retrieval may be an option, such as a tripod and winch system with retrieval line attached to the entrant. In your description, however, you mention that internal elements that may hinder the ability to do external retrieval. If this is the case, then some type of internal rescue capability will be needed.

When it comes to the response time, we think Appendix F 1910.146 explains it best… 

"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 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."

Thank you for your question, and we hope this information has been helpful. If we may be of further service, please don’t hesitate to contact us.


NOTICE:
The information provided on our website or by our Tech Panel is a complimentary service for our readers. It is a general information resource for rescuers and is not intended as legal advice in any way. Because standards and regulations are typically performance based, and compliance with those standards and regulation is often dependent on the specific circumstances and conditions at hand, it is always important to carefully review all relevant standards and regulations, and to follow the proper protocols specific to your company or agency.

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Update: Question to OSHA on Individual Retrieval Lines

Tuesday, September 18, 2012

Report submitted by John Voinche', Sr. Vice President/COO, Roco Rescue

In July, a group of Roco instructors conducted a Confined Space Rope Rescue demonstration for OSHA representatives from Washington, DC. These agency officials represented both General Industry and Construction. This demo was used to clarify our concerns about a pending Letter of Interpretation (LOI) concerning Individual Retrieval Lines in confined spaces that was brought to our attention last year. Here is a little background…

Last July (2011), we brought you a story entitled, “What’s the talk about individual retrieval lines?”  At the heart of the issue was a pending LOI from OSHA regarding how retrieval lines are used inside confined spaces. [Note: This LOI is pending and has not been published in the Federal Register.]

Here’s the question to OSHA from a gentleman in Maryland which initiated the LOI…

“Does OSHA 1910-146 (k)(3) require that each individual entrant, including workers and/or rescuers, entering into a confined space be provided with an independent retrieval line or can more than one entrant be connected to a single retrieval line?”

The proposed answer from OSHA stated that each entrant should have an “individual” retrieval line, despite the fact that the word “individual” is not included in this section of the standard [1910.146 (k)(3)(i)].
 
Roco then wrote a letter to OSHA requesting clarification about the forthcoming LOI. A portion of our letter stated that, “This pending interpretation is different from our understanding of what’s required by the regulation. While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.”

One of the techniques being used is a “single retrieval line” for multiple entrant rescuers. The first rescuer to enter the space is attached to the retrieval line via an end-of-line Figure 8 on a Bight. Any subsequent rescuers enter the space attached to the same retrieval line using mid-line Butterfly knots. In our opinion, this satisfies the intent of the regulation in that each entrant is attached to a retrieval line.

However, in the case of multiple entrants, requiring “individual” lines as mentioned in the proposed LOI may represent an entanglement hazard. This, in effect, may cause entrants to opt out of using retrieval lines due to potential entanglement hazards (which is allowed by the standard if entanglement hazards are a concern). So, in our opinion, this effort to bring more clarity to the issue may further complicate the matter.
 
Again, we believe the single retrieval line method described above is one way to rescue entrants while satisfying the intent of the standard at the same time. More background is available by reading our original story.

Fast-forward back to July 2012… the demonstration lasted about four hours. During this time, Roco demonstrated numerous retrieval line techniques as well as the “pros and cons” for each system. There was a great deal of discussion back and forth on how this pending letter of interpretation could affect rescuers and entrants – and their ability to perform their jobs safely and efficiently.
 
We would like to thank OSHA for allowing us to offer our feedback concerning this topic. We also want to say a special thanks to the Baltimore Fire Department for allowing us to use their training facilities. We don’t know when a final LOI will be issued, but we will keep you posted!
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LAFD promotes Confined Space Awareness

Tuesday, June 26, 2012

“It is our experience that the victims, would-be rescuers, and co-workers either fail to adhere to their emergency plans or simply do not have a plan in place, with catastrophic results... In the last year alone, we have responded to three confined space rescues.”- Battalion Chief Jack Wise of the Los Angeles Fire Department

Joint Effort for Confined Space Awareness Education


The California Department of Industrial Relations' Division of Occupational Safety and Health (Cal/OSHA) joined forces March 28 with the Los Angeles Fire Department to urge employers and employees to prepare properly for working in confined spaces. Officials from both agencies participated in a news conference where LAFD personnel gave a confined space rescue demonstration and potential hazards were explained.

Cal/OSHA launched a statewide confined space education and awareness campaign in February after seven confined space deaths and numerous injuries in 2011. Illustrating the variety of industries where confined spaces are common, those deaths occurred at a Fortune 500 pharmaceutical facility, a winery, a paint manufacturing plant, and a recycling center.

“Today's event with the Los Angeles Fire Department helps raise awareness of the hazards associated with working in confined space environments and the need for employers to have an effective emergency response plan in place before a critical situation arises,” DIR Director Christine Baker said. “As a national leader in workplace safety, Cal/OSHA is working with labor, employers, and public safety officials to eliminate this type of preventable fatality in the workplace.”

Some of the 2011 fatalities involved potential rescuers attempting to aid someone who had collapsed in a confined space. “These confined space deaths and serious injuries were all preventable had safety practices been in place. It is even more tragic that, in many cases, workers attempting to rescue their co-workers also fall victim,” said Cal/OSHA Chief Ellen Widess. “Confined spaces can be deceptively dangerous. Employers need to assess if they have such a hazard, identify and mark those spaces, [and] provide employee and supervisor training and on-site rescue plans and equipment.”

Cal/OSHA has posted extensive information about confined space hazards on its website at http://ohsonline.com/articles/2012/03/30/la-fire-department-boosts-confined-space-awareness.aspx
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