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New Study: Relying on Municipal Rescuers for Confined Space Response

Tuesday, May 22, 2012

A study on the “reliance of municipal fire departments for confined space response” has been funded by a legal settlement following the deaths of two workers in a confined space incident in California.Research by the University of California, Berkeley, indicates that employers may be relying too heavily on local fire departments for confined space rescue.

These findings indicate that local fire departments may not have the resources to provide the specialized training needed for confined space rescue, especially when "response and rescue" times are such critical factors.


Key Points from Study


•  Confined space incidents represent a small but continuing source of fatal occupational injuries;

•  A sizeable portion of employers may be relying on public fire departments for permit-required confined space response; and,

•  With life-threatening emergencies, fire departments usually are not able to effect a confined space rescue in a timely manner.


Municipal Response Statistics


The study includes some very interesting statistics about fire department response times, rescue times, and capabilities. It also shows that rescue times increase dramatically when hazardous materials are present. For example, according to the report, fire department confined space rescue time estimates ranged from 48 to 123 min and increased to 70 and 173 min when hazardous materials were present.

According to the report, “estimates made by fire officers show that a worker who experiences cardiac arrest, deprivation of cerebral oxygen, or some other highly time-critical, life-threatening emergency during a confined space entry will almost certainly die if the employer’s emergency response plan relies solely on the fire department for rescue services.”

Researchers proposed that a more appropriate role for fire departments would be to support a properly trained and equipped on-site rescue team and to provide life support following a rescue.

Information excerpted from, “Confined Space Emergency Response: Assessing Employer and Fire Department Practices,” by Michael P. Wilson, Heather N. Madison & Stephen B. Healy (2012). This study was published in the Journal of Occupational and Environmental Hygiene (Feb 2012) and is available for purchase from Taylor & Francis Online.

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Multiple Confined Space Entries

Tuesday, May 08, 2012

QUESTION: What is required for making multiple confined space entries, and can an Attendant/Hole Watch monitor more than one entry at a time?

ANSWER: Good question! And, the answer is YES according to OSHA 1910.146. However, each space must be evaluated on its own merits with all regulations and requirements applying to each individual entry. Here we will provide some tips when considering one Attendant for multiple entries. This is also where preparing comprehensive rescue preplans becomes essential, and we'll start there.

Suggestions for Writing Rescue Preplans

1.  One of the first things is to identify and categorize the space as “permit-required” or “non-permit required.” You’ll need to carefully consider the possible hazards based on the information gathered.

2.  Once you’ve identified the hazards, you’ll want to consider what actions might be taken to eliminate or control the hazard to allow for a safe entry. OSHA 1910.146 defines "acceptable entry conditions" as the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.

3.  Next, you would need to consider the type of work that is going to take place inside the space. A very important question to ask... could the work create its own hazard? (An example would include hot work being performed inside the space.) Then, what about rescue capabilities and requirements? Next, you’ll need to determine whether the entry should be considered “Rescue Available” or “Rescue Stand-by?”

Roco uses the terms “Rescue Available” or “Rescue Stand-by” to better prepare for safe entry operations and in determining more specific rescue needs for that particular entry. Here’s the way we use these distinctions...Rescue Available would be your normal entry that is NOT considered an IDLH (Immediately Dangerous to Life and Health)entry. In this case, a 10-15 minute response time for a rescue team would generally be sufficient to satisfy OSHA regulations and is typical during turnarounds where multiple entries are taking place.

On the other hand, we use Rescue Stand-by when a more immediate need is anticipated, such as with a hazardous atmosphere or potentially hazardous atmosphere. For example, with an IDLH entry, it may require the team to be standing by just outside the space in order to reach the patient in a timely manner (i.e., how long can you live without air...3 to 4 minutes?)  Or, how quickly can the entrant be engulfed where there is a potential engulfment hazard?  OSHA 1910.134 requires a standby person or persons capable of immediate action with IDLH atmospheres. (See reference below.)

OSHA Reference Note to Paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §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.

Regarding multiple entries, this Rescue Stand-by status could certainly limit the number of entries that could take place due to the availability of qualified responders and equipment. You must also consider that if you’re doing an entry that requires Rescue Stand-by and are called to respond to a rescue from a Rescue Available space, the entrants at the Rescue Stand-by entry must be evacuated before the team can respond. And, if there is only one rescue team, all other entries must stop during a rescue, as the team is no longer available.
Can an Attendant cover more than one confined space entry at the same time?

According to OSHA (see below), attendants can cover multiple spaces as long as they meet the responsibilities and duties at each entry site. If the spaces are “Rescue Available” and are in close proximity, this may be possible. However, without seeing the spaces and if they are on different levels as you mentioned, it could be very difficult for an Attendant to meet all of the requirements OSHA defines for Attendants.

OSHA Notes regarding Attendants and Multiple Entries...
NOTE to 1910.146(d)(6): Attendants may be assigned to monitor more than one permit space provided the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored. Likewise, attendants may be stationed at any location outside the permit space to be monitored as long as the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored.

1910.146(d)(7) If multiple spaces are to be monitored by a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendant's responsibilities under paragraph (i) of this section;

Once all these critical factors have been reviewed, you will need to consider the following when writing a rescue plan for an identical space:

    Internal configuration
    Elevation
    Portal Size

For hazards and LOTO procedures, you may be able to use the same rescue plan to cover those spaces. An example would be in doing ten (10) ground-level entries into 6-ft deep manholes, each with a 24” round, horizontal portal with a valve at the bottom. The rescue plan may be identical for all of these entries with the same description and hazards. However, on the rescue plan, you would need to allow for any unexpected hazards such as a possible change in atmosphere. This would be needed to be detected and properly handled by the responders at the time of the incident.

So, these are some of the basics you need to consider when writing a rescue preplan for confined spaces and for determining if (and when) an Attendant can effectively monitor multiple spaces.

If you have questions concerning these topics, please feel free to contact Roco at 800-647-7626.
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Can your Rescue Team “Walk-the-Walk?” The Value of Performance Evaluations

Tuesday, January 31, 2012

As an employer with permit-required confined spaces, you’ll need to determine if your rescue team or selected rescue service can truly “walk-the-walk” when it comes to confined space rescue. OSHA’s Permit Required Confined Space Standard (1910.146) is “performance-based” – meaning it’s all about capabilities when the stakes are high.Conducting a performance evaluation of your rescue service is a vital component in determining their true capabilities as well as fully meeting the performance requirements of 1910.146.

The Dilemma

Determining the adequacy of the team’s rescue capability can present a dilemma for many employers. That is, does the employer have the depth of understanding in technical rescue required to administer an accurate, meaningful performance evaluation? Do they know what to look for in terms of proper equipment use, efficiency, compliance with industry standards, and required safety systems – just to name a few. If not, is it then possible that the team may not be able to affect rescue when the need arises?

As we know, it’s quite easy to demonstrate a rescue capability for a very “straight forward” situation. This is what we call a “Dog and Pony Show.” They tend to be very controlled and scripted to ensure that everything goes smoothly. Unfortunately, when there’s an actual emergency, it seems the victims never get a copy of the script. Unless the rescue team or service is prepared for the “other than straight forward” rescue, the operation has little chance of going smoothly. There are still way too many incidents involving injury or death to would-be rescuers that can be directly attributed to lack of proficiency in the type of rescue being attempted.

The Guidance

Fortunately, Appendix F (Non-Mandatory) of 1910.146 provides guidance for employers in choosing an appropriate rescue service. It contains criteria that may be used to evaluate the capabilities both of prospective and current rescue teams. For all rescue teams or services, the evaluation should consist of two components:

An initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform permit space rescues of the kind needed at the facility and whether such rescuers can respond in a timely manner.

A performance evaluation, in which employers measure the performance of the team or service during an actual or practice rescue.

Another way to break down these two evaluation components is something like this… 
(1) The initial evaluation is to determine if the rescue service can “talk-the-talk”; and, (2) the performance evaluation is to determine if the rescue service can “walk-the-walk.”

During the initial evaluation the employer should interview the prospective rescue service or team to determine response times, availability, a means to summons in the event of an emergency, reciprocal communications should the service/team become unavailable, whether they meet the requirements 1910.146 paragraph (k)(2), and whether they are willing to perform rescue at the employer’s workplace.

Additionally during the initial evaluation the employer should determine if the rescue service/team has the necessary equipment to perform rescues. This includes both technical rescue equipment and if a space may pose a significant atmospheric hazard which requires entry rescue, does the team/service have adequate supplies of SCBA [or SAR].

ROCO NOTE:  Another aspect often overlooked is HazMat capabilities… does the team have the proper training and PPE to protect themselves from the particular hazards they may face? Can they deal with de-con issues that may result from exposure? Or, as the employer, will you provide the appropriate PPE and decon?

Finally, the employer should evaluate if the rescue team/service has the technical knowledge for vertical rescues in excess of five feet, the knowledge of rope work or elevated rescue, if needed, and the necessary skills for medical evaluation and patient packaging. Other than the visual and/or physical review of the rescue equipment; and, if necessary, emergency breathing air, the initial evaluation of the team/service is primarily completed through interviews and a review of training documents. In other words, can the team or service “talk-the-talk”?

Therefore, it is simply not enough for an employer to rely on the initial evaluation. While it’s a good start in narrowing the field of prospective rescue team/services, it is incumbent on the employer to determine if the rescue service can indeed walk-the-walk.  And the only way to ensure that is to complete a performance evaluation during an actual or practice rescue from the actual or representative types of spaces that they may be summoned to.

The Third Party Advantage

Performance evaluations can be administered to a prospective rescue service, or as a periodic evaluation of current rescue services. As an option, an employer may choose to use a third party that has extensive experience in this type of rescue.

This is especially beneficial when employers may not have the in-house expertise necessary to administer an accurate evaluation, or for employers who are more comfortable with having a third party evaluation as a documented, independent, and unbiased record of the rescue service/team’s capabilities.

As an independent evaluator, Roco has conducted these team (TPE) and individual (IPE) performance evaluations for many years using specific grading criteria. It is a valuable tool for the employer to ensure and document that the selected rescue team/service (whether an outside service or in-plant team) has the required proficiencies for rescue at their facility. These TPE/IPEs also provide a degree of refresher training that will help bring the team/individual up to the level they need to be.

In rare instances, our recommendation may be that the team requires more than spot training in order to meet an acceptable level of proficiency. Another benefit of third party TPE/IPEs is that it may be an opportunity for the evaluator to recommend minor changes in equipment or techniques that would enhance the capability of the team. In fact, Section B of Appendix F states,

“As part of each practice session, the service should perform a critique of the practice rescue, or have another qualified party perform the critique, so that deficiencies in procedures, equipment, training, or number of personnel can be identified and corrected.”

Another area where third party evaluations are beneficial is when contractors will be providing their own rescue capability. Some host employers mistakenly believe that theyare relieved of all responsibility when the contractor’s employees are performing the entries. But 1910.146(c)(8) and (9) place reciprocal responsibilities on both employers to each other. This includes the host employer informing the contractor that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146, and the contractor informing the host employer of the permit program it will be following.

Although this paragraph of the standard lacks specific direction, it certainly contemplates that the host employer cannot turn a “blind-eye” to deficiencies in the program presented by the contractor – including insufficient rescue capabilities. A team performance evaluation would be helpful in determining the contractor’s ability to provide rescue services for their employees. While some host employers may be qualified to evaluate contractor’s technical rescue capabilities, that is usually not the case.

Keeping Skills Fresh

Employers must also realize that technical rescue skills are very perishable. While a team or individual can successfully complete rescue training and attain a high degree of proficiency, regular practice is crucial to maintaining these skills. Unfortunately, all too often, the time and resources required to maintain this level of proficiency are not provided. How quickly these skills erode will vary. However, even with the most experienced rescuers, they will eventually lose their edge if practice time is not provided. For newer rescuers that complete their training but don’t the chance to practice fairly soon, their skills can erode at an incredibly fast rate.

The degree of difficulty for the anticipated rescues must also be considered. When more complex rescues are involved, teams may require even more training and practicetime to maintain their level of expertise. And, while a training certificate is good to have, the only way an employer can truly know if the rescue team/service meets the OSHA performance requirement for confined space rescue is by completing a properly administered performance evaluation.

For all those employers who have workers entering confined spaces to work, we hope that you will carefully consider this rescue evaluation process – it could save a life or even prevent multiple fatalities. For you rescuers out there, we hope that you will do everything you can to maintain and increase your proficiencies – so when the time comes, you can walk-the-walk with pride in a job well done.

If you would like additional information on a documented Team Performance Evaluation for your rescue service, please contact Roco at 800-647-7626.
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INVISIBLE HAZARD KILLS AGAIN

Wednesday, January 18, 2012

Roco Director of Training/Chief Instructor, Dennis O’Connell reviews the importance of following OSHA safety standards for confined space entry, no matter how many times workers have entered the space. The take away? With confined spaces…It’s NEVER old hat! The importance of preplanning confined space entries and identifying “potential hazards ”should be old hat by now. Yet every year we are still killing entrants and rescuers in confined spaces.

In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

Atmospheric Hazards Continue to Claim Lives in Confined Space Entry Scenarios

The importance of preplanning confined space entries and identifying “potential hazards” should be old hat by now. Yet every year we are still killing entrants and rescuers inconfined spaces.  In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

It’s always important to remember that each entry stands alone. Each and every time a space is entered, we need to:

(a) identify potential hazards;

(b) eliminate or control them, when possible;

(c) use proper PPE; and,

(d) have an EFFECTIVE Rescue Plan.

Otherwise, as in this story, we will lose or injure workers as well as those attempting the rescue.

Start from scratch and treat each entry like it’s the first time you’re entering the space – it could save your life.

Keep in mind, the history of a space really has nothing to do with the current entry. We’ve all heard people say, “We do this all the time, and we’ve never had a problem!” Or, “We’ve entered this space a thousand times and the air is always good!” Remember this… IT DOES NOT MATTER!! This entry has nothing to do with the last.

As you read of yet another unfortunate incident, let it be a reminder to those of us who make entries or do rescues from confined spaces – do not let your guard down, do not get complacent…it could be deadly. Atmospheric hazards are still one of the leading ways that people are dying in confined spaces. Because humans are visually oriented by nature, if we can see a hazard, we’ll protect ourselves from it. However, if we can’t see it, we tend to assume it’s safe. OSHA’s 1910.146 PRCS standard and others were developed for a reason… people were making tragic mistakes and dying in confined spaces. These standards and guidelines are written so we don’t make the same mistakes.

OSHA FINES UTILITY FIRM $118,580 FOLLOWING WORKER’S DEATH

OSHA has cited a contracting and utilities company for two willful and two serious safety and health violations following the death of a worker at the company’s Texas facility. Proposed penalties total $118,580. An inspection was initiated by OSHA on June 28 in response to a report that employees working on a new sewer line were exposed to inhalation of a hazardous chemical. One employee who entered a manhole to remove a plug in order to flush out accumulated debris became overwhelmed by toxic fumes and died. Another employee was hospitalized after attempting to rescue his co-worker.

The willful violations are for failing to test for atmospheric conditions and provide adequate ventilation and emergency retrieval equipment prior to entry into a manhole.

The serious violations are failing to provide or require the use of respirators as well as conduct an assessment to determine the potential for a hazardous atmosphere where oxygen deficiency, methane, and/or hydrogen sulfide were present or likely to be present.

“The company failed to ensure that proper confined space entry procedures were followed,” said Jack Rector, OSHA’s area director in Fort Worth. “If it had followed OSHA’s safety standards, it is possible that this tragic incident could have been prevented.”
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RESCUE IV-ADVANCED SCENARIOS

Wednesday, December 07, 2011

We’ve had so many requests for “advanced-level scenario training” that we’ve added Rescue IV to our 2011 schedule. You can add new techniques to your rescue toolbox while putting your problem-solving skills to the test.Challenging confined space and high-angle evolutions, including Roco’s“Yellow Brick Road” multi-station scenario, will give rescuers and rescue teams the most realistic rescue experience possible. This 40-hour course will challenge participants in a wide variety of confined space and high angle rescue scenarios.

RESCUE IV – ADVANCED SCENARIOS (40 hours)
Prerequisite: Rescue I-Plus or Industrial I/II

Challenging confined space and high-angle evolutions, including Roco’s “Yellow Brick Road” multi-station scenario, will give rescuers and rescue teams the most realistic rescue experience possible. This 40-hour course will challenge participants in a wide variety of confined space and high angle rescue scenarios.Advanced problem-solving skills and additional techniques will equip rescuers to function more effectively in time-critical emergency situations. This 40-hour course will challenge individual rescuers and rescue teams in a wide variety of confined space and high angle rescue scenarios. These scenarios will increase in complexity to include simulated IDLH and non-IDLH atmospheres, using both SCBA and SAR air equipment. For training conducted at Roco’s training facility, practice scenarios will be completed in all six (6) types of representative confined spaces. At other sites, the number of types completed will depend on the availability of practice spaces.This course will provide documented confined space practice scenarios in accordance with OSHA 1910.146 and as referenced in NPFA 1006.

OSHA 1910.146(k)(2)(iv)

Ensure that affected employees 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. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

NFPA 1006 A.3.3.38 Confined Space Type

Figure A.3.3.38* shows predefined types of confined spaces normally found in an industrial setting. Classifying spaces by “types” can be used to prepare a rescue training plan to include representative permit spaces for simulated rescue practice as specified by OSHA. (*Roco Confined Space Types Chart)
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