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It's Final-Confined Spaces in Construction-Effective 8/3/15!

Monday, May 04, 2015

The Occupational Safety and Health Administration today issued a final rule to increase protections for construction workers in confined spaces. 

Confined spaces rule (29 CFR 1926 Subpart AA) could protect nearly 800 construction workers a year from serious injuries and reduce life-threatening hazards…Construction protections now match those in manufacturing and general industry. 

Manholes, crawl spaces, tanks and other confined spaces are not intended for continuous occupancy. They are also difficult to exit in an emergency. People working in confined spaces face life-threatening hazards including toxic substances, electrocutions, explosions and asphyxiation.

Last year, two workers were asphyxiated while repairing leaks in a manhole, the second when he went down to save the first – which is not uncommon in cases of asphyxiation in confined spaces.

“In the construction industry, entering confined spaces is often necessary, but fatalities like these don’t have to happen,” said Secretary of Labor Thomas E. Perez. “This new rule will significantly improve the safety of construction workers who enter confined spaces. In fact, we estimate that it will prevent about 780 serious injuries every year.”

The rule will provide construction workers with protections similar to those manufacturing and general industry workers have had for more than two decades, with some differences tailored to the construction industry. These include requirements to ensure that multiple employers share vital safety information and to continuously monitor hazards – a safety option made possible by technological advances after the manufacturing and general industry standards were created.

“This rule will save lives of construction workers,” said Assistant Secretary of Labor for Occupational Safety and Health Dr. David Michaels. “Unlike most general industry work sites, construction sites are continually evolving, with the number and characteristics of confined spaces changing as work progresses. This rule emphasizes training, continuous work site evaluation and communication requirements to further protect workers’ safety and health.”

On OSHA's website, it also states than an employer whose workers are engaged in both construction and general industry work in confined spaces will meet OSHA requirements [for 1910.146] if that employer meets the requirements of 29 CFR 1926 Subpart AA - Confined Spaces in Construction.

Five (5) key differences in the construction rule, and several areas where OSHA has clarified existing requirements:

  1. More detailed provisions requiring coordinated activities when there are multiple employers at the work site. This will ensure hazards are not introduced into a confined space by workers performing tasks outside the space. An example would be a generator running near the entrance of a confined space causing a buildup of carbon monoxide within the space.
  2. Requiring a competent person to evaluate the work site and identify confined spaces, including permit spaces.
  3. Requiring continuous atmospheric monitoring whenever possible.
  4. Requiring continuous monitoring of engulfment hazards. For example, when workers are performing work in a storm sewer, a storm upstream from the workers could cause flash flooding. An electronic sensor or observer posted upstream from the work site could alert workers in the space at the first sign of the hazard, giving the workers time to evacuate the space safely.
  5. Allowing for the suspension of a permit, instead of cancellation, in the event of changes from the entry conditions list on the permit or an unexpected event requiring evacuation of the space. The space must be returned to the entry conditions listed on the permit before re-entry.

OSHA has added provisions to the new rule that clarifies existing requirements in the General Industry standard. These include:

  1. Requiring that employers who direct workers to enter a space without using a complete permit system prevent workers’ exposure to physical hazards through elimination of the hazard or isolation methods such as lockout/tag out.
  2. Requiring that employers who are relying on local emergency services for emergency services arrange for responders to give the employer advance notice if they will be unable to respond for a period of time (because they are responding to another emergency, attending department-wide training, etc.).
  3. Requiring employers to provide training in a language and vocabulary that the worker understands.

Finally, several terms have been added to the definitions for the construction rule, such as "entry employer" to describe the employer who directs workers to enter a space, and "entry rescue", added to clarify the differences in the types of rescue employers can use.

Host Employers, Controlling Contractors, and Entry Supervisors

The rule makes the controlling contractor, rather than the host employer, the primary point of contact for information about permit spaces at the work site. The host employer must provide information it has about permit spaces at the work site to the controlling contractor, who then passes it on to the employers whose employees will enter the spaces (entry employers). Likewise, entry employers must give the controlling contractor information about their entry program and hazards they encounter in the space, and the controlling contractor passes that information on to other entry employers and back to the host. As mentioned above, the controlling contractor is also responsible for making sure employers outside a space know not to create hazards in the space, and that entry employers working in a space at the same time do not create hazards for one another’s workers.

Click for an update on this ruling

Download 29 CFR 1926 Subpart AA Confined Space in Construction Ruling

Source: www.osha.gov

Frequently Asked Questions: https://www.osha.gov/confinedspaces/faq.html

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WH Completes Review of OSHA's Confined Spaces in Construction

Friday, April 10, 2015

Washington – On April 3, the Office of Information and Regulatory Affairs (OIRA) completed its review of OSHA's Confined Spaces in Construction Standard, paving the way for the final rule to move forward. The rule (29 CFR 1926.36) has been in the works for more than a decade. An OIRA review is one of the last steps a federal agency must take before it can publish a final rule. According to OSHA's timetable, the confined spaces final rule was originally scheduled for publication in March.

In 1993, OSHA issued a general industry rule to protect employees who enter confined spaces while engaged in general industry work (29 CFR 1910.146). This standard has not been extended to cover employees entering confined spaces while engaged in construction work because of unique characteristics of construction work sites. Pursuant to discussions with the United Steel Workers of America that led to a settlement agreement regarding the general industry standard, OSHA agreed to issue a proposed rule to protect construction workers in confined spaces.

Source: Membership News Alert from National Safety Council

UPDATE: Roco is hearing that a final ruling will be released within the next 6 weeks. As soon as the information is provided, we will be sure to post for you!

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Dialing 911 for Confined Space Rescue

Thursday, March 19, 2015

By Pat Furr, Roco Chief Instructor/VPP Coordinator 

It is still happening out there, folks. Fatalities are still occurring during permit required confined space entries. Unfortunately, workers are dying because the permit space (or the entrant) was not properly prepared prior to entry. And, tragically, many of these fatalities are the would-be rescuers, who are trying to aid their co-workers! Most often, these would-be rescuers are authorized attendants or passersby that reacted improperly and took heroic, but inappropriate action. Or they may have been professional rescuers, who were not trained or equipped for this type of rescue.

In nearly every case, these fatalities are completely preventable - simply by properly preparing the permit space prior to entry by isolating or if needed, controlling all hazards. However, should an emergency arise, the rescue service must be prepared to respond to these types of emergencies. This includes proper training and equipment to ensure a successful rescue and that everyone involved goes home safe and sound.

Considering Rescue Service Options

In a previous article, we outlined the three primary ways that an employer can ensure there is a proper confined space rescue service in place as part of their written permit required confined space program. These options include:

(1) an in-house rescue team made up of host employees;

(2) a third party contracted rescue service, or

(3) relying on 911 emergency responders.

All three options have their benefits and their shortcomings. However, it is critically important that the employer focus on the entrant’s safety more than any other consideration, be it monetary, personnel, equipment, or any other resource when deciding what type of rescue service to employ.

I get around…(no, not the Beach Boys’ song). I travel extensively visiting a variety of private and governmental sector work sites, and I also do the trade show/lecture circuit. In my travels, I hear all sorts of variations to the “confined space rescue service” theme. Many employers use in-house rescue teams and accept the funding and time commitments required to keep this capability proficient in the needed skills. Some employers rely on a third party professional rescue service to meet this requirement. Sometimes these third party agreements are for the short term such as during turnarounds, or even for sustaining operations as imbedded contractors. Still other employers rely on 911 public safety responders for their confined space rescue needs.

All three options can and do work, but the one option that I hear having only a cursory vetting process in many cases is the 911 option. At times, I have asked an employer to describe the extent of the agreement between their facility and the 911 responders. That’s when I typically hear an answer such as, “Well, all our employees know the phone number to dial.” That’s when I offer to buy coffee so we can have a little chat. This article will focus on using 911 as your confined space program rescue service.

Before I go any further, I want to say that in my view, our 911 emergency responders are true heroes. And many times, I feel they are under-appreciated. Until a major national disaster hits, many of us are guilty of overlooking the risks that these men and women take on a regular basis. I also think it’s important for employers to understand the extensive set of skills, and wide variety of skills, that emergency responders are required to master in order to perform their primary job responsibilities.

Extensive Skill Requirements for Municipal Responders

For example, firefighters are required to maintain a wide variety of special skills, such as pump operations, ventilation, PPE, emergency vehicle driving, along with medical skills such as advanced airway management, pharmacology, advanced cardiac life support and…are you getting the picture? The skills and knowledge required to perform technical rope rescue is a specialty not typically included in a firefighter’s job description unless they are assigned to a heavy technical rescue (HTR) squad.

NFPA 1006 (2013 edition, with next one coming in 2017) lists all the specialty areas that a rescue service may be called on to master. The first set of requirements is established by the department’s authority having jurisdiction (AHJ) and may include such things as a minimum level of physical fitness, HAZMAT training, emergency medical care training, and several other requirements. Then, there is what used to be referred to as “core skills” now known as Job Performance Requirements. These requirements are extensive before even addressing any of the 19 different technical rescue specialty areas such as: swift water rescue, trench rescue, machinery rescue, structural collapse rescue, wilderness rescue, and the list goes on. Also included in this list is confined space rescue.

In Albuquerque, New Mexico, where I live, we are fortunate to have a dedicated HTR squad within our fire department that is trained, equipped, and staffed 24/7. This team is called upon to respond to flash-flood rescues in our many arroyos, mountain rescue in the peaks east of the city, vehicle entrapments on two interstate highways as well as our surface streets, and may also be called to an employer’s work-site to perform a variety of rescues there. This could be anything from trench rescue to – you guessed it – confined space rescue.

CS Emergencies Require Special Skills and Equipment

It is fairly rare that municipal responders are provided the resources (including specialized training and equipment) to safely and effectively respond to confined space rescue emergencies. Rarer still, for these responders to have been afforded the opportunity to practice in the types of confined space rescues that may be required in their local industrial corridors. Any rescue service would need to be trained and equipped in advance to handle the many hazards and obstacles of permit required confined spaces.

It is the employer’s responsibility, both morally and legally, to engage with the 911 service that is being considered as their confined space rescue service.

Appendix F of 1910.146 is a very valuable means to ensure that both the rescuers and the employer know what the requirements are and that proper agreements are in place prior to confined space entry operations. 

Roco has provided a sample for you to download.

Any shortfalls must be addressed. This may include lack of training, equipment, staffing, or many other requirements necessary to ensure a response appropriate for the types and hazards of the spaces onsite.

OSHA states in section (d)(4) of 1910.146 that “the Employer shall provide rescue and emergency equipment needed to comply with paragraph (d)(9) of this section, except to the extent that the equipment is provided by rescue services…” This is where an employer and a public safety agency may enter a cooperative arrangement beyond what is already expected of the 911 responder's normal duties.

Funding through grants and other resources has become very lean in the last several years. As public safety budgets are trimmed down, both career and volunteer fire departments must make budgetary decisions that in many cases result in sacrificing emergency service capabilities beyond firefighting and emergency medical services. This would mean that many of the technical rescue capabilities outlined in NFPA 1006 are not within the means of many fire departments. The impact on an employer may be that they lose a previously established ability to rely on a 911 agency for their confined space rescue needs, or they may not be able to rely on that rescue service option during the development of their permit required confined space program.

However, we also understand that it is becoming more and more common for employers to provide rescue equipment and/or funding for rescue training specific to the needs of the employer’s confined space program. Various state and local requirements may differ, but generally this can be accomplished by having the employer set up a grant with monies being donated for specific training or equipment purchases. Depending on the local ordinances, equipment can be directly transferred from the employer to the 911 agency through a simple agreement that outlines its intended purpose and ownership. There may be tax advantages to the employer while benefiting the community as well. Bottom line...there are critical steps to take before relying solely on a local 911 agency.

Evaluating Rescue Response Capabilities

Appendix F of 1910.146 clearly explains the need for employers to evaluate a prospective rescue service before depending upon their services. It states,

Merely posting the service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

Other critical factors include response time and availability. Response time is generally extended when relying on an offsite rescue service such as 911. According to OSHA, the response time must be appropriate for the types of known or potential hazards affecting the confined spaces at the employer’s facility. Relevant factors include:

(1) Location of the rescue team or service relative to the employer's workplace

(2) Quality of roads and highways to be traveled

(3)  Potential bottlenecks or traffic congestion that might be encountered in transit

(4) Reliability of the rescuer's vehicles, and the training and skill of its drivers

And, what about the availability of the rescue service? Is it unavailable at certain times of the day or in certain situations? What is the likelihood that key personnel of the rescue service might be unavailable at times? If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the entry operation can be aborted immediately?

In fact, these considerations also apply to any of the three means of providing a confined space rescue service, be it an in-house service, a contracted service, or a 911 emergency response. However, response times and availability are typically crucial limitations in relying on 911 for confined space rescue.

Careful Planning Required!

If you have identified 911 as the rescue service written into your confined space program, it is crucial that you take all the necessary steps to vet the agency as being a good fit to protect your employees. 

In addition to all requirements of Appendix F, it is of utmost importance to pay particular attention to the service’s ability to respond in a time appropriate for your needs, and to ensure that reliable two way communications are in place. The 911 dispatch will be notified when entry operations are to commence; and, just as importantly, the 911 dispatch will notify the employer when the service is not able to respond to an emergency so entry operations can be immediately aborted.

With careful planning, thorough communications, and proper training and equipment, relying on 911 response for confined space rescue can work. Unfortunately, in some instances, the outcome is tragic with loss of life not only to the entrants, but also to the unprepared 911 responders who had little clue as to what they were about to encounter. As an employer, it is your responsibility to make sure the rescue service is adequately prepared!


Additional OSHA References:

1910.146(d)(9) Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue;

1910.146(k)(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of 1910.146(k)(1)(i). Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

1910.146(k)(2)(i) Provide affected employees with the personal protective equipment (PPE) needed to conduct permit space rescues safely and train affected employees so they are proficient in the use of that PPE, at no cost to those employees;

1910.146(k)(2)(ii) Train affected employees to perform assigned rescue duties. The employer must ensure that such employees successfully complete the training required to establish proficiency as an authorized entrant, as provided by paragraphs (g) and (h) of this section;

1910.146(k)(2)(iii) Train affected employees in basic first-aid and cardiopulmonary resuscitation (CPR). The employer shall ensure that at least one member of the rescue team or service holding a current certification in first aid and CPR is available; and

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.

Note to paragraph (k)(l)(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.

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Combustible Dust and Confined Spaces

Monday, January 05, 2015

In January 2004, an explosion at the West Pharmaceutical Company in Kingston, NC killed 6 workers and injured 34 others. Two firefighters were injured during the response to the incident.  One month later, an explosion and fire occurred at the CTA Acoustics manufacturing facility in Corbin, KY, killing 7 workers. In February 2008, an explosion at the Imperial Sugar Company facility in Wentworth, GA, killed 13 workers and injured 42 others. Three very different types of facilities with very different products, but with one thing in common—dust!

"A 'safe’ area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations."

The Chemical Safety Board reported that there were 281 explosions of combustible dust in the United States between 1980 and 2005. These explosions resulted in 199 deaths and 718 injuries. And these are just the actual explosions. There are countless more combustible dust environments just waiting for the right (or wrong) conditions to align to become the next fatal explosion. The fact is that with the exception of silicon or sand, every kind of dust is potentially combustible to some degree.

Combustible dusts are measured on a “deflagration index,” (see box) which measures the relative explosion severity compared to other dusts. They range from such seemingly innocuous items such as dust from powdered milk and egg whites that can create “weak explosions,” to dusts from items such as magnesium and aluminum that can result in “very strong explosions.” But I think we can all agree that no explosion, even a “weak” explosion, is a good explosion—especially if it occurs during rescue operations. 

As rescuers, you should already be familiar with the “fire triangle.” To understand the danger of combustible dusts, you should also be familiar with the “dust explosion pentagon.” The dust explosion pentagon consists of the following:

-       Combustible Dust (Fuel)

-       Ignition Source

-       Oxygen

-       Dispersion of dust (suspension)

-       Containment of the dust in a confined or semi-confined area (Enclosures/Building/Confined Space)

Rescuers should be on the lookout for any appreciable accumulation of dust when sizing up a rescue situation. Keep in mind that your atmospheric monitor containing a sensor for combustible gases is not effective for detecting a hazard from combustible dust.  

Always remain aware that in a suspended state, dust becomes explosive. Dust explosions occur when combustible dust is present, forms a dust cloud in an enclosed environment, and is exposed to oxygen and an ignition source. The explosion occurs as a result of the rapid burning of the dust cloud, which creates a rapid pressure rise in the enclosed area or confined space. 

A dust pile that may burn while an ignition source is being applied, then go out immediately or shortly after the ignition source is removed, can become lethally explosive when scattered and suspended in the air. 

Always consider the potential for combustible dust in any rescue situation, particularly when ventilation of an enclosure, building, or confined space is considered. A “safe” area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations.

This article was written by Robert Aguiluz, who is currently an Administrative Law Judge for the State of Louisiana. He is also an attorney who specializes in Occupational Safety and Health Law, and regulatory and compliance issues. He is a former Certified Safety Professional and Roco Rescue Instructor with over twenty years’ experience in both industrial and municipal emergency response and rescue.
 

Combustible Dust Considerations for Emergency Responders:

1.  Know your response area and the types of industry that may have the potential for combustible dust. If you are performing standby rescue duties, meet with the SH&E management team to learn about any combustible dust hazards at their facility.

2.  Become familiar with the “deflagration index” for various types of materials. See sample Chart below.

Examples of Kst Values for Different Types of Dust

 

3.  Consider the effect of ventilating a space that has accumulations of combustible dust.

        •  Will you cause the dust to become suspended?
        •  Will the suspended moving dust create a static charge/discharge and become a source of ignition?
        •  Can your ventilation equipment become a source of ignition?

4.  Is there information to review on the SDS (Safety Data Sheet) regarding the material’s potential to become combustible dust?


HELPFUL LINKS:

OSHA Quick Card: Prevent Dust Explosions

“Firefighting Precautions at Facilities with Combustible Dust”

“Hazardous Communication Guidance for Combustible Dust”

“Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions”

“NFPA 654: Standard for the Prevention of Fire and Dust Explosions”

 



















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Tips for Using Roco’s Confined Space Types Chart

Thursday, December 11, 2014

Is your rescue team (or service) truly capable of rescuing workers from the various types of confined spaces on your site?

What about rescue services for the contractor who’s working on your site with personnel entering permit spaces?

As a rescue team, have you considered all the angles in preparing for confined space rescue?

Refineries, plants and manufacturing facilities have a wide range of confined spaces – some having only a few, where others may have hundreds. In OSHA’s 1910.146, a big consideration is allowing rescue teams the opportunity to practice and plan for the various types of confined spaces they may be required to respond for rescue.

Obviously, it would be impossible to practice in each and every one of the spaces – from a time standpoint as well as most times the spaces are operating and functioning units within the plant. That’s why section (k) of 1910.146 also allows practice from “representative” spaces.

Using OSHA’s guidelines for determining representative spaces, Roco’s Confined Space Types Chart was developed to assist rescue teams in planning and preparing for the various types of spaces in their response area. Our CS Types Chart allows you to categorize permit spaces into one of six types – which can be used to prepare rescue plans, determine rescue requirements and practice drills or evaluate a prospective rescue service.

While there may be hundreds of permit spaces on site, many of them will fit into one of these six types and require the same (or similar) rescue plan. Of course, there are always unique situations in addition to physical characteristics, such as space-specific hazards or specialized PPE requirements, but we feel this chart is a valuable tool that can be used for critical planning and preparation for confined space rescue operations.

Over the decades here at Roco, we have seen just about every type of confined space configuration there is. We’ve also learned that it is imperative to understand the physical limitations of the space access and internal configuration and how this affects the choice of equipment and techniques in order to provide a viable, safe rescue capability.

During an emergency is NOT the time to learn that your backboard or litter will not fit through the portal once the patient is packaged. By referring to the Types Chart and practicing simulated rescues from the relevant types of spaces will help identify these limitations in a controlled setting instead of during the heat of an emergency.

Here’s an example


Most backboards are 16 to 20-inches wide. With an 18-inch round portal, the backboard will only fit through the “widest” part (or diameter) of the opening. In effect, this cuts the size of the opening in half (see illustration). If the thickness of the backboard is approximately 1-inch, then you only have about 7 or 8-inches of space remaining to clear the patient. This is one example where all the rescue equipment components may fit into the space but cannot be removed once the patient is packaged.

 


On the Roco Types Chart, you will note that there are six (6) general types identified, which are based on portal opening size and position of portal. For example, Types 1 and 2 are “side entries”; Types 3 and 4 are “top entries”; and Types 5 and 6 are “bottom entries.” There are two types of each due to portal size as discussed above. Openings greater than 24-inches will allow packaged patients on rigid litters or rescuers using SCBA to negotiate the opening. Spaces less than 24-inches will require a higher level of expertise and different packaging and patient movement techniques.
Confined Space Portal Types defined by OSHA

Because OSHA 1910.146 requires employers to allow access for rescue planning and practice purposes, here’s an opportunity to be better prepared and practiced on thetypes of spaces in the response area. So, get out your clipboard, tape measure, some sketch paper, and a flashlight (if safe to do so) in order to view as much of the interior of the space as you can. Gaining access to architectural or engineering drawings may also be helpful in determining the internal configuration of the space for the times that actual entry is not feasible. Armed with this information, it is time to “type” the spaces in your response area using the Roco CS Types Chart.

Once this is completed, pay particular attention to spaces that have been identified as Types 1, 3, or 5. These spaces have restrictive portals (24-inches or less) and are considered “worst case” regarding entry and escape in terms of portal size. As mentioned, this is very important because it will greatly influence the types of patient packaging equipment and rescuer PPE that can be used in the space.

Another critical consideration is accessibility to the space – or “elevation” of the portal. While the rescue service may practice rescues from Top, Side and Bottom portals – if it’s from ground level, that’s very different from a portal that’s at a 100-ft elevation. Here’s where high angle or elevated rescue techniques normally are required for getting the patient lowered to ground level. This is important! Rescue practice from a representative space needs to be a “true” representation of the kind of rescue that may be required in an emergency.

In Appendix F, OSHA offers guidelines for determining Representative Spaces for Rescue Practice. OSHA adds that “teams may practice in representative spaces that are ‘worst case’ or most restrictive with respect to internal configuration, elevation, and portal size.” These characteristics, according to OSHA, should be considered when deciding whether a space is truly representative of an actual permit space.

Roco Note: Practice in portals that are greater than 24-inches is also important so that rescuers can practice using all proper patient packaging protocols that may be allowed with larger size openings.

(1) Internal Configuration – If the interior of the space is congested with utilities or other structural components that may hinder movement or the ability to efficiently package a patient, it must be addressed in training. For example, will the use of entrant rescuer retrieval lines be feasible? After one or two 90 degree turns around corners or around structural members, the ability to provide external retrieval of the entrant rescuer is probably forfeited. For vertical rescue, if there are offset platforms or passageways, there may be a need for directional pulleys or intermediate haul systems that are operated inside the space.

What about rescues while on emergency breathing air? If the internal configuration is so congested that the time required to complete patient packaging exceeds the duration of a backpack SCBA, then the team should consider using SAR. Will the internal configuration hinder or prevent visual monitoring and communications with the entrant rescuers? If so, it may be advisable to use an “internal hole watch” to provide a communication link between the entrant rescuers and personnel outside the space.

What if the internal configuration is such that complete patient packaging is not possible inside the space? This may dictate a “load and go” type rescue that provides minimal patient packaging while providing as much stabilization as feasible through the use of extrication-type short spine boards as an example.

(2) Elevation – If the portal is 4 feet or greater above grade, the rescue team must be capable of providing an effective and safe high angle lower of the victim; and, if needed, an attendant rescuer. This may require additional training and equipment. For these situations, it is important to identify high-point anchors that may be suitable for use, or plan for portable high-point anchors, such as a “knuckle lift” or some other device.

(3) Portal Size – The magic number is 24 inches or less* in diameter for round portals or in the smallest dimension for non-round portals. It is a common mistake for a rescue team to “test drive” their 22-to-23-inch wide litter or backboard on a 24-inch portal without a victim loaded and discover that it just barely fits. The problem arises when a victim is loaded into the litter. The only way the litter or backboard will fit is at the “equator” of the round portal. This will most likely not leave enough room between the rigid litter or backboard and the victim’s chest, except for our more petite victims.

And, it’s already difficult to negotiate a portal while wearing a backpack SCBA. For portals of 24 inches or less, it is nearly impossible. DO NOT under any circumstances remove your backpack SCBA in order gain access to a confined space through a restricted portal or passageway. If the backpack SCBA will not fit, it is time to consider an airline respirator and emergency escape harness/bottle instead.

By using the Roco Types Chart in preplanning these “worst case” portals and the spaces that fall into the type 1, 3, or 5 categories, the rescue team will be able to determine in advance that different equipment or techniques may be required in order to effect rescue through these type portals.

*ROCO NOTE: In Appendix F, OSHA uses “less than 24-inches” in Section B (#8); however, in (3) Portal Size (a) Restricted, it uses “24-inches or less,” which we are using in our Types Chart.

(4) Space Access – Horizontal vs. Vertical? Most rescuers regard horizontal retrievals as easier than vertical. This is not always the case. If there are floor projections, pipe work or other utilities, or just a grated floor surface, it may create an incredible amount of friction or an absolute impediment to the horizontal movement of an inert victim. In this case, the entrant rescuers may have to rely on old-fashioned arm and leg strength to maneuver the victim. Once the victim is moved to the portal, it may become an incredibly difficult task to lift a harnessed victim up and over the lower edge of the portal. Even if the portal is as little as three feet above the level of the victim, it is very difficult to lift a victim’s dead weight up and over the portal lower edge. Sometimes using a long backboard as an internal ramp may do the trick. For vertical access, there may be a need for additional training or equipment to provide the lifting or lowering capability for both the victim and the entrant rescuer.

Appropriate rescue pre-plans and realistic rescue practice can be one of the best ways to be prepared for confined space rescues – and allow rescuers to operate more safely and effectively in an emergency situation. Roco CS Types Chart can be used as a quick reference when doing an initial assessment of confined spaces and permit-required confined spaces. It helps in designing rescue training and practice drills that will truly prepare rescuers for the particular spaces on site. The information can also be used when conducting performance evaluations for your team, a contracted stand-by rescue service, a local off-site response team, or a contractor who supplies their own rescue services while working in your plant.

In section (k), OSHA requires employers to evaluate the prospective rescue service to determine proficiency in terms of rescue-related tasks and proper equipment. If you are relying on a contracted rescue service or if an on-site contractor is providing their own rescue capabilities, we encourage you to have them perform a simulated rescue from a representative type space. Otherwise, if an incident occurs and the “rescuers” you are depending on are not capable of safely performing a rescue, your company could be culpable.
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