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What is a Competent Person?

Wednesday, March 02, 2016

Many OSHA standards, especially in construction, require a “competent person” to be designated at the jobsite. Filling this role requires proper training, relevant experience to the work being performed and adequate knowledge of the associated regulations. 

The competent person should be able to recognize critical hazards as well as have the authority to take the action needed to mitigate hazards. It’s much more than just picking someone to fill a slot.

A previous article, "What is a Competent Person?" found in the National Safety Council's Safety+Health publication, talks about how the term is often taken too lightly. Again, it's much more than just selecting a body to fill a role or attending one 10-hour training class covering all the various standards. Competency must be considered and evaluated for this important role. 

At a minimum, your designated competent person should meet the following minimum qualifications:
(1)    A high level of understanding of the types of hazards typically encountered in that area of work;
(2)    A solid review of applicable standards relating to that type of work; and,
(3)    A thorough understanding of types of solutions to control or eliminate the hazards
.

To assist in preparing your competent person in fall protection, we encourage you to register for Roco's Fall Protection
Competent Person - April 4-5, 2016 course in Baton Rouge. This course will provide practical experience in recognizing fall hazards and developing appropriate measures for reducing or eliminating those hazards. 

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Q&A: What are the Rescue Requirements for Trenches/Excavations?

Tuesday, May 19, 2015

READER QUESTION:
One of our readers recently asked about rescue requirements in excavations. We did some searching and found an interesting Letter of Interpretation (LOI) from OSHA that explains when rescue provisions are required during trenching operations.  

ROCO TECH PANEL ANSWER:
The following is from OSHA LOI in regards to this answer. In regard to whether emergency rescue equipment is required at every trenching job site located near or passing by a gas station, refinery, gas line, sewer main, etc., please be advised by the following:

Emergency rescue equipment is required to be readily available where a competent person determines, based on the conditions at each job site, that hazardous atmospheric conditions exist or may reasonably be expected to develop during work in an excavation. In regard to whether a contractor can rely on a local rescue squad instead of providing the rescue equipment, please be advised that many emergency situations associated with the hazards involved with hazardous atmospheres in trenches would normally require an immediate response within a few minutes or even seconds. A rescue squad would be unable to provide the necessary response and therefore could not be used to comply with 1926.651(g)(2).

As more and more industrial sites realize that just about every day, somewhere on their property, there is an open trench. Trench collapses cause dozens of fatalities and hundreds of injuries each year. Obviously, this creates concerns, especially for the rescue personnel who may be called to the scene during an emergency.

We’ve been getting questions from clients that have effective rescue teams for medical, hazmat, fire, confined space and rope but are realizing that they are lacking if a trench collapse occurs on their site. “Who will do the rescue?” is a question often asked. There is concern by supervisors, who have been given the responsibility for signing trench permits, but have not had adequate training in trench and excavations. Many are not “competent persons” as referenced in OSHA1926.651-652.

After looking at the dozen of questions in the referenced LOI, it should raise a few more:

  1. Are the people you have signing off that a trench is constructed properly and safe for entry, trained to know what to look for and have the authority to act (competent person), or are they assuming that the contractor is “doing the right thing”?
  2. Who will be called if a trench emergency should occur?
  3. Are their local resources that have the training and equipment to respond, or are you an island unto yourself when it comes to trench rescue? 

The link to the referenced LOI is shown below – and the questions are still very relevant : https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=20597

Additional Resources:

OSHA Technical Manual

OSHA Trenching and Excavation Safety

Trench Safety Poster – An Unprotected Trench Is An Early Grave

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Roco Tech Panel Q&A - Prompt Rescue by Shift

Sunday, February 01, 2015

READER QUESTION:
Our company procedures require an on-site rescue capability for permit- required confined space entry operations during normal Monday-Friday “day shift” operations, but for entries other than during that shift, we rely on an off-site rescue service. Shouldn’t the rescue capability, specifically the rescue response time, be the same no matter when the permit required confined space entries are being made?

ROCO TECH PANEL ANSWER:
Yes; and no, not necessarily.

Yes, if the nature of any known or potential hazards that may affect the entrants in the permit space, and the configuration of the confined space are the same during regular M-F day shift as they would be during off-shift entries, then the answer is yes. The rescue capability regarding response time, manning, equipment, and overall performance capability should be the same.

No, not necessarily. For example, if the nature of the known or potential hazards of a permit space entered during the day shift requires a shorter response time, or if the configuration of the space requires a higher level of rescue expertise, rescuer PPE, number of rescue personnel, or if there is any other factor that may require a different performance capability than the requirements of the day shift entries, then no, the same rescue capability would not necessarily be required.

This is because OSHA 1910.146 is a performance-based standard. For confined space rescue, specifically regarding what would be considered “prompt rescue,” the performance standard will be most influenced by the nature of the potential and known hazards and how quickly the hazards will affect the authorized entrants, as well as the complexity of providing effective rescue from the particular permit-required confined space.

To demonstrate this point, here are some extracts from OSHA 1910.146 Permit Required Confined Space Regulation Section K, the Summary and Explanation of the Final Rule, and also from OSHA 1910.146 Appendix F.

From 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;

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.”

From the Summary and Explanation of the Final Rule (1910.146) “OSHA has therefore decided to promulgate the requirement it proposed for "timely" rescue, a requirement that was not opposed by any rulemaking participant, rather than to define precisely what is timely. That determination will be based on the particular circumstances and hazards of each confined space, circumstances and hazards which the employer must take into account in developing a rescue plan. OSHA has added a note to paragraph (k)(1)(i) to clarify this point.”

From 1910.146 Appendix F, A. Initial Evaluation, II, 1. “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.”

The response time of the rescue service is also different than the time needed to provide rescue. Response time generally means the time it takes for the rescue service to arrive on scene. From that time forward, the rescue service must perform a size-up, identify and don PPE, set up rescue systems, and perform many other tasks before initiating entry rescue. Any need to provide victim packaging or to deliver breathing air to the victim will add to the total time it takes to complete the rescue.

Therefore, it is imperative that the employer ensures that the measure of “Prompt Rescue” is driven by the nature of the known or potential hazards of the permitted confined space as well as the complexities of the configuration of the space and how those will effect the time required to the setup the rescue system.

Roco provides confined space rescue services for a variety of industries and is confronted with a very wide range of hazards associated with the entry operations and a vast range of space configurations. The determination on the rescue team’s posture is based primarily on the answer to the following questions.

  • 1.  How quickly will the entrants be overcome by the known or potential hazard(s) of the space, and /or how quickly will the entrants suffer permanent injury if exposed to those hazards?

  • 2.  If non-entry retrieval systems are not employed due to the system not contributing to an effective rescue, or the retrieval system creates a greater hazard, how much time would be needed to arrive on scene, set up an entry rescue system to support the entrant rescuer(s) and the victim(s)?

These are just two of the primary questions that we consider for our CSRT operations. If the nature of the known or potential hazards would require a near immediate rescue of the entrant(s), we would assume a “Rescue Standby” posture where the rescue systems are pre-rigged, the entrant rescuers are already in appropriate PPE or have it available to be quickly donned, and the rescue effort can be initiated in a very short time in an effort to meet that “Prompt Rescue” performance benchmark.

It is vitally important that the employer honestly evaluates the nature of the hazards or potential hazards of the permitted confined spaces that they plan on entering. This can be accomplished by reviewing product SDS (Safety Data Sheets), understanding the nature of the hazards that are not included in the SDS, and always considering worst case scenarios. Additionally, the employer must include an evaluation of the time it would take the rescue service to arrive on scene as well as the additional time to safely assess the situation and setup the required rescue systems prior to initiating rescue.

The answer to the question of a different rescue capabilities based on the “day shift” or “night shift/week-ends” can only be answered by performing a thorough assessment of the permitted spaces. And, on a case by case basis, determine if the rescue capability for that particular entry operation does indeed meet the spirit of “Prompt Rescue.” 

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Q&A: Appendix F (1910.146)

Wednesday, January 07, 2015

READER QUESTION:
If Appendix F is non-mandatory, then why is it relevant to my PRCS program?

ROCO TECH PANEL ANSWER:
Questions often arise about the application of Appendix F of OSHA’s Permit Required Confined Spaces standard. Those questions usually focus on the “non-mandatory” characterization of the appendix.

The question most often asked is “If it’s non-mandatory, why should I even bother with it?” The answer is simple: even though Appendix F itself is “non-mandatory,” the methods for compliance in the appendix all relate to mandatory requirements of the standard. Appendix F is simply a non-mandatory method for complying with mandatory requirements.

The trick when evaluating the methods of compliance outlined in Appendix F is to match the particular non-mandatory provision of the appendix with the corresponding mandatory requirement of the standard. Then the employer can either use the method suggested in the appendix, or devise its own method to comply with the mandatory requirement.

For example, with regard to outside rescue services, Appendix F paragraph A(3) asks the question: “If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately?”

This provision does not create a mandatory requirement, but it does prompt the employer to take into account mandatory requirements of the standard. OSHA 1910.146(j)(3) makes it mandatory for the entry supervisor to terminate the entry and cancel the permit as required by paragraph (e)(5) of the standard.

Paragraph (e)(5) requires the entry supervisor to cancel the entry permit when “a condition that is not allowed under the entry permit arises…” If the particular entry requires rescue service availability and the rescue service suddenly becomes unavailable during the entry, that would be “a condition that is not allowed under the entry permit” requiring the entry supervisor to cancel the permit.

So although there is no provision that specifically states that the rescue service notify the employer if it becomes unavailable, from a practical standpoint the employer cannot comply with the requirement that it cancel the permit and terminate the entry when a condition not allowed under the entry permit arises unless such a notification system is in place. This is just one example of how the provisions of non-mandatory Appendix F provide a method to comply with mandatory requirements.

When considering the provisions of non-mandatory Appendix F, the employer would be wise to determine which mandatory provisions the method stated in the appendix addresses. Of course, the employer is free to choose some other method to comply with the mandatory provision and does not necessarily have to follow the method suggested in the appendix. In that sense, the appendix is “non-mandatory.” But, nonetheless, the employer must comply with the underlying mandatory provision, and take any steps necessary to do so.

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Q&A: Sked Stretcher - Is a Backboard Required?

Wednesday, April 02, 2014

READER QUESTION:
Can a patient be lowered in a vertical or horizontal Sked without being lashed to a backboard or without a backboard at all?

ROCO TECH PANEL RESPONSE:

The answer is YES! This is one of the advantages of choosing the Sked stretcher.


It can be used with most (if not all) backboards, with a short spine immobilizer, or with nothing at all.

There are two general considerations in deciding what device to use with the Sked or other flexible litters:

(1) Patient Condition - If spinal injuries or other injuries need the splinting effects or the protection of a backboard, then the victim should be lashed to a backboard. When a backboard is not in place, the Sked will help keep the body in line when tightened; however, the spine can continue to be manipulated up and down as patient is moved over objects or edges which can compromise the spine.

If you are just using the backboard to keep the Sked rigid or protect the patient while placing them over edges, then technically you would not need to lash them to the backboard.

When a confined space is too tight to use a backboard and possible spinal injuries are suspected, or additional protection for placing a patient over an edge is wanted, then a short spinal immobilizer such as the OSS can be used. If a spinal injury is not suspected, then no additional equipment needs to be used with the Sked. It is always good to keep in mind, however, that the thin plastic make-up of the Sked will allow the patient to feel every edge or bump you place or drag them over.


(2) Location
- What size portal do you need to get the patient and packaging through in order to perform the rescue? Many times in portals less than 18-inches, the individual pieces of equipment will fit into the space, but once put together they will not fit back out of the space. The Sked was designed for this specific circumstance. The thin plastic construction allows it to fit in places many other litters will not.

The Sked can also be used vertically with the bottom not curled and secured in cases where a hare-traction splint or other injury doesn’t allow securement at the bottom.

The Sked is a very user-friendly device that can be used in a multitude of configurations and for various applications. This is one of the reasons why it is such a popular rescue tool, especially for confined space rescue! Stay safe!


NOTICE: The information provided on our website and by our Tech Panel is a complimentary service for our readers. Responses are based on our understanding of the reader’s inquiry, the equipment and/or the technique in question. All rescue systems should be evaluated by a competent person before use in the support of any human loads. Proper training is required prior to use of rescue techniques or systems discussed. Because standards and regulations are typically performance based and often dependent on specific circumstances, it is important to review all regulations in their entirety and to follow the proper protocols for your company or organization.

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