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When should I retire my rescue rope?

Monday, October 24, 2011

Unfortunately, there’s not a reasonably priced “non-destructive” test to determine a particular rope’s strength. Your best bet is to have trained personnel using the rope, keep good rope use logs and inspect the rope after every use. It’s always best to refer to your rope manufacturer for proper care, inspection and replacement, so that’s what we did.

Here’s what Steve Hudson, President of PMI Rope, had to say.
He first referenced the product literature that’s included with PMI rope that states:

RETIRE IMMEDIATELY:
- Any rope whose strength may have been compromised during use.
- Any rope which is subjected to uncontrolled or excessive loading.
- Any rope which is greater than 10 years old, regardless of history and usage.
- Any rope whose history and past usage you are uncertain about.

While these are simple statements, I realize that it is difficult to determine what is “excessive loading” or what is “compromised.” And, if you think it’s hard to look at a rope after an operation and tell if it was compromised or not – think how hard it is for us at the factory to know without being there or having the rope to look at.

Unfortunately, there’s not a reasonably priced “non-destructive” test to determine a particular rope’s strength. Your best bet is to have trained personnel using the rope, keep good rope use logs and inspect the rope after every use. Anytime you have lost faith in what you know about the rope’s condition, for any reason, you should retire it.

A PMI rope, if properly cared for, should last at least 5 years of regular rescue training use and longer than that with intermittent use. By 10 years, it’s simply time to replace it. There are just too many things in the environment that the rope might pick up and are potentially harmful to the yarn.

And, as always, when in doubt, throw it out… CUT RETIRED ROPE into short lengths which will discourage future use – or discard it entirely. A retired rope should not be stored, kept or maintained in such a way that it could inadvertently be used as a lifeline. In some cases, when only a single point or a small area of a rope has been damaged and the remainder of the rope is in good condition, the user may elect to cut that section out of the rope and continue to use the remaining sections. This is a judgment call and such a decision is left to the user’s discretion.

Again, never take chances – if you’re not sure about the integrity of a rope, throw it out!

Quick Reference for Rope Retirement:

  •     Extensive Use (e.g. Roco’s training rope) – replace every two (2) years or as needed.
  •     Occasional Use (e.g. once a month) – replace every five (5) years or as needed.
  •     Regardless of Use – replace every ten (10) years.
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Can I use my training rope for rescue?

Tuesday, October 18, 2011

We're often asked about using training rope for rescue purposes, so here's what we discovered...

The short answer is yes. However, NFPA 1500 provides some additional guidelines.

NFPA 1500 Standard on Fire Department Occupational Safety and Health Program (2007 Edition)
7.16.3* Life safety rope used for rescue at fires or other emergency incidents or for training shall be permitted to be reused if inspected before and after each such use in accordance with the manufacturers’ instructions and provided that the following criteria are met:

(1) The rope has not been visually damaged by exposure to heat, direct flame impingement, chemical exposure or abrasion.

(2) The rope has not been subjected to any impact load.

(3) The rope has not been exposed to chemical liquids, solids, gases, mists or vapors of any material known to deteriorate rope.

7.16.3.1 If the rope used for rescue at fires or other emergency incidents or for training does not meet the criteria set forth in 7.16.3(1), 7.16.3(2), or 7.16.3(3) or fails the visual inspection, it shall be destroyed.

7.16.3.2 If there is any question regarding the serviceability of the rope after consideration of the criteria listed in 7.16.3, the rope shall be taken out of service.

(*) Asterisk indicates that explanatory material is included in Annex A. While Annex A is not a part of the requirements of the NFPA document, it is included for informational purposes only.
Annex A (NFPA 1500)

A.7.16.3 Life safety rope can be significantly weakened by abrasion, misuse, contamination, wear, and stresses approaching its breaking strength, particularly impact loading. Because there is no approved method to service test a rope without compromising
its strength, rope rescue and training operations should be carefully observed and monitored for conditions that could cause immediate failure or result in undetectable damage to the rope. If a rope has been used in a situation that could not be supervised or where potential damage could have occurred, it should be removed from service and destroyed.

It is important that ropes be inspected for signs of wear by qualified individuals after each use. If indications of wear or damage are noted, or if the rope has been stressed in
excess of the manufacturers’ recommendations or has been impact loaded, it should be destroyed. The destruction of the rope means that it should be removed from service and altered in such a manner that it could not be mistakenly used as a life safety rope. This alteration could include disposal or removal of identifying labels and attachments and cutting the rope into short lengths that could be used for utility purposes.

The assignment of disposable life safety ropes to members or to vehicles has proven to be an effective system to manage ropes that are provided for emergency use and are used
infrequently.

Special rescue teams, which train frequently and use large quantities of rope, should include members who are qualified to manage and evaluate the condition of their ropes and determine the limitations upon their reuse.

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Is relying on my local fire department in compliance with OSHA 1910.146?

Tuesday, September 13, 2011

Often the question comes up about using a local fire department for confined space rescue coverage in an industrial facility; and if it would be in compliance with OSHA 1910.146? In addition to the proper evaluation of the prospective rescue service, we always stress the need for “reciprocal communications” between the rescue service and the employer. For example, if the rescue service becomes unavailable at any time during a PRCS entry, the rescue service agrees to contact the employer so that the entry can be immediately suspended until the rescue service is once again available to respond in a timely manner.


The following is from an OSHA Letter of Interpretation dated 5/23/08.

Scenario: An employer evaluates and selects a local fire department using the guidance provided in Appendix F of the PRCS standard, Rescue Team or Rescue Service Evaluation Criteria (Non- mandatory). The employer has determined that the local fire department is adequately trained and equipped to perform permit space rescues of the kind needed at the facility. The employer has also made a performance evaluation of the service in which the employer has measured the performance of the team or service during an actual or practice rescue. However, the local fire department cannot guarantee that the rescue team will not be sent on another call during the employer’s permit-space entry operations. In other words, they have the ability to respond in a timely basis, unless another call prevents them from doing so.

Question: If the employer selects this local fire department as its off-site rescue service, would the employer be in compliance with 1910.146(k)(1)?

29 CFR 1910.146(k)(1) provides:

(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of his section, shall:

(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.

(ii) Evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified;

(iii) Select a rescue team or service from those evaluated that:

(A) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;

(B) Is equipped for and proficient in performing the needed rescue services;

(iv) Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and

(v) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

Note to paragraph (k)(1): Non-mandatory appendix F contains examples of criteria which employers can use in evaluating prospective rescuers as required by paragraph (k)(1) of this section.

The employer must evaluate and select an off-site rescue service that has the capability to respond in a timely manner to the particular hazards at issue and to the types of emergencies that may arise in the employer’s confined spaces. The criteria employers can use in evaluating and selecting a service include determining whether the service is unavailable at certain times of the day or in certain situations, the likelihood that key personnel of the rescue service might be unavailable at times, and, if the rescue service becomes unavailable while an entry is underway, whether the service has the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately.

Compliance may require the employer to be in communication with the off-site rescue service prior to each permit space entry. In the scenario described, the employer must ensure close communication with the rescue service during entry operations so that if the rescue service becomes unavailable while an entry is underway, the employer can instruct the attendant to abort the entry immediately. Entry operations cannot resume until the entry supervisor verifies that the rescue service is once again able to respond in a timely manner.

ROCO COMMENTS:

It’s important to note that the off-site service must be willing to perform rescues at the employer’s workplace. As referenced in Appendix F (5)… For off-site services, is the service willing to perform rescues at the employer’s workplace? (An employer may not rely on a rescuer who declines, for whatever reason, to provide rescue services.)

Also, while a written agreement with the local agency is not necessarily required by the regulation, it certainly would make it easier to document that an agreement to respond was in place – and that the department had an understanding of the scope of services to be provided at the employer’s site (i.e., confined space rescue).
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Cleaning Your Rope…Here’s What the Experts Have to Say

Wednesday, July 27, 2011

We are often asked, “How should I maintain my rescue equipment – especially rope?”

So, we went to our friends at CMC and PMI for the answers.  Keep in mind, however, you should always follow your rope manufacturer’s care and cleaning instructions.

CMC offers their rope cleaning suggestions: Rinse off muddy or especially dirty rope or web with water. Scrub any tough spots with a nylon bristle brush. Soak the rope in a tub of water with a mild detergent.

Woolite or other mild detergents that are safe for nylon may also be used. The rope can be rinsed using a rope washer or placed directly into the washing machine. Washing rope and webbing in a top-loading washing machine is the easiest method. Run the empty machine through a cycle with plain water to rinse any harsh detergents from the machine before starting. Use cold water and the appropriate amount of detergent.

Double the rope (or web) and “daisy-chain” it. This keeps single lines from tangling or getting caught in the agitator. Put the rope in the machine and wash on the gentle cycle. If the rope bag needs washing, put it in with the rope. During the rinse cycle, add a small amount of Downy fabric softener. (No more than one ounce of Downy to 3 gallons of water.) The fabric softener replaces the lubricant the rope loses during use and washing.  Air dry the rope and webbing in a cool, shaded place. Do NOT dry nylon products in the sun because of the damaging effects on nylon from prolonged exposure to ultraviolet rays. If necessary, ropes can be stuffed into the bags wet. The ropes may mildew but this does not adversely affect the rope. Rope that has come into contact with blood or other body fluids can be cleaned using a chlorine bleach per your department’s protocols for contaminating equipment.

PMI offers special precautions about cleaning exposed rope:

In cases where equipment may be exposed to blood‐borne pathogens or other infectious substances, we’re often asked about appropriate methods for cleaning ropes. Certain authorities recommend specific concentrations of household bleach for disinfecting gear that has been exposed to certain contaminants, so naturally customers often wonder at what concentration their PMI rope will experience deterioration. While PMI cannot speak to the subject of infectious diseases, or what solution might neutralize a given hazardous substance, we are happy to provide at least some guidance regarding the effect of bleach on rope fibers.

Specifically, PMI has found that a mixture of 1 part household bleach (with active ingredient of Sodium hypochlorite at 5.25% concentration) with 9 parts room temperature tap water and a 10 minute or less exposure time, immediately followed by a thorough rinse of room temperature water appears not to cause any appreciable harm to nylon or polyester ropes. PMI cannot, however, speak to whether or not such a mixture will truly disinfect your rope from contaminants.

Precautionary Note:  PMI’s testing suggests that a “single disinfection” of ropes using the above recommended method will not cause appreciable harm to nylon or polyester ropes. However, if this process is repeated multiple times, the damage will inevitably become appreciable, and this damage is not necessarily detectable through visual inspection.

Remember, ropes are a critical element of the life safety system, and it can be difficult to make subjective decisions about the strength of rope without actually testing it to failure. The prudent course of action is to discard any rope about which there is any doubt.
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What’s the talk about individual retrieval lines?

Wednesday, July 20, 2011

Because it is important to keep our readers and students updated, we wanted to share the following information with you. Please note that this issue is not resolved as of this time, and we have a letter submitted to OSHA for clarification. However, we wanted to keep you in the loop so that you can make better decisions when it comes to your rescue preplanning and operations.

It has recently come to our attention that there is a pending OSHA Letter of Interpretation (LOI) regarding the requirement for an “individual retrieval line” for each entrant. This pending interpretation is different from our understanding of what’s required by the regulation (1910.146). While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.

As mentioned above, Roco has submitted a detailed letter to OSHA for a clarification, stating our position that the use of individual lines for entrants in all cases is problematic for a number of reasons. Although OSHA’s response in its letter of interpretation is ambiguous as to its applicability to entry rescue operations, in our commitment to follow the intent of all OSHA standards, Roco is assuming that OSHA’s response was intended to apply to all entries, including rescue entries. Therefore, we will teach and use “individual lines” for the time being until we get further clarification from OSHA.

Question to OSHA:
In a request for clarification, a gentleman from Maryland had asked this question, “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?”

OSHA’s Response:
OSHA’s response in the LOI states, “OSHA 1910.146(k)(3)(i) requires that each authorized entrant into a permit-required confined space must have a chest or full-body harness attached to their ‘individual’ retrieval line or life line to ensure immediate rescue of the entrant.”

Roco Note: It is important to note that “individual” retrieval line is not used in (k)(3)(i); it simply refers to “a” retrieval line. The standard states, “Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant’s back near shoulder level, above the entrant’s head, or at another point….”

Additional Roco Comments:
First of all, OSHA’s Permit-Required Confined Spaces Standard is, for the most part, a “performance-based” standard, meaning that it generally provides a result that is to be met, but leaves the manner by which that result is to be obtained to the judgment of the employer. This is particularly true of the rescue and retrieval requirements, as the specific circumstances and conditions of each entry or rescue will dictate what equipment and techniques may be required. However, this pending Letter of Interpretation (LOI) regarding the use of retrieval lines in Confined Spaces crosses over into the area of specific equipment and techniques that must be used.

Consistent with the performance-based nature of the standard, Roco has taught for years a technique that uses a single retrieval line for multiple entrants as an option to reduce line entanglement hazards during a rescue. The use of this technique was based on testimony given to OSHA prior to the Permit Required Confined Spaces Standard (29CFR 1910.146) being published, and indeed our interpretation of the intent of the standard. The particular technique in question is a common practice for rescuers in which one retrieval line is used and multiple entrant/rescuers are attached at different intervals with butterfly knots to reduce entanglement hazards during a rescue (see example below.)


This pending interpretation would put restraints on techniques used by rescuers when entanglement issues could be a problem. It would result in the management of multiple retrieval lines in the space which could affect the effectiveness of the rescue or result in an increased danger to the entrants and/or rescuers. In effect, this OSHA interpretation could cause an “all or nothing” response regarding the use of retrieval lines for rescuers and entrants. This LOI would eliminate the opportunity of using an external rescue technique for certain situations.

Paragraph (k)(3)  allows entrants to forgo using a retrieval line in certain situations –
“To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”

The technique in question is an option that falls between each individual having an “individual” retrieval line, and having to opt out of using a retrieval line at all, and it allows for external retrieval to still be an option in many cases. And, as most of you know from personal experience, for most confined space portals only one individual can pass through at a time anyway. Even with multiple retrieval lines, it is still a “one at a time” event.  A shared retrieval line allows the same to take place.

It is Roco’s position that the rescue and retrieval techniques used in rescue should be performance based to allow for the ever-changing conditions and problems that are unique to rescue. We also feel this pending LOI could affect the safety and ability of rescuers to adjust to these situations. However, until this issue is clarified, Roco will not teach or use the technique of having multiple rescuers/entrants attached to the same retrieval line in consecutive order using midline knots as their attachment points.
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