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Confined Space Stand-by Teams: How many members?

Monday, March 28, 2011

This topic was brought to light by one of our blog participants. Since it may affect many industrial rescue teams in our readership, we are posting the information here to share with the entire community.

In response to a question about manpower requirements for stand-by rescue teams (How many members should be on a standby team?), the Roco Tech Panel has gathered some information which we hope will be helpful. First of all, we will address it from a regulations and standards prospective, and then offer some considerations and practical guidelines that we use here at Roco. 

Of course, your company’s internal policy and safety procedures must always be considered first.

OSHA’s Permit Required Confined Space Regulation (1910.146) is our primary reference for this topic; and, as mentioned, it does not state the specific number of personnel required for stand-by operations. This standard is intended to be “performance based” and a determination of the prospective rescue service’s ability to perform rescue from the types of spaces which they may respond is to be evaluated by the employer. If the evaluated team, regardless of number, can safely and effectively perform rescue from the applicable spaces in a timely manner, then the team would be deemed capable.

However, we must also use a degree of judgment and take into consideration all the particulars of the types of spaces that may be encountered and the types of injuries that the entrants may incur – which will dictate the type of patient packaging that may or may not be required inside the space.  All the factors, such as twists and turns into and out of the space, communications, placement of directionals, and intermediate anchors and haul/lowering systems should all be considered factors in determining the size of the rescue team. As an example, rescuing an entrant from a 24-inch round horizontal portal that is 3-feet off the ground would require a minimum of personnel. But, take this same scenario to 80-feet off the ground, or an on-air IDLH event, and it’s a much different story!

Next, the Respiratory Standard (1910.134), section (g)(3)(i) states that “One employee or, when needed, more than one employee is located outside the IDLH atmosphere;” and Section (g)(3)(iii) adds that…“The employee(s) located outside the IDLH atmosphere are trained and equipped to provide effective emergency rescue” – however, we are given no set number of personnel.

Sometimes we hear the HAZWOPER standard (1910.120) cited regarding IDLH response requirements. This standard requires the use of the “buddy system with stand-by personnel” for emergency response operations involving the release of hazardous substances producing IDLH conditions for employees responding. This regulation specifies a minimum of four personnel, two as a team in the buddy system and two stand-by personnel, to conduct operations in hazardous areas safely. Again, however, this is from the HAZWOPER regulation.

From the National Fire Protection Association, NFPA 1670 (Standard on Operations and Training for Technical Search and Rescue Incidents) states that six (6) rescue technicians shall be the minimum staffing for a “Technician Level” confined space response. This typically means any IDLH condition (breathing air; complexity; elevated or entanglement concerns) that exists in a permit required confined space rescue operation.

Now, we’ll give you an idea of how we address this at Roco with our stand-by rescue services. First of all, our typical (standard) Confined Space Rescue Team is made up of three persons including a Crew Chief and two Rescue Technicians. Keep in mind, that these are experienced, professional emergency responders, who perform stand-by rescue operations and/or train on a regular, if not daily, basis. In addition, the job circumstances and scope of work are carefully evaluated prior to committing a specific number of personnel. As a example, here are some basic guidelines:

Four-person team (minimum) for jobs involving inert entries, other types of IDLH entries, unusual space configurations (i.e., long distances, underground piping or complex obstructions.) As mentioned above, a three-person team made up of experienced rescuers is our standard operational manning requirement. This applies to the majority of our stand-by rescue work. In certain instances, a two-person team may be appropriate. For example, when there is very low potential for atmospheric hazards; large and easily assessable manways; no secondary lowering operations required; strictly horizontal movement, etc.

In closing, we must re-emphasize that OSHA 1910.146 is a performance-based standard that requires safe, timely and capable rescue response for confined space incidents. A realistic, hands-on rescue performance evaluation as referenced in Appendix F of this regulation can be a valuable tool in determining training, equipment and personnel needs based on the circumstances in your response area.

We hope this information has been helpful. Roco Rescue Online and the information herein is provided as a complimentary service for rescuers and emergency response personnel. As always, proper training is required prior to use of any technique described. If we may be of further assistance, please don’t hesitate to contact us at Roco headquarters by calling, 1-800-647-7626.
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How often should I replace my rescue harness?

Tuesday, March 15, 2011

We get many calls asking about the “life expectancy” of rope, harnesses and other nylon products. Of course, there are many factors involved and no one “set in stone” answer, but a lot depends on how much you use your harness and the ways you use it. Even where you store your gear is a factor. 

For example, for emergency responders working in industrial environments, atmospheric exposures may be a key consideration for nylon products even while in storage. Another consideration is “when” the harness or rope was made… manufacturing parameters change as technology improves and you may just want a product that’s been tested to the latest standards. However, as with all of your rescue equipment, it’s important to account for its use as well as to follow the manufacturer’s instructions.


Never take chances when there’s any doubt about the serviceability of a life safety product. For more details on the service life of nylon products, our harness manufacturer, CMC Rescue, has provided the following information:

The service life of a rescue harness is closely related to the life of a rescue rope – both are used in the same environments, both are made from nylon or polyester, and both receive similar levels of inspection and care. Since harnesses are worn on the body, they are generally better protected than the ropes. On the other hand, harnesses rely on the stitching to hold them together, and due to its small diameter, the thread can be more susceptible to abrasion, aging, and chemical damage than web or rope.

The fall protection industry recommends 2 to 3 years as a service life for a harness or belt in use. They recommend 7 years for the shelf life. The military was using 7 years as a service life for nylon products. The Climbing Sports Group of the Outdoor Recreation Coalition of America says that a climbing harness should last about two years under normal weekend use. At this time, the rescue industry does not have a recommended service life for harnesses.

Through the ASTM consensus standards process, the rescue industry set 10 years as the maximum service life for a life safety rope, see ASTM Standard F1740-02 Guide for Inspection of Nylon, Polyester, or Nylon/Polyester Blend, or both Kernmantle Rope. The guide stresses that the most significant contributing factor to the service life of a rope is the history of use. A rope that is shock loaded or otherwise damaged should be retired immediately. Hard use would call for a shorter service life than would be acceptable for a rope that sees very little use.

If we apply the same analysis to the rescue harness, then the actual use and the conclusions drawn from inspection would be the significant criteria for retirement. We do know that with any use, a rope will age, and thus a harness is likely to do the same, so a 10-year maximum service life may well be appropriate for harnesses as well assuming inspection has not provided any reason for early retirement.

As with ropes, if the harness has been subjected to shock loads, fall loads, or abuse other than normal use, the harness should be removed from service. If there is any doubt about the serviceability of the harness for any reason, it should be removed from service.
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What does it mean when my atmospheric monitor gives negative or minus readings?

Thursday, December 02, 2010

At some point, most atmospheric monitors will display a “negative” or minus reading for a flammable gas or toxic contaminant. First of all, it is not actually possible for an atmosphere to contain a “negative amount” of a substance. These negative readings usually result from improper use of the monitor.

Most monitors will “Field Zero” or “Fresh Air Calibrate” its sensors when powered on. Because of this, it is very important to power on the unit in a clean, fresh air environment away from confined spaces, running equipment or other possible contaminants. Otherwise, the monitor may falsely calibrate based on the contaminant that is present.For example, a monitor that is powered on in an atmosphere that contains 10 ppm of a contaminant and then moved to fresh air may display a reading of minus 10 ppm. Even more troublesome, if that same monitor is then brought to a confined space that actually contains 25 ppm of the contaminant, it may display a reading of only 15 ppm. As you can see, this could easily lead to the improper selection of PPE for the entrant and result in a confined space emergency.

As always, it is very important to consult with the manufacturer of your particular atmospheric monitor in order to determine how to use it properly. Don’t take any chances with this critical part of preparing for confined space entry or rescue operations.
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Is there a regulation requiring rescuers to use respiratory protection that is “one level higher” than that required for the entrants?

Thursday, November 18, 2010

To our knowledge, there is no regulatory requirement. However, we’ve heard this before and have used it as well when stressing the importance of proper PPE for rescuers, particularly when IDLH atmospheres may be involved. Here’s our thinking… if the entrant’s PPE did not provide adequate protection and he or she is now requiring rescue assistance, then using their “same level of protection” isn’t going to protect you either!

What triggers the use of a greater level of protection? This comes from the rescuer’s assessment of the hazards – including the use of an independent atmospheric monitor from that used by the entrant(s). That’s why it’s so important for the rescue team to provide their own atmospheric monitoring equipment. It also illustrates why written rescue preplans are so important – you need to preplan what equipment and techniques will be required well in advance of an emergency. It’s critical; the PPE selected must be adequate to protect the rescuers.

When preparing rescue preplans, you must also take into consideration any unusual hazards or circumstances that may arise from any work being done inside or near the space. For example, special cleaning solvents might be used or other hazards may be introduced into the space by the workers. Referencing and understanding the MSDS as well as “listening to what your monitor is telling you” are key factors in PPE determination.

OSHA does mention, however, if the atmospheric condition is unknown, then it should be considered IDLH and the use of positive pressure SCBA/SAR must be used. This will protect you from low O2 levels and other inhalation dangers; however, you must also consider LEL/LFL levels. Other factors include non-atmospheric conditions as well. For example, have you considered “skin absorption” hazards and what precautions must be taken?

So, the bottom line, the decision to go with breathing air for rescuers can be determined from your hazard assessment; or, in some cases, by company policy; and even required by OSHA when there’s an unknown atmosphere involved. Remember, it’s much better to be safe than sorry!
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Municipal Response to Permit-Required Confined Spaces

Tuesday, November 16, 2010

A blog reader, who is a member of a municipal rescue team assigned to an airport, expressed concern about fulfilling “timely response” obligations for permit-required confined space entries within his district. Here are some suggestions from our Tech Panel…

First of all, the departments and agencies involved must carefully consider the obligations in providing rescue response for permit-required confined spaces.

Obviously, we cannot advise on departmental policy concerning response and notification, this must be determined by management officials. However, for you as an emergency responder, we cannot stress enough the importance of preplanning and conducting a hazard analysis for all confined spaces within your response area. The information gained by the analysis will help you determine what level of “timely response” may be required for a particular type of entry.

OSHA does not set a specific response time because there are too many variables involved – plus, they don’t want to set requirements that might cause a rescue team to “rush” into entering a space to attempt a rescue. OSHA does reference how long a person might survive an IDLH atmosphere (such as an oxygen deficient atmosphere) before becoming incapacitated (4 to 6 minutes). However, even this is up to interpretation depending on the level of oxygen present. For example, an 18% O2 level vs. a 6% O2 level, both are O2 deficient but have very different response requirements for successful rescue.

Another important consideration is when an entrant is entering an IDLH environment. In this case, having a team standing by the portal, fully equipped and ready to go may be the only way to meet a timely response for that situation. OSHA’s 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.”

Most entries, however, are not IDLH. This means that other forms of “external” rescue (vs. internal rescue) may be appropriate. Many times, in the rush of the moment, rescuers forget about external retrieval. Guessing that many of the spaces around the airport are manholes or vaults, these can most often be handled by the confined space attendant with an external retrieval system. This would include a mechanical winch attached to a tripod with a cable attached to the entrant’s high-point dorsal connection. Of course, this decision would be based on a prior hazard analysis.

NOTE: It’s important to note that ALL entrants are required to have “an immediate means of retrieval.” Reference OSHA 1910.146 [note to paragraph (k)(1)(i)] concerning timely response: “What will be considered timely will vary according to the specific hazards involved in each entry…”

As a final note, if hazard analysis and rescue preplans have not been conducted on your potential sites as required by OSHA, we encourage you to do so. Taking the time to do so will better enable you to determine what would be considered an appropriate “timely response” for a particular type of entry. It will also better prepare you as an emergency responder should the need arise.
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