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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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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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OSHA's Confined Space Construction Rule Under OMB Review

Tuesday, November 25, 2014

OSHA's final rule on confined spaces in construction is being reviewed by the Office of Information and Regulatory Affairs. The review is one of the final steps required before OSHA can formally publish the rule.

OIRA, which is a branch of the White House's Office of Management and Budget, received the rule for review on Nov. 14. The office is limited to a 90-day review but can request an extension. The rule has been in the works since at least 2003; the proposed rule was published in 2007.

Several provisions in the proposed rule are similar to those found in the agency's confined spaces standard for general industry. That rule, issued in 1993, mandates specific procedures and includes requirements such as a written program, atmospheric monitoring and training.

Stand by for additional updates on this regulation.

News story from the National Safety Council. 

 

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OSHA Emergency Response Meeting in Washington, DC

Thursday, August 07, 2014

Reported by Jim Breen, Roco Rescue Director of Operations

On July 30 and 31, OSHA held an Emergency Response and Preparedness Stakeholders meeting in Washington, DC for the purpose of discussing the merits and potential content of an emergency response and preparedness standard.

Meeting participants were from a broad range of both public and private industry experts to include two Roco representatives, Jim Breen, Director of Operations, and Dennis O’Connell, Director of Training. Also participating were representatives from NFPA, IAFF, IAFC, USFA, Louisiana Fire Chiefs Association, Phillips 66, BASF Corporation, Chevron Pipeline Company, Chicago Fire Department, and the American Red Cross to name a few.


The discussion allowed participants to highlight their experiences, voice concerns, and provide input to OSHA administrators who are tasked to make a need and content recommendations to OSHA's senior leadership.

The meeting consisted of four main topics:

1.  Which phases of an emergency incident should be included in a standard?

2.  Should the standard be inclusive of all incident types or should it be focused on those types of incidents that have resulted in a line-of-duty deaths (LODDs)?

3.  What content should be included in the standard?

4.  How can OSHA construct a standard that is practical, relevant, and flexible enough to cover all organizations, regardless of size and complexity?

OSHA was particularly mindful of having participants identifying issues that would impede the practical application of an emergency response and preparedness standard. OSHA administrators were very receptive of the views of the participants and stressed that they were not interested in writing a tactical or tactics standard. Although OSHA did not elaborate on any specific course of direction, it is our impression and hope that OSHA will begin drafting an emergency response and preparedness standard that is performance based, with a strong strategic focus, that emphasizes a recognized incident management system, outlines preparation activities inclusive of pre-incident planning, and is structured around the basic functions of command that will apply to all emergency response organizations that are subject to OSHA oversight.  

Emergency response is one of the most hazardous occupations in America. Emergency responders include firefighters, emergency medical service personnel, hazardous material employees, and technical rescue specialists. Also, law enforcement officers usually are considered emergency responders because they often assist in emergency response incidents.
Source: OSHA.gov and NFPA/FEMA 2012 Reports on Firefighter Fatalities

Background Information from OSHA.gov:

OSHA notes that there are no standards issued by the Agency that specifically address occupational hazards uniquely related to law enforcement activities. Many emergency responders have cross training in these specialties, and may serve in multiple roles depending upon the type of emergency incident involved. Skilled support employees are not emergency responders, but nonetheless have specialized training that can be important to the safe and successful resolution of an emergency incident.
 
OSHA issued a Request for Information in September 2007 that solicited comments from the public to evaluate what action, if any, the Agency should take to further address emergency response and preparedness. Recent events, such as the 2013 tragedy in West, Texas, that killed several emergency responders, and an analysis of information provided make it clear that emergency responder health and safety continues to be an area of ongoing concern. For this reason, OSHA conducted the stakeholder meetings to gather additional information.

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OSHA Seeks Input on Emergency Response Standard

Thursday, June 12, 2014

Prompted by the 2013 fire and explosion that killed 12 firefighters at a Texas fertilizer facility, as well as other recent incidents, OSHA is considering the development of a standard on emergency response and preparedness.

Stakeholders are invited to provide input at an informal OSHA meeting in Washington on July 30 and, if needed, on July 31. Attendees must register by July 2.

OSHA first sought public input on an emergency response and preparedness rulemaking in 2007, when the agency issued a Request for Information. In that request, OSHA noted that although several of its current standards address certain issues emergency responders face (including blood borne pathogens and confined spaces), some of those standards are decades old.

In 2012, 231 deaths occurred in the protective service industry, which includes firefighters and law enforcement personnel, according to Bureau of Labor Statistics data.

Story from The National Safety Council

 

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