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Safe Confined Space Entry - A Team Approach

Wednesday, September 12, 2018

Having been involved in training for 30 years, I have had the opportunity to observe how various organizations in many different fields approach confined space entry and rescue. And, when it comes to training for Entrants, Attendants and Entry Supervisors, the amount of time and content varies greatly.

Roco Rescue CS EntryMost often, training programs treat the three functions as separate, independent roles locked into a hierarchy based on the amount of information to be provided. However, it’s critical to note, if any one of these individuals fails to perform his or her function safely or appropriately, the entire system can fail – resulting in property damage, serious injury or even death in a confined space emergency.

Before I go any further, I have also seen tremendous programs that foster cooperation between the three functions and use more of a confined space “entry team” approach. This helps to ensure that the entry is performed safely and efficiently.

It also allows all parties to see the overall big picture of a safe entry operation.
In this model, all personnel are trained to the same level with each position understanding the other roles as well. This approach serves as “checks and balances” for confirming that:

• The permit program works and is properly followed;
• The permit is accurate for the entry being performed;
• All parties are familiar with the various actions that need to occur; and,
• The team knows what is expected of each other to ensure a SAFE ENTRY!

However, I am often surprised to find that Entrant and Attendant personnel have little information about the entry and the precautions that have been taken. They are relying solely on the Entry Supervisor (or their foreman) to ensure that all safety procedures are in place. If you have a well-tuned permit system and a knowledgeable Entry Supervisor, this may be acceptable, but is it wise? As the quality of the permit program decreases, or the knowledge and experience of the Entry Supervisor is diminished, so is the level of safety.


Roco CS Entry Supervisor & AttendantIn my opinion, depending exclusively on the Entry Supervisor is faulty on a couple of levels. First of all, the amount of blind trust that is required of that one person. From the viewpoint of an Entrant, do they really have your best interest in mind? And, we all know what happens when we “ass-u-me” anything! Plus, it puts the Entry Supervisor out there on their own with no feedback or support for ensuring that all the bases are covered correctly. There are no checks and balances, and no team approach to ensuring safety.

Looking at how 1910.146 describes the duties of Entrant, Attendant and Entry Supervisor tends to indicate that each role requires a diminishing amount of information. However, we believe these roles are interrelated, and that a team approach is far safer and more effective. To illustrate this, we often pose various questions to Entrants and Attendants out in the field. Here is a sample of some of the feedback we get.

We may ask Entrants…Who is going to rescue you if something goes wrong? Has the LOTO been properly checked? At what point do you make an emergency exit from the space? What are the acceptable entry conditions, and have these conditions been met? How often should the space be monitored? Typically, the answer is, “I guess when the alarm goes off, or when somebody tells me to get out!”

When we talk to Attendants about their duties, we often find they only know to “blow a horn” or “call the supervisor” if something happens, or if the alarm on the air monitor goes off. We also ask…What about when the Attendant has an air monitor with a 30 ft. hose, and there is no pump? Or, if you have three workers in a vertical space and the entire rescue plan consists of one Attendant, a tripod and a winch, plus no one in the space is attached to the cable – what happens then?
  
These are very real scenarios. Scary, but true. It often shows a lack of knowledge and cooperation between the three functions involved in an entry. And, that’s not even considering compliance!
We ask, would it not be better to train your confined space entry team to the Entry Supervisor level? Wouldn’t you, as an Entrant, want to know the appropriate testing, procedures and equipment required for the entry and specified on the permit? Would it not make sense to walk down LOTO with the Attendant and Entrant? This would better train these individuals to understand non-atmospheric hazards and controls; potential changes in atmosphere; or, how to employ better air monitoring techniques. All crucial information.

More in-depth training allows the entry team to take personal responsibility for their individual safety as well as that of their fellow team members. It also provides multiple views of the hazards and controls including how it will affect each team member’s role. Having an extra set of eyes is always a good thing – especially when dealing with the hazards of permit spaces. Let’s face it, we’re human and can miss something. Having a better-trained workforce, who is acting as a team, greatly reduces this possibility.

Roco Rescue Remote MonitoringMany times, we find that the role of Attendant is looked upon as simply a mandated position with few responsibilities. They normally receive the least amount of training and information about the entry. However, the Attendant often serves as the “safety eyes and ears” for the Entry Supervisor, who may have multiple entries occurring at the same time. In reality, the Attendant becomes the “safety monitor” once the Entry Supervisor okays the entry and leaves for other duties. So, there’s no doubt, the better the Attendant understands the hazards, controls, testing and rescue procedures – the safer that entry is going to be!

As previously mentioned, training requirements for Entrant, Attendant and Supervisor are all over the board with little guidance as to how much training or how in-depth that training should be. Common sense tells us that it makes better sense to train entry personnel for their jobs while raising expectations of their knowledge base.

OSHA begins to address some base qualifications in the new Confined Spaces in Construction standard (1926 Subpart AA) by requiring that all confined spaces be identified and evaluated by a “competent person.” It also requires the Entry Supervisor to be a “qualified person.” Does the regulation go far enough? We don’t think so, nor do some of the facilities who require formal, in-depth training courses for their Entrant, Attendant and Entry Supervisor personnel.

OSHA 1926.32 DEFINITIONS:
• Competent person: “One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.” 
• Qualified person: “One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” 

So, do yourself a favor…go out and interview your Entrants and Attendants on a job.
Find out how much they do (or don’t) understand about the entry and its safety requirements. Do not reprimand them for not knowing, as it may not be their fault. It may be a systemic deficiency and the training mentality of distributing a hierarchy of knowledge based on job assignment.

Simply put, we believe that arming the entry team with additional information results in safer, more effective confined space operations. After all, isn’t that what it’s all about? GO TEAM!

Additional Resources:
• Download our Confined Space Entry Quick Reference Checklist. This checklist reiterates the value of approaching permit-required confined space entries as a team. In addition to OSHA-required duties and responsibilities for the three primary roles, we have included our recommendations as well. These are duties that we feel are important for the individual(s) fulfilling that role to be knowledgeable and prepared to perform if need be.

Safe Entry Workshop: Entrant, Attendant & Entry Supervisor is now available. See the full course description for details.

Roco Rescue - Dennis O'Connell

Author's Bio: Dennis O'Connell has been a technical rescue consultant and professional instructor for Roco Rescue since 1989. He joined the company full-time in 2002 and is now the Director of Training and a Chief Instructor. He currently is responsible for Roco's training curriculum to include Confined Space & High Angle, Trench Rescue, Structural Collapse and Instructor Development. Dennis has played a key role in the development of Roco's Rescue Technician certification programs to NFPA 1006. Prior to joining Roco, he served on the NYPD Emergency Services Unit (ESU) for 17 years. He was a member of NY's Task Force 1 and has responded to numerous national disasters such as the World Trade Center and the Oklahoma City bombing.

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Know When NOT to Enter a Confined Space!

Friday, August 17, 2018

There are countless injuries and deaths across the nation when workers are not taught to recognize the inherent dangers of permit spaces. They are not trained when "not to enter" for their own safety. Many of these tragedies could be averted if workers were taught to recognize the dangers and know when NOT to enter a confined space.

While this incident happened several years ago, it emphasizes the senseless loss of life due to a lack of proper atmospheric monitoring and confined space training. Generally, the focus for training is for those who will be entering spaces to do the work. However, we also must consider those who work around confined spaces – those who may be accidentally exposed to the dangers. Making these individuals aware of the possible hazards as well as to stay clear unless they are properly trained.

Note: This case summary from the New York State Department of Health goes on to say that the DPW had a confined space training program but stopped the training after the last trainer retired.

CASE SUMMARY - TWO (2) FATALITIES
A 48-year-old male worker (Victim I) employed by the Department of Public Works (DPW) and a 51-year-old male volunteer firefighter (FF Victim II) died after entering a sewer manhole located behind the firehouse. In fact, the Fire Chief was on scene because he had been called by the DPW general foreman to unlock the firehouse and move the firetruck so it would not be blocked by the DPW utility truck working at the manhole. Another firefighter also arrived to offer assistance, he later became FF Victim II.

The manhole was 18 feet deep with an opening 24-inches in diameter (see photo above). Worker Victim I started climbing down the metal rungs on the manhole wall wearing a Tyvek suit and work boots in an attempt to clear a sewer blockage. The DPW foreman, another firefighter and FF Victim II walked over to observe. They saw Victim I lying on the manhole floor motionless. They speculated that he had slipped and fallen off the rungs and injured himself. The Fire Chief immediately called for an ambulance.

Meanwhile, FF Victim II entered the manhole to rescue Victim I without wearing respiratory protection. The other firefighter saw that FF Victim II fell off the rungs backwards while he was half way down and informed the Fire Chief. The Fire Chief immediately called for a second ambulance and summoned the FD to respond. FD responders arrived within minutes.

The Assistant Fire Chief (AFC) then donned a self-contained breathing apparatus. He could not go through the manhole opening with the air cylinder on his back. The cylinder was tied to a rope that was held by the assisting firefighters at the ground level. The AFC entered the manhole with the cylinder suspended above his head. He did not wear a lifeline although there was a tripod retrieval system. He secured FF Victim II with a rope that was attached to the tripod.

FF Victim II was successfully lifted out of the manhole. The AFC exited the manhole before a second rescuer entered the manhole and extricated Victim I in the same manner. Both victims were transported to an emergency medical center where they were pronounced dead an hour later. The cause of death for both victims was asphyxia due to low oxygen and exposure to sewer gases.

Contributors to the Firefighter's Death:
• Firefighters were not trained in confined space rescue procedures.
• FD confined space rescue protocol was not followed.
• Standard operating procedures (SOPs) were not established for confined space rescue.

The DPW had developed a permit-required confined space program but stopped implementing it in 2004 when the last trained employee retired. They also had purchased a four-gas (oxygen, hydrogen sulfide, carbon monoxide and combustible gases) monitor and a retrieval tripod to be used during the training. It was reported that a permit-required confined space program was never developed because DPW policy “prohibited workers” from entering a manhole. However, the no-entry policy was not enforced. Numerous incidents of workers entering manholes were confirmed by employee interviews.

This incident could have been much worse. Training is the key, whether it’s just an awareness of the dangers in confined spaces or proper entry and rescue procedures. In this case, the victims had no C/S training even though they may have to respond to an incident, and the worker had not had on-going training through out his career. Periodic training to keep our people safe and aware of proper protocols is key to maintaining a safe work force.

Unfortunately, training is usually one of the first things to be cut when the budget gets tight; however, after an incident, it usually becomes the primary focus. Often the lack of training is determined to be a key element in the tragedy.
Investing in periodic training for the safety of your workforce includes spending the time and money to keep your trainers and training programs up to speed and in compliance. The old saying, “closing the barn doors after the horses escaped,” is no way to protect your people – a little investment in prevention goes along way in preventing these tragedies.

One last comment on my biggest pet peeve – proper, continuous air monitoring. This one step can reduce the potential of a confined space incident by about 50%! Don’t take unnecessary chances that can be deadly.

Dennis O'Connell has been a technical rescue consultant and professional instructor for Roco Rescue since 1989. He joined the company full-time in 2002 and is now the Director of Training and a Chief Instructor. Prior to joining Roco, he served on the NYPD Emergency Services Unit (ESU) for 17 years.

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Firefighter Deaths Lower in 2017

Tuesday, August 07, 2018

Deaths among career and volunteer firefighters continued to be low in 2017 with both at the second lowest level since 1977, when the NFPA study began. There were 60 on-duty firefighter fatalities across the nation in 2017. Of these deaths, 21 were career firefighters and 32 were volunteers. The seven remaining deaths were employees or contractors of federal land management agencies. Sudden cardiac death accounted for the largest share of fatalities with 29 deaths. 

There were 17 deaths at fire scenes (9 structure fires and 8 wildland fires). NFPA also reported that an unusually high number of firefighters (10) were struck and killed by vehicles. Two firefighters were killed and another injured by a drunk driver at the scene of downed power lines.

For more detailed information, visit NFPA.org.
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Is Your Rescue Team Ready?

Monday, July 23, 2018

Guidance for improving and maintaining rescue team proficiency...

We all want to succeed, no matter what we are doing. And success is always better than the alternatives…whether a mediocre performance or worse yet, failure. When it comes to rescue, all of a sudden, the difference between success and failure takes on much greater significance.Not only are the lives of the rescue subjects held in the balance, but also the rescuers. Multiple risks are involved with technical rescue and failure may cost the rescuers mightily, and this has been proven too many times. There are many things, however, that rescuers can do to help improve their chances of success, and that's what we will talk about here. 

We have found that the one thing that seems to be a lagging factor is a "lack of proficiency" in performing the required skills either as individuals or as a team. Having rescue preplans, the newest and best equipment, sufficient manning, and reliable communications are all pieces of the puzzle. But all of that becomes nothing more than window-dressing if the team or individuals on the team are unable to perform their duties safely and effectively. This is such an important consideration that several regulations and standards make a point to remind us that proficiency is a high-interest issue. 

For instance, OSHA 1910.146 paragraph K and Appendix F, as well as 1926.1211, require designated rescuers to 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. It is our position that this does not even come close to the training time needed to maintain an appropriate level of proficiency. 

Additionally, NFPA 1006 requires rescuers to demonstrate competency on an annual basis. One of NFPA’s recommendations is to attend workshops and seminars, read professional publications, and participate in refresher training as ways technical rescue personnel can update their knowledge and skills. 

I am routinely asked how often a rescue team should practice. And they're always a bit surprised when I do not give them a hard and fast answer such as quarterly or monthly for a minimum of 4 hours. My answer is and will always be, “as often as it takes to ensure you are proficient, as individuals and as a team, to safely and effectively rescue potential victims from any situation you may be called to respond.”

You would be amazed at the spectrum of training schedules that are out there. Some teams practice on a bi-weekly basis and mix in different scenarios to ensure they will not miss any opportunities to improve their skills or to identify any gaps they may have in technique or equipment. Whereas other teams may feel that once a year is all that they need. Knowing how perishable these skills are, we tend to disagree.

It has been our experience that the teams who practice on a very regular basis and really mix it up when they design their training scenarios are the ones who perform best when they come to our facility or we go to theirs for a team performance evaluation (TPE), which can also include an individual performance evaluation (IPE), if desired. The teams and individuals that struggle most during our TPE/IPE visits are the ones that seldom train. And, even though we all call these TPE/IPE visits, we do provide tips and spot training to help correct any deficiencies observed. 

But frequency is no guarantee of excellent performance. It isn’t just about the quantity of training; it must be the quality of training as well. One of the best ways to supplement in-house training is to attend third party refresher training. Or, if it has been a while since a full-on training class, by all means a more extensive and complete training package may be a great option. Roco's annual Rescue Challenge provides an excellent learning experience as well as a way to confirm the true rescue capabilities of your team. 

Technical rescue skills are one of the most perishable skills I have known. Without regular practice and quality training, it is not long before the individual and team skills erode to the point of becoming a liability to the victim and to other team members.

Again, none of us wants to fail - especially on a rescue mission. A good way to avoid this is to dedicate adequate resources to training along with regular refreshers and practice drills. Prepare and practice for your "worst case" scenarios because you just never know when your team may be put to the test. Be ready!

Written by Pat Furr, VPP Coordinator for Roco Rescue, Inc.

About the Author:
Pat Furr has been employed with Roco since 2000 and has been actively involved with technical rescue since 1981. Pat is a Chief Instructor for Roco as well as its VPP Coordinator and Safety Officer. He is also a presenter at national conferences such as ASSE and VPPPA. Prior to Roco, Pat served 20 years in the USAF as a Pararescueman (PJ). His background includes eight years as a member of the 71st Pararescue team in Anchorage, Alaska, where he specialized in mountain and glacier rescue. Pat was a team leader of the 1986 and 1988 PJ teams that summited Mt. McKinley and augmented the National Park Service mountain rescue team. He also spent two tours of duty in Iceland where he put in multiple “first ascent” ice routes.


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OSHA-1926 Dockside Rescue Requirements

Tuesday, July 17, 2018

Roco now offers marine rescue standby services for the Baton Rouge-New Orleans industrial corridor. As with other Roco services, our personnel are experienced emergency responders trained to provide lifesaving skills when it matters most.

All Roco marine standby personnel are First Responder/ CPR/First Aid trained, and most are EMT’s. Our boats are fully equipped with First Aid kits, AEDs and O2 for prompt emergency care.

For construction work over or near waterways, OSHA 1926.106 requires certain safety precautions – including the timely response of a boat to rescue a fallen worker. In fact, according to one OSHA LOI, the retrieval of an employee from the water is required no more than 3 to 4 minutes from the time they entered the water. And, depending on hazards present, it could be required even sooner.

Section 1926.106(d) states:
At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.

The intent of the paragraph is to ensure prompt rescue of employees that fall into the water, regardless of other precautions taken to prevent this from occurring. Thus, OSHA requires that employers supply a skiff to affect a prompt water rescue. As a skiff supplies a backup to potential failures of fall protection devices, the use of fall protection systems is not a substitute for the skiff.

The requirement in 1926.106(d) addresses the hazard of falls that may occur in the event of a failure of the operation of fall protection devices or a lapse in their use. An employer is also required to comply with all other applicable standards including, but not limited to, the requirements that an injured employee be treated by medical personnel or an employee certified in first aid within 3 to 4 minutes from the time the injury occurred. This could mean that first aid treatment would have to begin in the lifesaving skiff or boat.

For more information on this service, please contact Roco at 800-647-7626 or email info@rocorescue.com.

Resources: OSHA 1926.106 as well as Letters of Interpretation (LOI’s) dated 8/23/04; 12/5/03; 12/6/91; and 06/13/90.

NOTE:  In this article, Roco cites OSHA 1926.106 which applies to construction activities while working over or near water. For other industries such as shipyard (Part 1915), marine terminals (Part 1917), or longshoring (Part 1918), please refer to those standards for specific requirements, particularly for PFDs and rescue skiffs. OSHA does not require rescue skiffs for all industry activities. However, keep in mind, OSHA sets minimum standards. And, remember, there’s a safe way and a safer way!

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