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Valero’s Measure of Success: Safety

Tuesday, August 02, 2011

Valero Energy Corporation pledges “consistent, high-quality products” but its most important measure of success is the “health and safety of its employees, contractors, customers and neighbors.” So, it’s no surprise that Valero sends its rescue teams to the Roco Challenge. One Valero team member professed that while Roco’s Rescue Challenge was indeed “very challenging,” he also added that his team benefited from the communication, leadership, safety awareness, problem-solving experience and teamwork.

Valero invests in emergency preparedness and response training to ensure that employees are prepared to respond quickly to any emergency. The company is committed to “frequent training for all personnel in emergency management, incident command and tactical operations.”

Each of Valero’s four rescue teams, one for each of their shifts, completes quarterly training that covers IPE’s (Individual Performance Evaluations), TPE’s (Team Performance Evaluations), High Angle Rescue, Confined Space Rescue and Team Building.

With its recordable-injury rate among the lowest in the industry, the Valero teams have been fortunate not to have to use their skills in a real rescue,  but without a doubt will be ready in case an emergency arises.
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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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Petzl RECALL

Monday, July 18, 2011

We have learned that Petzl America is recalling about 375,000 shock-absorbing lanyards that were sold worldwide beginning in 2002, according to an announcement on July 12 from the Consumer Product Safety Commission. Consumers are advised to stop using the devices immediately, and contact Petzl for more information.



Petzl America Inc. has voluntarily recalled about 375,000 Scorpio and Absorbica shock-absorbing lanyards that have been sold since 2002, the U.S. Consumer Product Safety Commission announced July 12. Some of the lanyards are missing a safety stitch on the attachment loop, which could cause the lanyard to separate from the climbing harness, the posted announcement states. No injuries have been reported in the U.S., but one fall injury in France has been. Consumers should stop using them immediately; CPSC notes that it is illegal to resell or attempt to resell a recalled consumer product.

The lanyards were made in France. All Scorpio and Absorbica lanyards manufactured before May 2011 are included. Scorpio lanyards manufactured between 2002 and 2005 with model numbers L60 and L60 CK, which are yellow and blue, Y-shaped lanyards with yellow stitching on both ends, connected by a metal O-ring to one end of a blue pouch containing the tear-webbing shock absorber, are included. The pouch has a tag on it with the word “PETZL” in white letters, and the other end of the blue pouch has a blue and yellow webbing attachment loop that connects to the climbing harness. Scorpio lanyards manufactured between 2005 and 2011 are model numbers L60 2, L60 2CK, L60 H, and L60 WL. They are red, Y-shaped lanyards connected by a black metal O-ring to one end of a grey zippered pouch containing the tear-webbing shock absorber. The other end of the pouch has a black webbing attachment loop that connects to the climber’s harness.

Absorbica lanyards included in the recall have model numbers L70150 I, L70150 IM, L70150 Y, L70150 YM, L57, L58, L58 MGO, L59, and L59 MGO. They have a black zippered pouch with yellow trim and the Petzl logo on the side and a tear-webbing shock absorber accessible through the zippered pouch. The pouch has a connector attachment on one end and a connector attachment, a single lanyard, or a Y-shaped lanyard on the other end. Authorized Petzl dealers in the United States and Canada sold them from January 2002 through May 2011.

For a free inspection and replacement, contact Petzl America Inc. at 877-740-3826 between 8 a.m. and 5 p.m. Mountain time weekdays or visit Petzl's website.
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What about rescue response for fallen workers at height?

Thursday, July 14, 2011

We recently received a question about  what constitutes a prompt and capable rescue response for fallen workers at height suspended by their Personal Fall Arrest System (PFAS).

Question:
  My question concerns guidance on the number of rescue/standby team members needed for response to “worker at heights” type incidents. We work in a chemical plant, so it’s basically areas such as columns, etc.

Answer:  OSHA guidance for rescue of fallen workers utilizing personal fall arrest systems (PFAS) is quite vague in that it calls for “prompt rescue.” For more definitive guidance on the subject, ANSI Z359.2 Para E6.1 recommends that contact with the rescue subject (communication or physical contact) should occur as soon as possible after the fall. The recommended goal for rescue subject contact should be less than six minutes. What constitutes “prompt rescue” can vary depending on the circumstances. The type of potential hazards identified in the Fall Hazard Survey report should determine rescue planning.

For example, if the work area exposes the worker to an IDLH condition such as energized equipment, then the Fall Hazard Survey should trigger the “Rescue Plan” to include a near immediate rescue provision because of the potential of worker electrocution leading to a fall and subsequently, a suspended victim. In a situation like this, it is imperative that prompt rescue would provide a means to have the rescue subject in a position that allows CPR in less than 6 minutes — and preferably much faster than that! The only way to respond this quickly is to have a “Stand-by Rescue” posture where the rescue system and personnel are pre-rigged and ready to initiate the rescue immediately.

For other situations, if communications with the rescue subject are established in six minutes or less, and it is determined that the victim is relatively unharmed (alert and oriented, good airway and breathing, and no signs of active bleeding) then the urgency is reduced and a more measured approach to the rescue could be employed. There is still the potential for suspension trauma to develop over a range of several minutes, so a “prompt” but measured rescue would still be necessary.

With this in mind, it is important for an employer with workers at height to complete a Fall Hazard Survey report to determine the most appropriate way to abate any fall hazards. If the use of PFAS is necessary, that triggers the need to complete fallen worker Rescue Preplans. The employer will need to identify the rescue assets and ensure they are available, equipped, and trained to perform safe and prompt rescue for any situation that they may be summoned to at the employer’s facility. For rescuers outside the employer’s workforce, it is important to thoroughly vet the prospective rescuers to make these assurances.

This information was provided by Pat Furr, Roco Chief Instructor and Technical Consultant. He regularly assists Roco customers in identifying opportunities to improve their fall protection programs and can guide safety professionals in the completion of Fall Hazard Survey reports. Roco can also assist in the development of fallen worker Rescue Preplans. For help with selecting the proper equipment or training, call us at 800-647-7626.
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1910.147 LOTO vs. 1910.146 Isolation

Wednesday, July 06, 2011

Question:  If I close and Lockout/Tagout the main valve on the natural gas line supplying a boiler unit – does this satisfy OSHA’s requirement for eliminating the hazard of a permit required confined space?

Answer:  No, it does not. You are asking a question that we address quite often and it reveals some misconceptions regarding “eliminating” or “isolating” the permit space from hazards. Lockout/Tagout (LOTO) procedures are covered in OSHA’s 1910.147 “Control of Hazardous Energy (Lockout/Tagout).

” Many times this regulation is incorrectly referenced when addressing permit space hazards that are not covered by this regulation.
OSHA’s 1910.147 LOTO regulation applies to the control of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. It does not apply to engulfment hazards (liquid or flowable solids), flammable gasses, or other gasses that may be toxic or oxygen displacing.

It is important to understand this distinction because the use of isolation procedures appropriate for the hazards addressed in 1910.147 may not be effective in eliminating other hazards.  “Isolation,” as defined in the Permit Required Confined Space regulation (1910.146) spells out the various measures required to eliminate hazardous energies as covered in the LOTO regulation as well as the types of hazards that are not addressed in that regulation.  You will note that 1910.146 cites LOTO as a means to isolate all sources of energy (emphasis added), but outlines other methods used to isolate the other hazards such as hazardous materials. These isolation procedures include the process by which a permit space is “removed from service” and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

By closing and placing a LOTO device on a single valve of a natural gas feed line, you may have controlled the hazard but you have not eliminated it. To provide true isolation (elimination), you will have to employ such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; or a double block and bleed system.

Download the LOTO tip sheet from NIOSH.
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