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Planning for Successful Confined Space Rescue

Thursday, September 21, 2017

By Dennis O'Connell, Roco Director of Training & Chief Instructor

I am often asked by plant managers or rescue team supervisors about getting their team on the right track as far as training and competency is concerned. Here are a few tips for doing just that…

First of all, I always recommend that they choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) adds to the confusion of team members as to what techniques and equipment are being used – especially during a real rescue!

I then suggest that the team’s training records be reviewed in order to determine what level of training has been completed. I also strongly recommend getting everyone to the same level; especially if your facility is what I refer to as an “island unto itself.” In other words, do you have nearby facilities or other local agencies who can offer additional manpower, equipment, etc. in an emergency – or, are you fairly isolated?

Same Page, Same Language
If your facility is somewhat isolated, getting all your rescue team members on the same page, talking the same language, and at the same level of training is extremely important. You may have some experienced rescuers who have completed a variety of courses from different providers and are trained to different levels. Is this previous training properly documented should you be asked about it and to what levels? Having everyone on the same level – with the same basics under their belt – is key to performing a timely and successful rescue
And, do you have a particular goal or level you want your team to strive for, achieve, and maintain? Determining your overall goal for the team is significant in planning for and achieving results. Haphazard training “just for the sake of training” is not necessarily a good thing, and it tends to generate complacency among team members. Besides the obvious, your team “needs to be able to perform a rescue should the need arise.”

Is It Documented?
Take a look at how the training was conducted, documented and what standards were met, if any. And, if you have permit spaces or personnel working at height, I’m assuming that OSHA compliance is a given, but what about meeting requirements of the National Fire Protection Association (NFPA) for rescuers; namely, NFPA 1006 and 1670.

If there is an incident and OSHA or some other regulatory organization were to investigate, how would you provide the documentation that your team is capable of doing what is required of them? Remember, if it can’t be documented, it doesn’t exist!
Using NFPA 1670 (“team” standards) and NFPA 1006 (“individual rescuer” standards) as a basis for the team’s training level will help to provide the needed documentation and add to the credibility of your team’s capabilities. Ideally, all your team members should be certified to the Confined Space Rescue Technician level (NFPA 1006) along with the documentation to back it up.

Because NFPA’s Confined Space Rescue Technician includes confined space and high angle (elevated) rope techniques, I don’t necessary suggest that industrial clients be required to achieve “Rope Rescue Technician.” The added skills of Rope Rescue Technician include less-seldom-used techniques in industrial rescue such as rope ascension and traverse. Do make sure, however, that the course you choose for Confined Space Rescue Technician incorporates some (not all) of the high angle skills you would need to perform elevated rescue at your site.

A Mix of Confined Space and Rope Rescue

If you have a variety of experience and training levels among your team members, it’s important to get them consistently trained and all trained to the same level. Of course, I would recommend Roco’s Fast Track 80™ course, which includes a two-year certification. This course was designed to meet the needs of industrial facilities with a mix between “confined space” and “rope” technician skills needed. The class is geared for confined space rescue with some of the additional rope technician skills needed for elevated or high angle rescue. The class efficiently gets the rescuer to the Confined Space Rescue Technician level in only 80 hours using both performance-based and written testing.

Of course, the next challenge is getting the entire team trained to the same level. It’s not going to be easy to get an entire team released for training all at once – thus compromising the availability of rescue personnel onsite should an emergency arise. Therefore, you may have to run a couple of classes to get everyone certified – or send some of your team (or new team members) to an open-enrollment course.

Testing to the NFPA 1006 Professional Qualifications standard is conducted on the last day of the Fast Track 80™ class. Note: If some of your personnel have already completed this class, they can join the class for the last four days in order to be recertified. This will allow the new members and more experienced team members to work together in realistic practice scenarios. It will help get everyone on the same page as far as techniques plus give the experienced personnel a 3-day refresher and practice time before re-certification testing.

Training Cycle for Compliance
Once all team members are trained to the same level, I recommend going to a two-year rotation. For example, once everyone is certified, the next year would be a Roco Team Performance Evaluation (TPE) where we come for two-to-three days and run teamed-based evaluations using multiple rescue scenarios. Each scenario is critiqued by evaluators to adjust any problems found along the way. The TPE would be followed by a written report to document the scenarios conducted as well as discrepancies found and corrected. The following year would be Re-certification to NFPA 1006 (three-to-four-day session) that includes Individual Performance Evaluations (IPE) where team members would refresh personal skills as well as run several scenarios before testing for re-certification to Confined Space Technician level.
This rotation will help with OSHA compliance by meeting the minimum annual practice requirements as well as by providing a performance evaluation of rescue services as stated in Note to paragraph (k)(1) from 1910.146: “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.”
In addition, both OSHA 1910.146 and 1926.1211 require timely and capable rescue services for permit spaces. They also require minimum annual rescue practice in the applicable types of confined spaces as well as proficiency for team members. This cycle of training works well in documenting that you have met these minimum requirements while also meeting the requirements of NFPA.

The TPE supporting documentation also provides a “snapshot” of where your team and its individual rescuers stand in terms of competency. This information can then be used as a tool to design internal drills that correct any discrepancies while getting the most from your “all too limited” practice time.

I hope these recommendations are helpful in planning for the success of your rescue team – especially when it’s all on the line during an emergency situation. If you have any questions, don’t hesitate to call me at 800-647-7626 or send an email to info@rocorescue.com.
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Trench Collapses…one of the most dangerous hazards in construction

Wednesday, July 19, 2017

A month after a 33-year-old worker died while working in an unprotected trench, OSHA inspectors found another employee of the same Missouri plumbing contractor working in a similarly unprotected trench at another job site. OSHA determined that, in both cases, the company failed to provide basic safeguards to prevent trench collapse and did not train its employees to recognize and avoid cave-in and other hazards. OSHA issued 14 safety violations found during both inspections, and proposed penalties totaling $714,142.

Trench collapses are among the most dangerous hazards in the construction industry.

Twenty-three deaths from trench and excavation operations were reported in 2016. In the first five months of 2017, at least 15 fatalities have been reported nationwide.

Gain knowledge, develop skills, and learn to recognize trench hazards by registering for Roco's Trench Rescue course. Our desire is for everyone to return home safely each day, and for this fatality number to not continue to increase.

Source: OSHA QuickTakes July 2017

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Cal/OSHA Cites Two Companies After CS Death

Tuesday, May 30, 2017

On Oct. 21, 2016, a D&D Construction employee entered a drainage shaft to clean out mud and debris. No personal fall protection was utilized as the worker descended via bucket 10 ft. into the shaft, which was 4.5 ft. in diameter and lined with concrete.

At some point, the worker lost consciousness due to the oxygen deficient atmosphere in the confined space and fell 40 ft., then drowned in a foot of water.

“Cal/OSHA launched a confined space educational program to bring attention to the dangers and preventable deaths that occur in confined spaces,” said Cal/OSHA Chief Juliann Sum in a statement. “The program helps employers identify hazards and create effective safety plans that include air monitoring, rescue procedures and training before work begins.”

General contractor Tyler Development was constructing a single-family residence in the Bel Air area and hired subcontracted D&D Construction to install and service reinforced concrete posts known as caissons on the property, according to the agency’s report.

The state-run occupational safety unit cited Tyler Development and D&D Construction Specialties Inc. a combined $352,570 for ten serious and willful health and safety violations following an investigation. Cal/OSHA said neither company was in compliance with required confined space procedures.

D&D Construction previously was cited in 2012 for similar safety violations at a different job site.

In total, D&D has to pay a proposed $337,700 for 13 violations, including two willful serious accident-related, one willful serious, one serious accident-related, six serious, and three general in nature.

According to Cal/OSHA, the company failed to:
• ensure safe entry into the confined space
• have an effective method to rescue the worker in the confined space in an emergency
• test the environment to determine if additional protective equipment, such as a respirator or oxygen tank, were required to work safely in the shaft.

Tyler Development was cited $14,870 for five violations, three of them serious, for a failure to:
• evaluate the worksite for possible permit-required confined spaces
• ensure that the subcontractor meets all requirements to comply with a permit space program
• protect workers from the hazard of impalement by guarding all exposed reinforced steel ends that extend up to six feet above the work surface with protective covers

A full copy of the report is available here.

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The Clock's Ticking on Timely Response

Tuesday, April 25, 2017

By Dennis O'Connell, Roco Director of Training & Chief Instructor

As Director of Training, I get many questions about rescue techniques and regulations from our students and readers. In the past month alone, I have received three inquiries about "timely response for rescue teams" regarding permit required confined spaces (PRCS). So, let's break it down and try to clear the air on this subject. For clarification, we will refer to the General Industry Standard 1910.146; the Construction Standard 1926-1211; and the Respiratory Standard 1910.134.

In 1910.146, OSHA provides guidance on timely response in Subpart K (Rescue and Emergency Services) and again in Non-Mandatory Appendix F (Rescue Team or Rescue Services Evaluation Criteria). Subpart (k)(1)(i) states: "Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified."

This one sentence actually says volumes about response times. The first question to be answered is, "Can the rescue service respond in a timely manner?" It then gives a hint as to what a timely manner should be based on. The second part of the sentence refers to "considering the hazard(s) identified." What this so eloquently says is the response time must be determined based on the possible hazard(s). This means the "known and potential hazard(s)" must be identified for each space to be entered. The hazards discovered -- based on severity, type, how rapidly the hazard could become IDLH or injure the worker, how quickly the need to treat the injury, or how quickly hazards might interfere with the ability to escape the space unaided -- would then be used to determine an acceptable response time. This is why OSHA only alludes to response times and does not set hard and fast times to follow -- it depends on the hazards of that particular space.

Another aspect we need to consider is that "response time" begins when the call for help goes out, not once the team is on scene. It ends when the team is set-up and ready to perform the rescue. So, how long will it take your team to be notified, respond and set-up is a big portion of that acceptable response time calculation. For example, a dedicated onsite fire/rescue team would be able to respond faster than workers who have other responsibilities and need to meet at the firehouse before responding. Or, more quickly than an outside service, such as a municipal department, that would have to respond to the facility, get through the gate, and be led to the scene.

In the note to paragraph (k)(1)(i), it adds: What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA 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.

Here we see OSHA better defining an acceptable response time for IDLH atmospheres -- i.e., immediate action! However, it's important to note this doesn't just refer to low O2...depending on the type of contaminant in the atmosphere, other respiratory equipment such as half- or full-face APRs could be used. It may include a dusty environment where the entrant wears a mask and visibility is less than 5 feet. Technically, that would be considered an IDLH environment. Many people get hung up on the use of SAR/SCBA as the trigger for a standby team, and that is just not the case.

For an IDLH atmosphere where respiratory protection is needed, an adequate number of persons (rescuers) is required to perform a rescue from the type of space involved - ready, trained, equipped and standing by at the space -- ready to take immediate action should an emergency occur. So, when dealing with possible IDLH atmospheres, we are looking at "hands-on" the patient in 3-4 minutes as possibly being an appropriate response time. Basically, this is about how long an entrant can survive without air. The only way to safely make rescue entry in that time frame is to have rescuers standing by, suited up and ready to go!

So, if dealing with an IDLH atmosphere, we revert back to 1910.134. Many people think that that is the only time we need a team standing by ready to take immediate action. I pose the question, "If the hazard is a liquid (engulfment hazard), what would be a reasonable response time?" If the victim is Tarzan or Johnny Weissmuller (okay, Michael Phelps, for you younger people), we may have a longer stay-afloat time. But if a non-swimmer, or in an aerated solution or other engulfment hazard, immediate action may be their only chance of survival! And, what about radiation (time, distance, shielding)? I am sure you can think of a few more possibilities.

And, while OSHA referred to an IDLH atmosphere in this example, it's important to consider other IDLH hazards as well. Here's where we note that the definition of IDLH in the Respiratory Standard (1910.134) differs slightly in Permit-Required Confined Spaces (1910.146). The Respiratory standard specifically refers to an IDLH "atmosphere" while the PRCS standard states the following: Immediately dangerous to life or health (IDLH) means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. This includes more than simply atmospheric hazards! 

OSHA NOTE: Some materials -- hydrogen fluoride gas and cadmium vapor, for example -- may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim feels "normal" until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.

In Non-Mandatory Appendix F (I hate that non-mandatory language), OSHA gives guidance on evaluating response times under Section A - Initial Evaluation. What are the needs of the employer with regard to response time (time for the rescue service to receive notification, arrive at the scene, and set up and be ready for entry)? For example, if entry is to be made into an IDLH atmosphere, or into a space that can quickly develop into an IDLH atmosphere (if ventilation fails or for other reasons), the rescue team or service would need to be standing by at the permit space. On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutes might be adequate.

Not a bad paragraph for a non-mandatory section of the standard! Here they explain what they are looking for in regards to response times. They even take the OSHA 1910.134 IDLH atmosphere requirement for a team standing by at the space a little further by adding "or into a space that can quickly develop into an IDLH atmosphere." It also states if the hazard is mechanical in nature, 10-15 minutes might be adequate. That’s right, "might" not will be, but might be. Again, it depends on the hazard.

Paragraphs 2-7 in Appendix F goes on to describe other conditions that should be considered when determining response times such as traffic, team location, onsite vs. offsite teams, communications, etc. If you have not done so, I highly recommend that you review the not-so-Non-Mandatory Appendix F. It is also important to note that while it's not mandatory to follow the exact methods described in Appendix F, meeting the requirements are! OSHA also uses the word "should" in Appendix F, not following the OSHA recommendations could certainly lead to some hard questions post incident.

OSHA 1926 Subpart AA Confined Spaces in Construction closely mirrors 1910.146. In this relatively new standard, they simplified the definition of timely response and omitted Non-Mandatory Appendix F, which helps to eliminate the confusion of the "non-mandatory" language, and included the requirements right in the standard, which is good. However, 1910.146 really gives you a better idea of what timely would be for different situations through the notes in Section (k) and Appendix F.

Section 1926.1211 of the Construction Standard for Rescue and Emergency Services (a)(1) states: Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. This is immediately followed by: Note to paragraph 1926.1211(a)(1). What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA1926.103, Respiratory Protection (for construction) 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.

In closing, these regulations are driving you in the same direction for identifying what a timely response would be...THERE IS NO SET TIME FRAME! Each space must be evaluated based on potential hazards and how quickly rescue would need to take place. I hope this will make you take a closer look at "how and what" you consider a timely response. An employer's PRCS program must identify and evaluate the rescue resources to be used. It is then up to the entry supervisor to make sure the identified rescue service is available to respond in a timely manner, which can literally mean life or death for the entrants.

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Pre-entry Atmospheric Clearance Measurements

Friday, March 17, 2017

The following article was written by Russell Warn and published in ISHN magazine (ishn.com), December 2016. Roco comments have been added to the article and are noted in red.

Working in confined spaces presents a unique and dangerous challenge in combatting the unseen – oxygen deficiency, poisonous or explosive gases, and other hazardous substances are among the most frequent causes of accidents associated with work in confined spaces and containers.

From 2005-2009, the Bureau of Labor Statistics reported nearly two deaths per week, or roughly 96 per year, could be attributed to confined space, with about 61 percent occurring during construction repair or cleaning activities.

With conditions subject to change in a moment’s notice, taking steps to protect against life-threatening dangers should always be a top priority in confined spaces. Performing a thorough clearance measurement is a demanding — yet crucial — task that dictates the safety environment, and should not be taken lightly. To help guide you along your road to enhanced safety, outlined below are several best practices based on frequently asked questions.

When should I perform a clearance measurement?

Conduct clearance measurements immediately before operations begin. Environmental factors such as temperature and air flow can change the atmosphere, causing readings to fluctuate. One shift’s measurement taken at 7 a.m. is not representative of the conditions when work operations commence for another shift at 4 p.m. New clearance measurements must be taken immediately to account for the nine hours of changing temperatures and ventilation patterns, depicting the accurate readings of present conditions.

Roco Comment: In addition to pre-entry clearance measurements, entry into permit spaces during construction activities requires "continuous atmospheric monitoring" unless the entry employer can demonstrate that equipment for continuous monitoring is not commercially available or periodic monitoring is sufficient. Ref. 1926.1203 (e)(2)(vi), 1926.1204 (e)1)(ii), and 1926.1204 (e)(2). Additionally, Roco believes that for "ALL" permit entry operations, it is advisable to provide continuous atmospheric monitoring no matter what the industry activity entails.

What’s the importance of zero-point adjustment?

When performing clearance measurements, it’s crucial to determine the reference point of the gas detector by calibrating the zero-point. The zero-point ensures that the indicated values correspond to the actual existing gas concentrations. In order to determine that the actual zero-point has been found, calibrate equipment in an environment where the hazardous substance is not present, such as fresh air environments. With every scientific test, no matter the field, a control group, which serves as a starting point of reference, permits for the comparison of results to show any contrasting changes. The zero-point calibration acts as such, allowing workers to identify the presence, or lack thereof, of different gas concentrations.

Where do I measure/take the sample?

When it comes to measuring samples, there are four things to keep in mind: the physical properties of gases, and the type and shape, temperature and ventilation patterns of the confined space.

Know the differences between light and heavy gases. Clearance measurement experts must have a strong working knowledge of hazardous substances’ properties, as they play a role in where measurements should be taken. For example, if a sample is pulled from the top of the confined space and hydrogen sulfide (H2S) is detected, the sample may not be entirely reliable. H2S has a molar mass of 34 g/mol, which is significantly heavier than that of air (29 g/mol). As a result, H2S sinks to the bottom of a space, where its concentration would be greatest. Identifying a presence at the top of the confined space says immediate danger and appropriate actions should be taken.

Light gases quickly mix with air and rise to the top. As a result, any measurements in open atmospheres should be performed close to the leak, and increases in concentration should appear in the highest points of the confined space. Heavy gases, on the other hand, should sink and flow like liquids, pass obstacles or stick to them. They barely mix with air like light gases do, so their samples should always be taken at the lowest points of the confined space.

Determine the type/shape of the confined space: In an ideal scenario, each confined space area would be in an “even” or level position. This isn’t always the case, and a container may be placed on an inclined surface, making the highest point in the corner positioned toward the top of the inclined surface. Thus, entry may be nearer to where the heavy gases have accumulated.

Take tabs on temperatures. All matter is made up of atoms and molecules that are constantly moving. When heat is added to a substance, such as a gas, the molecules and atoms vibrate faster. As the gas molecules begin to move faster, the speed of diffusion increases. If the sun has been shining on a tank for hours, there’s a good chance the clearance measurement taken at dawn no longer reflects the current readings due to the increase in diffusion.

Vet the ventilation. Air currents change the position and concentration of air clouds, and often times, the way a confined space is ventilated can affect readings. Containers cannot always be separated from pipelines, or there may be leaks in the tanks that must be accounted.

Roco Comment: Not only is it required by certain OSHA provisions like alternate entry procedures, but Roco highly recommends monitoring the atmosphere prior to initiating ventilation. This is intended to provide a reasonable assessment of the potential atmosphere change should the ventilation equipment fail. The rate for a potential hazard to re-develop will be based on factors such as the effectiveness of isolation, any residual product within the space, temperature, humidity and passive ventilation which are among just some of the factors.

How do I safely conduct the measurement for an accurate reading?

People often question why they can’t just use the carrying strap of their device to lower the device into the confined space for a reading. Although this seems like a simple fix, it’s not a safe or recommended way to conduct the measurement. Lowering the device into the container this way not only obscures the way the display is read, but it may not audibly alarm. If the measured value is slightly below the threshold value and the alarm does not sound, a worker would not be notified of the dangerous concentrations lurking below. Not only this, but measurements may be inaccurate since the measured gases, due to their molar masses, may be concentrated at a higher or lower point within the container. Clearance measurements should be conducted on-site and on-the-ground of the confined space for accurate, safe readings.

Roco Comment: The points made in the preceding paragraph are certainly valid. The best solution that we can offer is to use remote sampling probes or tubes to actively draw (pump) samples from the stratified levels of the space while the direct reading instrument is in a position outside the space to observe the real time readings. To expound upon the point the author makes, if the pre-set threshold for the alarms are not enough to trigger the alarm indicating the presence of a hazardous atmosphere, and the individual performing the assessment relies instead on rapidly pulling the monitor from the space in the hope that they are able to read the display before the values change, is a very dangerous way of approaching this procedure. Depending on the sampling rate of the monitor, the hazardous gas(s) may have cleared from the monitor in the time it takes to withdraw it from the space, and it is very likely that the instrument will display a normal atmosphere by the time it is back within view. Additionally, for areas within the space that cannot be remotely assessed by remote sampling prior to entry, the only safe recourse is to limit entry to the areas that have been assessed and to take a monitor into the space to continuously assess the unreachable regions before venturing further.

What do I need to document during clearance measurement protocols?

Just as it’s important to remain thorough in clearance measurements procedures, it’s equally as important to remain thorough in the general housekeeping protocols surrounding samples. This includes documenting:

  • The container number
  • The measuring point of the container, and whether there was more than one measuring point
  • At which time was the clearance performed
  • Under what condition was the measurement performed
  • Measured hazardous substances
  • Name of person performing measurement
  • Equipment used for clearance

Safety, regardless of job title or responsibility, should be everyone’s top priority. When working in the midst of poisonous and explosive hazards, performing clearance measurements correctly and carefully means not only keeping one’s self safe, but keeping the working environment safe, as well.

About the Author:
Russell Warn is the product support manager for gas detection products at Dräger. He has been in the safety industry for more than 29 years, with most of this time dedicated to gas detection product and application support.

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