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Can I Use a Crane as Part of my Rescue Plan?

Thursday, October 02, 2014

One question that is often asked, "Can I use a crane as part of my rescue plan?"

With the exception of positioning the load attachment point of a crane for a high-point anchor, or using a properly rated “personnel basket” to move rescuers and victims, the answer is typically “no” – except in very rare and unique circumstances. The justification for using a crane to move personnel, even for the purposes of rescue, is very limited. Be sure you have a clear understanding of the guidelines and precautions.

Both OSHA General Industry and Construction Standards severely limit the use of cranes to move personnel, and prescribe the proper safety measures for these operations.


Using a crane for rescue is not a carte blanche exception to the requirements of these standards unless very specific criteria are met. OSHA requires the use of personnel platforms when moving personnel with a crane. Personnel platforms that are suspended from the load line and used in construction are covered by 29 CFR 1926.1501(g). There is no specific provision in the General Industry standards, so the applicable standard is 1910.180(h)(3)(v). This provision specifically prohibits hoisting, lowering, swinging, or traveling while anyone is on the load or hook.

OSHA has determined, however, that when the use of a conventional means of access to any elevated worksite would be impossible or more hazardous, a violation of 1910.180(h)(3)(v) will be treated as “de minimis” if the employer complies with the personnel platform provisions set forth in 1926.1501(g)(3), (4), (5), (6), (7), and (8).

Even the use of a personnel platform is restricted. OSHA prohibits hoisting personnel by crane or derrick except when no safe alternative is possible. OSHA has determined that hoisting with crane or derrick-suspended personnel platforms constitutes a significant hazard to employees. Therefore, the hoisting of personnel is not permitted unless conventional means of transporting employees are not feasible. Or, unless conventional means present greater hazards (regardless if the operation is for planned work activities or for rescue). Where conventional means would not be considered safe, personnel hoisting operations meeting the terms of this standard would be authorized. OSHA stresses that employee safety, not practicality or convenience, must be the basis for the employer's choice of this method.

It’s important to consider, however, that in some instances such as when entering permit-required confined spaces, OSHA specifically requires rescue capabilities. In others, the general duty to protect an employee from workplace hazards would require rescue capabilities. Consequently, being “unprepared” for rescue would not be considered a legitimate basis to claim that “moving a victim by crane was the only feasible or safe means of rescue.” This is where the employer must complete written rescue plans (or ensure that their designated rescue service has done so), for permit-required confined space operations and for workers-at-height using fall arrest systems. 

When developing these written rescue plans, it may be determined that there is no other feasible means to provide rescue without increasing the risk to the rescuer(s) and victim(s) other than using a crane to move the human load. These situations would be very rare; thus, requiring very thorough documentation which may include written descriptions and photos of the area as part of the justification for using a crane in rescue operations.

Here’s the key… Simply relying on using a crane to move rescuers and rescue victims without completing rescue plans with very clear justification would not be in compliance with OSHA regulations. It must be demonstrated that the use of a crane was the only feasible means to complete the rescue while not increasing the risk compared to other means. Even then, there is the potential for an OSHA Compliance Officer to determine that there were indeed other feasible and safer means.

In other words, using a crane as part of a rescue plan must have rock solid written justification demonstrating that it is the safest feasible means to provide rescue capability.

On the practical side, however, the use of cranes as “stationary, temporary high-point anchors” can be a tremendous asset to rescuers. It may also be part of a rescue plan for a confined space or a top entry fan plenum, for example. The use of stationary high-point pulleys can allow rescuers to run their systems from the ground. It can also provide the headroom to clear rescuers and packaged patients from the space or an elevated edge.

Of course, security of the attachment of the system to the crane and the ability to “lock-out” any potential movement are a critical part of the preplanning process.

Taking it a step further, where some movement of the crane may be required to do the rescue, extreme caution must be taken! It may require advanced rigging techniques in order to prevent movement of the crane from putting undo stress on the rescue system and its components. Rescuers must also evaluate if the movement would unintentionally “take-in” or “add slack” to the rescue system, which could place the patient in harm’s way.

Consider this, movement of a crane can take place on multiple planes – left-right, boom up-down, boom in-out and cable up-down. If movement must take place, rescuers must evaluate how it might affect the operation of the rescue system.

Of course, one of the most important considerations in using any type of mechanical device is its strength and ability (or inability) to “feel the load.” If the load becomes “hung up” while movement is underway, serious injury to the victim or overpowering of system components can happen almost instantly.

No matter how much experience a crane operator has, when dealing with human loads, there’s no way he can feel if the load becomes entangled – and, most likely, he will not be able to stop before injury or damage occurs. Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is lost when energized devices are used to do the work.

Applicable OSHA standards only restrict the “movement of personnel” with a crane. The same practical safety considerations that led OSHA to enact these standards should apply to decisions involving the use of cranes for rescue.  For rescuers, a crane is just another tool in the toolbox – one that can serve as temporary, stationary high-point making the rescue operation an easier task.

However, once again, using a crane that will require some movement while the rescue load is suspended would be a “last resort” option! There are just too many potential downfalls and concerns associated with using cranes in rescue. This also applies to fire department aerial ladders, which are essentially the same thing. Rescuers must consider the manufacturer’s recommendation for use, who knows their equipment best. What does the manufacturer say about human loads? And, what about the attachment of human loads to different parts of the crane or aerial?

So, to answer the question, Can I include the use of a crane as part of my written rescue preplan?”

Well, it’s yes and no. The use of any powered load movement will most likely be an OSHA violation, the question is, will it be considered a “de minimis" violation if used during a rescue? Most likely, it will depend on the specifics of the incident. However, you can be sure that OSHA will be looking for justification as to why using a crane in motion was considered to be the least hazardous choice.

Municipal Emergency Responders

This article was primarily directed toward private employers who control permit-required confined spaces and have Authorized Persons working-at-height while using fall arrest systems. When an employer fails to ensure that rescue preplans have been completed, or fails to inform a municipal agency that has agreed to provide rescue service to their facility about the types of rescues they may be summoned to, it places the municipal responders in a very difficult position. If municipal responders have not had the opportunity to complete a rescue plan ahead of time, they will have to do a “real time” size-up once on scene. Due to difficult access, victim condition, and/or available equipment and personnel resources, it may be determined that using a crane to move rescuers and victims is the best course of action. Ultimately, it is the responsibility of the employer to ensure that rescue plans are completed ahead of time. Planning before the emergency will go a long way in providing options that may provide fewer risks to all involved.

NOTE: Stay tuned for Part II of this story where we will talk more about the use of aerial fire apparatus as high-point anchors in rescue operations.

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Are You Sure You Don't Need On-Air Rescue Practice?

Thursday, August 28, 2014

Reported by Dennis O’Connell, Director of Training

After more than 25 years in the rescue industry, I always cringe a bit when I hear rescue teams say they don’t practice “on-air” rescues because personnel at their facilities are not allowed to do planned work activities in IDLH or low O2 areas. But I always ask, what about the permit spaces that may have the “potential” for atmospheric hazards? What about those spaces that may unexpectedly become IDLH or low O2 – what then?  

"I have raised this flag many times before and according to NIOSH, a little less than half the deaths from atmospheric conditions occurred in spaces that originally tested as being acceptable for entry. Something happened unexpectedly, and something went very wrong."

Remember, OSHA states that a confined space simply has to have the “potential” for a hazardous atmosphere; not that it is actually present as one of the triggers to make a space a “permit required space” and require rescue capabilities.

So, for these unexpected instances, do you really have the appropriate rescue response in place? In our opinion, not training your team to respond to IDLH emergencies is like buying a gun for home protection, but not buying any bullets.

Also, 1910.146 section (k)(1)(i) makes reference to 1910.134 OSHA’s respiratory regulation. Here OSHA talks about respiratory protection being worn by entrants as the trigger for “standby” rescue personnel capable of immediate action. It is not necessarily based on the level of O2. It calls for “rescue standby” not rescue “available.” Immediate action is called for… not just a timely response

OSHA Note to Paragraph (k)(1)(i)…
What will be considered timely will vary according to the specific hazards involved in each entry. For example, §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.

If that’s not a hint as to how seriously OSHA takes the possibility of an IDLH atmosphere arising in a permit space, I don’t know what would be.

So, if you don’t think you’ll ever need on-air rescue capabilities, take a look at this incident from a few years back. The way this confined space fatality occurred and the possibility of it happening is a real eye opener. It emphasizes the critical importance for considering all possible (or potential) hazards associated with confined space entry and rescue.

Folks what I’m trying to say here is, as rescuers, we need to be prepared for the worst case scenario as well as the unexpected! This is especially true when it comes to confined spaces. When I hear, "We don’t need on-air practice because we don't allow IDLH entries at our facility." Well, neither did these guys...


Fatal Activation of CO2 Fire Protection System in Confined Space

 


Sheffield Forgemasters was ordered to pay heavy fines and costs for safety failings that led to an employee dying of carbon dioxide poisoning after the cellar he was working in filled with the deadly gas. A worker was found unconscious at the South Yorkshire foundry after a confined underground area swiftly flooded with the fire-extinguishing mist. Four of his co-workers desperately tried to reach him but were themselves almost overcome by the fast-acting gas. The worker, who had three grown-up sons, was pronounced dead on arrival at the hospital after the incident at the firm’s plant on 30 May 2008.

The Health and Safety Executive (HSE) investigated and prosecuted the company for serious safety failings. On December 19th 2013 Sheffield Crown Court heard that on the morning of the incident, the worker had carried out part of the cable cutting task in an electrical drawpit and then went to carry out the rest of the job in the switchroom cellar, which was only accessible by lifting a manhole cover and dropping down a ladder. Once underground at the electrical drawpit, the worker used a petrol-driven saw to cut through redundant 33,000 volt cables. At some point, he moved from there to the nearby switchroom cellar with the saw.

Later that morning, colleagues heard the carbon dioxide (CO2) warning alarms sounding from the cellar. A supervisor and other workmates rushed to help, with several of them trying to get down the ladder from the manhole to rescue the worker from the cellar’s confines. However, all attempts were defeated as each worker struggled to breathe and remain conscious when exposed to the debilitating concentrated carbon dioxide. The victim had to be brought to the surface later using slings.

HSE found that use of the petrol-driven saw in the switchroom cellar had likely activated a smoke sensor and prompted the release of the carbon dioxide from the fire extinguishing system.

The court was told Sheffield Forgemasters had failed to provide any rescue equipment for either the cellar or the drawpit. Other issues identified included a lack of a risk assessment by the firm for the cable cutting task and failing to provide a safe system of work in either underground location. In addition, there was no secure way to isolate the carbon dioxide fire system while work was going on in the cellar.

After the hearing, a HSE Inspector said: “This was a very upsetting incident that resulted in the needless death of this employee. It could have been an even worse tragedy as it was pure chance that another four workers who entered the cellar in a desperate bid to save their colleague did not also perish.” 

“Exposure to between 10-15% of CO2 for more than a minute causes drowsiness and unconsciousness. Exposure to 17-30% is fatal in less than one minute. Carbon dioxide is poisonous even if there is an otherwise sufficient supply of oxygen. 

“The risks associated with confined spaces are well known in industry and there is an entire set of regulations dealing with controlling the risks associated with them. Multiple fatalities do occur when one person gets into difficulty in such a space and then the rescuers are similarly overcome.”

“Sheffield Forgemasters had given no thought to the risks associated with the task being undertaken, nor had they provided emergency rescue equipment. This case shows how important it is for companies to effectively risk assess work activities; looking at how the work will be carried out and in what circumstances.” 

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Roco QUICK DRILL #4 - Selecting the Proper Knot and Tying Correctly

Wednesday, August 13, 2014

Being able to tie a knot in the classroom with a rope short vs. selecting the proper knot and tying it correctly in the field during an emergency requires experience. With a little imagination, you can provide your team members numerous scenarios to practice in just a short period of time while they are still within a controlled environment. This practice will help them to gain more experience that should pay off in the long run if needed during a real life emergency.

1.  Identify the knots your team uses, and where they are used in various systems.

2.  Lay out a series of applications where team members would need to tie a knot. Decide in advance what knots are acceptable in these applications since many times more than one knot may get the job done.

3.  Once you have established the acceptable knots, lay out a gauntlet of knot tying stations.

4.  Each team member will go through each station... first, deciding which knot to use, and then tying it as it would be used in the application (examples: end knot in a lower line, vertical bridle knot, lashing a backboard, adjustable anchor, self-equalizing anchor, etc.)

The goal is to have team members choose an appropriate knot, tie it correctly, and apply it properly based on the rescue system presented. Two examples for knot stations are: (1) Backboard lashing - have the lashing complete except for the knot at the end; and (2) Mainline rigged except for the knot attaching it to the anchor.

CHECK OUT OUR RESCUE KNOT VIDEO SERIES!

Download the Rescue Knots PDF
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Roco QUICK DRILL #3 - Knot Tying Challenge

Monday, June 09, 2014


A question that we often hear is, “How proficient should rescuers be with knot tying?” We recommend that rescuers be able to tie any of the knots used by their team without hesitation, or without even having to look at the knot as they are tying it.

As part of the skills requirement in our Roco certification courses, we require students to tie each knot (with safeties, as required) within 30 seconds. This gives us a good idea of the student’s proficiency in the basics of knot tying.

Here's a knot drill that we recommend: 

1.  Give each team member a length of rope and a piece of webbing. Note: Some knots will require an object to tie around.

2.  In a room capable of being darkened, call out the name of the knot to be tied and then turn off the lights. As each person finishes, have them shout “Completed.”

3.  Once all members have completed the knot, turn on the lights and check for accuracy.

Having the lights off during this drill forces rescuers to use their other senses in remembering how to tie the knots. It helps to reinforce their skills and is an excellent way to identify the individual knot(s) that may require more practice for increased proficiency. When the pressure is on – as in a real rescue – you need to be able to count on all your team members to tie the needed knot in a timely and accurate manner.

CHECK OUT OUR RESCUE KNOT VIDEO SERIES!

Download the Rescue Knots PDF

  




 

 

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