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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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Roco Competent Person Equipment Inspection

Wednesday, February 15, 2017

Does a competent person inspect your rescue equipment each year?

If not, you may want to consider having an independent third party perform the inspection for you. This service is offered by Roco as a stand-alone service, or it can be added to your next private training session. 

Functional Ops Check

The service includes a “sight and touch” functional inspection of hardware, nylon products (including rope, webbing, and anchoring components), harnesses, and accessory equipment (including litters and stretchers) utilized in confined space/high angle applications. The inspection will be conducted in accordance with manufacturer’s specifications and will satisfy the requirement for an annual2 inspection by a competent person.
Note: Equipment recommendations will NOT be provided by inspection personnel unless requested to do so.

Service Inspection Benefits include:

• Certified personnel to inspect equipment to manufacturer's standards.
• Inspection documentation from an independent third party.
• Frees your personnel from the responsibility of equipment inspections.

A full report of findings will be provided to include accessibility of equipment to responders and any other recommendations to improve overall team performance. It will include other pertinent information such as the manufacturer, product number, and serial/lot number (where applicable), date of manufacture, and in-service date (when available). It will also include the results of pass/fail testing for both visual and functional inspection. All equipment deemed unsuitable for use will be tagged for removal from service.

Regardless of the stated service life, the condition of equipment – as determined through inspection by a qualified party – is a key factor in determining whether or not a piece of equipment is fit for service.

Although the definition of “equipment lifespan” is very broad depending on the manufacturer, each provides specific instructions on proper inspection of equipment and detailed explanations on when to retire the service item. Several general identifiers that pertain to all equipment are shown below.

Reasons for Equipment Retirement include:

• Item fails to pass any pre/post use or competent person inspection.
• Item has been subjected to a major fall or load.
• Item is constructed of plastic or textile material and is older than 10 years.
• You cannot determine the complete full-use history of item.
• You are not certain or have lost confidence in the equipment.

As a reminder, it is very important to keep the manufacturer’s instructions when purchasing new equipment. This is vital to identifying and keeping track of the manufacture date as well as other important information. For example, if the manufacture date of equipment, such as life safety rope and harnesses, cannot be identified; it can pose extreme liability for agencies or facilities whose teams may potentially be operating with equipment that has passed its service life. It could also create a compromise in the safe operation of the equipment.

A 10-year service life for nylon/polyester products is set according to ASTM F1740-96 (American Society for Testing and Materials).

Inspect Rescue Equipment Every Time It’s Used

All team members should be qualified and knowledgeable enough to perform pre- and post-use inspections of equipment. It is crucial that all members document each use of equipment, denote any deficiencies, and report to the proper person. One person should be designated to perform the competent person annual inspection. This person should have complete knowledge of the equipment and inspection procedures as well as the authority to keep or remove equipment from service as they see fit. If team members are unable to fill this role, a qualified third party with applicable manufacturer certifications in competent person inspection should be utilized to assist in determining the condition and estimated service life of rescue equipment.

Download Roco's Quick Checklist for your convenience. →

Rescue team members are encouraged to attend this inspection where they will receive information on proper pre- and post-use inspections for their equipment. Guidance can be also offered in areas of equipment care, inspection, record-keeping, and proper storage. Again, equipment recommendations will not be addressed unless specifically asked to do so – this is only an inspection of the equipment you currently have on site.

Remember, with rescue gear, lives are literally “on the line,” – if in doubt, throw it out!

To schedule your Roco Competent Person Inspection, or add it to your current training dates, call us at 800-647-7626 or email info@rocorescue.com. Roco offers this service at no charge for current customers or for a very nominal fee for non-customers.1


1 Current customers receive a one-day equipment inspection at no charge. Travel expenses apply for out-of-town customers.
2 References include: 1926.502 Appendix C; ANSI Z359.2 Section 5.5.2 Inspections; ASTM Rope Inspection Guide; NFPA 1983 Section 5.2; ANSI Z359.11 Annex A (harnesses); and ANSI Z359.4 Section 6.1.

NOTICE: The client remains responsible for ensuring that all guidelines and requirements for maintaining and, where indicated, removal of equipment from service, are followed. This includes removing equipment from service anytime there is a situation or incident that occurs during handling, training, or rescue, that might have caused damage or otherwise compromised the integrity of the equipment, particularly where internal damage that is not visible might be present (e.g. equipment dropped from height, exposure of nylon products to chemicals or other potentially degrading substances, etc.). Client will be required to complete a certification that between Roco inspections, the equipment was properly stored, was available only to personnel trained to use the equipment properly, and that any equipment that was exposed to any condition or occurrence that could have resulted in hidden damage has been removed from service. A company representative, preferably someone from the rescue team, must be present during the inspection process.

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Roco Rescue Training in North Dakota

Monday, January 23, 2017

Roco is excited to be conducting several Rescue & Fall Protection Workshops at the 44th Annual Safety Conference next month in Bismarck, ND. This will kick off our working relationship with the ND Safety Council to provide safe, effective confined space rescue training for their membership. 

What's more, the North Dakota Safety Council (NDSC) is currently constructing a new safety campus in Bismarck that will house a 5,000 square foot hands-on training lab. Roco, as a training partner, will provide high-level technical rescue courses at this new facility on a year-round basis.

For the conference on February 20-23, we will be conducting a number of hands-on rescue workshops and presentations to be presented by Roco Lead Instructors Dennis O’Connell, Pat Furr, Brad Warr, Eddie Chapa and Josh Hill. Sessions include:

  • Intro to Competent Person Requirements for Fall Protection
    2/20 9am-6pm (classroom w/demo)
  • Confined Space Entrant, Attendant, and Supervisor Requirements
    2/20 9am-6pm (classroom w/demos) 
  • Tripod Operations
    2/21 11am-5pm (hands-on training) 
  • So You’ve Fallen, Now What?
    2/22 10am-11:30am (classroom)
  • Dial 911 for Confined Space Rescue
    2/22 1:30pm-2:30pm (classroom w/demos)
  • Confined Space and Rope Rescue...
    2/22 1:30pm-5pm (hands-on training) 
  • Trench Collapse Rescue Considerations
    2/22 2:45pm-3:45pm (classroom) 
  • Fallen/Suspended Worker Rescue
    2/23 8am-11:15am (classroom w/demos) 
  • We look forward to meeting you at Roco booths (#202 & #203) or in these training sessions. For more info, click to NDSC’s 44th Annual Safety & Health Conference. Don't forget to register online at www.ndsc.org for these training sessions.
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Why Knot?

Thursday, December 01, 2016

By Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

As rescuers, we all have our favorite knots and our favorite ways of tying them. Depending on the application, there may be several knots to choose from that will perform slightly differently in terms of efficiency or knot strength. You can go online and order any number of books ranging from a couple of pages thick to 2’ thick with hundreds of knots in it. The trick is to decide what applications you will need to perform with your ropes and knots. If you don’t need to shorten a rope, then you don’t need to know how to tie a sheepshank. Or, if you use manufactured harnesses, then a tied Swiss Seat is not a needed skill in your inventory.


For the most part, we can break applications into 6 categories for rescue purposes: 

1) Knots that form a permanent loop in the end of a rope (Ex. Figure-8 on-a-bight)
2) Knots to tie around objects (Ex. Bowline)
3) Knots to join ropes together (Ex. Square Knot)
4) Knots tied in the middle of ropes (Ex. Butterfly)
5) Hitches binding and adjustable (Ex. Prusik Wrap or Clove)
6) Utility knots (Ex. Daisy Chain)

Whenever we tie a knot in a line we lose some of the efficiency in the rope or webbing we are using. Generally, the more acute the first bend in the knot, the more efficiency is lost.

Other factors such as angle deflection, direction of pull, and rope construction all have effects on a knot’s efficiency. Then, there’s the type of load the knot will see (two directions or three directions). The direction and critical angle applied forces may change the efficiency rating of a knot greatly. In rescue, we try to use knots with fairly small efficiency losses, generally between 18-37%.

There are some other considerations beyond knot strength when choosing which knot to use for any particular application.

Ease of Tying

In addition to knot efficiency (strength), we also must think about many other things such as ease of tying especially in those hard to access places where you wish you had more Gumby genes. Where and under what circumstances will you need to be tying the knot? Will it need to be tied one-handed? Is speed a consideration? Take a calf roper, for example, he needs a knot he can tie quickly and securely. Would you be able to tie a Prusik on line for self-rescue with one hand if the other is stuck in the device? What about an emergency situation where you might need to bail out a window while blinded by smoke?

Say you want to clip into a fixed rope but need to do it one-handed? The Clove Hitch will be much easier to tie into a carabiner one-handed than most loop knots. Not only that, if you need to adjust your position after clipping in, the Clove Hitch is easily adjusted one-handed.

Ease of Untying

Not only ease of tying, but ease of untying a knot should be thought through, especially with wet rope or heavy loads. Once the knot gets loaded – or if it sees a heavy or shock load – will you be able to get the knot untied? Will you need to use a tool like the marlin-spike to get your loaded knot untied? How often will you be tying and untying the knot? Will the knot be wet or dirty? (Example: a loaded Bowline is easy to untie, while the Figure-8 Bend is more difficult.)

Knot Security

Knot security must always be considered but this is especially true if the knot will be subjected to tension and slack repeatedly. Will the knot be able to untie itself if it is cycled between tension and slack? (i.e., Square Knot vs. Figure-8 Bend) We know that a Butterfly Knot performs much better than a Figure-8 on-a-Bight if the knot is to be pulled in more than two directions. But what about some of the lessons learned over time that we know will make a difference in which knot to select based on other considerations. How difficult is it to untie a Figure-8 on-a-Bight after it has been loaded wet vs. a Two Loop Figure-8?

Tying a fixed line for a rappel? There are several choices to tie a fixed line instead of clipping it to an anchor strap. The Bowline, Clove Hitch, Figure-8 Follow-Through will all work, but if the line goes in and out of tension, how secure is the Clove Hitch compared to the Bowline or Figure-8? If security isn’t a concern, it will be easier to untie the Clove Hitch after it has been loaded followed by the Bowline, with the Figure-8 probably being the most difficult to untie, especially if the rope is wet.

Tying an anchor around a very large object? You will use up a lot more rope and time tying a Clove Hitch vs. a Figure-8 Follow-Through or a Bowline.

How will a knot handle a sustained load or shock load?

If you anticipate a heavy load on a Prusik Knot, consider making it a triple wrap instead of double. This will give you more friction, and it will definitely make it easier to untie later on. A little trick I use to loosen a loaded Prusik is to “push the bar.” By that, I mean to push the section of the knot that runs parallel to the rope that it is tied around away from the main line, which will loosen the knot.

The Water Knot is great for tying webbing together to form a runner or sling. But if it is really loaded, it can be a bear to untie. Try this, turn the knot so it is oriented vertically along its axis and place it between the palms of your hands. Rub your palms together squeezing on the knot and really be aggressive. After a few seconds, see if you are able to work a little looseness into the knot to start untying it. Same thing with a Figure-8 on-a-Bight, grasp the knot with both hands beside each other with half of the knot in each hand. Then, bend the knot back and forth as if you were activating a chem-light. Do this several times and see if you are able to milk a little slack into one side of the knot to start working it loose. Try to push slack into the knot instead of pulling the knot apart. Attack different parts of the knot until you see some movement.

Fighting untying knots?

If you are fighting untying knots on a regular basis, it may be time to add a marlin spike to your kit. A marlin spike is a tapered tool that finishes with a blunt or flat tip. They have been around since ancient times and may be useful to get that first bit of looseness into the tight knot. The warning here is to never place the knot in a position that the spike could slip and puncture your leg or arm, always push the spike away from your body.

If you know you’re going to really load up your knot and especially if the rope is wet, consider clipping a carabiner into the bends of your knot between the lays. This works really well for the Figure-8 on-a-bight or follow-through. Once you are done with that knot, remove the carabiner – this may provide enough slack to work the knot out.

We generally advocate stuffing rope into a bag and working out of the bag, but sometimes we “coil” the rope to go from point A to point B. How often has this led to a bird’s nest of rope? To help prevent a coiled rope from tangling, hold the coil up in one arm and let it hang free. Uncoil the rope with the other hand not allowing the lines to cross. By holding the coil up, gravity will show you which sections are crossing. You will then be able to keep the line straighter than if you dropped the entire coil to the ground and just started pulling rope.

So, you can see there is a lot to think about and consider when choosing what knot you should use and why. As we said earlier, there are hundreds of knots to choose from and many of them do the same jobs. And many are called different names in different books. The key is to identify the category, the application and the circumstances where the knot will be used. Then consider the above and you should be able to identify the proper knot for the job at hand.

Visit our Resources page for videos on knot tying and much more! http://www.rocorescue.com/resources_videos

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Roco Quick Drill #13 - Silent Drill (Know your job, do your job!)

Thursday, November 03, 2016

Many rescue scenes (and teams) are plagued by confusion because of too much communication. And, if you have three people assigned to do a task, each one will have his or her own idea of how it should be done, where the system should be anchored, etc. Many times the discussion that follows eats up valuable time and slows the team’s ability to get rescuers into a location and get hands on the patient.

This drill is designed to instill confidence among team members, to ensure that rescuers understand their responsibilities at the scene and to help rescuers understand that there are different ways to accomplish the same goals safely. It also helps in getting rescuers to look at the entire scene and understand where their assignment fits in the big picture. It encourages team members to anticipate and solve their own problems.

1) Assign a safety officer/drill manager.

2) Locate a simple vertical simulated space to enter or a balcony or roof edge. The goal is to lower the rescuer into an area.

3) Safety officer/drill manager describes the event to the team and assigns task(s) to each team member.

4) Instructs the team that they are not allowed to speak unless a dangerous condition is observed.

5) Instructs team members to gather the equipment necessary to accomplish their job or task. (Remember No Talking!)

6) Once team members have the needed equipment, move them to location and let them start rigging to get rescuer into the space or over the edge.

7) Once rescuer is lowered into area, leave systems rigged and debrief entire team on the rigging, the order that it was done and what could be done differently.

The difficulty of this drill can be increased by doing an entire simulated rescue or adding SCBA/SAR to the station requirements. You will find that a lot of unnecessary chatter that occurs at rescues will be reduced. It will allow you to see who truly understands “where and how” each component of a rescue system fits in the overall operation. It also encourages rescuers to look at the big picture and anticipate what, where and when they will need to have their assignments completed without waiting for direct supervision.

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