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

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

It also allows all parties to see the overall big picture of a safe entry operation.

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

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

  

These are very real scenarios. Scary, but true. It often shows a lack of knowledge and cooperation between the three functions involved in an entry. And, that’s not even considering compliance!

We ask, would it not be better to train your confined space entry team to the Entry Supervisor level? Wouldn’t you, as an Entrant, want to know the appropriate testing, procedures and equipment required for the entry and specified on the permit? Would it not make sense to walk down LOTO with the Attendant and Entrant? This would better train these individuals to understand non-atmospheric hazards and controls; potential changes in atmosphere; or, how to employ better air monitoring techniques. All crucial information.

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

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

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

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

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

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

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

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

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

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

Unfortunately, training is usually one of the first things to be cut when the budget gets tight; however, after an incident, it usually becomes the primary focus. Often the lack of training is determined to be a key element in the tragedy.

Investing in periodic training for the safety of your workforce includes spending the time and money to keep your trainers and training programs up to speed and in compliance. The old saying, “closing the barn doors after the horses escaped,” is no way to protect your people – a little investment in prevention goes along way in preventing these tragedies.

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

As we all know, the moment you enter an industrial facility, you’re instructed about who to notify in case of an emergency. And if something happens – no matter what the emergency – you can bet they’re going to call the rescue team. The question is, “When the call comes in, will your team be ready?”

Having taught rescue in industrial plants for more than 20+ years, I’ve observed how industrial rescue teams have been created and how they’ve been trained. I’ve also observed how they have responded to various types of incidents – including some rescue scenarios they could have never expected.

Over the years, I’ve also seen how the needs of rescue teams change. That’s one reason we continue to update and modify our training programs. We want the industrial teams that we train to be able to respond safely and effectively to all the various types of emergencies they may face at an industrial facility. Again, when help is needed, the onsite rescue team will be called!

Greater Demands on Industrial Responders

Back in the day, most sites typically only offered fire brigade training for their emergency responders. Eventually, medical was added, then hazmat, and finally confined space rescue – primarily in response to OSHA 1910.146. And, with permit-required confined spaces, most often comes the need for high angle rescue abilities as well. Once a victim is removed from a confined space, there is generally the need for raising or lowering the victim to ground level for medical transport.

As new regulations and standards have emerged, additional demands have been placed on industrial rescuers. This includes the new Confined Spaces in Construction Standard from OSHA (1926 Subpart AA). This new ruling provides construction workers with protections similar to those manufacturing and general industry workers have had for more than two decades. Differences tailored to the construction industry include requirements to ensure that multiple employers share vital safety information and to continuously monitor hazards – a safety option made possible by technological advances since 1910.146 was issued.

It is also becoming more difficult to justify "dialing 911" with the hope that the local fire department will be able to respond in a timely manner. Industrial sites are being forced to examine the reality of relying on local response agencies. And, in some cases, the plant’s industrial emergency response team may be the community’s best trained and equipped technical rescue capability. As one of our client’s stated after evaluating local response capabilities,

"We are truly an island unto ourselves. When it comes to certain types of emergencies, we're on our own!"

What Can Possibly Go Wrong?

We often focus on the importance of confined space and high angle rescue, but what about the other potential scenarios that industrial rescue teams may face. In recent years, we’ve seen an increase in requests from our clients in a wider variety of rescue disciplines – including Suspended Worker Rescue (Rescue from Fall Protection), Trench Rescue, Machinery Entrapment Rescue (“man in machine” is probably a better description), Water Rescue and Building Collapse for First Responders.

Let’s talk about these disciplines and how they can apply to industrial situations – keeping in mind that medical care will be required in most every situation. Many times those first on the scene have the greatest opportunity to make the difference for an injured worker. The first hour in a medical emergency is a crucial factor in increasing chances for survival.

Suspended Worker Rescue (Rescue from Fall Protection)

With expansion and construction work occurring in many facilities, you can often spot a variety of potential rescue scenarios just waiting to happen. For example, from stacks and vessels to scaffolding and towers, you will often find workers operating at varying heights

Here’s where the industrial rescue team must be ready for a timely response to Suspended Worker Rescue. Because suspension trauma can occur rapidly, time is of the essence. First of all, just reaching a suspended worker can be a challenge. Then, the victim must be raised or lowered to a safe area. Rescuers must have the appropriate equipment to keep themselves from harm’s way and be prepared to act quickly and efficiently.

Trench Rescue

Many sites will have some type of trenching job going on this year. Is your team trained to handle that type of collapse? Do you have the equipment for emergency shoring? Or, who can you call for help?

With an unsupported or improperly shored trench, it will collapse 100% of the time. It’s only a matter of when. Also keep in mind, even a relatively small cave-in involves about 1.5 cubic yards of dirt – or about 4,000 lbs. It is imperative that rescue personnel be trained and equipped prior to tackling one of these type emergencies – they are much more dangerous than they look!

Another key concern or consideration for trench or excavation work is “who” is signing off as to the safety of the trench? In talking with many of our clients, they may send an “entry supervisor” (company representative) to evaluate and sign off on a confined space permit. These individuals may have never been taught what to look for to determine if the protective system is adequate or installed properly. 

OSHA 1926.651(k)(1) states that a “Competent Person” shall inspect the shoring system. This refers to an individual who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.

OSHA Reference Excerpt [1926.651(k)(1)]
Daily inspections of excavations, the adjacent areas, and protective systems shall be made by a competent person for evidence of a situation that could result in possible cave-ins, indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions. An inspection shall be conducted by the competent person prior to the start of work and as needed throughout the shift. Inspections shall also be made after every rainstorm or other hazard increasing occurrence.

Machinery Entrapment Rescue

As gruesome as it sounds, another eventuality in an industrial or manufacturing facility is someone getting caught in or under machinery or heavy equipment. Is your rescue team ready for this? In these instances, the rapid use of hydraulic spreaders or pneumatic lifting bags can mean the difference in life or death for an entrapped worker.

Consider the many applications that a simple lifting bag might have for rescue or maintenance work. For example, by sliding a one-inch thick lifting bag under or between two objects, you can lift up to 70 tons, up to 20 inches off the ground, depending on bag size. A bag like this could come in pretty handy at a plant or refinery. 

For these horrific incidents, you must consider how long it will take the municipal department to get to your site. Once on scene, are they familiar with the various types of equipment at your facility that may be involved? Do they understand the hazards of the working environment in an industrial facility?

Another gruesome part of machine rescue is impalement. This type of injury requires very specialized care. First of all, do not attempt to remove the impaled object! It needs to remain as is and transported with the patient to the emergency care facility. Again, the question is, who, what and where are the resources to handle this type of job?

Water Rescue

Does your facility have a dock? Do your people work over water? Do you have sediment ponds? If you answered yes to these questions, you should be asking yourself, “What will we do if someone falls in?” “Who will rescue them?” Or, are you going to depend on a coworker to jump in and try to save his buddy? Even basic “Throw, Don’t Go” training and some basic water safety equipment can make a huge difference in a person’s survivability. It could also prevent the situation from getting worse by failed heroic actions. Personal flotation devices are great, but what about when a worker gets swept under a dock or into a current? How will you handle these situations?

Building Collapse Rescue for First Responders

This one caught me off guard when requested by several industrial facilities, but it turns out there are some very good reasons for it. Considering weather disasters, explosions or acts of terrorism, it is a very real concern. Of course, this training for first responders isn’t the full program that is provided for FEMA or USAR teams, but it includes some very specific skill sets that can be extremely useful in industrial incidents.

Here are just a few examples. Emergency shoring techniques can be used to stabilize pipe racks or damaged structures for the rescue of injured workers. They also give industrial teams the ability to move heavy loads (5,000 to 10,000 lbs.) with simple hand tools. Remember, cranes can’t get everywhere, especially in a severely damaged area.

As emergency responders, we need to evaluate our capabilities continually and consider the types of rescue situations to which we may be called. We also need to know what outside resources are available – and, if it’s even possible for them to respond in a timely manner. Just like with confined spaces, we can’t simply dial 911 and hope they know what to do. While you hope it never happens, you’ve got to be prepared for the worst.

Readings are 20.9/0/0/0…so it must be safe for entry, right? Not necessarily!

After completing an interesting confined space standby job for Roco, I wanted to caution rescuers about the possibilities of atmospheric hazards within a confined space – despite what the atmospheric monitor says!

For this particular job, the atmosphere in the workspace never varied on the 4-gas monitor readings. The readings were consistently 20.9% for O2; 0 for LEL; 0 for H2S; and 0 for CO. However, this entry required the use of air-purifying respirators even though there were no visible signs of anything unusual – no odor, no product warning signs, no indication that there may be an inhalation hazard in the space.

This particular space was located at a public water facility. It was a 70-ft. deep concrete metering pit with six consecutive 12-ft x10-ft levels. It had concrete floors and walls with a vertical ladder that accessed each level. Although the space was not designed to store any product, in this case, we still had an atmospheric hazard.

The purpose of the entry was for remediation of mercury contamination on the concrete surface. The gross cleanup of liquid mercury had been performed years prior, but further action was required to eliminate vapor hazards still present in the lower chambers.

During the first phases of the entry, vapor levels that exceeded 40,000 ng/m3 (nano-grams per cubic meter) were detected. The more frequently updated ACGIH Threshold Limit Value is only 25,000 ng/m3. The work environment in this space routinely approached twice this level, even though there were no visible signs of liquid mercury. The source of the toxic atmospheric hazard was invisible and odorless – mercury vaporizing from the concrete surfaces.

Mercury is only one example of a toxicant that can produce a hazardous atmosphere in confined spaces that will not be indicated on a typical 4-gas meter or atmospheric monitor. Many rescuers assume that their 4-gas meter will detect all atmospheric conditions that may present a risk to their health or safety, but this is just not true. There are a wide variety of agents or toxicants besides mercury that will not be detected and whose presence may require other controls or the use of respiratory protection. This mistake could be deadly, or leave rescuers with chronic health issues.

In this scenario, for example, if you were an off-site rescuer responding to the above described space in an emergency situation. Without someone on site to inform you of the possible hazard, you would have no indication that any hazards were present. Many times as municipal rescuers we respond to, shall we say, shady locations where unauthorized storage or illegal dumping of hazardous products has taken place; there are no SDS, placards, or signage. Personnel on scene may not know, or may not want to relay vital information about a space of any products within the space.

Rescuers Beware: It's important to play the role of “detective” when planning or preparing to make a confined space entry.

Oftentimes, there are placards or signs on tanks or storage containers to start the investigation into what hazards may be present – and SDS for additional information. However, as rescuers, we often fall into a state of “false security” with our 4-gas meter readings.

While much of our training may include “Go/No Go” scenarios for rescue teams, the use of respiratory protection is usually based on one of the “Big 4” readings on our atmospheric monitors. Unfortunately, this may only serve to reinforce the notion that a 4-gas monitor will always provide the “complete” information of what may be going on inside a confined space. We get dependent on these monitors to tell us if it’s safe to enter without respiratory protection – and there may be much more to the story!

OSHA’s Respiratory Standard [1910.134 (d)(1)(III)] specifies "Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.” 

In the above statement, if you substitute Team Leader for “employer” and “Rescue Team” for employee, you may find that you cannot “identify or reasonably estimate the employee exposure.” Therefore, rescuers would need to use SCBA/SAR and other PPE until you can completely identify what hazards are in the space even though typical monitoring devices are telling us that all is well.

While your standard 4-gas meter is an important screening tool – it is NOT a "catch all" for every atmospheric hazard.

Remember that NIOSH statistics indicate that 40%-60% of confined space entry fatalities are (would-be) rescuers, including both dedicated on-site standby teams and off-site professional rescuers (municipalities) who attempt to perform confined space rescues.

But let’s take this a step further. If you ask most rescuers at what O2 level does an atmosphere become dangerous, they will say below 19.5%. I know from my initial hazmat/confined space training on 4-gas monitors included oxygen displacement. It was so elegantly described to me as “if your monitor shows a decrease in oxygen, it is telling you that something else has pushed out that percentage of oxygen and replaced it with some other agent.” Now, it would be up to you to figure out what else is in the air.

For example, normal breathing air is 20.9%. To get a reading of 19.5% means that about 1.4% of “something else” has displaced the oxygen. Then, depending on what that “something else” is, could require the use of respiratory protection. Hey, wait, the good news keeps coming, and I am getting in way over my head on this science stuff, but my high school chemistry teacher should still be proud. Ambient air is made up of about 79% nitrogen and other gases and 21% oxygen. So, using fingers and toes mathematics, that equals about a 4:1 ratio of nitrogen to oxygen.

In other words, if we have a 1% displacement of oxygen from the breathing air, it will be accompanied by about a 4% displacement of nitrogen (both gases displace at about the same rate). Therefore, instead of it being about a 1.4% percent of an unknown product in our breathing air, it could be as much as 5.6% or more! And, depending on what that product is, it could already be at its IDLH level.

Project Scientist Spencer Pizzani of Weston Solutions provides this insight.