The following article was featured in the July 2014 issue of ISHN, and authored by Roco's own Chief Instructor Pat Furr.

Have you ever wondered who that person is who hovers around the portal of a permit space while workers are in the space? What does a Confined Space Attendant (often referred to as the “Hole Watch”) do anyway? What may seem like a cushy job is actually a critical safety responsibility. Here’s why:

First, OSHA instituted regulations regarding Permit-Required Confined Spaces (1910.146) due to the high number of serious injuries and deaths in confined spaces. Entering these spaces is dangerous business, and the attendant serves as the “safety watchman” for entrants as well as those who may casually try to enter. This also applies in an emergency situation when others may be tempted (but unqualified) to enter the space to rescue a co-worker.

OSHA requires that the attendant be able to safely and effectively perform the duties required in Section (i) of 1910.146. (See “Duties of the Confined Space Attendant”) Once a permit is issued and work begins, the attendant needs to be aware of his or her surroundings and be diligent in monitoring the space and entrants at all times. This individual is not there to be a “gofer” for workers inside the space.

Get real

If entrants need assistance or an emergency situation develops inside (or outside) the space that requires entrants to be evacuated, the attendant is the “vital link”. Unfortunately, it is common practice to fill the Hole Watch position with the least experienced or greenest person on the crew. Many times, this person has no idea what is expected of them. They also may not be aware of potential hazards inside the space or hazards that may be introduced as work is performed. Often, these individuals are not experienced in industrial environments and are not properly trained in the OSHA-required duties. And, in most cases, they don’t realize how critical their duties could become in an emergency when split-second decisions are required.

Train your attendants

It is unrealistic to expect a new employee to perform these duties without receiving appropriate training and being granted the authority to take action as needed. In 1910.146(d)(8), OSHA is specific in its requirements for the various roles involved in conducting safe permit entry operations. Employers are required to provide adequate training and ensure that personnel are capable of performing their duties. At minimum, the regulation requires employers to ensure that each Hole Watch/Attendant knows and understands the following safety precautions:

(1) Hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure to those hazards;

(2) Possible behavioral effects of hazard exposure for the authorized entrants.

Additional duties and responsibilities include:

(1) Continuously maintaining an accurate count of entrants in the permit space.

(2) Performing non-entry rescues as specified by the employer’s rescue procedure.

One of the most critical duties of the attendant is to be able to effectively communicate with entrants and take appropriate actions in an emergency. Communications are required to monitor the status of the entrants and to ensure that there are no signs of exposure to hazards. The attendant must recognize this need and be able to order evacuation of the space. Most importantly, the confined space attendant can perform NO duties that might interfere with their primary duty to monitor and protect the entrants.

Prevent fatalities

Employers must ask themselves, “Will the person designated as the “Hole Watch” be able to react in an effective manner when the pressure is on? Will they be able to initiate a non-entry rescue in an emergency situation?” Again, we witness too many instances where the “Hole Watch” has little or no knowledge of the responsibilities assigned, while some have had virtually no training whatsoever. Sometimes it seems they are there for no other reason than to fill a square to meet an OSHA requirement.

Many times the lack of understanding regarding confined space hazards, combined with the lack of a clear understanding of emergency actions to be taken (as well as actions to avoid) can lead to confined space fatalities, both for the entrants as well as the attendant.

We urge employers to take a serious look at the selection and training of confined space attendants. These individuals must be capable, responsible and properly trained as spelled out in the OSHA standard. When things go wrong in a confined space, the actions (or inaction) of the attendant can be the difference between life and death for the entrants. They must have the knowledge, the tools and the experience to function as an effective, and ultimately safe, “Hole Watch.”

 

Additional Resources

• Attendant Safety Requirements Poster (pictured here)
• Confined Space Entry Checklist
• Common Causes of Confined Space Fatalities
• Limitations of Atmospheric Monitors

 

 

The following article was featured on the cover of the March 2014 issue of ISHN, and authored by Roco's own Chief Instructor Pat Furr.

It’s a Saturday night December 21st and the plant is running on a skeleton crew. Operations wants to get a head start on annual preventative maintenance and decides to knock out several permit required confined space entries before the majority of the work is to be done when the regular shifts return after the New Year. Randy has just finished the third of five vessels that are identical in configuration. His authorized attendant and good friend Hector have been working together for over 15 years and they both know the drill. They have changed out the stainless steel bolt sets on the agitator blades of these vessels every year at about this same time. The entry supervisor just closed out the permit for the third vessel and after reviewing the permit for the fourth vessel and helping with the pre-entry atmospheric monitoring; he signs the permit authorizing entry.

Hector checks Randy’s harness and the attachment of the non-entry rescue retrieval cable to his dorsal D-ring, and double checks the davit arm and the mounting point of the self-retracting lifeline with the built in retrieval winch. As Randy climbs 25 feet down the rope ladder to access the bottom of the vessel, all is going according to plan. As he steps off the ladder and begins to loosen the first bolt set, he slips on the concave floor of the stainless steel vessel. Before he can react, he strikes his head on the agitator blade which causes a 5 inch gash to his left temple and knocks him unconscious. He falls between two of the agitator blades and then slides to the bottom of the vessel with his retrieval line wrapped over one of the blades and under another. Hector tries to winch his friend out of the space only to find that Randy’s limp body gets wedged under the agitator blade. You can probably guess what happened next.

Realizing there is no entry rescue capability on this shift; Hector’s gut reaction is to enter the space to help his friend. In his rush, he slips from the rope ladder and falls 20 feet to his death. When the entry supervisor arrives 30 minutes later to close the permit and initiate the last entry, he sees two bodies at the bottom of the space.

Understand OSHA rescue requirements  

Are there permit required confined spaces at your worksite? Are employees allowed to enter these spaces? If you answered yes to these two questions, it is critically important to understand the OSHA requirements for rescue. As part of a written permit space program, the employer must “Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue”.

When considering what methods should be used for rescuing authorized entrants, the safety of the rescuer(s) should be considered as important as the effectiveness of the rescue technique. If it is possible to perform non-entry rescue of the entrant(s), that should always be the first choice. It’s always a given – keep additional personnel (even rescuers) out of the space unless absolutely necessary. It is important to consider potential scenarios that could arise when determining if non-entry (or retrieval) rescue is sufficient.

Non-entry rescue

What are the requirements for non-entry rescue? OSHA states “To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”

Let’s examine this further. What conditions would preclude the use of non-entry retrieval systems? Here are some guidelines that OSHA will use to make this determination:

• A permit space with obstructions or turns that prevent pull on the retrieval line from being transmitted to the entrant does not require the use of a retrieval system.
• A permit space from which an employee being rescued with the retrieval system would be injured because of forceful contact with projections in the space does not require the use of a retrieval system.
• A permit space that was entered by an entrant using an air supplied respirator does not require the use of a retrieval system if the retrieval line could not be controlled so as to prevent entanglement hazards with the air line.

 

Assess the space

The ONLY way to determine if a non-entry retrieval system will provide adequate safety for entrants and satisfy OSHA’s requirement is to perform an honest and thorough assessment. This assessment should provide careful consideration for the capabilities and limitations of the retrieval system for any planned or unplanned condition that may arise during entry. We have all heard of “Murphy’s Law” and most of us have experienced the effects of that particular law. I encourage you to remember that Murphy is always lurking close by.

So when evaluating these spaces to determine if non-entry or entry rescue is the appropriate choice, always ask yourself “what if?” For the fictitious accident that opened this article, the plan was to do all the work on the near side of the agitator blade directly below the top portal. In that case, it would have been safe to assume non-entry retrieval was the only plan needed for rescue. Enter Murphy…… Was the rescue plan developed with the assumption that the planned work activities would always ensure the successful use of the retrieval system, but failed to consider the “what ifs”? Some might say that we can “what if” things to death. Let’s turn that around; we SHOULD “what if” these questions in an effort to PREVENT death.

When evaluating permit spaces to determine the appropriate rescue capability, please explore those “what ifs”. This is not to say that in the case cited above that the only option would have been entry rescue. That may not be necessary and if the non-entry retrieval system would have worked, then there is no need to expose rescuers to the hazards of entering the permit space. But there was a potential for the condition to change, and it sure did. So recognizing that potential, an entry rescue capability should have been planned in the event that the change in conditions rendered the non-entry rescue system ineffective.

Backup plan

 

The point of this article is to consider non-entry rescue as the default for assisted permit space rescue unless the conditions cited by OSHA are present. At that point, entry rescue must be planned. But this isn’t necessarily a one or the other choice. As we can see from this story, it is sometimes best to plan for non-entry rescue as the primary technique, but if there is any reasonable potential for an unplanned change in conditions, then an entry rescue capability must be in place as a back-up.

FEMA and the FCC will conduct the first “nationwide” test of the Emergency Alert System (EAS) on Nov. 9 at 2 p.m. Eastern time. The test may last up to three and a half minutes, FEMA announced. The test will involve broadcast radio and television stations, cable TV, satellite radio and TV services, and wireline video service providers in all states and the territories of Puerto Rico, the U.S. Virgin Islands, and American Samoa. The two agencies said this test will help the federal partners and EAS participants determine the reliability of the system and its effectiveness at notifying the public of critical information that could save lives and protect property.

“Because there has never been an activation of the Emergency Alert System on a national level, FEMA views this test as an excellent opportunity to assess the readiness and effectiveness of the current system,” according to Damon Penn, FEMA’s assistant administrator of National Continuity Programs. “It is important to remember that the Emergency Alert System is one of many tools in our communications toolbox, and we will continue to work on additional channels that can be a lifeline of information for people during an emergency.”

“The upcoming national test is critical to ensuring that the EAS works as designed,” said Jamie Barnett, chief of FCC’s Public Safety and Homeland Security Bureau. “As recent disasters here at home and in Japan have reminded us, a reliable and effective emergency alert and warning system is key to ensuring the public’s safety during times of emergency. We look forward to working with FEMA in preparation for this important test.”

(as reported in OH&S; Jun 09, 2011)

Well, maybe not half the time, but certainly some fraction of the time.

In How to Haul a Victim in Half the Time: Part 1, we covered ways to reduce the time needed to haul a rescue package by taking advantage of changes of direction.

Here, we want to address OSHA and ANSI guidance regarding retrieval systems – specifically mechanical devices used for rescue.

OSHA 1910.146(k)(3) states “To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.

Additionally, OSHA follows the ANSI Z117-1-1989 approach that was in effect at the time of OSHA 1910.146 promulgation, which states, “A mechanical device shall be available to retrieve personnel from vertical type PRCS’s greater than 5 feet in depth.” It also adds, “In general, mechanical lifting devices should have a mechanical advantage adequate to safely rescue personnel.”

Subsequent revisions to ANSI Z117 included the recommendation that “The mechanical device used should be appropriate for rescue service.” The revised standard adds,“Mechanical lifting devices should have a mechanical advantage of at least four to one and the capacity to lift entrants including any attached tools and equipment.”

Two key points that must be considered: (1) OSHA follows the ANSI approach that was in effect at the time 1910.146 was promulgated which did not recommend a minimum mechanical advantage ratio; and, (2) The rule makers intended to leave a degree of latitude for the rescue service to select a lifting device that is most appropriate for the particular situation encountered.

Roco’s rule of thumb is… the mechanical device used should be appropriate for rescue service – and the employer should not use any mechanical device that could injure the entrant during rescue, which would include a mechanical device with too great a mechanical advantage (MA) for the number of people operating the system. Here’s a guideline we use for determining the proper number of rescuers for a particular system – it should take some effort to haul the victim, but not so much effort that it wears the rescuers completely out. And, it should not be too easy, or you won’t as readily feel if the victim gets hung-up.

Because 1910.146 is a performance-based regulation, it does not specify the rescue procedures that are most appropriate for any given PRCS. It leaves this to the responding rescue service based on their assessment of the PRCS in terms of configuration, depth, and anticipated rescue load. Current ANSI Z117 recommends that the MA “should” be at least four to one. Notice that it does not state “shall” and thus the discretion of the rescue service is taken into account. A generic recommendation of a 4:1 is a good start but should not be considered as a catch-all answer to the problem of lifting the load. Even a 4:1 may not be enough if the person doing the hauling is not strong enough and may require a greater M/A in order to remove the load from the space.

Must we always use a minimum MA of 4:1, or could there be justification in using an MA below the 4:1 ratio when there is a need to provide a faster means of hauling the rescue package? Consider the possibility of reducing the mechanical advantage ratio when there is plenty of haul team members. If you have 4 haul team members for a 250 pound rescue package, do you really need that 4:1 MA? Consider going with a 3:1 or even a 2:1, especially if the throw is short and the haul is long. However, keep in mind that the package will be traveling much faster by reducing the MA – so it is imperative that a “hole
watch” be assigned to monitor the rescue package and be ready to call an immediate “STOP” should the package become hung up.

Caution: If you’re using a piggyback system, make sure the haul team does not outpace the individual taking in the mainline slack through a ratchet device. Should a lot of slack build up in the mainline and the haul team lose control of the haul line, the resulting free-fall of the load could spell disaster. Of course we always encourage the use of a safety (belay) line, but on rare occasions the urgency of the rescue may warrant not using a safety line on the victim.

Ultimately it is the employer’s responsibility to evaluate the selected rescue service’s ability to provide prompt and effective rescue. If the rescue service is able to demonstrate their capability using an MA that is less than the current ANSI recommendation, then that would meet the performance-based nature of the standard. In reality, by using a reduced MA, the time required to extricate the rescue package can be cut by 1/3 to 1/2 depending on the situation. In certain emergencies, that saved time could very easily mean the difference between a successful rescue and a body recovery.

The answer may be in the description “trusty old”. The ID has a wear indicator cast into the friction bobbin. It is located at the top of the bobbin on the side of the bobbin that the swinging side plate is on. When in usable condition the wear indicator is visible as a slightly raised ridge about a half-inch long. If the wear indicator is not visible the bobbin is worn out and the ID needs to be taken out of service.

 Smart answer courtesy of Pat Furr