We recently had a Facebook inquiry about attaching a rappeler's belay line (safety line) to their high-point dorsal connection on their harness. We choose to do this for a number of reasons including: (a) compliance with applicable regulations; (b) adherence to safe and practical rescue procedures; and, (c) the physiological effects of falls – how the body absorbs an impact force. Let’s take a general look at these considerations.

Compliance

OSHA considers our rappel/lower main lines as “work positioning” lines and our belay or safety lines as “fall protection.” The fact that they and we, as rescuers, consider the safety line as fall protection, or more accurately as our Personal Fall Arrest System (PFAS), kicks in a few requirements and considerations for all private sector responders and for municipal responders governed by OSHA-approved State Plans. These responders are required to comply with applicable OSHA regulations.

However, keep in mind, these regulations are designed to protect workers (and rescuers) from harm and injury. During training, since it is not a real rescue, we should be following the applicable regulations and standards for safety as well as liability reasons. Even during actual rescues, it is important to adequately protect our people from injury. The days of “rescue at all costs” are gone. We are responsible for designing training, systems and SOPs/SOGs that protect our people in a rescue situation.

Note the following key points from OSHA 1926.502(d):

• Limiting the free fall distance (max free fall 6 feet)
“…be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level”

• Deceleration distance of 3.5 feet (41 inches)
“…bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m)”

• Maximum allowable impact load 1,800lbf.
“…limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness”

• Improvised anchorage strengths of 5,000lbf or twice the anticipated load.

“Anchorages used for attachment of personal fall arrest equipment shall be…capable of supporting at least 5,000 pounds (22.2 kN) per employee attached…”
“Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.”

• Harness attachment should be to the high-point dorsal connection point.

“The attachment point of the body harness shall be located in the center of the wearer's back near shoulder level, or above the wearer's head.”

You may have heard the statement, “Firefighters/rescuers don't need fall protection or need to follow OSHA.” This is not true for the 27 State Plan states where OSHA regulations do apply to public sector employees including emergency responders. It puts the burden on the employer, agency or department to establish fall protection and rescue protocols that would adequately protect their people.

To illustrate this, here is an excerpt from an article written by Stephen Speer, a NY career firefighter, for “Fire Rescue” magazine which deals with potential OSHA violations during rescue operations and training exercises. (Note: New York is a State-Plan state.)

“I spoke to a New York State Public Employee Safety & Health (PESH) supervisor about the following scenario and asked if there were areas that could be potential violations.

Scenario: A firefighter operating from a roof ladder is cutting a ventilation hole on a pitched roof. The firefighter falls from the roof and is injured.

In what areas, if any, could an incident commander or company officer be cited? In response, I received 12 pages of documentation. The documents showed that in evaluating potential violations of the general duty clause to see if anyone is responsible, the following four elements must be met:

1. The employer failed to keep the workplace free from a hazard to which employees of that employer were exposed.
2. The hazard was recognized.
3. The hazard was causing or likely to cause death or serious physical harm.

NFPA 1500, chapter 8.5.1.1, states that operations should be limited to those that can be completed safely. In this scenario, there is the potential for citation if all four elements apply. As the above scenario illustrates, whether or not you have an aerial apparatus, you must consider fall arrest protection.”

Practicality

When rescuers are sent into a vertical confined space, we use the safety line (PFAS) to protect them as they are being lowered and raised from the space. It is also used as “an immediate means of retrieval” should something go wrong inside the space. Having the safety/retrieval line attachment point at the high-point dorsal position allows us to attempt an emergency retrieval with the victim being extracted in a low profile to fit through a narrow portal.

Physiological Effects

There have been numerous studies on the effects on the body when subject to a fall and arrest while in a harness. They generally come to the same conclusion that high-point dorsal attachment is the most survivable and provides for the greatest injury reduction. Here are excerpts from two studies.

1) Excerpt from a study conducted by Dr. M. Amphoux entitled, “Exposure of Human Body in Falling Accidents,” which he presented at the International Fall Protection Seminar in 1983:

In experiments on the position of the attachment point on the harnesses, Amphoux found that a high attachment point was preferable because “it gave a better-disposed suspension” and that it was “especially effective when the attachment is on the back. When the falling stops, the neck flexes forward. If the attachment point is in the front of the sternum, the neck flexes backwards and the lanyard may strike the face.”

Amphoux continued that it would be better for the compression to be localized on the body of vertebrae and not on the posterior joints, which were too fragile. “Therefore,” he said, “the attachment point would be better on the back than pre-sternal and should be high enough to reduce the potential neck injury. In addition, the forward flexion would be stopped by the thrust of the chin on the chest.”

This was why Amphoux and his colleagues strictly recommended attachment high on the back. It also protected the face from the lanyard when falling. In the case of falling head first, regaining a feet-first position would involve flexion of the head, whereas if the attachment were pre-sternal, the head would more often be projected backwards [whiplash effect].

However, it was accepted that a front attachment might be preferred in a few working situations. This was only acceptable when the height of the potential fall was very short. Whatever the choice of body support, it should not be forgotten that it was only a compromise and not a guarantee of absolute security.

2) Excerpt from “Survivable Impact Forces on Human Body Constrained by Full Body Harness,” HSL/2003/09 by Harry Crawford:

The one-size-fits-all policy of some harness manufacturers may not be suitable for the range of body weight 50kg to 140kg. Although it may be possible for those in the wide range of body weight/size to don such a harness, the position of the harness/lanyard attachment is of paramount importance. For best performance and least risk of injury, the attachment should be as high as possible between the shoulder blades.

Note: They also concluded that the shorter the fall, the less impact and less chance of injury no matter which type of harness or where the connection point was.

Like any rescue or work safety technique, you need to look at all the variables and decide which technique and equipment will best protect you or your co-workers. We choose the high-point back connection because of the variety of situations and locations we might face during a rescue based on the three considerations mentioned earlier in this article.

Thanks for a great question and taking the time to look into the reasons why systems or techniques are used. I hope this answers your question. If you have additional questions, please contact me at 800-647-7626.

By Dennis O'Connell, Roco Director of Training

Federal OSHA and other OSHA State Plans do a good job of providing updates on newly recognized hazards in the workplace, as well as reminding us of existing hazards. We need to heed this information as it takes lessons learned the hardest way, and shares it for others that work in the same or similar environments.  No matter what industry our employees are performing their jobs, the fact remains, we are all humans and will suffer the same consequences of exposure to hazards no matter if we are in construction, general, agricultural, or any other industry. 

Often times there are significant differences in the OSHA regulations for identical hazards from one industry to another.  For instance, the height threshold for requiring fall protection in general industry is four feet, whereas the threshold in construction industry is six feet.  Are construction employees able to withstand the impact of a fall better than a general industry worker?  No, the main reason for the difference was due to the rules making process and dialog between OSHA and the industry stakeholders.

If you were to spend some time reading OSHA’s agricultural regulations, you will find that you won’t need much time.  They are pretty lean.  But there is one very important OSHA regulation that must be considered, and that is Section 5 (a)(1), General Duty Clause. 

If a recognized hazard is not addressed in an industry specific regulation, the General Duty Clause is there to protect the employees and the employer MUST comply with it.

For now, there are many instances in the agricultural industry that have no specific regulation addressing the various hazards and thus the General Duty Clause is very important to remember.

Confined spaces are areas large enough for a worker to enter and perform work, have a limited or restricted means of entry or exit; and are not designed for continuous employee occupancy. The following quote is from OSHA Fatal Facts publication No. 16-2018 and provides clear expectations for protecting employees where no specific industry regulation exists. The purpose of this Fatal Facts is to highlight the importance of identifying confined spaces in agricultural workplaces to prevent another fatality.

"The General Duty Clause requires employers to provide employees with workplaces, including confined spaces, which are free from recognized hazards likely to cause death or serious physical harm. Agricultural opera­tions are covered by several Occupational Safety and Health standards including Agriculture (29 CFR 1928) and parts of General Industry (29 CFR 1910), as well as the General Duty Clause of the Occupational Safety and Health Act (section 5(a)(1)). OSHA’s confined spaces standard at 29 C.F.R. 1910.146 does not apply to agricultural operations, but serves as a guide for how to prevent these accidents.”

Comments on this story were made by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

Resources:
Washington State DOL and OSH
Safety+Health Magazine

QUESTION: Should industrial rescue team members be informed of any scheduled confined space entries at the beginning of their shift?

ANSWER: While OSHA does not mandate that individual team members be notified; common sense and best practices do. Here’s our reasoning for encouraging this “information sharing” at the beginning of each shift.

First of all, it is the Entry Supervisor’s responsibility to ensure that the rescue service is available prior to each PRCS entry. This verification should be performed in a way that confirmation of availability can be documented. There are various reasons that the in-house team may not be immediately available, so it’s up to the Entry Supervisor to plan ahead and coordinate with the team. Most often in-house industrial rescue team members have regular job assignments in addition to their rescue duties. Depending on the particular assignment, he or she may or may not be available to respond to a rescue emergency. In fact, we have heard of incidents where the Entry Supervisor just “assumed” that because the facility had an in-house rescue team that the team would always be ready to respond. In one instance when an in-house team was notified of a PRCS emergency, only one (1) team member was on shift and available to respond. Apparently, other team members were on sick leave, vacation, or at shift change. As you can see, two-way communication between the Entry Supervisor and the rescue service is a must!

Having a system in place that allows on-duty team members to be aware of PRCS entries that are scheduled during a given shift allows them to start the preplan process, which will help reduce response and preparation times. It also provides Team Leaders (IC) with a better understanding of possible rescue needs and how best to utilize available resources if an emergency situation should arise. And, these are just some of the reasons we recommend that on-duty team members be accounted for and be made aware of any entries occurring during their shift - including the location, the type of entry and the hazards involved. It simply provides for better preparation; thus, making everyone safer.

One of OSHA’s Agency Priority Goals is to reduce trenching and excavation hazards. According to the Bureau of Labor Statistics, excavation and trench-related fatalities in 2016 were nearly double the average of the previous five years. OSHA’s goal is to increase awareness of trenching hazards in construction, educate employers and workers on safe cave-in prevention solutions, and decrease the number of trench collapses.

OSHA plans to issue public service announcements, support the National Utility Contractors Association’s Trench Safety Stand Down, update online resources on trench safety, and work with other industry associations and public utility companies to create an effective public-private effort to save lives. OSHA’s trenching and excavation national emphasis program is also currently under revision. For more information on trench safety, visit OSHA’s safety health topics page.

Over the past few years, Roco has made trench safety a priority goal by dedicating more than 15 articles on this website as well as a podcast to trench-related subjects in an attempt to increase awareness for trench safety and rescue, just as OSHA is doing.

One area we have identified where facilities may be in violation is having personnel who are not “trench” competent persons sign off on trenches. Many times, the company representative is a “Confined Space Competent Person” or “Entry Supervisor,” and we are asking them to sign off that a trench shoring system is adequate when they have little or no training.

Just because you are competent person in one area does not mean you are a competent person in all of them. A confined space knowledge base is not the same as a trench knowledge base.

The OSHA Construction Standard Defines a Competent Person “as someone 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.”

Now that NFPA 1006 Standard for Technical Rescue Personnel Professional Qualifications (2017 edition) has been in place for a while, it’s a good time to revisit the changes that have been made. While we won’t go into every single change from the previous 2013 edition, we will cover some of the more significant ones – particularly for the specialty areas that we deal with most.

So, let’s get to the big changes right off the bat. As you are probably aware, there was a big disconnect between NFPA 1006 and NFPA 1670 Standards on Operations and Training for Technical Search and Rescue Incidents. While there are technical committees for the development of both 1006 and 1670, very few committee members sit on both committees. The need for a correlating committee became apparent, and it is that correlating committee that coordinated and at times arbitrated changes to both standards in an effort to marry them up.

For example, NFPA 1006 Levels I & II have been replaced with Awareness, Operations and Technician levels to correlate with 1670 performance levels. This change may seem minor, but it allows for (and provides guidance in) training auxiliary personnel to a level of competency to support the Technical Rescue Team. This is reflected in the title change of 1006 from “Standard for Technical Rescuer Professional Qualifications” to “Standard for Technical Rescue Personnel Professional Qualifications.”

This change provides the option to train a team to a level for handling less technical incidents and still meet the standard for that level of proficiency. It also allows for a level of competency to begin a rescue effort while awaiting a more technically trained and equipped team to respond. This aids teams that do not have the manpower, equipment or funding to train to the Technician level by providing performance goals for Operations and Awareness levels.

NFPA 1006-2017 has also added several new specialty areas to include: Floodwater Rescue, Animal Rescue, Tower Rescue, Helicopter Rescue, and Watercraft Rescue. Several new definitions have been added to correlate with NFPA 1670. Clarification is provided by further defining dive operations, search, watercraft, wilderness, and other terms. You will also find that the word “search” (as used in the title of 1670) has been incorporated into many of the specialty areas of 1006 – another attempt to better correlate the two standards.

Again, we have attempted to highlight some of the key changes in NFPA 1006-2017. We think the modifications will make it easier to understand what is required of technical rescuers as well as auxiliary support personnel. As always, we encourage you to read the standard in its entirety. If you have any questions, please call us at 800-647-7626.