Report submitted by John Voinche', Sr. Vice President/COO, Roco Rescue

In July, a group of Roco instructors conducted a Confined Space Rope Rescue demonstration for OSHA representatives from Washington, DC. These agency officials represented both General Industry and Construction. This demo was used to clarify our concerns about a pending Letter of Interpretation (LOI) concerning Individual Retrieval Lines in confined spaces that was brought to our attention last year. Here is a little background…

Last July (2011), we brought you a story entitled, “What’s the talk about individual retrieval lines?”  At the heart of the issue was a pending LOI from OSHA regarding how retrieval lines are used inside confined spaces. [Note: This LOI is pending and has not been published in the Federal Register.]

Here’s the question to OSHA from a gentleman in Maryland which initiated the LOI…

“Does OSHA 1910-146 (k)(3) require that each individual entrant, including workers and/or rescuers, entering into a confined space be provided with an independent retrieval line or can more than one entrant be connected to a single retrieval line?”

The proposed answer from OSHA stated that each entrant should have an “individual” retrieval line, despite the fact that the word “individual” is not included in this section of the standard [1910.146 (k)(3)(i)].
 
Roco then wrote a letter to OSHA requesting clarification about the forthcoming LOI. A portion of our letter stated that, “This pending interpretation is different from our understanding of what’s required by the regulation. While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.”


One of the techniques being used is a “single retrieval line” for multiple entrant rescuers. The first rescuer to enter the space is attached to the retrieval line via an end-of-line Figure 8 on a Bight. Any subsequent rescuers enter the space attached to the same retrieval line using mid-line Butterfly knots. In our opinion, this satisfies the intent of the regulation in that each entrant is attached to a retrieval line.

However, in the case of multiple entrants, requiring “individual” lines as mentioned in the proposed LOI may represent an entanglement hazard. This, in effect, may cause entrants to opt out of using retrieval lines due to potential entanglement hazards (which is allowed by the standard if entanglement hazards are a concern). So, in our opinion, this effort to bring more clarity to the issue may further complicate the matter.
 
Again, we believe the single retrieval line method described above is one way to rescue entrants while satisfying the intent of the standard at the same time. More background is available by reading our original story.

Fast-forward back to July 2012… the demonstration lasted about four hours. During this time, Roco demonstrated numerous retrieval line techniques as well as the “pros and cons” for each system. There was a great deal of discussion back and forth on how this pending letter of interpretation could affect rescuers and entrants – and their ability to perform their jobs safely and efficiently.
 
We would like to thank OSHA for allowing us to offer our feedback concerning this topic. We also want to say a special thanks to the Baltimore Fire Department for allowing us to use their training facilities. We don’t know when a final LOI will be issued, but we will keep you posted!

By Roco Chief Instructor Pat Furr

A Job Hazard Analyses (JHA) is a very effective tool that most every employer should consider incorporating into their safety management program. This tool, otherwise known as a Job Safety Analyses (JSA) or Risk Assessment (RA) is a process that identifies workplace hazards, and then spells out means to eliminate, control, or provide protection to employees from the identified hazards. Once completed, the JHA can then be used as both a training tool and a pre-task safety checklist. There are a variety of formats that can be used to create an effective and logical JHA.

However, the JHA should become a living document that may require frequent updating as the work process, tools, work environment, safety legislation, and the workforce changes. Even if these factors do not change, the JHA should be reviewed periodically to ensure that it’s still current and still applicable to the job or task.

“The goal of the JHA is to identify workplace hazards and take corrective action BEFORE an incident occurs.”

The preparation of a JHA should be a collaborative effort between safety personnel and front line workers. It’s often the front-line worker who can provide valuable insight into the specific tasks involved as well as provide solutions to the most common hazards. Of course, it’s always vitally important to have a safety professional intimately involved with the process to ensure that input provided works hand-in-hand with established company policy and any legislated safety requirements. By involving front line workers, they will feel like they had valuable input to the process, which is very true by the way.

Whatever format that you choose, it’s important to develop your JHA in a logical, easy-to-use manner. Here are some guidelines:
1. Identify the hazards.

• This may be obvious based on any history of accidents or near misses.
• Interview front line workers to hear their concerns.
• Evaluate the workplace to ensure it is in compliance with legislated and consensus safety standards.
• Brainstorm with workers to dig deeper into the subtle or overlooked hazards. Break the work process down into individual steps or tasks to help uncover any obscure hazards.

2. Determine the consequences of exposure to the hazard and any contributing factors or triggers. It may be helpful to develop a ranking system based on a variety of factors.

• Describe the likely outcome of exposure to the hazard.
• Does the hazard have the potential to harm multiple employees?
• How likely is the hazard to cause harm?
• How quickly will exposure to the hazard cause harm?
• Rank the hazards in terms of the most severe in order to determine which hazards must be given priority attention!

3. What protective measures are available to prevent the hazard from causing harm?

• Can the hazard be eliminated?
• Example: Eliminate fall hazards by bringing the work to the ground.
• Can the hazard be controlled? Example: Install machine guards on rotating parts
• Finally, if the hazard cannot be eliminated or controlled, what personal protective equipment (PPE) is required to protect the worker?

JHA’s can be very simple or very complex. The goal, however, is to find a balance between overburdening the worker with exhaustive paperwork and a document that is so lacking in detail that it is essentially useless. My experience is that the JHA should be just detailed enough to provide a succinct means to identify the hazards of the task, or the various steps of the task, predict the consequences of exposure to the hazard, and to provide a hierarchical means to protect the worker from the hazard. I like to keep the JHA simple and concise as it tends to encourage the worker to think into the situation and make – for lack of a better term- a “real time evaluation of the hazard.”

Remember, the JHA (JSA, RA) should be considered a living document that is updated to reflect any changes. It should also be an easy-to-use tool that workers and management can employ to identify hazards, rank the hazards in terms of their potential consequences, and provide an escalating hierarchy to abate the identified hazards. These documents should also be retained for a period of time because they may be useful in investigating any accidents after the fact.

Workers are injured every day on the job. JHA’s can be very useful for discovering, preventing or even eliminating some hazards from your workplace. At minimum, the process is likely to result in fewer injuries, more effective work methods, and increased worker productivity. What’s more, a simple, step-by-step JHA can be a valuable tool in training new workers to do their jobs more safely and effectively.

Reviewed by Pat Furr, Roco Chief Instructor/Technical Consultant

Cobra™ quick connect buckles are offered as a special order on new Sked® and as a retrofit kit for Sked® you already have. For users of the SKEDCO flexible litter, there is good news.  The SKED® Litter can now be ordered with Cobra™ quick connect buckles. Or you can order a Cobra™ Buckle Retrofit Kit for your original SKED®.

The uses of the new quick connect buckle system cuts the victim packaging time in about half.  The buckles are each rated at 3,000 pounds and require a dual action to release which provides a high level safety.

The price of the SKED® is a bit higher with the Cobra™ buckles; however, you do get everything you pay for with these buckles. They dramatically speed up the patient packaging because of the ease of using them. And, as rescuers, we're always looking for ways to evacuate our patients in a quicker and more efficient way.

By Pat Furr, Roco Chief Instructor/Technical Consultant

OK, who has not had the opportunity to use the Petzl ID? The ID is one of the most versatile bits of rescue hardware that I have in my kit. It comes in both NFPA G and L(*) rated versions and provides the closest thing to a “Jack of all Trades” capability that I can think of.

It was originally designed as an evolutionary improvement to the Petzl Stop and Gri Gri and as its name suggests, it was intended to be an “Industrial Descender” thus ID.

In very short order it became apparent that this device could do so much more than provide an auto stop capability during rappels.

The "auto stop" feature also acts as an instant progress capture, or ratchet while pulling rope through the device in the direction opposite that it was designed to control friction. This feature provides the option of using the ID as the first change of direction and ratchet in mechanical advantage systems. Granted, the bobbin of the ID is not nearly as efficient as a true pulley, but the efficiency gained by having virtually every fraction of an inch of progress captured and the ease of changing over from a haul to a lower far outweighs any efficiency loss at the bobbin.

My go-to system for situations where I need to change over from lowers to hauls, or from hauls to lowers, is the ID with the addition of a cam, a biner, and a pulley (Omni-Block), which gives me an easily assembled 3:1 Z-Rig. If I need more MA ratio, I just use a double sheave pulley at the load end and an additional single sheave pulley at the anchor end -- now I've got a 5:1 MA.

In addition to the use of the ID as the foundation of MA systems, it can also be used for short ascents, and the manufacturer is now allowing it to be used as a belay device. The ID-L still retains the quick load side plate that allows it to remain anchored while loading or unloading the rope from the device.

If you have an extra 5 minutes, watch this video where Roco Director of Training, Dennis O'Connell shares some tips about using the Petzl ID as a part of your confined space rope rescue equipment kit.

(*) Note: The 2012 edition of NFPA 1983 has changed its Light Use (L) designation to Technical Use (T).

By Pat Furr, Roco Chief Instructor/Technical Consultant

When doing our "risk vs. benefit" analysis, we always want to limit the exposure of our rescuers to the lowest level of risk practical. The SureClip™ telescopic rescue pole is one tool that can do just that. This system provides a means to make a remote attachment to a suspended or otherwise isolated victim (such as confined spaces) while minimizing risk to the rescuer.

This system is especially effective in attaching rescue systems to fallen workers that are suspended from their personal fall arrest systems. By eliminating the need to put a rescuer “on line” to make contact with the victim, this system reduces the risk to the rescue team members. The SureClip™ universal head is designed to hold a variety of auto locking carabiners in the open position and mount on a standard telescopic pole that provides from 8 to 25 feet of reach depending on the model.

For more information on this handy device, contact Roco at 800-647-7626. Or, for technical assistance, ask for Pat Furr or one of our other knowledgeable instructors.