UPDATE: OSHA recently unveiled its top 10 most frequently cited violations for 2010, and topping the list is Fall Protection. With 7,139 violations, Fall Protection is still at the top, switching places with last year’s first place holder, Scaffolding. OSHA reported that 260 workers died in 2010 from falls, which continues to be the leading cause of death in construction. So, you’ve developed an exemplary employee safety program and the shining gem is your fall protection program.

Using an organized approach and ANSI guidance for completing a “Fall Hazard Survey Report,” you have identified all the areas that workers are exposed to falls from height. Adhering to the hierarchy of fall protection, you’ve also been able to engineer out many of these fall hazards by bringing the work to the ground. Outstanding! For several of the remaining areas, you’ve installed passive fall restraint systems like guard rails and parapets. Great! Still, there are several areas that could not be protected by engineering out the hazard or providing passive restraint.

For some of these areas you are able to protect your employees from falls with active restraint, using body support and a restraint lanyard connected to a suitable anchor that prevents the worker from falling. Good. But, there are still a few remaining areas that you could not protect your employees from falls using the lower hierarchy solutions, and the only feasible solution was the use of personal fall arrest systems (PFAS). OK. You are still providing a compliant and possibly the most logical and feasible program that will provide a high degree of fall protection for your work force. Job well done! Or is it?

By taking the steps covered above and using the “Hierarchy of Fall Protection,” the employer is doing exactly what OSHA expects of them to protect their employees from the devastating injuries resulting from falls. However, there is one more piece to the puzzle…what are the potential outcomes and OSHA expectations after an employee falls? Especially if the employee is using PFAS.

OSHA’s Fall Protection regulations state that the employer shall provide prompt rescue in the event of a fall, or shall assure that employees are able to rescue themselves (OSHA 1926.502 and 1910.66 app. C). Although both regulations include “self-rescue” as the first choice in most cases — can we really rely on a worker to self-rescue in the event of a fall? What if the worker is injured during the fall, or what if a sudden medical emergency caused the fall? Are we confident that the individual will be able to perform self-rescue? In our opinion, relying on an employee to provide self-rescue after a fall does not fully meet the spirit of OSHA Fall Protection regulations. In fact, we feel that the only way to provide 100% rescue coverage is to assume that self-rescue is not a reliable option.

The irony is that an employer with an inadequate fall protection program may not face the need for a fallen/suspended worker rescue capability. In this environment, if the employee falls and has no PFAS, there is probably no need for rescue; it is more likely now a recovery. At this point, what the employee really needs is a “help wanted” ad to replace the employee and a very good lawyer.

Just a few years ago it was fairly common for employers not to be aware of the “after fall” hazards created by the PFAS. The understanding was that the PFAS did its job and the emergency was averted. However, in 2004, OSHA published a Safety and Health Information Bulletin (SHIB 03-24-2004 updated 2011 https://osha.gov/dts/shib/shib032404.html) that provided advice and information on suspension trauma/orthostatic intolerance. In fact, the bulletin states that “research indicates that suspension…can result in unconsciousness, followed by death, in less than 30 minutes.” As a recognized hazard, an understanding of suspension trauma makes it clear that post fall arrest suspended workers are still at risk of serious and possibly fatal injury even in the absence of primary injury prior to, or during the fall.

Although OSHA regulations do not assign a specific time criteria to what constitutes “prompt rescue,” ANSI Z359.2 does. ANSI recommends that “physical or verbal” contact be made with the fallen worker within four (4) to six (6) minutes. Notice that ANSI includes verbal contact in their recommendation. It makes sense that if verbal contact is established, the fallen worker’s condition can be assessed and a determination made on the general urgency of the situation. For example, if responders can establish verbal contact with the fallen/suspended worker, and the victim is alert and oriented, has normal or near normal breathing function, and has no obvious signs of bleeding, then the rescue can be approached in a measured manner. Responders should also remind the suspended worker to “bicycle” their legs — or to deploy any system that is designed to delay the onset of suspension trauma. Obviously, the victim needs to be rescued in a safe and expeditious manner before the onset of suspension trauma, if possible.

However, if the victim is unresponsive, or showing signs of breathing difficulty, or active bleeding, then the sense of urgency should be elevated and the victim must be rescued ASAP. This presents a true dilemma for the employer who has not included a prompt rescue capability in their comprehensive fall protection program.

In fact, it is common to refer to a PFAS system as having four components:


A great way to ensure that a prompt rescue capability is available in the event of a fallen/suspended worker is to complete a “Fallen Worker Rescue Preplan” for all areas where employees are working at height. For general industry facilities, which tend to be fairly static, this can be done initially with periodic review and updates as needed. For the typical construction industry with its dynamic activities, a much more diligent and regular review of rescue needs and rescue plans may be needed.

Employers have a few options in developing a prompt rescue of fallen/suspended worker capability. Coordinating with municipal emergency responders is one option. Contracting third party professional rescue services is another possibility — especially during turnaround activities or major reconfigurations/additions. Or, the employer can choose to develop an in-house rescue capability made up of their own employees that are trained and equipped to perform the types of rescues that they may be confronted with at their facility.

Whichever option the employer chooses, it is of utmost importance that the employer vets the rescuers, even their own in-house assets, to ensure that they can actually perform the types of rescue, including the worst case that they may be responding to. For those using an outside rescue service, it is a great practice to invite the rescuers to the facility for the purpose of rescue planning and a performance evaluation of their capabilities. It is very common for outside rescuers to be caught off guard when confronted with unique structural or victim access constraints upon seeing the facility for the first time. This may be so significant that the rescuers find themselves unequipped or lacking in the skills required to provide rescue.

The recent advent of pre-engineered rescue systems has also lulled many employers into the belief that these systems will provide an all-encompassing rescue capability. While most of these “Plug–and–Play” systems do provide a certain level of performance, they also have limitations, especially if access to the fallen/suspended worker requires a rescuer to be put on line to make physical contact with the victim. In this case, it is quite likely that the employer may need to consider a technical rescue capability exceeding the capabilities of a pre-engineered rescue system.

The need for a more technical rescue approach can only be determined after a thorough evaluation of rescue needs based on Fallen Worker Rescue Preplans. We often refer to this as a fallen worker “walk-about” where knowledgeable representatives of the employer (usually the competent person or the competent rescuer) tour the facility to develop Fallen Worker Rescue Preplans. These individuals will need a thorough understanding of the work processes, the areas of workers at height, the access routes, the types of PPE/PFAS being used, and most importantly, an understanding of the techniques and equipment necessary to affect a safe and prompt rescue.

Once the Fallen Worker Rescue Preplans have been completed, they become part of the comprehensive fall protection program and should be reviewed and updated as necessary.  With the seemingly continuous advent of new rescue equipment and techniques, it would be a great idea to review your preplans to see if there are opportunities to add these innovations, especially if they provide a safer and more efficient means of rescue.

In summary, it is of utmost importance for employers to ensure that their workers at height (especially if using PFAS) are afforded prompt rescue should they fall and remain suspended from their PFAS system. Whether the employer chooses an outside rescue service or elects to develop an in-house team, they should ensure that the rescue team can perform any and all types of rescues they may be summoned to. If a pre-engineered rescue system or a technical rescue capability is determined to be the most appropriate route, ensure that the rescuers receive thorough, high quality training on the types of systems they will need to employ.

If you would like more information or need assistance in preparing your Fallen Worker Rescue Preplans, please call Roco at 800-647-7626.

Randy Miller, Roco’s Chief Instructor and Trench/Structural Collapse guru knew at an early age rescue was his calling. It all began when he joined the Hagerman volunteer fire department in his late teens, and went on to study at Florida State Fire College in Ocala and the University of Florida in Gainesville. Since then, Miller has served as a firefighter, fire chief, paramedic, police officer and rescue team manager to name a few.

Miller is the real thing. He has been boots on the ground in this century’s most morbid natural disasters including; September 11, Hurricane Katrina and the Haiti earthquake. He lives in Long Island, New York with his wife and 3 young sons. Besides being a Chief Instructor for Roco, he is a detective with the NYPD’s Emergency Service Unit (ESU), a Rescue Team Manager for New York Task Force One (National Urban Search and Rescue Team), and is still volunteering at the Hagerman (Long Island) Fire Department.

During an  interview with Miller he laughed as he described himself as a typical Type A personality…always wanting more, and never busy enough. We believe!

How do you rescue a man stuck in grain to just above his waist?  Very carefully — and slowly — said Corpus Christi, Texas, firefighters who built a special wooden box that enclosed the trapped man. They were then able to lower the grain level around the worker enough to pull him to safety, hours after he became stuck in a grain elevator. Thirty firefighters, rotating in teams, spent about five hours in the delicate rescue effort at the Corpus Christi Grain Co., said Assistant Fire Chief Randy Paige.

CNN reported this dramatic grain rescue by the Corpus Christi Fire Department back in April. OSHA has just announced significant penalties and multiple violations for theTexas grain company. Here’s more…

How do you rescue a man stuck in grain to just above his waist?  Very carefully — and slowly — said Corpus Christi, Texas, firefighters who built a special wooden box that enclosed the trapped man. They were then able to lower the grain level around the worker enough to pull him to safety, hours after he became stuck in a grain elevator. Thirty firefighters, rotating in teams, spent about five hours in the delicate rescue effort at the Corpus Christi Grain Co., said Assistant Fire Chief Randy Paige.

The 50-year-old unidentified man was alone inside the grain elevator when he became stuck, said Paige, who did not know what the employee was doing inside or what variety of grain was in the structure. The man was discovered more than an hour later by co-workers, and the rescue began, with a successful conclusion around 8:30 p.m. The man was taken Wednesday night to a local hospital for observation and was in stable condition, Paige told CNN. The man did not complain of injuries.

Firefighters who arrived on the scene opened a hatch on the side of the round elevator, which is about 100 feet in diameter and about 75 feet tall, officials said. They could see the employee who was a few feet above ground level in the tank. He also was standing above valves that release grain to an area below ground, Paige said. As they got to work, they also saw that the grain rose in a “V” shape along the tank’s walls to about 50 feet above the worker, who was in the middle of the elevator, Paige said.

“This stuff is real fine and granular and he was unable to move,” the chief said. Crews used plywood to build wood shoring that was about the shape of a small closet. They put it in position around the employee. When they opened the valve, the grain dropped and they were able to pluck the employee to safety. “We had to be very careful and slow at this,” said Paige. “We were worried about an avalanche effect.”

The fire official was proud of his team, which had three members inside the tank at all times. They had to deal with warm temperatures and were able to get fluids, by water and intravenously, to the trapped man. “Luckily, the dust was not too bad.” It all came down to training and resourcefulness, Paige said.

What were the other options? Plan B called for using a hoisting device at the top of the elevator, but crews were worried about the stress on the employee’s body if they tried to pull him up. Plan C involved a vacuum truck that would have removed the grain.”Luckily, Plan A worked on this one,” said Paige.

OSHA has cited Corpus Christi Grain Co. in Corpus Christi, Texas, for six willful and 20 serious violations with total proposed penalties of $258,900. OSHA‘s Corpus Christi Area Office initiated its inspection at the company’s facility after it was reported that a worker was engulfed while emptying grain from a storage bin. The employee was rescued due to the exceptional efforts of the Corpus Christi Fire Department.

“Employees working in grain storage buildings are exposed to dangerous conditions, and proper safety measures must be taken,” said Michael Rivera, director of OSHA’sCorpus Christi office. “If OSHA’s standards were followed, it is possible this unfortunate incident could have been avoided.”

The willful violations include failing to provide personal protective equipment, such as a body harness and life line, for employees working with stored grain; perform lockout/tagout procedures for the energy sources of equipment, such as augers and conveyors, while workers are inside the grain bins; and have a competent attendant present with rescue equipment when workers enter grain storage bins.

The serious violations include failing to ensure that employees are trained on the hazards associated with grain handling, cover openings with grates in grain bins, ensure that workroom floors are clear of combustible dust, and provide a preventive maintenance schedule for machinery.

(An updated review of more recent data is available at Confined space Fatalities...an updated look at the numbers)

At some point during just about every Roco CSRT Rescue Stand-By job, someone will ask us why we are there. After we tell them that we’re there to make sure all the workers go home safely (and explain some of the basic requirements of OSHA’s 1910.146 regulation), they will normally add, “Well, we’re glad you’re here!”When asked how often we have to do a rescue, we’ll tell them that it’s not often – because our goal is to make sure a rescue never has to happen. With careful pre-planning and proper entry procedures, an entry rescue should not be needed. 

As we all know, however, things go wrong – especially in a confined space. And that’s when a Stand-by Rescue Team can make all the difference in the world – especially to the worker(s) in the hole.

With a facility that plans for confined space entry and routinely follows all safety precautions, employees just might not realize how common these confined space emergencies can be. With that in mind, we decided to do some very basic analyses of statistics from the Department of Labor. In looking at permit-required confined space incidents from 2005 through 2009, we found some of these statistics to be surprising.

Here’s what we found… during the 5-year period (2005-2009), there were a total of 481 fatalities. This averages to about 96.2 fatalities per year (or 1.85 fatalities per week). If you carry this logic forward, it equates to 1 fatality about every 4 days. And keep in mind that this data only covers incidents with at least one fatality or death, so these numbers don’t include all of those incidents that resulted in serious injuries or illnesses. 

These fatalities occurred in 28 states…with just about every age group other than the very young and the very old equally represented. Over 61% (or 298) of these incidents occurred during construction, repairing or cleaning activities. For 203 of the fatalities, the victim worked in the construction industry regularly; however, 17% (or 83) of the victims were in management positions.

Over 61% of confined space entry fatalities occurred during construction, repairing or cleaning activities.

One of the most surprising statistics had to do with the causes of these fatalities. Generally, you would assume that the most common cause of confined space emergencies would be atmospheric hazards. However, during this particular period, that was not the case. The largest cause by a significant measure was “Physical Hazards.” This broad term encompasses a lot of territory including, “struck by”; “caught in”; “collapses”; and “falls.” Physical hazards accounted for 294 or 61% of the fatalities. Atmospheric hazards (including fires) accounted for 160 or 33% of the incidents.

These numbers serve to remind us how important proper safety precautions are when it comes to confined spaces. For emergency responders, atmospheric hazards are always on our minds – however, from this, we also must consider the many physical hazards that are often found in confined spaces – especially when construction or maintenance activities are in process.

Unfortunately, there’s not a reasonably priced “non-destructive” test to determine a particular rope’s strength. Your best bet is to have trained personnel using the rope, keep good rope use logs and inspect the rope after every use. It’s always best to refer to your rope manufacturer for proper care, inspection and replacement, so that’s what we did.

Here’s what Steve Hudson, President of PMI Rope, had to say.
He first referenced the product literature that’s included with PMI rope that states:

RETIRE IMMEDIATELY:
- Any rope whose strength may have been compromised during use.
- Any rope which is subjected to uncontrolled or excessive loading.
- Any rope which is greater than 10 years old, regardless of history and usage.
- Any rope whose history and past usage you are uncertain about.

While these are simple statements, I realize that it is difficult to determine what is “excessive loading” or what is “compromised.” And, if you think it’s hard to look at a rope after an operation and tell if it was compromised or not – think how hard it is for us at the factory to know without being there or having the rope to look at.

Unfortunately, there’s not a reasonably priced “non-destructive” test to determine a particular rope’s strength. Your best bet is to have trained personnel using the rope, keep good rope use logs and inspect the rope after every use. Anytime you have lost faith in what you know about the rope’s condition, for any reason, you should retire it.

A PMI rope, if properly cared for, should last at least 5 years of regular rescue training use and longer than that with intermittent use. By 10 years, it’s simply time to replace it. There are just too many things in the environment that the rope might pick up and are potentially harmful to the yarn.

And, as always, when in doubt, throw it out… CUT RETIRED ROPE into short lengths which will discourage future use – or discard it entirely. A retired rope should not be stored, kept or maintained in such a way that it could inadvertently be used as a lifeline. In some cases, when only a single point or a small area of a rope has been damaged and the remainder of the rope is in good condition, the user may elect to cut that section out of the rope and continue to use the remaining sections. This is a judgment call and such a decision is left to the user’s discretion.

Again, never take chances – if you’re not sure about the integrity of a rope, throw it out!

Quick Reference for Rope Retirement:

•     Extensive Use (e.g. Roco’s training rope) – replace every two (2) years or as needed.
•     Occasional Use (e.g. once a month) – replace every five (5) years or as needed.
•     Regardless of Use – replace every ten (10) years.