We recently received a question about  what constitutes a prompt and capable rescue response for fallen workers at height suspended by their Personal Fall Arrest System (PFAS).

Question:  My question concerns guidance on the number of rescue/standby team members needed for response to “worker at heights” type incidents. We work in a chemical plant, so it’s basically areas such as columns, etc.

Answer:  OSHA guidance for rescue of fallen workers utilizing personal fall arrest systems (PFAS) is quite vague in that it calls for “prompt rescue.” For more definitive guidance on the subject, ANSI Z359.2 Para E6.1 recommends that contact with the rescue subject (communication or physical contact) should occur as soon as possible after the fall. The recommended goal for rescue subject contact should be less than six minutes. What constitutes “prompt rescue” can vary depending on the circumstances. The type of potential hazards identified in the Fall Hazard Survey report should determine rescue planning.

For example, if the work area exposes the worker to an IDLH condition such as energized equipment, then the Fall Hazard Survey should trigger the “Rescue Plan” to include a near immediate rescue provision because of the potential of worker electrocution leading to a fall and subsequently, a suspended victim. In a situation like this, it is imperative that prompt rescue would provide a means to have the rescue subject in a position that allows CPR in less than 6 minutes — and preferably much faster than that! The only way to respond this quickly is to have a “Stand-by Rescue” posture where the rescue system and personnel are pre-rigged and ready to initiate the rescue immediately.

For other situations, if communications with the rescue subject are established in six minutes or less, and it is determined that the victim is relatively unharmed (alert and oriented, good airway and breathing, and no signs of active bleeding) then the urgency is reduced and a more measured approach to the rescue could be employed. There is still the potential for suspension trauma to develop over a range of several minutes, so a “prompt” but measured rescue would still be necessary.

With this in mind, it is important for an employer with workers at height to complete a Fall Hazard Survey report to determine the most appropriate way to abate any fall hazards. If the use of PFAS is necessary, that triggers the need to complete fallen worker Rescue Preplans. The employer will need to identify the rescue assets and ensure they are available, equipped, and trained to perform safe and prompt rescue for any situation that they may be summoned to at the employer’s facility. For rescuers outside the employer’s workforce, it is important to thoroughly vet the prospective rescuers to make these assurances.

This information was provided by Pat Furr, Roco Chief Instructor and Technical Consultant. He regularly assists Roco customers in identifying opportunities to improve their fall protection programs and can guide safety professionals in the completion of Fall Hazard Survey reports. Roco can also assist in the development of fallen worker Rescue Preplans. For help with selecting the proper equipment or training, call us at 800-647-7626.

Question:  If I close and Lockout/Tagout the main valve on the natural gas line supplying a boiler unit – does this satisfy OSHA’s requirement for eliminating the hazard of a permit required confined space?

Answer:  No, it does not. You are asking a question that we address quite often and it reveals some misconceptions regarding “eliminating” or “isolating” the permit space from hazards. Lockout/Tagout (LOTO) procedures are covered in OSHA’s 1910.147 “Control of Hazardous Energy (Lockout/Tagout).

” Many times this regulation is incorrectly referenced when addressing permit space hazards that are not covered by this regulation.
OSHA’s 1910.147 LOTO regulation applies to the control of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. It does not apply to engulfment hazards (liquid or flowable solids), flammable gasses, or other gasses that may be toxic or oxygen displacing.

It is important to understand this distinction because the use of isolation procedures appropriate for the hazards addressed in 1910.147 may not be effective in eliminating other hazards.  “Isolation,” as defined in the Permit Required Confined Space regulation (1910.146) spells out the various measures required to eliminate hazardous energies as covered in the LOTO regulation as well as the types of hazards that are not addressed in that regulation.  You will note that 1910.146 cites LOTO as a means to isolate all sources of energy (emphasis added), but outlines other methods used to isolate the other hazards such as hazardous materials. These isolation procedures include the process by which a permit space is “removed from service” and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

By closing and placing a LOTO device on a single valve of a natural gas feed line, you may have controlled the hazard but you have not eliminated it. To provide true isolation (elimination), you will have to employ such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; or a double block and bleed system.

Download the LOTO tip sheet from NIOSH.

Here’s an “ON THE ROAD” segment by Roco Chief Instructor and Director of Training, Dennis O’Connell.

I just got back from Beaumont, Texas, where I taught our new 50-hour Industrial Rescue I/II. In this class, we focus on preparing responders for the unique challenges of industrial rescue – whether you’re a member of an industrial team or a municipal firefighter who may respond to plants or manufacturing facilities.

And if you’ve taken ROCO classes in the past couple of years, you know we’re constantly updating our techniques and equipment as we try to find safer and more efficient ways to do rescue.

It’s been a number of years since ROCO has conducted training in Beaumont and it was good to be back. The BEST Complex offers excellent facilities for industrial and municipal emergency response training – both in firefighting and rescue. The multiple confined space props and 6-story training tower make it an ideal place to conduct high angle and confined space rescue classes. These training props give students realistic anchoring and industrial confined space rescue situations that enhance the techniques taught during the class.

Roco’s Industrial Rescue I/II class provides rescue skills and techniques to handle the vast majority of rescues a team would face in a plant or refinery. The class covers both inert rescue procedures as well as on-air IDLH entry rescue. The first three days are dedicated to skills and techniques while the last two include a variety of scenario-based exercises using the skills learned. One of the nice things about the Beaumont facility is the ability to practice rescues from all six types of confined spaces as referenced in OSHA 1910.146 as well as practicing rescue from height which is often overlooked during confined space training.

This particular class consisted of a mix of firefighters and industrial plant and refinery workers – some brand new to the rescue world and others with a lot of experience. Some of the more experienced rescuers took the class as a “back to basics” review and to meet their annual “confined space types practice” for the year. However, even the experienced rescuers in the class found a few new ways to use the equipment and get the job done.

Most of the students were from the local Beaumont-Port Arthur area, but we did have students from other parts of Texas and some as far away as Alaska. I think the Alaskans were ready to head back to the “minus 30 degree” weather north of the Arctic Circle after experiencing a week of temperatures hovering around 100 degrees!

For our readers who may use Petzl GriGri 2’s, we wanted to make you aware of this recall. Please check the serial number of your device to see if it’s in this range. You will also need to contact Petzl as indicated below. As noted, this does not apply to the previous generation GriGri.

NOTICE FROM PETZL
As a measure of precaution Petzl has decided to take the following actions:

Increase the mechanical strength of the handle on all GRIGRI 2’s since serial number 11137. Recall all GRIGRI 2’s with the first five digits of the serial number between 10326 and 11136, and replace with a new revised GRIGRI 2. Petzl will pay for all shipping costs to complete this replacement.

If you have a GRIGRI 2 (D14 2O, D14 2G, D14 2B) with the first five digits of the serial number between 10326 and 11136, stop use immediately and contact Petzl America to initiate an exchange.

Contact Petzl America in one of two ways:

•     By phone: 1 (800) 932-2978 (toll free)
•     By email: grigri2recall@petzl.com

The previous generation GRIGRI is not concerned by this recall.

Roco Rescue, Inc. and the Beaumont Emergency Services Training Complex (BEST Complex) have announced a partnership to deliver more options in rescue training for fire departments and industry.

In addition to open-enrollment rescue training, Roco’s private courses will also be available.

Upcoming Roco events scheduled at BEST include:

Oct 5-6,  2011 – Rescue Challenge
Dec 5-8, 2011 – Rescue IV-Advanced Rescue Scenarios

The partnership marks a return for Roco to the Southeast Texas facility. For many years, BEST (the former Beaumont Fire/Rescue Training Center) provided a great venue for Roco’s rope rescue and confined space training programs. The location is convenient and economical for many clients in the Texas industrial corridor and surrounding states.

Based on the early success of the partnership, both Roco and BEST say they will be adding more dates and courses to the 2012 open-enrollment training schedule. New offerings will include Confined Space, High Angle, Structural Collapse and Trench Rescue. This will provide additional training options for municipal and industrial rescue teams in the area. It’s a win-win-win.

For more information about Roco training at the BEST facility, contact  Aimee Sims at Roco (800-647-7626).