We had a very interesting inquiry regarding OSHA’s requirements for rescue plans and wanted to share it with you.

Reader’s Question: Does OSHA 1910.146 (k)(1)(v) state that a plan must be developed by a rescue service before an entry can be made? Can entries be conducted with the understanding that a rescue service has the competence to rescue someone without seeing the space prior?

Section (k)(1)(v) of the regulation states that the employer shall…“Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.” [Emphasis added]

First of all, it’s important to note that the term “plan” as used in safety-related regulations and standards such as the Permit-Required Confined Space (PRCS) standard, can have a more general meaning than what rescuers typically think of when they refer to “rescue preplans.” When rescuers refer to “rescue preplans,” what usually comes to mind is a very specific, detailed plan for rescue from a particular space.

Although the regulations do not specifically state that a “plan must be developed by a rescue service before an entry can be made,” the regulation assumes that a properly selected (and evaluated) rescue team or service will develop appropriate rescue plans, and requires that rescuers be given access as necessary to develop those plans. OSHA makes it very clear, however, in Non-Mandatory Appendix F, the Preamble to the Final Rule, Summary and Explanation of the Final Rule, and its Compliance Directive on Permit-Required Confined Space, that it interprets the regulation to require rescue plans. [See links below.]

How specific a “rescue plan” must be in order to meet OSHA requirements can be determined by answering this question…“How detailed must the rescue plan be to enable me to safely perform a timely rescue from the permit-required confined space being entered?” Generally speaking, the simpler and more generic the space and the entry, the simpler and less detailed the plan must be. The more complex the space and the hazards, the more specific and detailed the plan must be. And, the more likely the rescue service should see the space and/or a representative space in advance.

As such, the degree and content of the rescue plan should be determined by the rescue service – and it must be provided access to do so. Ultimately, however, it is the employer’s responsibility to perform an adequate evaluation of the prospective rescue service. The viability of the rescue plan should be demonstrated; therefore, proving that the rescue service is staffed, equipped, available, and proficient in performing timely rescue from that particular space (or representative space). The employer must be confident that the rescue service can “Talk the talk, and walk the walk.”

When evaluating the capabilities of a rescue service, Non-Mandatory Appendix F provides guidelines for doing so and specifically references “rescue plans” for the types of spaces involved. It is also important for employers to note that while it is “not mandatory” that the evaluation is performed in exactly the same way; you still have to reach the same result. In other words, it is a non-mandatory means of meeting the mandatory requirements.

Section B (1) of Appendix F asks…
Does the rescue service have a plan for each of the kinds of permit space rescue operations at the facility?

Is the plan adequate for all types of rescue operations that may be needed at the facility?

Note: Teams may practice in representative spaces, or in spaces that are ‘worst-case’ or most restrictive with respect to internal configuration, elevation, and portal size.

Appendix F also offers recommendations for determining whether a space is “truly” representative of an actual space. [See link below.]

You can also refer to Roco’s Confined Space Types Chart (click here to download) which illustrates various confined space types for rescue practice and planning purposes.

In summary, prior to permit required entry operations, the employer must afford the selected rescue service access to the permit spaces they may respond to for the purposes of rescue planning.  The degree and content of the rescue plan should be determined by the rescue service. The rescue service must be prepared and proficient in rescue from the “same type(s) of confined spaces” in terms of configuration, access, and hazards.

IMPORTANT: The information in Roco Rescue Online is provided as a complimentary service for emergency response personnel. It is a general information resource and is not intended as legal advice. Because standards and regulations relating to this topic are typically performance based, and compliance with those standards and regulation is often dependent on the specific circumstances and conditions at hand, it is always important to carefully review all relevant standards and regulations, and to follow the proper protocols specific to your company or agency.

ONLINE REFERENCES:

OSHA 1910.146 Appendix F.

OSHA CPL 02-00-100, 5/5/1995, Application of the Permit-Required Confined Spaces (PRCS) Standards, 29 CFR 1910.146  Appendix D, V. Rescue, D. Combinations: 1. a.

OSHA 1910.146 Permit-Required Confined Spaces, Section: 2, II. Summary and Explanation of the Final Rule

This topic was brought to light by one of our blog participants. Since it may affect many industrial rescue teams in our readership, we are posting the information here to share with the entire community.

In response to a question about manpower requirements for stand-by rescue teams (How many members should be on a standby team?), the Roco Tech Panel has gathered some information which we hope will be helpful. First of all, we will address it from a regulations and standards prospective, and then offer some considerations and practical guidelines that we use here at Roco. 

Of course, your company’s internal policy and safety procedures must always be considered first.

OSHA’s Permit Required Confined Space Regulation (1910.146) is our primary reference for this topic; and, as mentioned, it does not state the specific number of personnel required for stand-by operations. This standard is intended to be “performance based” and a determination of the prospective rescue service’s ability to perform rescue from the types of spaces which they may respond is to be evaluated by the employer. If the evaluated team, regardless of number, can safely and effectively perform rescue from the applicable spaces in a timely manner, then the team would be deemed capable.

However, we must also use a degree of judgment and take into consideration all the particulars of the types of spaces that may be encountered and the types of injuries that the entrants may incur – which will dictate the type of patient packaging that may or may not be required inside the space.  All the factors, such as twists and turns into and out of the space, communications, placement of directionals, and intermediate anchors and haul/lowering systems should all be considered factors in determining the size of the rescue team. As an example, rescuing an entrant from a 24-inch round horizontal portal that is 3-feet off the ground would require a minimum of personnel. But, take this same scenario to 80-feet off the ground, or an on-air IDLH event, and it’s a much different story!

Next, the Respiratory Standard (1910.134), section (g)(3)(i) states that “One employee or, when needed, more than one employee is located outside the IDLH atmosphere;” and Section (g)(3)(iii) adds that…“The employee(s) located outside the IDLH atmosphere are trained and equipped to provide effective emergency rescue” – however, we are given no set number of personnel.

Sometimes we hear the HAZWOPER standard (1910.120) cited regarding IDLH response requirements. This standard requires the use of the “buddy system with stand-by personnel” for emergency response operations involving the release of hazardous substances producing IDLH conditions for employees responding. This regulation specifies a minimum of four personnel, two as a team in the buddy system and two stand-by personnel, to conduct operations in hazardous areas safely. Again, however, this is from the HAZWOPER regulation.

From the National Fire Protection Association, NFPA 1670 (Standard on Operations and Training for Technical Search and Rescue Incidents) states that six (6) rescue technicians shall be the minimum staffing for a “Technician Level” confined space response. This typically means any IDLH condition (breathing air; complexity; elevated or entanglement concerns) that exists in a permit required confined space rescue operation.

Now, we’ll give you an idea of how we address this at Roco with our stand-by rescue services. First of all, our typical (standard) Confined Space Rescue Team is made up of three persons including a Crew Chief and two Rescue Technicians. Keep in mind, that these are experienced, professional emergency responders, who perform stand-by rescue operations and/or train on a regular, if not daily, basis. In addition, the job circumstances and scope of work are carefully evaluated prior to committing a specific number of personnel. As a example, here are some basic guidelines:

Four-person team (minimum) for jobs involving inert entries, other types of IDLH entries, unusual space configurations (i.e., long distances, underground piping or complex obstructions.) As mentioned above, a three-person team made up of experienced rescuers is our standard operational manning requirement. This applies to the majority of our stand-by rescue work. In certain instances, a two-person team may be appropriate. For example, when there is very low potential for atmospheric hazards; large and easily assessable manways; no secondary lowering operations required; strictly horizontal movement, etc.

In closing, we must re-emphasize that OSHA 1910.146 is a performance-based standard that requires safe, timely and capable rescue response for confined space incidents. A realistic, hands-on rescue performance evaluation as referenced in Appendix F of this regulation can be a valuable tool in determining training, equipment and personnel needs based on the circumstances in your response area.

We hope this information has been helpful. Roco Rescue Online and the information herein is provided as a complimentary service for rescuers and emergency response personnel. As always, proper training is required prior to use of any technique described. If we may be of further assistance, please don’t hesitate to contact us at Roco headquarters by calling, 1-800-647-7626.

Our thoughts and prayers go to the people of Japan as well as the many incredible personnel involved in the rescue and recovery efforts. Sharon Bulova, Chairman of the Fairfax County Board of Supervisors, provided this update on VA Task Force 1, who was deployed to Japan a few days ago.

March 16, 2011 - Last night, I participated in a conference call arranged by Fairfax County Fire and Rescue Department with Chief Joe Knerr, co-head of our Urban Search and Rescue Team, VATF-1, in Japan. According to Chief Knerr the nature of the devastation in Ofunato has resulted in no live rescues.

None the less, his team has maintained good spirits, and they are holding out hope that they will find victims. They recognize that with each passing hour, the likelihood of doing so dwindles.

Unlike in Haiti or in other rescue operations, the destruction in Japan has left very few “survivable voids,” which is a space created within a collapsed building that contains enough oxygen and room for people to survive. A Tsunami “wipes everything out, and then takes it out to sea,” Joe said on the call.

VATF-1 is stationed in an elementary school 10 miles from the search area. On Tuesday, with a temperature of 23 degrees and a couple of inches of snow on the ground,VATF-1 searched an area of Ofunato two square kilometers in size, and located eight deceased victims.

Our team and other international rescue teams are under the command of local first responders, in our case the Osaka Fire Department, so many of whom have lost so much. Despite the overwhelming devastation that surrounds them, these brave souls have chosen to lead teams of visitors into the wreckage that was once their homes, their schools and their neighborhoods, and search for signs of life in a sea of destruction.

Our team will remain on the ground until they are told by the Japanese leadership to stop. They are constantly monitoring the radiation levels and using every means available to stay informed of what’s happening. The troubled reactors are to their south, and they are monitoring winds to make sure they avoid any potential problems. They’ve been experiencing some small aftershocks on a regular basis, but Joe joked that the last one was not severe enough to wake his team at 3:15 a.m. local time.

My thoughts and prayers continue to go out to the victims and their families as well as the rescue workers and their families back home waiting for their return.  I also assured the Task Force that the work they are doing makes all of us so proud to call Fairfax County home.

For more information and videos, go to www.fairfaxcounty.gov.

We get many calls asking about the “life expectancy” of rope, harnesses and other nylon products. Of course, there are many factors involved and no one “set in stone” answer, but a lot depends on how much you use your harness and the ways you use it. Even where you store your gear is a factor.

For example, for emergency responders working in industrial environments, atmospheric exposures may be a key consideration for nylon products even while in storage. Another consideration is “when” the harness or rope was made… manufacturing parameters change as technology improves and you may just want a product that’s been tested to the latest standards. However, as with all of your rescue equipment, it’s important to account for its use as well as to follow the manufacturer’s instructions.

Never take chances when there’s any doubt about the serviceability of a life safety product. For more details on the service life of nylon products, our harness manufacturer, CMC Rescue, has provided the following information:

The service life of a rescue harness is closely related to the life of a rescue rope – both are used in the same environments, both are made from nylon or polyester, and both receive similar levels of inspection and care. Since harnesses are worn on the body, they are generally better protected than the ropes. On the other hand, harnesses rely on the stitching to hold them together, and due to its small diameter, the thread can be more susceptible to abrasion, aging, and chemical damage than web or rope.

The fall protection industry recommends 2 to 3 years as a service life for a harness or belt in use. They recommend 7 years for the shelf life. The military was using 7 years as a service life for nylon products. The Climbing Sports Group of the Outdoor Recreation Coalition of America says that a climbing harness should last about two years under normal weekend use. At this time, the rescue industry does not have a recommended service life for harnesses.

Through the ASTM consensus standards process, the rescue industry set 10 years as the maximum service life for a life safety rope, see ASTM Standard F1740-02 Guide for Inspection of Nylon, Polyester, or Nylon/Polyester Blend, or both Kernmantle Rope. The guide stresses that the most significant contributing factor to the service life of a rope is the history of use. A rope that is shock loaded or otherwise damaged should be retired immediately. Hard use would call for a shorter service life than would be acceptable for a rope that sees very little use.

If we apply the same analysis to the rescue harness, then the actual use and the conclusions drawn from inspection would be the significant criteria for retirement. We do know that with any use, a rope will age, and thus a harness is likely to do the same, so a 10-year maximum service life may well be appropriate for harnesses as well assuming inspection has not provided any reason for early retirement.

As with ropes, if the harness has been subjected to shock loads, fall loads, or abuse other than normal use, the harness should be removed from service. If there is any doubt about the serviceability of the harness for any reason, it should be removed from service.

Additional Resources

Quick-Connect Harness Buckle Safety

Service Life Guidelines for Rescue Equipment

Guidelines for Permanent Marking of Rescue Hardware

 

We get many calls asking about the “life expectancy” of rope, harnesses and other nylon products. Of course, there are many factors involved and no one “set in stone” answer, but a lot depends on how much you use your harness and the ways you use it. Even where you store your gear is a factor. 

For example, for emergency responders working in industrial environments, atmospheric exposures may be a key consideration for nylon products even while in storage. Another consideration is “when” the harness or rope was made… manufacturing parameters change as technology improves and you may just want a product that’s been tested to the latest standards. However, as with all of your rescue equipment, it’s important to account for its use as well as to follow the manufacturer’s instructions.

Never take chances when there’s any doubt about the serviceability of a life safety product. For more details on the service life of nylon products, our harness manufacturer, CMC Rescue, has provided the following information:

The service life of a rescue harness is closely related to the life of a rescue rope – both are used in the same environments, both are made from nylon or polyester, and both receive similar levels of inspection and care. Since harnesses are worn on the body, they are generally better protected than the ropes. On the other hand, harnesses rely on the stitching to hold them together, and due to its small diameter, the thread can be more susceptible to abrasion, aging, and chemical damage than web or rope.

The fall protection industry recommends 2 to 3 years as a service life for a harness or belt in use. They recommend 7 years for the shelf life. The military was using 7 years as a service life for nylon products. The Climbing Sports Group of the Outdoor Recreation Coalition of America says that a climbing harness should last about two years under normal weekend use. At this time, the rescue industry does not have a recommended service life for harnesses.

Through the ASTM consensus standards process, the rescue industry set 10 years as the maximum service life for a life safety rope, see ASTM Standard F1740-02 Guide for Inspection of Nylon, Polyester, or Nylon/Polyester Blend, or both Kernmantle Rope. The guide stresses that the most significant contributing factor to the service life of a rope is the history of use. A rope that is shock loaded or otherwise damaged should be retired immediately. Hard use would call for a shorter service life than would be acceptable for a rope that sees very little use.

If we apply the same analysis to the rescue harness, then the actual use and the conclusions drawn from inspection would be the significant criteria for retirement. We do know that with any use, a rope will age, and thus a harness is likely to do the same, so a 10-year maximum service life may well be appropriate for harnesses as well assuming inspection has not provided any reason for early retirement.

As with ropes, if the harness has been subjected to shock loads, fall loads, or abuse other than normal use, the harness should be removed from service. If there is any doubt about the serviceability of the harness for any reason, it should be removed from service.