Simply put, No. We get this question all the time. Sure, with proper vetting of the rescue service and mutual agreement, you can list 911 as your rescue plan within your Permit Required Confined Space Entry program. However, there are clear precautions that must be taken and put into place.

In the world of OSHA Standard language, we have a clear answer in this case. OSHA 1910.146, Appendix F spells it out very clearly.

“The employer should meet with the prospective rescue service to facilitate the evaluations required by 1910.146(k)(1)(i) and (k)(1)(ii). At a minimum, if an off-site rescue service is being considered, the employer must contact the service to plan and coordinate the evaluations required by the standard. Merely posting the service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

You cannot get a much clearer answer than that from an OSHA Standard. And, keep in mind, while Appendix F is listed as “non-mandatory,” this does not mean that you do not have to comply with it. Using the method described is the non-mandatory part.

So, no, you cannot simply list 911 as your rescue service. You can however make an agreement with a private or municipal rescue service to provide that service provided you have evaluated the service to determine that they can perform the confined space rescue services needed for your facility.

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If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying you so that the entry operation can be canceled?

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For the employer, this is where an evaluation of the rescue service comes into play. OSHA 1910.146 Appendix F clearly outlines the need for employers to evaluate a prospective rescue service before relying on their services.

Once that occurs, one of the biggest challenges is determining how to make sure the municipal rescue service is available when you need them. Will they be available when you are ready to make entry, and what if the rescue service gets another call? If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying you so that the entry operation can be canceled?

Evaluating Rescue Response Capabilities

According to OSHA, the rescue service must be evaluated for:

• Ability to respond in a timely manner considering the hazards identified.
• Proficiency with rescue-related tasks and equipment.
• Ability to function appropriately while rescuing entrants from types of permit spaces identified.

The rescue service selected must be:

• Capable of reaching the victim(s) in a timely manner appropriate for the hazards identified.
• Equipped and proficient in performing the needed rescue services.
• Willing to provide the service. Employers may not rely on an outside service that is unwilling to provide rescue services.

Appendix F provides a valuable means to ensure that both the rescuers and the employer know the requirements and that proper agreements are in place prior to confined space entry operations. Roco Confined Space Compliance Guide and Types Chart includes Appendix F along with information and checklists for conducting an (A) Initial Evaluation, and (B) Performance Evaluation.

Critical factors include response time and availability. According to OSHA, the response time must be appropriate for the types of known or potential hazards affecting the confined spaces at the employer’s facility – and the rescue service must be available to respond in a timely manner during entry operations.

It is the employer’s responsibility, both morally and legally, to engage with the rescue service that is being considered. If you have identified an off-site team as the contracted rescue service in your confined space program, which includes municipal rescue, it is crucial that you take all the necessary steps to vet the agency as being a good fit to protect your employees. To document the arrangement, a written agreement is highly recommended. Click here to view a Sample Agreement to Provide Rescue Response.

Confined Spaces Require Special Rescue Skills and Equipment

Other than larger municipal departments, it is rare for local emergency responders to have the required confined space rescue resources including specialized training and equipment. Any shortfalls in an effective response must be addressed by the employer or confined space owner. This includes training, equipment, staffing, or other requirements to ensure a response appropriate for the types and hazards of the spaces onsite. Any rescue service would need to be trained and equipped in advance to face the many hazards and obstacles of permit-required confined space rescue.

OSHA states in section (d)(4) of 1910.146 that “the Employer shall provide rescue and emergency equipment needed to comply with paragraph (d)(9) of this section, except to the extent that the equipment is provided by rescue services…” This is where an employer and a public safety agency may enter a cooperative arrangement beyond what is expected of the emergency responder's normal response duties.

Conclusion

With careful planning, thorough communications, and proper training and equipment, relying on a private or municipal rescue response for confined space rescue can work. As an employer, it is your responsibility to make sure the rescue service is adequately prepared, equipped, and willing to provide confined space rescue services.

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Additional OSHA References:

1910.146(d)(9) Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue;

1910.146(k)(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of 1910.146(k)(1)(i). Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

1910.146(k)(2)(i) Provide affected employees with the personal protective equipment (PPE) needed to conduct permit space rescues safely and train affected employees so they are proficient in the use of that PPE, at no cost to those employees;

1910.146(k)(2)(ii) Train affected employees to perform assigned rescue duties. The employer must ensure that such employees successfully complete the training required to establish proficiency as an authorized entrant, as provided by paragraphs (g) and (h) of this section;

1910.146(k)(2)(iii) Train affected employees in basic first-aid and cardiopulmonary resuscitation (CPR). The employer shall ensure that at least one member of the rescue team or service holding a current certification in first aid and CPR is available; and

1910.146(k)(2)(iv) Ensure that affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

Note to paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, 1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

 

Additional Resources

• Confined Space Types Chart (pictured here) 
• Evaluating Your Rescue Service 
• Agreement to Provide Rescue Response
  
• Requirements for Rescue Plans

 

 

The power industry has its unique hazards – especially when it comes to rescue. Whether it’s generation, transmission or distribution, the hazards can be formidable in an emergency. Highly energized equipment, work at height, confined spaces, fall hazards, remote operations and limited workforce – these are just a few of the challenges that face workers (and rescuers) in the power industry.  

Fortunately, developments in modern, lightweight equipment along with specialized rescue techniques have made rescue quicker, safer and more efficient than ever. We have found that applying these technical enhancements to the power industry can make all the difference in a confined space or high angle emergency. Tools and techniques that are easier to learn (and use) will pay off in the long run.

To learn more about the special hazards inherent to the power industry as well as potential rescue solutions – we interviewed several of our Roco Industrial Services Managers and Lead Instructors, who have spent thousands of hours in industrial facilities and power plants across the country.

Why do confined spaces pose particularly hazardous environments in the power industry?

First of all, there’s the volume of confined spaces in a typical power plant; they can be numerous. These spaces include boilers, turbines, vaults, cooling towers, transformers, penstocks and more – many are permit spaces requiring complex technical rope rescue operations. Then, there are ever-present electrical hazards plus all of the many other hazards found in a working plant. There’s no doubt – any rescue service must be on their A-game when performing rescue operations in a power plant. Hazard assessments and detailed preplanning become crucial functions in order to perform safe and effective rescues. Having a rescue service that can mitigate the inherent hazards (atmospheres, electrical, engulfment, entrapment) is key to a successful rescue versus a body recovery.

For rescue training purposes, what are some practical scenarios used to prepare workers and/or emergency responders?

Practice scenarios are developed based on the anticipated rescue applications for the team. The following are a few examples of scenarios we would use in training or practice drills. In certain cases, complex confined space rescues may be included, which require a trained and equipped technical rescue team. Remote operations may also apply in which an employee may be required to self-rescue or rescue a co-worker with limited equipment.

1. Power Generation - Permit Required Confined Space and Rescue from Fall Protection
2. Power Transmission - Tower, Pole Top, Bucket Rescue
3. Power Substation - Transformer Top, Permit Required Confined Space, Suspended Worker
4. Power Distribution - Tower, Pole Top, Bucket, Trench/Excavation, Utility Manholes/Vaults

What about special regulations for the power industry – are there unique regulations and standards for rescue operations?

For rescuers, OSHA 1910.146 Permit-Required Confined Spaces remains the guiding regulation. OSHA 1926 Subpart AA applies if new construction is involved and OSHA 1910.269 covers the operation and maintenance of electric power generation, transmission, and distribution. These regulations require employers to provide rescue services for employees entering permit confined spaces. The rescue service must be capable of performing confined space and high angle rescues in a safe, effective and timely manner. It is highly recommended that any rescue service be evaluated for true performance capabilities. There are numerous other rules and regulations that may apply including Fall Protection, LOTO, Respiratory, Electrical Safety, Trench Rescue, FR/Arc Flash clothing, etc.

What do you consider to be a “worst-case” rescue scenario for the typical power plant?

No doubt, permit-required confined spaces pose a huge challenge for emergency responders in power plants. And many local fire and rescue agencies do not have the training or the equipment to address this type of emergency. Plus, there’s the matter of “timely response” – which is a requirement of OSHA 1910.146 Permit Required Confined Space regulations. Many times, local agencies cannot respond in a timely manner due to power generation plants (or dams) being located in remote areas. Bottom line…if a rescue capability is not located within the plant’s fence line, it will be very difficult to meet OSHA’s timely response criteria requirements for permit space entry rescue.

Why is proper rescue training so important for remote electrical workers?

Working in stressful situations and remote locations is an everyday occurrence for many power company employees, such as linemen. Potential rescue situations that are commonplace in the lineman’s world are transformer top, tower, bucket, pole top, confined space, and trench/excavation rescues. The majority of these rescues warrant an immediate means of rescue due to inherent hazards. Equipment for these particular rescue scenarios must be kept minimal in most cases – equipment that is lightweight and multi-purposed, pre-rigged and ready to go in an instant. Bottom line…power generation personnel, often working remotely, must be prepared and able to self-rescue or rescue their co-worker in an emergency.

What if a worker is stranded at height in a remote area? What about suspension trauma if hanging in their harness?

Suspension trauma is a serious, life-threatening condition that when left unresolved, can be fatal in as little as 5-15 minutes. Having a detailed rescue plan, proper training, equipment and proficiency in performing a rescue are critical if a worker becomes suspended from fall protection. Relying on 9-1-1 is rarely acceptable as response times can be excessive. Also, in remote locations, the nearby agency may not have the training or equipment needed. Having workers that are competent and proficient in rescue is ultimately the safest route when performing tasks at height.

Why not just depend on “911” for rescue?

There are numerous reasons why 9-1-1 might not meet the requirements for confined space and high angle rescue as required by OSHA 1910.146. As mentioned earlier, the rescue service must be able to perform in a safe, effective and timely manner. How far away is the nearest fire/rescue organization? Are they trained and equipped in technical rope rescue to perform complex confined space or high angle rescue operations? Do you have a method for making sure the rescue service is ready and available when you’re doing an entry? Other challenges include remote locations or very large, complex plant sites to navigate. 

What is the most unusual or unique rescue challenge you’ve seen in the power industry?

One rescue standby job included a mile-long Penstock entry at a hydroelectric dam. Another challenge includes working in nuclear plants in which special training is required. Other challenges include the height of Heat Recovery Steam Generators (HRSG), coal dust and plants located in remote locations. 

Are energy or power sources a big concern for Roco’s standby rescue teams – and what is done to alleviate these concerns?

It is probably the biggest concern for Roco standby teams. We have worked around extremely high voltage systems (transformers, turbines, nuclear, etc.) where the electrical potentiality is mind boggling. To help alleviate some of these concerns, Roco is always engrained in the pre-job switching and tagging process that eliminates the electrical hazards which creates the acceptable “clearance.”

With our standby teams, the main goal is preventing an incident from ever occurring – what special precautions or preparations are made to ensure this in power plants?

It’s true, the main goal for Roco standby teams is preventing an incident from ever occurring in the first place. We pride ourselves in always keeping safety a priority for our standby operations – to keep our personnel safe as well as our customers. As part of our efforts, we make sure that our teams always attend the morning tailboard meetings. We physically walk through the “clearance” procedures to ensure that all Roco personnel are aware of potential hazards and how they have been isolated prior to the start of work. This applies to generation, distribution, transmission and substation rescue standbys or when we are conducting training classes. Other key factors include detailed rescue plans in which hazards are assessed and detailed plans for rescue are in place. This is especially important for a power plant. Whether it is hydro, nuclear, coal or steam, many power plants have some very complex permit spaces. The ability to respond quickly, safely and appropriately is largely dictated by the rescue preplan and ensuring that all responsible parties are aware of the site-specific hazards and emergency procedures.

In summary, power plants – as common as they are – present many challenges to emergency responders and would-be rescuers. Preparation and preplanning for anticipated incidents are key to preventing one from ever occurring. But, if the worst should happen, at least there’s a plan and forethought in place, which could be lifesaving. Are your personnel, those responsible for rescue of a co-worker or even self-rescue, prepared to act safely and effectively? Always remember, in these situations, lives are literally on the line.

 

Additional Resources

• Confined Space Rescue: Non-Entry or Entry Rescue?
  

• How Do I Choose a Qualified Rescue Service?

• Suspension Trauma Poster (pictured here)
  
  
• For More Information on Roco Training or Standby Services

 

On Friday, March 10^th at approximately 11:25 AM, the Minnkota Power Rescue Team responded to a “Man Down” call. A scaffolding contractor was in the process of dismantling scaffolding inside a scrubber tower. One of the contractor employees who was working at the top of the scaffolding had a misstep and injured his left knee. The contractor’s serious knee injury prevented him from self-rescuing from the scaffolding.

Minnkota Power’s rescue team was requested to respond. The MPC rescue team is well-trained and well-equipped to respond to both high-angle and confined space emergencies. The team was well-staffed this day with Treavor Hendrickson, Simon Manifold, Trever Himmelspach, Ben Howard, and Dan Imdieke gearing up and arriving on the scene to determine the scope of the emergency. EMTs Laura Fleckenstein and Troy Karlberg also responded to the scene to provide emergency medical care.

Rescue team members made patient contact at the top of the 40-foot scaffold. The patient was assessed and found to have an issue with the left knee, which appeared to be a significant patella dislocation. After the team assessed possible rescue plans, they made the decision to remove the standard Fall Arrest Harness from the patient and assist the patient with donning one of the team member’s Petzl AVAO Class III rescue harness. The Petzl harness would allow rescuers to support the patient in a seated position during removal by using the ventral and sternal D rings.

To support removal from the top of the scaffold, while rescuers provided medical care and changed harnesses, on-scene scaffold contractors installed a header on the top deck of the scaffold to provide high-point anchors for the rescue. Team members rigged a mainline and an anchored Petzl ASAP belay system. Utilizing the knowledge, skills, abilities, and equipment obtained through Roco Rescue training, the MPC Rescue Team loaded the line and seamlessly began the lower.

Rescuers were placed on the scaffold along the path of travel to guide the patient and prevent further injury. The patient was lowered directly onto a stretcher for quick medical evaluation. The MPC EMTs updated the responding ambulance crew who completed a secondary patient assessment and moved the patient into a waiting ambulance.

From the time the call was received to the time of the patient being safely lowered off the scaffold was less than 30 minutes. The current MPC rescue team consists of 14 members covering multiple shifts. This is the first time in the recent years at the plant that a rope extrication has been utilized to support patient egress. “We are very appreciative of the training and skills obtained during our long partnership with Roco Rescue,” said Rescue Team Program Manager Tim Krous.  

Roco Rescue is proud to have played a role in preparing the MPC Rescue Team. We are honored to present Minnkota Power and their talented MPC Rescue Team with the Roco Rescue “Real Rescue” Award.

 

Roco Would Like to Recognize Your Outstanding Rope Rescue!

Nominate your rescue team so we can recognize your professional efforts with a Roco Outstanding Rope Rescue Plaque. All reports that we receive highlighting an actual rescue event will be considered.

Click here to download the Real Rescue Form. You can then email form to info@RocoRescue.com.

 

May 1, 2023 – The U.S. Department of Labor announced that its Occupational Safety and Health Administration (OSHA) has implemented a National Emphasis Program to prevent falls. This targeted program is based on historical data from both Bureau of Labor Statistics (BLS) and OSHA enforcement activities.

According to the most recent data from BLS, 680 deaths were associated with falls from elevation in 2021. This accounts for nearly 13 percent of the 5,190 fatal workplace injuries that occurred in that year.    

According to the Assistant Secretary for OSHA, Doug Parker, “This national emphasis program aligns all of OSHA's fall protection resources to combat one of the most preventable and significant causes of workplace fatalities...”

The scope of this National Emphasis Program (NEP) applies “OSHA-wide” where an OSHA compliance safety and health officer may open an inspection whenever they observe someone working at heights. If a compliance officer determines that an inspection is not necessary after entering a worksite and observing work activities, they will provide outreach on fall protection and leave the site.

Detailed information on this NEP may be found in Directive Number CPL 03-00-025 National Emphasis Program – Falls.

See our article for tips to help create a safer workplace for you and your co-workers.

Links:

https://www.bls.gov/iif/

https://www.osha.gov/sites/default/files/enforcement/directives/CPL_03-00-025.pdf

https://www.osha.gov/news/newsreleases/national/05012023#

 

Additional Resources

• Fall Hazard Survey (pictured here) 
• Hierarchy of Fall Protection Poster 
• Personal Fall Arrest Systems (PFAS)

 

It holds true every year – falls are one of the leading causes of fatalities and injuries in the construction industry. Falls continue to make OSHA’s “Fatal Four” list year after year. What’s more, this trend doesn’t seem to be improving. The Bureau of Labor Statistics shows 371 fatal falls out of 1,034 total fatalities in construction in 2020. This is the primary reason OSHA organizes an annual National Safety Stand-Down to Prevent Falls in Construction. This voluntary event encourages employers and workers to pause and talk about fall hazards and prevention.

As a company that specializes in training and safety services, Roco Rescue knows the importance of preventing falls and preparing for emergencies. We have been teaching technical rescue, including rescue from fall protection, and providing standby rescue teams for more than 40 years. We have seen firsthand the consequences of inadequate and improperly used fall protection.

Here are five tips on how to protect yourself and your co-workers from falls when working at height:

1) Plan ahead.

Before you start any work at height, you should identify the fall hazards and plan on how to eliminate or mitigate them. OSHA offers a free fall protection plan template that you can use if you don’t know where to start. You can use the hierarchy of fall protection when identifying your plan for working at heights. OSHA also provides a free workbook, to help you manage fall protection hazards on your worksite.

You should also have a plan in place to rescue someone suspended in a fall arrest system. Being proactive will not only help you prevent falls, but can also significantly decrease the time that it takes to perform a rescue in the event one is needed. You can access our Fall Hazard Survey template here and our Rescue from Fall Protection Preplan template here.

OSHA provides a free fall protection plan template that can serve as an outstanding baseline for you to develop or improve your current fall protection plan. For jobs entailing unique hazards, complex fall protection systems, or areas where extended emergency response times may occur, a professional on-site rescue team may be the best option. Make sure you have the right equipment, such as ladders, scaffolds, aerial lifts, harnesses, lanyards, anchors, etc., and that they are inspected and maintained regularly. OSHA provides a general harness inspection checklist.

2) Use proper fall protection equipment.

Depending on the type of work and the height involved, you may need to use different kinds of fall protection systems, such as guardrails, safety nets, personal fall arrest systems (PFAS), or positioning devices. Make sure you know how to use them correctly and that they are compatible with each other. Always wear a full-body harness that fits you correctly and is adjusted properly. Connect your harness to a suitable anchor point that can support your anticipated load and prevent you from hitting the ground or any lower level. 

3) Follow safe work practices.

When working at height, you should always follow the rules and procedures established by your employer and relevant OSHA fall protection standards. Don't take shortcuts or improvise with equipment that is not designed for fall protection. Always try to work with others; working alone, especially at heights, can be fatal if something goes wrong. Avoid working in inclement weather conditions, when possible, especially on slippery or unstable surfaces. Don't lean over edges or reach too far. Don't carry too much weight or use untethered tools that can cause you to lose your balance. 

4) Train regularly.

Fall protection training is essential for anyone who works at height. You should receive training on how to recognize and avoid fall hazards, how to properly use fall protection equipment, how to inspect and maintain your equipment, how to rescue yourself or others in case of a fall, and how to report any incidents or near misses. Click here to learn more about the importance of near-miss reporting. You should also refresh your training periodically and whenever there are changes in your work environment or equipment. Consider implementing a “fall emergency drill” to your periodic training. The worst time to see if you have an effective system in place is after someone falls!

5) Be aware and alert.

One of the most important things you can do to prevent falls is to be aware of your surroundings and alert to any potential dangers. Pay attention to where you are walking, standing, or working. Look for signs, warnings, or barriers that indicate fall hazards. Communicate with your co-workers and supervisors about any issues or concerns. Report any unsafe conditions or behaviors to your supervisors and make sure that they get addressed.

By following these tips, you can help create a safer work environment for yourself and your co-workers. Remember, falls are preventable if you take the necessary precautions.

 

Chris McGlynn is the Director of Safety/VPP Coordinator for Roco Rescue. He is a Certified Safety Professional (CSP) through the Board of Certified Safety Professionals as well as a Certified Confined Space and Rope Rescue Technician, and a Nationally Registered Paramedic. As Director of Safety, Chris oversees all corporate safety initiatives, ensuring that employees at Roco have the tools and training that they need to do their work safely and effectively. He is also responsible for managing Roco's Safety Services Division, which provides trained safety professionals for turnarounds and other special projects. Finally, Chris serves as the VPP Coordinator for Roco, continuing Roco’s long-standing commitment to excellence in safety and health. Roco has been an OSHA VPP Star Worksite since 2013.

Follow Chris 

 

Additional Resources

• Fall Hazard Survey (pictured here) 
• Hierarchy of Fall Protection Poster 
• Personal Fall Arrest Systems (PFAS)