Does OSHA 1910.146 (k)(1)(v) state that a plan must be developed by a rescue service before an entry for work can be made?

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 (or preplans). The standard requires that rescuers be given access as necessary to develop those plans. 

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.” [1910.146 (k)(1)(v)]

OSHA makes it very clear, however, in Appendix F of the standard, 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 link below.]

It is the employer’s responsibility to perform an adequate evaluation of any prospective rescue service.

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The degree and content of the rescue plan should be determined by the rescue service – and the team must be provided access to do so. The viability of the rescue plan should be demonstrated by the rescue team, proving that the rescue service is staffed, equipped, available, and proficient in performing timely rescue from an actual space or representative spaces. It is the employer’s responsibility to perform an adequate evaluation of any prospective rescue service.

How specific must a rescue plan be to meet OSHA requirements? We like to say it can be determined by answering this question – How detailed must the rescue plan be to enable the rescue service to perform a safe and timely rescue from the permit-required confined space being entered? 

Normally, less complex spaces and entries require simpler and less detailed rescue plans. However, the more complicated the space and the hazards, the more specific and detailed the plan. Rescue complexity also influences the rescue team’s need to evaluate the space and/or a representative space in advance.

When evaluating the capabilities of a rescue service, Appendix F provides guidelines and references rescue plans for the types of spaces involved. You can also refer to Roco’s Compliance Guide and Types Chart (click here to download) which illustrates various confined space types for rescue practice and planning purposes. It also includes Appendix F for evaluating a rescue service or team.

When evaluating the capabilities of a rescue service, Appendix F provides guidelines and references rescue plans for the types of spaces involved.

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Employers with permit spaces must afford the selected rescue service access to the spaces 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.

ADDITIONAL REFERENCE: NFPA 350 Confined Space standard also references “rescue plans” or “pre-incident emergency action plans” for each type of space which may be entered. This is listed in the criteria for evaluating a potential rescue service.

ONLINE REFERENCES:
OSHA 1910.146 Appendix F.

Additional Resources

• Rescue PrePlans
• Roco’s Compliance Guide and Types Chart 
• Evaluating Your Rescue Service

ANSWER: As a Paramedic, I strongly feel that having your rescue personnel trained to the EMR (Emergency Medical Responder) level is extremely beneficial for any industrial site. While EMR training is not required, it can truly make the difference in a life-or-death situation. From my personal experience, we found time and time again how this extra medical care made all the difference when responding to an incident.

Not only is the skill-level of first responders critical in an industrial emergency – many times the industrial site is fairly isolated. This can increase response times when rapid, critical care is so vital. Plant access and finding the exact location may also present potential delays to medical care. With EMRs initially on scene with your rescue team, you can know that your personnel are receiving a higher level of care when it matters most.   

To clarify, an Emergency Medical Responder (EMR) is a well-versed medical responder who can attend to basic needs in a critical need situation. EMR’s are nationally certified or state-licensed medical responders generally tasked with providing immediate emergency care to the sick and injured before an ambulance or higher level of care arrives.

While basic first aid and CPR may be the minimum required for rescue personnel OSHA 1910.146(k)(2)(iii), an EMR is trained to provide more enhanced care – particularly, inside a confined space or for a worker who is stranded at height. Plus, they can be there almost immediately with your rescue team to provide aid. The EMR can help with airway protection, bleeding control, mechanical ventilation, symptom recognition and support of vital functions until more advanced care is reached.

So, minimally, someone on your team needs to be certified in first aid and CPR training. And, while the techniques taught in most nationally recognized First Aid and CPR courses are great for lay folk responding in environments tamer than the industrial setting – the skills, clinical knowledge, and logistic awareness taught in the typical EMR class are a far better fit for confined space rescuers. If you’re looking to give your organization the greatest peace of mind and the best chance to avoid tragedy, we highly recommend EMR training.

Key Medical Questions for ERT Coordinators include:

• Based on hazards identified at your facility, what types and degrees of injuries could patients sustain while at your facility?
• What is the estimated response time for EMS/Fire Department? Is the service familiar with your facility and the potential hazards? Chemical, Mechanical, etc.
• How will EMS access your site, or will the patient be taken to a staging area?
• If air medical transport is necessary, has the facility coordinated a landing zone with EMS/Fire/Sheriff's office?
• Who at the facility will assess the patient and give the information about the patient's condition to EMS?
• Where is the nearest emergency room? Is the ER familiar with your facility and the potential hazards? Chemical, Mechanical, etc.
• What types of drills can your facility conduct, with or without EMS/Fire, to better prepare facility personnel for an emergency?

Prior to coming to work for Roco Rescue, Chris Warrick worked the street as a paramedic for three years, and then three years as a paramedic instructor. He was the section leader for “Cardiology” as well as “Anatomy and Physiology,” and “EMS Operations” at various times. Chris holds an AAS in Paramedicine from South Louisiana Community College and is also certified to teach BLS and ACLS through the American Heart Association. He is also a licensed EMS educator in Louisiana. As a Paramedic, Chris has responded to hurricanes: Harvey, Michael, Laura, Delta, and Ida. As Medical Program Manager for Roco Rescue, Chris oversees medical protocols, procedures, equipment, and education alongside our medical director. 

Follow Chris 

Additional Resources

• What to Look for When Choosing Medical Training for Emergency Response and Rescue Teams

• Emergency Medical Responder Course

• First Aid CPR and AED Training Course

Roco Rescue Challenge 2023 marks three decades of North America’s premier Rescue and Training event. Scheduled for October 18-19 at the Roco Training Center in Baton Rouge, Louisiana, Roco Rescue Challenge is much more than a competition. At its core, it is a learning event where comradery, teamwork, and networking rule the day.

“Hosting Rescue Challenge is always the highlight of our event calendar, but as you can imagine, this year is special to us. We have been truly honored to have the rescue community support this fantastic event for 30 years…and counting,” says Kay Goodwyn, President of Roco Rescue. Ms. Goodwyn added, “We are also trying to make Rescue Challenge more enticing and affordable to municipal fire departments – we had several fire departments last year, and it was a great addition to the event!” 

In addition to learning and competition, Rescue Challenge meets the OSHA 1910.146 requirement for annual training and covers all six (6) types of confined spaces identified in the standard. However, Rescue Challenge does far more than meet those training requirements. Teams will be thoroughly challenged by the six scored scenarios — including IDLH confined space rescues on air and multi-casualty scenarios which feature live victims with moulage for that extra touch of realism and pressure.

Roco Rescue Challenge was conceived for all rescue teams, regardless of experience level. Every year first-time rescuers work alongside experienced rescue technicians who have regularly attended Rescue Challenge’s 30-year run. While there is a strong competitive element, the event focuses on building and improving skills and fostering a sense of community and camaraderie among rescuers. 

Rescue Challenge’s biggest success and value as a learning event is the immediate feedback the teams receive. Roco’s experienced training cadre provides debriefing following each scenario. Every team receives a detailed report describing their performance at Rescue Challenge and how they can improve. Teams often find that this report provides an excellent roadmap to focus their post-Rescue Challenge training regimen.

On the competitive side, there are three awards for which teams compete. Individual Performance Evaluation is awarded to the team with the highest score on a particular rescue skill or set of skills. What is that skill set? You will find out when you arrive at that station. There is a reason it's called Challenge.

The second award — Team Performance Evaluation — is highly coveted by attending teams. The hardware is presented to the team that travels the farthest with no safety violations on the vaunted Yellow Brick Road scenario. 

Finally, the Top Team award recognizes the team with the highest average score across all scenarios.

When the weather in South Louisiana turns to nice cool days, join us at the world-class Roco Training Center in Baton Rouge, Louisiana, on October 18-19, 2023, to help celebrate the 30^th Anniversary of Roco Rescue Challenge. Space is limited, so enroll early to assure your team’s spot. We welcome all teams, regardless of experience level. Take part in this truly unique event: part learning, competition, and all CHALLENGE.

For more information about Roco Rescue Challenge, click here. To save your spot and register, click here. Fire departments looking to challenge their rescue teams should call the Roco office (800-647-7626) for more details and savings on registration.

Additional Resources

• Rescue Challenge Spotlight - Valero Wilmington
• Team Performance Evaluation (TPE™) – How Prepared are You?
• Team Benefits from Rescue Challenge!
  
  

We were so excited to see all the applicants for our Fire Department Scholarship Program – we decided to pick 10 instead of 1! The following individuals were selected to attend a Roco Urban/Industrial Rescue Essentials™ Course at no charge at the Roco Training Center in Baton Rouge. 

Roco Rescue hopes that this free training will help broaden the range of skills in confined space and rope rescue for firefighters and their departments.

Click button below if you are interested in applying for the next Fire Department Scholarship Program selection.

Offer valid for USA-based emergency responders only based on space availability. Must be 18 years or older and physically fit to participate in hands-on rescue exercises. Offer is valid for limited time and subject to change without notice. 

In the process of making paper, everything is big. From the logs that are cut from the dense forests of the south to the giant equipment used to push through huge piles of wood chips, the sheer size of the operation poses unique challenges for the crews working in this industry. For one southern rescue team in late 2022, those challenges would test both their training and their resolve.

December weather can be tricky in the south. Warm days followed by chilly nights can make conditions on the chip pile unpredictable. When the chip pile is 50 feet tall and hundreds of feet long, small changes in the moisture level and temperature of the wood chunks can have drastic results. On this night, the operator of a D9 Dozer was working the top of the pile moving chips towards the conveyor belt that pulls the chip into the feeder from the bottom of the pile. Changing conditions above the conveyor belt often result in small void spaces or bridges that are safely pushed back down by the weight of the dozer. The workhorse of moving dirt, the D9 is a spectacular piece of equipment. Thirteen feet tall, 27 feet long, and 54 tons of pure power, the D9 easily moves over the pile to keep chips moving into the plant.

Just before 8:00 PM, the dozer operator called the plant on his cell phone. While backing along the pile, the weight of the dozer collapsed a bridge under the pile. Not the common small bridge that wouldn’t even be noticed by the operator, this one was big, beyond the comprehension of even the longest-term employees. The bridge didn’t just collapse, it consumed the dozer. 

When rescuers arrived, only the blade of the dozer was visible, and it was facing straight up toward the now-black night sky. The huge earth mover had fallen backward into the collapsing hole, the force of the impact shattering the rear window, slamming chips into the cab behind the operator. With a rapidly dying cell phone battery, the operator stated that he was trapped in complete darkness below more than 20 feet of wood chips.

The rescue operation was led by a long-time member of the rescue team. Even when supervisors and safety managers arrived, the operation continued to be directed and led by that team member. The managers and safety department personnel seamlessly slipped into the roles of logistical support and safety officer. As more rescue team members arrived, the dig teams began the excavation.

Over the next 3-1/2 hours, a dozen rescuers rotated through 20-30 minute shifts moving wood chips by hand. With a now-dead cell phone, the operator was able to update the team by radio. As the rescue operation moved deeper into the night, it became apparent that the dozer operator was weakening, leading the rescue team to believe that the oxygen in the cab was being consumed at a rate that was faster than the rescue excavation.

As the hole expanded, the team needed rope systems to support their climbs in and out of the hole in the pile. Another dozer was gingerly moved to the top of the pile to create a portable anchor for the rope systems. Rescuers struggled to contain the flowing wood chip that continuously rolled back into the hole. At one point hours into the rescue, a track hoe was brought next to the pile to move the edges away to reduce roll-in material, but the bulk of the work was done by hand.

With the operator weakening, rescuers finally made it to the cab near midnight, 3-1/2 hours into the operation. With the very real possibility of a secondary collapse when the cab door was opened, the rescue team was forced to make the decision whether to open the hole wider or move the rapidly deteriorating patient now. The decision was made to make the move. A SKED stretcher was moved into position and a 3:1 mechanical advantage was built and made ready to haul. The door was opened and rescuers made entry into the cab, quickly transferring the patient to the SKED who was then hauled up the slope of the excavation.

The dozer operator was transferred to EMS who transported him to a local hospital where he was treated for symptoms of heat stroke, dehydration, and mild hypoxia. He was treated and later released with no long-term issues. The safety manager credits the operator’s off-shore helicopter crash survival simulator training with keeping him calm and preserving the air supply in the cab.

Roco Rescue was honored to present this talented and dedicated rescue team with the Roco “Real Rescue” plaque. Their dogged determination and training resulted in a great outcome for a very lucky heavy equipment operator.

Roco Would Like to Recognize Your Outstanding Rope Rescue!

Nominate your rescue team for a free 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.