It’s December 21^st on a Saturday night, and the plant is running on a skeleton crew. Operations wants to get a head start on annual preventive maintenance and decides to knock out several permit required confined space entries before the majority of the work is to be done after the New Year.

Randy has just finished the third of five vessels that are identical in configuration. He and his authorized attendant and good friend, Hector, have been working together for over 15 years and they both know the drill. They have changed out the stainless-steel bolt sets on the agitator blades of these vessels every year at about this same time. The entry supervisor has just closed out the permit for the third vessel. After reviewing the permit for the fourth vessel and helping with the pre-entry atmospheric monitoring, he signs the permit authorizing entry.

Hector checks Randy’s harness and the attachment of the non-entry rescue retrieval cable to his dorsal D-ring, and double checks the davit arm and the mounting point of the self-retracting lifeline with the built-in retrieval winch. As Randy climbs 25 feet down the rope ladder to access the bottom of the vessel, all is going according to plan. As he steps off the ladder and begins to loosen the first bolt set, he slips on the concave floor of the stainless-steel vessel. Before he can react, he strikes his head on the agitator blade which causes a 5-inch gash to his left temple and knocks him unconscious. He falls between two of the agitator blades and then slides to the bottom of the vessel with his retrieval line wrapped over one of the blades and under another. Hector tries to winch his friend out of the space only to find that Randy’s limp body gets wedged under the agitator blade. You can probably guess what happened next.

Keep additional personnel (even rescuers) out of the space
unless absolutely necessary.

Realizing there is no entry rescue capability on this shift, Hector’s gut reaction is to enter the space to help his friend. In his rush, he slips from the rope ladder and falls 20 feet to his death. When the entry supervisor arrives 30 minutes later to close the permit and initiate the last entry, he sees two bodies at the bottom of the space.

Understand OSHA Rescue Requirements  

Are there permit required confined spaces at your worksite? Are employees allowed to enter these spaces? If you answered yes to these two questions, it is critically important to understand the OSHA requirements for rescue. As part of a written permit space program, the employer must “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.”

When considering what methods should be used for rescuing authorized entrants, the safety of the rescuer(s) should be considered as important as the effectiveness of the rescue technique. If it is possible to perform non-entry rescue of the entrant(s), that should always be the first choice. It’s always a given – keep additional personnel (even rescuers) out of the space unless absolutely necessary. It is important to consider potential scenarios that could arise when determining if non-entry (or retrieval) rescue is sufficient.

Non-Entry Rescue

What are the requirements for non-entry rescue? OSHA states, “To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”

An assessment should carefully consider both capabilities and limitations of the retrieval system for any planned or unplanned condition that may arise during entry.

Let’s examine this further. What conditions would preclude the use of non-entry retrieval systems? Here are some guidelines that OSHA will use to make this determination:

• A permit space with obstructions or turns that prevent pull on the retrieval line from being transmitted to the entrant does not require the use of a retrieval system.
• A permit space from which an employee being rescued with the retrieval system would be injured because of forceful contact with projections in the space does not require the use of a retrieval system.
• A permit space that was entered by an entrant using an air supplied respirator does not require the use of a retrieval system if the retrieval line could not be controlled so as to prevent entanglement hazards with the air line.

Assess The Space

The ONLY way to determine if a non-entry retrieval system will provide adequate safety for entrants and satisfy OSHA’s requirement is to perform an honest and thorough assessment. This assessment should provide careful consideration for the capabilities and limitations of the retrieval system for any planned or unplanned condition that may arise during entry. We have all heard of “Murphy’s Law” and most of us have experienced the effects of that particular law. I encourage you to remember that Murphy is always lurking close by.

So, when evaluating these spaces to determine if non-entry or entry rescue is the appropriate choice, always ask yourself “what if?” For the fictitious accident that opened this article, the plan was to do all the work on the near side of the agitator blade directly below the top portal. In that case, it would have been safe to assume non-entry retrieval was the only plan needed for rescue. Enter Murphy… Was the rescue plan developed with the assumption that the planned work activities would always ensure the successful use of the retrieval system, but failed to consider the “what ifs”? Some might say that we can “what if” things to death. Let’s turn that around; we SHOULD “what if” these questions in an effort to PREVENT death.

If there is any reasonable potential for an unplanned change
in the conditions, then an entry rescue capability
must be in place as a backup.

When evaluating permit spaces to determine the appropriate rescue capability, please explore those “what ifs.” This is not to say that in the case cited above that the only option would have been entry rescue. That may not be necessary and if the non-entry retrieval system would have worked, then there is no need to expose rescuers to the hazards of entering the permit space. But there was a potential for the condition to change, and it sure did. So, recognizing that potential, an entry rescue capability should have been planned in the event that the change in conditions rendered the non-entry rescue system ineffective.

Backup Plan

The point of this article is to consider non-entry rescue as the default for assisted permit space rescue unless the conditions cited by OSHA are present. At that point, entry rescue must be planned. But this isn’t necessarily a one or the other choice. As we can see from this story, it is sometimes best to plan for non-entry rescue as the primary technique, but if there is any reasonable potential for an unplanned change in conditions, then an entry rescue capability must be in place as a backup.

This article was originally featured on the cover of the March 2014 issue of ISHN, and authored by retired Roco Chief Instructor Pat Furr.

Additional Resources

• Non-Entry Confined Space Rescue…Are You Sure?
• Confined Space Types - Are All Your Bases Covered?
• Confined Space Rescue Types Chart & Compliance Guide (pictured here)
  
  

Rescue Challenge 2022 finally returned after a two-year hiatus due to pandemic restrictions. The Roco Rescue Challenge has been an ongoing event since 1989. From inception, Rescue Challenge was meant to be far more than just a rescue “competition” that is all about trophies and bragging rights. It’s more about learning and sharing ideas. Rescue Challenge respects the risks—and yes, challenges—that are posed by the confined space environment. This year’s event had a great mix of industrial and municipal teams; and for many of the teams, it was their first Rescue Challenge.

This year teams were tasked with six confined space and high angle rescue scenarios found in industrial and urban settings. Teams also faced off head-to-head in the Team Performance Evaluation (TPE). Finally, team members showed off their skills in the Individual Performance Evaluation (IPE). All Challenge scenarios are designed to have teaching goals that require different rescue and rigging skills. They included simulated IDLH rescue entries with the use of SAR and SCBA equipment. Also included were single-person and multi-casualty scenarios with a mix of manikins and live victims as patients.

Challenge 2022 Participants:

Baton Rouge Fire Department Team 1 – Baton Rouge, LA


Baton Rouge Fire Department Team 2 – Baton Rouge, LA


Bossier City Fire Department – Bossier City, LA


CF Industries – Donaldsonville, LA


CHS McPherson Refinery – McPherson, KS

Exxon BRPO – Baton Rouge, LA

Some of the exceptional performances this year included:
CF Industries: “Top Team” Overall Highest Average for All Scenarios.
Baton Rouge Fire Department Team 1: 1^st Place Individual Performance Evaluation Station.
Bossier City Fire Department: 1^st Place Team Performance Evaluation Station.

To see more highlights from this years event click here.

If you missed this year’s Rescue Challenge, join us next year on October 18-19, 2023, at the Roco Training Center in Baton Rouge. Every year our instructors devise new surprise obstacles to challenge teams with hurdles they’ve never tackled before.

Is your team “Rescue Challenge ready?”

QUESTION: 

ROCO ANSWER: 

Yes! We’ve been using the Mini-Tripod for many years in our tactical training, and it’s been in the Pararescue inventory since 2009 thanks to the Guardian Angel Technical Recovery Program. Every PJ team in the world has these tripods, and we were wondering whether there were any useful applications in industry. In response to this question, we commonly hear, “Why would I use that tiny tripod that requires special techniques to get a litter patient out of a hole if I can just bring the full-size version?” Valid point…until you work in a tray column.

Roco Rescue’s Devin Payne evaluates the Skedco/Roco Mini-Tripod inside a tray column. This training prop has engineered anchors and a top portal, but many tray columns have neither.

Configurations vary, and some of these spaces do have interior high points or topside openings. However, many do not. Maneuvering a patient up through the trays and out a side portal, can be a significant challenge without a high-point anchor. In fact, we practiced this exact scenario last month during a 4-day in-house workshop. We had nine of our experienced personnel from our Training, CSRT, and Tactical divisions perform multiple iterations of the scenario, with and without high points. Afterwards, we introduced the Mini-Tripod to the equipment cache – and, boy, was it a hit!

The Mini-Tripod is small enough to fit inside the tray column on the top tray. No other rescue tripod on the market has this capability. Our CSRT Director immediately reserved the tactical program’s tripod and assigned it to a tray column job starting the following week! The Mini-Tripod weighs 35 pounds and the height is 54”. (This is the measurement to the bottom of the head when fully extended where you clip a carabiner, not the top.) These handy little tools will soon become standard on these jobs.

Additional Resources

• Artificial High Points (tripod) article

• What size rope do I need?

• Can my rope haul 1,000 pounds?

Companies with active safety and health programs that train workers to identify hazardous conditions and use required protective measures can prevent serious and fatal injuries.

In Centre County, PA, three family members died in a grain silo incident. A father, age 47, and his sons ages 14 and 19 all died after becoming trapped inside a silo. The family members reportedly died from asphyxiation due to gasses in the silo. Neighbors said it was a ripple effect with one going in to help the next when they all eventually succumbed to the hazardous atmosphere inside the space.

Tankers Can Be Death Traps

A 48-year-old worker entered a tanker-tailer in Lemont, IL, to inspect it as part of an annual U.S. Department of Transportation requirement and was overcome by exposure to bleach and chlorine gas. The worker was found unconscious in the tanker-trailer; however, he later died of his injuries.

An OSHA investigation determined that the worker’s employer had failed to:

1. identify and evaluate atmospheric hazards in the confined space,
2. train workers on the confined space program, and
3. ensure employees filled out a confined space permit before entry into a confined space.

OSHA also found that the employer failed to equip the worker rescuing the unconscious employee with a retrieval system, implement its own procedures for summoning rescue and emergency services and numerous other violations of its permit-required confined space regulations.

The company was also cited for failing to provide fall protection to an employee working on top of tanker trailers and providing training on fall hazards, respirators, and hazard communication.

The Chicago regional office established a Regional Emphasis Program in 2021 due to the dangers involved in inspecting tanker-trailers. The program is designed to reduce the risks tank cleaning workers face.

“In recent years, OSHA has investigated instances in which workers suffered tragic injuries because employers failed to follow appropriate procedures for ensuring healthy atmospheric conditions inside a confined space and use of adequate respiratory protection before allowing workers to enter tanks,” explained the OSHA Area Director.

Additional Resources

• Attendant Safety Requirements Poster (pictured here)
• Confined Space Entry Checklist
• Common Causes of Confined Space Fatalities

We’re often asked by plant managers or rescue team supervisors about how they can make sure their rescue team is ready and in compliance should a confined space emergency occur at their site. Our answer usually revolves around practice, practice, practice; but here are a few other recommendations that you may want to consider.

Consistency

First of all, make sure you and your team are speaking the same language when it comes to rescue techniques and equipment. Consistency is key in having an organized response to a confined space emergency. We always recommend that customers evaluate and choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) can result in confusion for team members as to what techniques and equipment are supposed to be used – especially during a rescue!

Compliance

If you have permit spaces at your site, then we assume OSHA compliance is a priority. OSHA’s Permit-Required Confined Space standard (1910.146) is a performance standard and is based on operational capabilities – as is OSHA’s Confined Spaces in Construction (1926 Subpart AA). While minimum practice requirements are once annually for each team member in the applicable representative spaces, the standard goes far beyond this in terms of proving that your team can function in a safe, timely and effective manner. Have you documented your annual rescue practice requirements in the relevant confined space types? Have you conducted an evaluation of your team’s performance in realistic confined space scenarios? Has your team prepared recommended preplans for the permit spaces on site?

Make sure you and your team are speaking the same language when it comes to rescue techniques and equipment.

There are other national consensus standards to take into consideration as well. This includes the National Fire Protection Association (NFPA) rescue skills requirements of NFPA 1006. This standard provides an excellent means of documenting individual proficiency of your team members. If there is an incident and OSHA were to investigate, would you be able to document the individual skills proficiency of your team members? Remember, if it’s not documented – with OSHA, it doesn’t exist!

Credentials

Team members should be trained to an appropriate level based on the potential scenarios they may be called to respond. Do your personnel routinely work at height? Is there a potential for IDLH atmospheres? Know the hazards that your team may face and make sure they are adequately prepared. For overall team proficiency, it’s important to determine what credentials or level of skills you expect of your individual rescue personnel.

Ideally, all team members would be certified minimally to the Confined Space Rescue Technician level (NFPA 1006) along with the third-party certification to back it up. Of course, all should be CPR certified at a minimum. Additional medical training may be required depending on what level of patient care you intend to provide. And, with these certifications, come recertifications and continuing education, which must be completed as appropriate.

“Can you document your team’s competency and prove that your team members are capable of functioning in a safe, timely and effective manner?”

It's also important to check your team’s training records and make sure everyone is “up to par” with their training currency and skill level. Do you have a particular goal or level that you want your team to strive for, achieve, and maintain? Determining an overall goal for your team is significant in planning for and achieving long-term results. If you’re counting on your team to be ready and prepared, we strongly suggest that all team members be trained to the same proficiency level.

Capabilities

Here’s where the rubber meets the road – how capable is your team of performing a confined space rescue? In the worst of circumstances, can your team safely rescue a patient in a confined space filled with obstacles and unforeseen hazards? Do they possess the technical skills and equipment to perform a rescue safely and timely?

One of the best ways to determine the capability of your team is via simulated, realistic rescue practice drills in the representative confined spaces they may be called to respond. Adding a time limit – without compromising safety – can increase the perceived pressure and further simulate a real rescue. It’s an excellent way to see how your team would respond in an actual emergency situation and correct any deficiencies discovered.

Roco offers two great methods for evaluating rescue team competency. One is a Roco Team Performance Evaluation and the other is our annual Rescue Challenge event. Both offer realistic scenarios conducted under the guidance of experienced instructors along with a critique or debrief of each evolution. Each scenario is graded for various rescue and medical components. With each, comes a Team Performance Report to provide documentation of rescue capabilities.

Certification

If you plan to take your rescue personnel to the level of Rescue Technician, Roco has several options. The quickest way of reaching this certification to NPFA 1006 is by attending our Fast-Track™ Confined Space Rescue Technician course, which is a 70-hour program. This course meets the needs of municipal and industrial emergency responders with a mix of confined space and rope rescue. The class is geared for confined space rescue with additional rope technician skills needed for elevated or high angle rescue. The certification process includes a written exam and performance skills testing and is valid for a period of two years.

“Establish training goals for the team as well as individual team members, so that every training session stays on track and is productive.”

An alternative path to certification includes attending Roco’s Urban/Industrial Rescue Essentials™ 50-hour course and then completing the certification process in a Confined Space Rescue Technician 40-hour program. In either method, your personnel will receive consistent training and be certified to the same level of competency.

Training Cycle for Compliance

Once all team members have reached the appropriate training level, skills maintenance and ongoing proficiency become the norm for continuing compliance. Again, OSHA 1910.146 is a performance and capabilities-based standard that includes minimum annual rescue practice requirements for each team member.

Because our certification is valid for two years, we recommend a rotating cycle. Once Rescue Technician certification is achieved, the following year would include a Roco Team Performance Evaluation – or the attendance of Roco’s Rescue Challenge event. Both events provide graded rescue scenarios, which are debriefed by evaluators to correct any deficiencies found. Each of these options includes a Team Performance Evaluation report, which provides excellent documentation for compliance. The alternative year would include attendance of a Roco Recertification program.

This cycle of training works well in documenting that you have met the minimum requirements of OSHA while also meeting the skills requirements of NFPA. The supporting documentation provided offers a realistic “snapshot” of where your team stands in terms of competency and proficiency. This information can then be used as a tool to design internal drills that correct any discrepancies while getting the most from your all too limited practice time.

Conclusion

Rescue skills are extremely perishable, and if not used or practiced routinely, they can be quickly lost. For an effective rescue, team members must be confident in their skills, their equipment and their other team members. This requires regular practice that is realistic and practical. Make sure your rescue team is ready for an actual emergency – as you know, lives are on the line.

Additional Resources

• Confined Space Types – Are All Your Bases Covered?
• Confined Space Rescue Types Chart & Compliance Guide (pictured here)