The alarming rise in trench-related fatalities has spurred US Department of Labor to announce enhanced nationwide enforcement.

In 2022’s first six months, 22 workers have fallen victim to the deadly hazards present in trenching and excavation work – surpassing 15 in all of 2021 – and prompting the U.S. Department of Labor’s Occupational Safety and Health Administration to launch enhanced enforcement initiatives to protect workers from known industry hazards.

To stress the dangers of disregarding federal workplace safety requirements for trenching and excavation work, OSHA enforcement staff will consider every available tool at the agency’s disposal. These actions will place additional emphasis on how agency officials evaluate penalties for trenching and excavation related incidents, including criminal referrals for federal or state prosecution to hold employers and others accountable when their actions or inactions kill workers or put their lives at risk.

Read the full press release: https://content.govdelivery.com/accounts/USDOL/bulletins/3213baa

Additional Resources

If you’re concerned that your rescue service may not be adequately prepared, give us a call or check out these resources for more information on how to keep you and your personnel safe around trenches.

• Trench Safety & Rescue Article: Read More
• Trench Training: Competent Person | Trench Rescue Technician
• OSHA’s Trenching and Excavation Webpage

Blindfolded personnel would be required to identify a knot by feel and touch only and then tie the knot in a separate piece of rope. The concept would be to have 5 knots pre-tied on rope shorts, and 5 additional rope shorts for personnel to tie. Each member would have to feel the knots that are pre-tied, and then replicate all 5 knots, no asking questions or guidance provided. 

Each participant would be given their own area to work, a classroom setting with table and chair is recommended. Five ropes with pre-tied knots (figure-8 on-a-bight, butterfly, double fisherman, square knot, bowline for example) and 5 different color rope shorts untied, would be covered to prevent students from learning what specific knots were there.

Then, when each person is in position, they would be blindfolded and given a specified time (e.g., 5 minutes) to identify each knot by feel and tie the knot identified using the ropes given. Evaluators would not provide any guidance on identifying the knots. Once time is up, or all participants have completed tying the knots, the blindfolds would be removed and the knots evaluated.

Personal Skills Challenge (Advanced)

Everything was going great, when all of a sudden, in the blink of an eye, the unthinkable happens. You find yourself in a situation where you need emergency services, and you need them FAST! You pick up the phone, dial 9-1-1, and await their arrival. It seems like an eternity, but the reality is, only a few minutes have passed. Emergency services arrive, and just as quick as tragedy struck, they’ve now seemed to make that chaos disappear.

So how does this apply to industrial facilities?

In the industrial world, tragedy can strike just as quickly as in the civilian world – the difference is, however, 9-1-1 may have a much longer response time. This is primarily due to being unfamiliar with the industrial facility. Normally, there are many obstacles to overcome between where they arrive and where the patient is located. There can also be the issue of proximity to the plant site, or what if the emergency response service is out on another call?

What can be done to ensure that the best resources are available immediately when they are needed?

And, while emergency service personnel are trained to handle many different types of emergencies, they likely have very limited training, if any at all, in industrial emergencies. As a paramedic who worked in EMS for over a decade, I can tell you that this was entirely the case during my EMS career. So, what can industrial facilities do to prepare for emergencies — particularly rescue emergencies? And, what can be done to ensure that the best resources are available immediately when they are needed? 

The answer – Standby Rescue Services.

Here’s why standby services can make the most sense. Standby rescue teams are often the only way to ensure that the best resources are readily available in the unfortunate event they are needed. Unlike most emergency services, standby rescue teams are trained specifically to handle emergencies in the industrial setting – especially for scenarios involving confined space rescue, high angle rope rescue, or rescue of a worker suspended from fall protection. For these scenarios, rapid response times are critical in determining the outcome, and possibly the survival of the victim entirely.

Rapid response times are critical in determining the outcome, and possibly the survival of the victim entirely.

In contrast to typical emergency response services, standby rescue services are already on-site; and oftentimes, staged in the area where the work is being performed. Standby rescue services are also likely to be very familiar with the facility to which they are assigned. This can contribute to an incredibly fast response time in the event that an emergency arises.

What about facilities that have their own rescue-trained personnel? There’s no doubt having facility personnel trained in rescue operations is an outstanding way to decrease response times and increase positive outcomes during an emergency. For routine and short-term tasks, relying on cross-trained facility personnel can be an effective solution; however, for large-scale projects and turnarounds with multiple areas of work or more complex technical rescues, a dedicated standby team may be your best bet.

An experienced standby team knows how to properly assess the worksite, prevent possible incidents and react in a calm and efficient manner.

Many times, large facilities with their own emergency response team will still contract professional 3^rd party rescue teams – especially during large projects or turnarounds when their team is already tasked to the max. With large-scale projects, there could be ten-fold the number of contractors and personnel on site in addition to the vast number of entries, on-air entries, work-at-height and other hazardous work.

You can see that having a professional standby rescue team onsite for hazardous work activities can be the difference between life or death. It can mean the quickest response and fastest recovery of an endangered worker. It can also make your project flow more smoothly while providing for added safety. An experienced standby team knows how to properly assess the worksite, prevent possible incidents and react in a calm and efficient manner. It simply makes good sense.

Additional Resources

• Roco CSRT Standby Rescue Services
• Confined Space Rescue Types Chart & Compliance Guide (pictured here)
  
  
  
  

Workers sent back into partially collapsed trench

OSHA proposes $243K in penalties following fatal, serious injuries

After escaping from a partial trench collapse hours earlier, two workers employed by an Austin (TX) contractor to install a residential wastewater line were not as fortunate later that day. Both were told to return to the unprotected 13-foot-deep trench to finish the job, and soon after, the trench collapsed again. This time, the collapse buried one worker causing fatal injuries and partially buried the second, who suffered serious injuries.

Following its investigation, OSHA cited the company for willful violations for:

• Failing to have a trench protective system in place.
• Exposing workers to cave-in hazards.
• Failing to inspect the excavation.
• Exposing workers to the dangers of being struck by material and equipment.

“Despite a partial trench collapse earlier in the day, the contractor recklessly sent employees back into the excavation without protective measures to prevent another cave-in,” said OSHA Area Director Casey Perkins in Austin. “The loss of this worker's life was preventable and the employer must be held responsible for ignoring excavation safety rules.”

Investigators also issued citations for serious violations for failing to train employees working in and around an excavation, exposing workers to struck-by hazards and failing to implement protective measures when water was present in the trench, exposing employees to cave-in hazards. OSHA also cited the company for failing to report the hospitalization of an employee to OSHA within 24 hours, as required. 

“The loss of this worker's life was preventable and the employer must be held responsible for ignoring excavation safety rules,” said OSHA Area Director Casey Perkins in Austin.

From 2011-2018, 166 workers died in trench collapses. In 2019, OSHA reports at least 24 workers died while working on trenching and excavation projects, all of them preventable had the required safety measures been taken.

OSHA has a National Emphasis Program on trenching and excavations. Trenching standards require protective systems on trenches deeper than 5 feet, and soil and other materials kept at least 2 feet from the edge of a trench. Additionally, trenches must be inspected by a knowledgeable person, be free of standing water and atmospheric hazards and have a safe means of entering and exiting before allowing a worker to enter.

The 2022 “Trench Safety Stand-Down” week, June 20-24, is a collaboration with the National Utility Contractors Association and OSHA to educate employers and workers and reduce the number of worker injuries and fatalities related to trench cave-ins.

OSHA's trenching and excavation webpage provides additional information on trenching hazards and solutions

See full article from OSHA. https://www.osha.gov/news/newsreleases/region6/04212022

Additional Resources

• Trench Safety & Rescue Articles: Read More
• Trench Training: Competent Person | Trench Rescue Technician

We’re often asked, “Can I use a crane as part of my rescue plan?” 

If you’re referring to using a crane as part of moving personnel or victims, the answer is “No, except in very rare and unique circumstances.” The justification for using a crane to move personnel, even for the purposes of rescue, is extremely limited. Therefore, it is very important to understand the “do’s and don’ts” for using a heavy piece of equipment in a rescue operation.

On the practical side, the use of a crane as a “stationary, temporary high-point anchor” can be a tremendous asset to rescuers. It may also be part of a rescue plan for a confined space –  a top entry fan plenum, for example. The use of a stationary high-point pulley can allow rescue systems to be operated from the ground. It can also provide the headroom to clear rescuers and packaged patients from the space or an elevated edge.

Because of the dangers involved in moving personnel with heavy equipment, OSHA strictly limits its use.

The security of the system's attachment to the crane and the ability to “lock-out” any potential movement are a critical part of the planning process. If powered industrial equipment is to be used as a high-point, it must be treated like any other energized equipment with regard to safety. Personnel would need to follow proper Lock-out/Tag-out procedures [Control of Hazardous Energy 1910.147]. Any equipment used in the rescue operation would need to be properly locked out – (i.e., keys removed, power switch disabled, etc.). You would also need to check the manufacturer’s limitations for use to ensure you are not going beyond the approved use of the equipment.

Because of the dangers involved in moving personnel with heavy equipment, OSHA strictly limits its use. In order to utilize a crane, properly rated “personnel platforms or baskets” must be used. Personnel platforms that are suspended from the load line and used in construction are covered by 1926.1431. There is no specific provision in the General Industry standards, so the applicable standard is 1910.180(h)(3)(v). This provision specifically prohibits hoisting, lowering, swinging, or traveling while anyone is on the load or hook.

OSHA prohibits the hoisting of personnel by crane or derrick except when no safe alternative is possible. The use of a crane for rescue does not provide an exception to these requirements unless very specific criteria are met.

An OSHA Letter of Interpretation (LOI 1993-02-17) states, “OSHA has determined, however, that when the use ofa conventional means of access to an elevated worksite would be impossible or more hazardous, a violation of 1910.180(h)(3)(v) will be treated as de minimis if the employer has complied with the provisions set forth in 1926.550(g)(3) through (g)(8).”

Note: De minimis violations are violations of standards which have no direct or immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way as any other violation, but are not included on the citation.

Therefore, the hoisting of personnel is not permitted unless conventional means of transporting employees  is not feasible. Or, unless conventional means present even greater hazards (regardless if the operation is for planned work activities or for rescue). Where conventional means would not be considered safe, personnel hoisting operations meeting the terms of this standard would be authorized. OSHA stresses that employee safety, not practicality or convenience, must be the basis for the employer's choice of this method.

However, it is also important to note that OSHA specifically requires rescue capabilities in certain instances, such as when entering permit-required confined spaces [PRCS 1910.146]; or when an employer authorizes personnel to use personal fall arrest systems [PFAS 1910.140(c)(21) and 1926.502(d)(20)]. In other cases, the general duty to protect an employee from workplace hazards would require rescue capabilities. 

Consequently, being “unprepared for rescue” would not be considered a legitimate basis to claim that moving a victim by crane was the only feasible or safe means of rescue.

This is where the employer must complete written rescue plans for permit spaces and for workers-at-height using personal fall arrest systems – or they must ensure that the designated rescue service has done so. When developing rescue plans, it may be determined that there are no other feasible means to provide rescue without increasing the risk to the rescuer(s) and victim(s) other than using a crane to move the human load. These situations would be very rare and would require very thorough documentation. Such documentation may include written descriptions and photos of the area as part of the justification for using a crane in rescue operations.

Bottom line… simply relying on using a crane to move rescuers and victims without completing a rescue plan and very clear justification would not be in compliance with OSHA regulations. It must be demonstrated that the use of a crane was the only feasible means to complete the rescue while not increasing the risk as compared to other means. Even then, there is the potential for an OSHA compliance officer to determine that there were indeed other feasible and safer means.

WARNING: Taking it a step further, if some movement of the crane  is required, extreme caution must be taken! Advanced rigging techniques may be required to prevent movement of the crane from putting undue stress on the rescue system and its components. Rescuers must also evaluate if the movement would unintentionally “take-in” or “add” slack to the rescue system, which could place the patient in harm’s way. The movement of a crane can take place on multiple planes – left-right, boom up-down, boom in-out and cable up-down. If movement of the equipment must take place, rescuers must evaluate how it might affect the operation of the rescue system.

Of course, one of the most important considerations in using any type of mechanical device is its strength and ability (or inability) to “feel the load.” If the load becomes  entangled while movement is underway, serious injury to the victim or an overpowering of system components can happen almost instantly. No matter how much experience a crane operator has, there is no way he can “feel” if the load becomes entangled. And, most likely, he will not be able to stop before injury or damage occurs. Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is completely lost when energized devices are used to do the work.

For rescuers, a crane is just another tool in the toolbox – one that can serve as a temporary, stationary high-point making the rescue operation an easier task. However, using a crane that will require some movement while the rescue load is suspended should be a last resort! There are simply too many potential downfalls in using cranes. This also applies to fire department aerial ladders. Rescuers must consider the manufacturer’s recommendations for use. What does the manufacturer say about hoisting human loads? And, what about the attachment of human loads to different parts of the crane or aerial?

However, there may be cases in which a crane is the only option. For example, if outside municipal responders have not had the opportunity to complete a rescue plan ahead of time, they will have to do a “real-time” size-up once on scene. Due to difficult access, victim condition, and/or available equipment and personnel resources, it may be determined that using a crane to move rescuers and victims is the best course of action. 

Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is completely lost when energized devices are used to do the work.

Using a crane as part of a rescue plan must have rock-solid, written justification as a demonstration that it is the safest and most feasible means to provide rescue capability. Planning before the emergency will go a long way in providing options that may provide fewer risks to all involved.

So, to answer the question, “Can I include the use of a crane as part of my written rescue plan?” 

Well, yes and no. Yes, as a high-point anchor. And, no, the use of any powered load movement will most likely be an OSHA violation without rock-solid justification. The question is, will it be considered a de minimis violation if used during a rescue? Most likely it will depend on the specifics of the incident. However, you can be sure that OSHA will be looking for justification as to why using a crane in motion was considered to be the least hazardous choice.

NOTE: Revised 5/2022. Originally published 10/2014.

Additional Resources

• Rescue PrePlans
• OSHA Lock-out/Tag-out Fact Sheet 
• Evaluating Your Rescue Service