This week, May 2-6, is OSHA’s National Safety Stand-Down to Prevent Falls in Construction. The reason for this emphasis is the continuing injuries and deaths resulting from workplace falls – especially in construction work. Fall protection was the #1 cited standard by Federal OSHA in 2021, and falls continue to make OSHA’s “Fatal Four” list year after year.

The statistics don’t lie. In 2019, there were 1,102 fatal injuries in the construction industry; according to the US Bureau of Labor Statistics, nearly 38 percent of these fatalities were fall-related. In 2020, employers spent over 16.5 billion dollars combined indirect costs as a result of falls according to Liberty Mutual’s Workplace Safety Index for the construction industry.

In doing our part for National Safety Stand-Down to Prevent Falls, we’ve created a list of Top 5 safety tips to consider before starting work.

1) Implement the Hierarchy of Fall Controls

The most effective method to protect workers against falls is to eliminate the hazards! All too often we see employers and workers simply accepting a hazard without fully attempting to eliminate it first. Admittedly, elimination is not always possible or feasible. In this case, we should make every attempt to use passive fall protection — such as physical barriers, guardrails, or hole covers to prevent falls.  Even this may not always be a practical application in the real world. If we are unable to implement these two methods of control, then (and only then) should it be acceptable to move on to personal protective equipment (PPE) and active measures of control.

2) Develop Effective Training

If there are remaining hazards in the workplace, you must provide workers with the knowledge and skills to be aware of the hazard and their potential effects. Workers should be able to identify when they are at risk for falls and take appropriate and effective measures to protect themselves. Be sure to incorporate hands-on skills into your training with knowledge and competency assessments before allowing workers to work at height. There is no replacement for direct, hands-on learning for this type of skill set. Some examples of this may include appropriate set-up of ladders, harness inspection, maintaining 100% tie-off, and lifeline anchor selection.

3) Provide Proper Personal Protective Equipment (PPE)

As mentioned previously, elimination and passive fall protection should always be our primary and secondary goals for reducing fall-related incidents. When we are unable to implement these methods, we must then rely on PPE to protect workers from the remaining hazard. Ensure that your workers ready have access to adequate PPE for the job; remember, PPE is not a “one size fits all” application. Consider providing different styles of PPE so that workers can choose what is most comfortable or convenient for them.  Workers are a lot more likely to use PPE that they like and are comfortable using.  Also, ensure that workers know how to inspect their PPE and how to wear, use, maintain, and store it appropriately. 

4) Select Appropriate Anchor Points

Fall protection equipment is only as good as the anchor point that it’s tied off to. The ideal anchor point will be located directly above the worker. The further away a worker is from the anchor, the greater potential a worker has to swing into objects during a fall. Additionally, anchor points must be able to withstand at least a 5,000 lb. load per worker. On occasion, workers can be found tying off to electrical conduit, small diameter pipes, or other unacceptable anchor points. Ensure that your workers know and understand how to select appropriate anchor points. As a best practice, consider discussing what anchor points will be used for the job prior to starting work.

5) Accurately Calculate Fall Distances

What good is fall protection if you hit the lower level before it engages? Accurately calculating fall distances can be the difference between life and serious injury or death. The formula used for calculating this is as follows:

Required Distance = Lanyard Length + Deceleration Distance + Height of Worker + Safety Factor

Lanyard Length is exactly that, the length of the lanyard being used. Most lanyards are around 6-ft. in length; be sure to reference the manufacturer’s specifications to determine the exact length of the lanyard.

Deceleration Distance refers to the distance from when the worker falls, to when the fall arrest device activates, and to the final stopping point. Most shock-absorbing lanyards deploy to about 3.5-ft. in length when engaged. Remember that any slack between the anchor point and the worker’s dorsal ring must be added to this distance. For instance, if a worker has a 6-ft. lanyard and connects it 3-ft. above their dorsal ring, that will create an additional 3-ft. fall before the system activates. Additionally, a full-body harness will likely stretch an additional foot during a fall – be sure to include these additional distances in your calculations.

Height of Worker is also self-explanatory, the height of the average worker is about 6-ft.

Safety Factor is an additional amount of space added into the calculation to serve as a buffer. The generally accepted safety factor is 3-ft.

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)

READER QUESTION: 
We’re hearing more about 11mm rope for rescue purposes – does this meet NFPA requirements? 

ROCO TECH PANEL ANSWER: 

That is a question we are getting quite often these days. The move from the traditional half-inch rescue rope (12.5mm) to 11mm is rapidly gaining momentum in the urban and industrial rescue world. While it is nothing new to rope access practitioners and back country rescuers, the skinny ropes can seem like a big jump for organizations doing their best to navigate the NFPA world.

At the end of 2017, the National Fire Protection Association released NFPA 1858, The Standard on Selection, Care, and Maintenance of Life Safety Rope and Equipment for Emergency Services. For the first time, NFPA had an equipment guidance document focused on the end user rather than the manufacturer of rescue equipment.

Most recently, this standard along with two other standards (1670 and 1983) have been consolidated into one comprehensive standard, NFPA 2500: Standard for Operations and Training for Technical Search and Rescue Incidents and Life Safety Rope and Equipment for Emergency Services, which became effective September 15, 2021.

A quick look at NFPA 2500 reveals that the end user has significant leeway to determine rope and equipment size and strength. For example, Chapter 30 Selection (NFPA 1858), states in Section 2 Life Safety Rope that: 

“Specific performance criteria or specific features shall be defined based upon the intended application of the rope and equipment being purchased. If the organization has multiple intended applications for life safety rope, the purchase of multiple ropes shall be considered that best fit those applications.” (30.2.1)

Section 2 goes on to state, “Organizations shall specify and select rope with a minimum breaking strength (MBS) to provide an adequate factor of safety, as defined by the AHJ, for the intended application(s) to ensure adequate strength.” (30.2.5) 

The standard then adds, “Rope diameter shall be considered with prioritization to ensure compatibility with the other components used in the system and the ability to grip the rope.” (30.2.6)

NFPA allows the Authority Having Jurisdiction (AHJ) wide latitude to choose 11mm rope and equipment should it meet the needs of your organization. If you need further convincing, the Annex tells us that; Chapters 24 through 28 (of NFPA 2500), which divide life safety rope and equipment into two designations: general use and technical use. NFPA does not establish or endorse a particular safety factor or ratio.

And then goes on to say, “Rescue organizations can elect to use either technical use– or general use–labeled equipment based on the anticipated loads of the incident; training/skill level of responders; and the AHJ’s established acceptable safety factors. What safety factor(s) is deemed appropriate might vary based on the acceptable level of risk, severity of consequences of a potential failure, types of technical rescues, and the corresponding level of operational capability of the organization.” (A.‍30.1.2.1(6))

Most major rope manufacturers now offer 11mm kernmantle rescue ropes that are rated for NFPA general use. Add in compatible hardware like the excellent 11mm CMC Clutch by Harken or the Petzl Maestro Small, and you have multiple choices for skinny rope technical rescue that rivals the strength of any half-inch system with a much easier carry burden.

At the end of the day, whatever size rope and equipment you choose to use, it should;

• meet a given standard (NFPA, ANSI, EN, CE)
• be used within manufacturer’s recommendations
• allow your team to complete the required task safely

This 11mm rope feels lighter, faster and rope companies are making it stronger, but is it right for you? Only you or your AHJ can decide.

We are extremely excited to share that Roco Rescue recently received Entergy's Premier Vendor Award in the Safety category.

This award is sponsored by Entergy to recognize and promote extraordinary vendor performance. In seeking and sharing best practices, the award-winning company must have a profound and direct impact on improving the safety and reliability of the utility industry. And, we were in competition with some very large corporations.

To be eligible for the award, service and material providers who have contracted with Entergy during the award year (2021) must have achieved high levels of performance, implemented transferable new practices, or significantly improved processes in the areas of safety, diverse/local spend, sustainability, customer centricity, and continuous improvement.

Roco provides Entergy with many highly trained and skilled confined space rescue teams across Arkansas, Mississippi, and Louisiana. Additionally, Roco’s Safety Services Division now provides Entergy with highly trained and motivated Certified Occupational Safety Specialists to add another level of depth to safety on large-scale outages and turnarounds. Our Safety Specialists have been involved in overall outage planning, safety consulting and observations throughout the outage, and overall support for anything that Entergy needed during their large projects. This year, Roco had the pleasure of providing oversite for two outages, including one major outage in Mississippi.

Additional Resources

• Confined Space Entry Checklist
• Evaluating Your Rescue Service
• Safety Services

The concept of Lock-Out/Tag-Out is a great one and it works. As rescuers, however, we have to take the common industrial application and expand it to ensure that the rescue scene is safe and that we are controlling hazards at the point of contact with the victim or in a space where something has gone very wrong.

What Does OSHA Say?

Although commonly referred to as the “Lock-out/Tag-out” (LOTO) standard, the actual title of 1910.147 is “The Control of Hazardous Energy.” This title probably better describes its true purpose – and there's no doubt that the understanding of this concept has saved many lives and prevented countless injuries. Prior to work, potential sources of hazardous energy must be identified and controlled. As responders, we do not have the luxury of studying blueprints and schematics to identify how to isolate the hazard. In fact, we’re most often responding to incidents where LOTO turned out to be ineffective or was improperly used.

Standard LOTO is usually defined in a work planning and control process or a job safety analysis. Days, weeks, and even months are spent planning and assessing cause and effect to ensure a safe work environment. During an actual emergency, rescuers have only minutes to assess and determine how to “make the scene safe.” This safety mindset serves to protect both the rescuer(s) and the victim(s) from additional harm following an incident.

NOTE: While LOTO tags are permissible by OSHA, they are not commonly used as you must prove that a tag is at least as effective as a physical lock – something that would be hard to ensure.

 We’ve found that if you ask different people to define LOTO and who is responsible for performing it, you will get a variety of answers. OSHA 29 CFR 1910.147(b) has a very narrow and specific definition of who can perform lock-out or tag-out operations. That definition does not include rescuers; and there is good reason for that. OSHA defines two types of persons in regard to LOTO; “authorized employees” and “affected employees.”

An authorized employee is a person who locks out or tags out machines or equipment in order to perform service or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing service or maintenance covered under this section.

Translation: A person that the employer says has the systems or mechanical knowledge and authority to safely lockout/tagout a machine or space.

An affected employee is an employee whose job requires him or her to operate or use a machine or equipment on which service or maintenance is being performed under lock-out or tag-out, or whose job requires work in an area in which such service or maintenance is being performed.

Translation: A person who has to work in an area where LOTO is in place. (Sounds like a rescuer to me.)

LOTO for rescuers

According to an OSHA clarification letter¹, an affected employee is one who does not perform service or maintenance work on the machine or a piece of equipment and does not implement the LOTO system procedural elements. Rather, the affected employee's job responsibilities include operating the machine or equipment or performing other work in an area where the service or maintenance work is being performed.

There is good reason for these prohibitions on applying Lock-out/Tag-out. Improperly performed LOTO can be just as dangerous, if not more so, than no LOTO at all. Allowing LOTO to be performed by personnel who are not familiar with the processes and equipment increases the chances of improper lock-out. As rescuers, we rarely (if ever) have the kind of institutional knowledge to perform true LOTO of a process or environment.

If the reason for the rescue is something other than an exposure to a hazardous energy source, and LOTO has already been performed, the rescuers should walk through and verify the "authorized employees'" LOTO and ensure no changes are made to the system.

If LOTO was performed improperly or has failed and is causing the emergency, then rescuers can lock-out the equipment as they see fit or as the rescue needs dictate. The control of hazardous energy is part of making the area safe for rescue operations, but doing so without understanding the bigger picture can be dangerous.  Whatever actions are taken should be completed with the coordination of a facility representative who understands where or what you are working with. 

From a rescuer’s viewpoint, our definition and options for effective LOTO needs to include other equipment and techniques that provide a safe area for rescue operations and prevent further harm to the victim. This includes equipment that is used every day in the municipal rescue world that may not typically be found in an industrial facility. This includes equipment such as hydraulic spreaders and high-pressure air bags. Even simple tools, such as metal wedges, can be used to isolate and protect the hand or arm of a victim trapped in a piece of machinery. The key is to review your current capabilities and identify what may be needed prior to an incident occurring.

Machine entrapment rescues are another all too common situation in which responders need to isolate the area at the point of contact with the patient to prevent further movement. RESCUERS BEWARE – Another huge consideration for rescuers is stored energy! Sometimes what sounds like a simple solution (such as turning off a machine) can do more harm IF the machine normally recycles before coming to a resting position. OSHA identifies these hazards and provides a pretty good list of examples to be aware of when responding. It includes stored or residual energy in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc. Rescuers need equipment and techniques to control, restrain, dissipate, and immobilize these hazards.

Municipal and industrial rescuers get called to a wide variety of rescues – each with its own unique problems. As we know, the number of ways people can get themselves in harm’s way is unlimited! In all entrapment incidents, however, it is essential that we protect both the victim and ourselves from further injury and limit our exposure to the hazards that are present. In every incident, rescuers must first identify the hazards and try to eliminate or control them in every way possible.

Sixth most cited standard

Every year, OSHA issues its “Top 10 Most Frequently Cited Standards” list. While the order of the list is different from year to year, it is generally still comprised of the same 10 standards year after year. LOTO, the control of Hazardous Energy (29 CFR 1910.147), consistently makes the list; and, for 2021, it was no different. For 2021, the LOTO standard landed as the 6^th most frequently cited standard in the industry.

Incident: An Ohio aluminum parts manufacturer with a history of safety violations now faces penalties for 38 safety and health violations and a proposed $1 million fine following an investigation into the death of a 43-year-old worker struck by a machine's barrier door on March 30, 2021.

OSHA alleges that the company allowed employees to bypass guarding mechanisms designed to protect employees from the barrier door closing on them and that a malfunction in the door's optic control existed prior to the deadly incident. The worker was loading a part into the machine when the barrier door closed on his head.

OSHA's investigation identified problems with machine guarding and a lack of protective procedures – commonly known as lockout/tagout – throughout the facility. OSHA claims that the company was aware of these problems and failed to address them adequately.

Incident: Another case of LOTO “gone bad” occurred during a Roco CSRT stand-by job at a local industrial plant. After LOTO had supposedly been performed, one of our team members decided to test it by pushing the “Start” button on a hyper bar in a tank – it turned “ON!” Further investigation revealed that electrical work had been done in the area and the fuse lock-out was moved to another box adjacent to its original location. No one had notified the workers or changed the written protocol. Workers were locking out the wrong circuit! Had this been a rescue, how would rescuers control the hazard without knowing where the problem was with the LOTO?

Conclusion

It is clear that rescuers need to look deeper into their technique toolbox for creative options to isolate energy sources in order to protect themselves as well as the victim. And, this doesn’t only apply to municipal rescuers. Industrial rescue teams are very likely to be called when an emergency like this occurs. In order to be proactive and prepared, take the time in advance to evaluate your response capabilities as well as that of local responders in your immediate area. Every minute is critical for that person trapped or injured.

¹ Standard Interpretation: Clarification of "authorized" and "affected" employees and proper energy control procedures, Feb 10, 2004, question #3

Additional Resources

• Improper LOTO Costs Company $283,390
• OSHA Lock-out/Tag-out Fact Sheet 
• Evaluating Your Rescue Service

We’re often asked, “How many team members should be on a standby rescue team?”

While there is no definitive answer, we wanted to share some practical guidelines that we use here at Roco. We will offer some key points for consideration as well as address relevant standards and regulations. The safety procedures and internal policies for your organization must also be given priority consideration.

In assessing the number of personnel needed, we normally start with the various “types of confined spaces” that are applicable to the site. Other factors include elevation of the space; internal obstructions; and the potential for hazardous atmospheres. In addition, access into and out of the space; size and shape of opening; internal configuration; communications; hazard types and sources; and required PPE. Consideration must also be given to the types of injuries that may occur, which will dictate patient care and movement limitations inside the space.

 As an example, to rescue an entrant from a 24-inch round horizontal portal that is 3-feet off the ground would require fewer personnel than one that is 80-feet off the ground, or if it has an IDLH environment. This is a much different story! Careful consideration must be given to the various factors involved so that rescuers can be adequately prepared to take the appropriate action when needed.

From a regulations standpoint

OSHA’s Permit-Required Confined Space Regulation (29 CFR 1910.146) is our primary reference for this topic. However, this regulation is “performance-based” – and does not provide a specific number of personnel required for stand-by operations. It simply requires that the team or service gets the job done in a safe and timely manner.

Section (d)(9) of the regulation states the requirement to “Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees…”. However, the number of team members is left up to the employer or agency.

Section (k) provides more details regarding rescue and emergency services but again does not include a specific number of team members required. It’s all based on the rescue service’s ability to perform rescue from the types of confined spaces to which they may respond. OSHA’s Confined Spaces in Construction (1926 Subpart AA) standard echoes 1910.146 with a few additional requirements, but again offers no specific numbers on rescuers needed for standby operations.

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, once again, we are given no set number of personnel.

NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents, (2017 Ed) Chapter 7.3.2.1, states that “The role of a confined space rescue service is intended to include entry into the space to perform a rescue and, as a minimum, shall be staffed to provide sufficient members with the following exclusive functions:

1. Rescue entrant/entry team of sufficient size and capability to perform the rescue…
2. Backup rescue entrants of a sufficient number to provide immediate assistance…
3. Rescue attendant…
4. Rescue team leader (supervisor)…”

Still, no definitive number of personnel, but at least it offers some guidance on the positions that should be taken into consideration. If you dig a little deeper into the Appendix of 1670, you can find in A.7.3.2.1, “In general, confined space rescue teams are composed of no less than six members to perform all the required functions listed. However, the size and capability of a team required to perform a specific rescue will depend on many factors, including the condition of the patient, the size and shape of the space, size of the access opening, and the hazards present...”.

How Roco’s stand-by rescue services would typically handle

So, how many team members does it take? We’ll give you an idea of how we address this with Roco’s stand-by rescue services. Our typical Confined Space Rescue Team consists of three personnel including a Crew Chief and two Rescue Technicians. Keep in mind, however, these individuals are experienced, professional emergency responders, who perform stand-by rescue operations and/or train on a regular basis.

Our teams also have the benefit of preplanning the rescue and setting up equipment in advance. Considerable effort goes into rescue planning by Roco teams prior to an entry. Preplanning precautions include:  

1. Analyze, identify and eliminate hazards in and around the confined space.
2. Ensure appropriate administrative and work practice controls are being used and followed.
3. Hazard-specific PPE is provided and correctly used by all personnel involved.
4. Communication methods are defined, verified and implemented (written and verbal).

Also, with our standby teams, the Crew Chief is responsible for filling two roles during an actual emergency… (1) the rescue team leader and (2) either the rescue attendant or the backup rescuer. One Rescue Technician fills the role the Crew Chief didn’t, and the other Rescue Technician becomes the rescue entrant.

This has proven to be an effective and efficient team when providing standby rescue services. Again, we have the benefit of being onsite while the entries are occurring and the opportunity to preplan the rescue. In addition, the job circumstances and scope of work are carefully evaluated prior to committing to a specific number of personnel.

As an example, we typically require a four-person team for jobs involving inert entries and other types of IDLH environments, unusual space configurations (i.e., long distances, entanglement hazards or complex obstructions), or any other high hazard condition. In certain instances, even a two-person team may be appropriate. This would include when there is no potential for atmospheric hazards; large and easily assessable openings; no secondary lowering operations; strictly horizontal movement, etc.

In closing, we must emphasize that employers are required to ensure that adequate rescue capabilities are readily available. OSHA 1910.146 is a performance-based standard that requires a safe and timely rescue response for confined space incidents. This is one reason it is so important to evaluate the rescue service you are depending upon to provide emergency services (i.e., is the team trained and equipped to provide confined space and elevated rescue appropriate to your needs?). Appendix F of 1910.146 provides a valuable tool for conducting rescue performance evaluations. It is critically important to know in advance that your rescue service is prepared, capable and ready to perform an emergency rescue. 

Additional Resources

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

Blog originally posted in March 2011.