Roco now offers marine rescue standby services for the Baton Rouge-New Orleans industrial corridor. As with other Roco services, our personnel are experienced emergency responders trained to provide lifesaving skills when it matters most.

All Roco marine standby personnel are First Responder/ CPR/First Aid trained, and most are EMT’s. Our boats are fully equipped with First Aid kits, AEDs and O2 for prompt emergency care.

For construction work over or near waterways, OSHA 1926.106 requires certain safety precautions – including the timely response of a boat to rescue a fallen worker. In fact, according to one OSHA LOI, the retrieval of an employee from the water is required no more than 3 to 4 minutes from the time they entered the water. And, depending on hazards present, it could be required even sooner.

Section 1926.106(d) states:
At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.

The intent of the paragraph is to ensure prompt rescue of employees that fall into the water, regardless of other precautions taken to prevent this from occurring. Thus, OSHA requires that employers supply a skiff to affect a prompt water rescue. As a skiff supplies a backup to potential failures of fall protection devices, the use of fall protection systems is not a substitute for the skiff.

The requirement in 1926.106(d) addresses the hazard of falls that may occur in the event of a failure of the operation of fall protection devices or a lapse in their use. An employer is also required to comply with all other applicable standards including, but not limited to, the requirements that an injured employee be treated by medical personnel or an employee certified in first aid within 3 to 4 minutes from the time the injury occurred. This could mean that first aid treatment would have to begin in the lifesaving skiff or boat.

For more information on this service, please contact Roco at 800-647-7626 or email info@rocorescue.com.

Resources: OSHA 1926.106 as well as Letters of Interpretation (LOI’s) dated 8/23/04; 12/5/03; 12/6/91; and 6/13/90.

NOTE:  In this article, Roco cites OSHA 1926.106 which applies to construction activities while working over or near water. For other industries such as shipyard (Part 1915), marine terminals (Part 1917), or longshoring (Part 1918), please refer to those standards for specific requirements, particularly for PFDs and rescue skiffs. OSHA does not require rescue skiffs for all industry activities. However, keep in mind, OSHA sets minimum standards. And, remember, there’s a safe way and a safer way!

We recently had a Facebook inquiry about attaching a rappeler's belay line (safety line) to their high-point dorsal connection on their harness. We choose to do this for a number of reasons including: (a) compliance with applicable regulations; (b) adherence to safe and practical rescue procedures; and, (c) the physiological effects of falls – how the body absorbs an impact force. Let’s take a general look at these considerations.

Compliance

OSHA considers our rappel/lower main lines as “work positioning” lines and our belay or safety lines as “fall protection.” The fact that they and we, as rescuers, consider the safety line as fall protection, or more accurately as our Personal Fall Arrest System (PFAS), kicks in a few requirements and considerations for all private sector responders and for municipal responders governed by OSHA-approved State Plans. These responders are required to comply with applicable OSHA regulations.

However, keep in mind, these regulations are designed to protect workers (and rescuers) from harm and injury. During training, since it is not a real rescue, we should be following the applicable regulations and standards for safety as well as liability reasons. Even during actual rescues, it is important to adequately protect our people from injury. The days of “rescue at all costs” are gone. We are responsible for designing training, systems and SOPs/SOGs that protect our people in a rescue situation.

Note the following key points from OSHA 1926.502(d):

• Limiting the free fall distance (max free fall 6 feet)
“…be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level”

• Deceleration distance of 3.5 feet (41 inches)
“…bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m)”

• Maximum allowable impact load 1,800lbf.
“…limit maximum arresting force on an employee to 1,800 pounds (8 kN) when used with a body harness”

• Improvised anchorage strengths of 5,000lbf or twice the anticipated load.

“Anchorages used for attachment of personal fall arrest equipment shall be…capable of supporting at least 5,000 pounds (22.2 kN) per employee attached…”
“Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.”

• Harness attachment should be to the high-point dorsal connection point.

“The attachment point of the body harness shall be located in the center of the wearer's back near shoulder level, or above the wearer's head.”

You may have heard the statement, “Firefighters/rescuers don't need fall protection or need to follow OSHA.” This is not true for the 27 State Plan states where OSHA regulations do apply to public sector employees including emergency responders. It puts the burden on the employer, agency or department to establish fall protection and rescue protocols that would adequately protect their people.

To illustrate this, here is an excerpt from an article written by Stephen Speer, a NY career firefighter, for “Fire Rescue” magazine which deals with potential OSHA violations during rescue operations and training exercises. (Note: New York is a State-Plan state.)

“I spoke to a New York State Public Employee Safety & Health (PESH) supervisor about the following scenario and asked if there were areas that could be potential violations.

Scenario: A firefighter operating from a roof ladder is cutting a ventilation hole on a pitched roof. The firefighter falls from the roof and is injured.

In what areas, if any, could an incident commander or company officer be cited? In response, I received 12 pages of documentation. The documents showed that in evaluating potential violations of the general duty clause to see if anyone is responsible, the following four elements must be met:

1. The employer failed to keep the workplace free from a hazard to which employees of that employer were exposed.
2. The hazard was recognized.
3. The hazard was causing or likely to cause death or serious physical harm.

NFPA 1500, chapter 8.5.1.1, states that operations should be limited to those that can be completed safely. In this scenario, there is the potential for citation if all four elements apply. As the above scenario illustrates, whether or not you have an aerial apparatus, you must consider fall arrest protection.”

Practicality

When rescuers are sent into a vertical confined space, we use the safety line (PFAS) to protect them as they are being lowered and raised from the space. It is also used as “an immediate means of retrieval” should something go wrong inside the space. Having the safety/retrieval line attachment point at the high-point dorsal position allows us to attempt an emergency retrieval with the victim being extracted in a low profile to fit through a narrow portal.

Physiological Effects

There have been numerous studies on the effects on the body when subject to a fall and arrest while in a harness. They generally come to the same conclusion that high-point dorsal attachment is the most survivable and provides for the greatest injury reduction. Here are excerpts from two studies.

1) Excerpt from a study conducted by Dr. M. Amphoux entitled, “Exposure of Human Body in Falling Accidents,” which he presented at the International Fall Protection Seminar in 1983:

In experiments on the position of the attachment point on the harnesses, Amphoux found that a high attachment point was preferable because “it gave a better-disposed suspension” and that it was “especially effective when the attachment is on the back. When the falling stops, the neck flexes forward. If the attachment point is in the front of the sternum, the neck flexes backwards and the lanyard may strike the face.”

Amphoux continued that it would be better for the compression to be localized on the body of vertebrae and not on the posterior joints, which were too fragile. “Therefore,” he said, “the attachment point would be better on the back than pre-sternal and should be high enough to reduce the potential neck injury. In addition, the forward flexion would be stopped by the thrust of the chin on the chest.”

This was why Amphoux and his colleagues strictly recommended attachment high on the back. It also protected the face from the lanyard when falling. In the case of falling head first, regaining a feet-first position would involve flexion of the head, whereas if the attachment were pre-sternal, the head would more often be projected backwards [whiplash effect].

However, it was accepted that a front attachment might be preferred in a few working situations. This was only acceptable when the height of the potential fall was very short. Whatever the choice of body support, it should not be forgotten that it was only a compromise and not a guarantee of absolute security.

2) Excerpt from “Survivable Impact Forces on Human Body Constrained by Full Body Harness,” HSL/2003/09 by Harry Crawford:

The one-size-fits-all policy of some harness manufacturers may not be suitable for the range of body weight 50kg to 140kg. Although it may be possible for those in the wide range of body weight/size to don such a harness, the position of the harness/lanyard attachment is of paramount importance. For best performance and least risk of injury, the attachment should be as high as possible between the shoulder blades.

Note: They also concluded that the shorter the fall, the less impact and less chance of injury no matter which type of harness or where the connection point was.

Like any rescue or work safety technique, you need to look at all the variables and decide which technique and equipment will best protect you or your co-workers. We choose the high-point back connection because of the variety of situations and locations we might face during a rescue based on the three considerations mentioned earlier in this article.

Thanks for a great question and taking the time to look into the reasons why systems or techniques are used. I hope this answers your question. If you have additional questions, please contact me at 800-647-7626.

By Dennis O'Connell, Roco Director of Training

Federal OSHA and other OSHA State Plans do a good job of providing updates on newly recognized hazards in the workplace, as well as reminding us of existing hazards. We need to heed this information as it takes lessons learned the hardest way, and shares it for others that work in the same or similar environments.  No matter what industry our employees are performing their jobs, the fact remains, we are all humans and will suffer the same consequences of exposure to hazards no matter if we are in construction, general, agricultural, or any other industry. 

Often times there are significant differences in the OSHA regulations for identical hazards from one industry to another.  For instance, the height threshold for requiring fall protection in general industry is four feet, whereas the threshold in construction industry is six feet.  Are construction employees able to withstand the impact of a fall better than a general industry worker?  No, the main reason for the difference was due to the rules making process and dialog between OSHA and the industry stakeholders.

If you were to spend some time reading OSHA’s agricultural regulations, you will find that you won’t need much time.  They are pretty lean.  But there is one very important OSHA regulation that must be considered, and that is Section 5 (a)(1), General Duty Clause. 

If a recognized hazard is not addressed in an industry specific regulation, the General Duty Clause is there to protect the employees and the employer MUST comply with it.

For now, there are many instances in the agricultural industry that have no specific regulation addressing the various hazards and thus the General Duty Clause is very important to remember.

Confined spaces are areas large enough for a worker to enter and perform work, have a limited or restricted means of entry or exit; and are not designed for continuous employee occupancy. The following quote is from OSHA Fatal Facts publication No. 16-2018 and provides clear expectations for protecting employees where no specific industry regulation exists. The purpose of this Fatal Facts is to highlight the importance of identifying confined spaces in agricultural workplaces to prevent another fatality.

"The General Duty Clause requires employers to provide employees with workplaces, including confined spaces, which are free from recognized hazards likely to cause death or serious physical harm. Agricultural opera­tions are covered by several Occupational Safety and Health standards including Agriculture (29 CFR 1928) and parts of General Industry (29 CFR 1910), as well as the General Duty Clause of the Occupational Safety and Health Act (section 5(a)(1)). OSHA’s confined spaces standard at 29 C.F.R. 1910.146 does not apply to agricultural operations, but serves as a guide for how to prevent these accidents.”

Comments on this story were made by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

Resources:
Washington State DOL and OSH
Safety+Health Magazine

Does your company authorize employees to work at height using personal fall arrest systems (PFAS)?

If so, you need to keep reading. Even if your employees don't use personal fall arrest systems, but they work at height using passive restraint, active restraint, or work-positioning systems, you need to keep on reading.

If you have demonstrated that there is no feasible means to utilize employee protection on the "Hierarchy of Fall Protection" other than fall arrest, meaning there is no way to bring the work to the ground or to use a fall restraint, then you have accepted that at some point, your employee will fall.

The personal fall arrest system (PFAS) is there to arrest their fall before they hit the ground or other hard parts, and to minimize injury during that fall and arrest event. OSHA requires employers who authorize personal fall protection systems to provide "prompt rescue," and a big reason for this is OSHA now recognizes suspension trauma as a hazard. Reference: 1910.140(c)(21) "The employer must provide for prompt rescue of each employee in the event of a fall," OSHA Safety and Health Information Bulletin (SHIB 03-24-2004, updated 2011) regarding Suspension Trauma.

Even though this is not specifically required by OSHA, wouldn't it make sense to have a prompt rescue capability for times when an employee is injured or becomes suddenly ill while working at height?

This could be an employee who is protected by passive restraint but not PFAS. For instance, if an employee needs to climb a vertical fixed ladder to access a platform with perimeter guardrails 20 feet above the next lower level and is incapacitated due to injury or illness, how will you get that employee to the ground for treatment and transport? Most likely it will require a technical rope rescue effort or some other means of getting them from height and safely to the ground.

Having Suspended Worker Rescue Preplans already in place goes a long way in preparing for the emergency of a fallen suspended worker or a worker that is injured or becomes ill but is isolated by height. By completing these preplans, it should become apparent when the requirements for viable rescue go beyond what I call the "Fred Flintstone" rescue (i.e., "so easy a caveman can do it!").

Additionally, there are products that will delay the onset of suspension trauma should a worker fall and remain suspended in their PFAS. These can significantly improve survivability after fall arrest while awaiting rescue.

Assisted, non-technical rescue can be accomplished using ladders, man lifts, or many other primitive but effective means. However, there comes a point where the situation will require some degree of technical rescue capability. If you have done an honest and knowledgeable assessment of the rescue needs for your facility for all the known or potential areas where you may have employees working at height, you very likely will have found the need for a technical rescue requirement.

If you are lucky, and your facility is located in a municipality that has emergency responders with a rope rescue capability that is willing and able to respond to your location, then you still must ensure that they can perform what needs to be done.

A really good way to do this is to have them come to your facility for the purposes of preplanning and hopefully demonstrating their abilities. Simply posting "911" as the plan, and calling it good, is not even close.

Some facilities have in-house teams that are equipped and trained to perform technical rescue. These in-house teams are generally the fastest to respond and it usually eliminates the problem of relying on a municipal rescue team that may be called out on a separate emergency.

For companies that do not have a municipal agency that can and will respond or does not have the technical ability to perform the types of rescues that may be required, there is always the option of training host employees to perform these types of rescue.

The first option is a single day of training using pre-engineered rescue systems or what we like to call "plug and play" systems. The second option is a two-day "build as you go" class that provides solutions in rescue environments that the pre-engineered systems are unable to cover.

Roco's one-day Pre-Engineered Rescue Systems training relies on manufactured rescue systems that require no knot tying, or the need to create mechanical advantages, or to load friction control devices. These systems are so straight forward that most students will be able to operate them safely and proficiently even if they haven't performed refresher training for several months. With these systems, you literally take the system out of a bag, hang it up to a suitable anchor, and you are ready to rescue.

Roco teaches a variety of techniques that are suitable for a conscious, uninjured suspended victim and also for an unconscious or injured victim who would need to be connected to the rescue system remotely by the use of a telescopic "gotcha pole." As straightforward and easy as this system is to become proficient with, it does have its limitations. For example, in order for this type of system to be employed, the rescuer(s) must be able to safely get into a position above or slightly offset, and within about 10 feet from the victim. If that is not possible, then it is time to prepare for a technical suspended worker rescue.

Roco's two-day Rescue From Fall Protection class teaches a limited variety of knots, including tied full-body harnesses, mechanical advantage systems, anchoring, friction control, lowering, rappelling, hauling, and line transfer systems. These skills are not that hard to master, but they are perishable and require sufficient practice at regular intervals in order to maintain proficiency. This type of "build as you go" capability allows the rescue team to create a system that will work for just about any situation and structural configuration except for the most extreme settings.

So, if your facility seems to be behind the curve regarding the rescue of workers from height, you may need to discuss training options - either for the worker that has fallen and remains suspended from their PFAS, or for the one who is injured or ill at height with no way to get down.

Remember, a worker cannot hang suspended for any length of time without the danger of suspension trauma, which can be deadly.

If we can assist you in assessing your fall protection rescue needs, please contact us at info@rocorescue.com, or call our office at 800-647-7626.

Additional Resources

• Hierarchy of Fall Protection Poster
• Sample Suspended Worker Rescue Preplan
• Suspension Trauma Poster

QUESTION: Should industrial rescue team members be informed of any scheduled confined space entries at the beginning of their shift?

ANSWER: While OSHA does not mandate that individual team members be notified; common sense and best practices do. Here’s our reasoning for encouraging this “information sharing” at the beginning of each shift.

First of all, it is the Entry Supervisor’s responsibility to ensure that the rescue service is available prior to each PRCS entry. This verification should be performed in a way that confirmation of availability can be documented. There are various reasons that the in-house team may not be immediately available, so it’s up to the Entry Supervisor to plan ahead and coordinate with the team. Most often in-house industrial rescue team members have regular job assignments in addition to their rescue duties. Depending on the particular assignment, he or she may or may not be available to respond to a rescue emergency. In fact, we have heard of incidents where the Entry Supervisor just “assumed” that because the facility had an in-house rescue team that the team would always be ready to respond. In one instance when an in-house team was notified of a PRCS emergency, only one (1) team member was on shift and available to respond. Apparently, other team members were on sick leave, vacation, or at shift change. As you can see, two-way communication between the Entry Supervisor and the rescue service is a must!

Having a system in place that allows on-duty team members to be aware of PRCS entries that are scheduled during a given shift allows them to start the preplan process, which will help reduce response and preparation times. It also provides Team Leaders (IC) with a better understanding of possible rescue needs and how best to utilize available resources if an emergency situation should arise. And, these are just some of the reasons we recommend that on-duty team members be accounted for and be made aware of any entries occurring during their shift - including the location, the type of entry and the hazards involved. It simply provides for better preparation; thus, making everyone safer.