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.

One of OSHA’s Agency Priority Goals is to reduce trenching and excavation hazards. According to the Bureau of Labor Statistics, excavation and trench-related fatalities in 2016 were nearly double the average of the previous five years. OSHA’s goal is to increase awareness of trenching hazards in construction, educate employers and workers on safe cave-in prevention solutions, and decrease the number of trench collapses.

OSHA plans to issue public service announcements, support the National Utility Contractors Association’s Trench Safety Stand Down, update online resources on trench safety, and work with other industry associations and public utility companies to create an effective public-private effort to save lives. OSHA’s trenching and excavation national emphasis program is also currently under revision. For more information on trench safety, visit OSHA’s safety health topics page.

Over the past few years, Roco has made trench safety a priority goal by dedicating more than 15 articles on this website as well as a podcast to trench-related subjects in an attempt to increase awareness for trench safety and rescue, just as OSHA is doing.

One area we have identified where facilities may be in violation is having personnel who are not “trench” competent persons sign off on trenches. Many times, the company representative is a “Confined Space Competent Person” or “Entry Supervisor,” and we are asking them to sign off that a trench shoring system is adequate when they have little or no training.

Just because you are competent person in one area does not mean you are a competent person in all of them. A confined space knowledge base is not the same as a trench knowledge base.

The OSHA Construction Standard Defines a Competent Person “as someone who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”

Now that NFPA 1006 Standard for Technical Rescue Personnel Professional Qualifications (2017 edition) has been in place for a while, it’s a good time to revisit the changes that have been made. While we won’t go into every single change from the previous 2013 edition, we will cover some of the more significant ones – particularly for the specialty areas that we deal with most.

So, let’s get to the big changes right off the bat. As you are probably aware, there was a big disconnect between NFPA 1006 and NFPA 1670 Standards on Operations and Training for Technical Search and Rescue Incidents. While there are technical committees for the development of both 1006 and 1670, very few committee members sit on both committees. The need for a correlating committee became apparent, and it is that correlating committee that coordinated and at times arbitrated changes to both standards in an effort to marry them up.

For example, NFPA 1006 Levels I & II have been replaced with Awareness, Operations and Technician levels to correlate with 1670 performance levels. This change may seem minor, but it allows for (and provides guidance in) training auxiliary personnel to a level of competency to support the Technical Rescue Team. This is reflected in the title change of 1006 from “Standard for Technical Rescuer Professional Qualifications” to “Standard for Technical Rescue Personnel Professional Qualifications.”

This change provides the option to train a team to a level for handling less technical incidents and still meet the standard for that level of proficiency. It also allows for a level of competency to begin a rescue effort while awaiting a more technically trained and equipped team to respond. This aids teams that do not have the manpower, equipment or funding to train to the Technician level by providing performance goals for Operations and Awareness levels.

NFPA 1006-2017 has also added several new specialty areas to include: Floodwater Rescue, Animal Rescue, Tower Rescue, Helicopter Rescue, and Watercraft Rescue. Several new definitions have been added to correlate with NFPA 1670. Clarification is provided by further defining dive operations, search, watercraft, wilderness, and other terms. You will also find that the word “search” (as used in the title of 1670) has been incorporated into many of the specialty areas of 1006 – another attempt to better correlate the two standards.

Again, we have attempted to highlight some of the key changes in NFPA 1006-2017. We think the modifications will make it easier to understand what is required of technical rescuers as well as auxiliary support personnel. As always, we encourage you to read the standard in its entirety. If you have any questions, please call us at 800-647-7626.

Foundry Fined for Confined Space Amputation Accident

Los Angeles - Cal/OSHA has cited a local foundry $283,390 for workplace safety and health violations following a confined space accident that resulted in the amputation of an employee’s legs. Cal/OSHA had cited the foundry for similar violations eight years ago.

Two workers were cleaning and unjamming a 38-foot long auger screw conveyor at the bottom hopper of an industrial air filtration device without effectively de-energizing or locking out the equipment.

One of the workers re-entered the 20-inch square opening after the cleaning was done to retrieve a work light from inside the confined space, when a maintenance worker 45 feet away energized the equipment to perform a test.

The moving auger screw pulled the worker into the screw conveyor. Both his legs had to be amputated in order to free him.

“Sending a worker into a confined space is dangerous, especially inside machinery that can be powered on at any time,” said Cal/OSHA Chief Juliann Sum.

Employers must ensure that machinery and equipment are de-energized and locked out before workers enter the space to perform operations involving cleaning and servicing.

Cal/OSHA’s investigation found that:
• The foundry did not have a permit-required confined space program.
• The screw conveyor was not de-energized and locked out before workers entered the hopper, and accident prevention signs were not placed on the controls.
• The worker re-entering the hopper was not monitored by a confined space attendant.
• The foundry lacked specific procedures for de-energizing and locking out the equipment.

Cal/OSHA issued eight citations with proposed penalties totaling $283,390. The eight violations cited included one willful serious accident-related, one willful serious, four serious, one willful general and one general in nature.

Source: www.dir.ca.gov News Release No.: 2018-15 Date: March 7, 2018