Many OSHA standards, especially in construction, require a “competent person” to be designated at the jobsite. Filling this role requires proper training, relevant experience to the work being performed and adequate knowledge of the associated regulations. 

The competent person should be able to recognize critical hazards as well as have the authority to take the action needed to mitigate hazards. It’s much more than just picking someone to fill a slot.

A previous article, "What is a Competent Person?" found in the National Safety Council's Safety+Health publication, talks about how the term is often taken too lightly. Again, it's much more than just selecting a body to fill a role or attending one 10-hour training class covering all the various standards. Competency must be considered and evaluated for this important role. 

At a minimum, your designated competent person should meet the following minimum qualifications:
(1)    A high level of understanding of the types of hazards typically encountered in that area of work;
(2)    A solid review of applicable standards relating to that type of work; and,
(3)    A thorough understanding of types of solutions to control or eliminate the hazards.

To assist in preparing your competent person in fall protection, we encourage you to register for Roco's Fall Protection Competent Person - April 4-5, 2016 course in Baton Rouge. This course will provide practical experience in recognizing fall hazards and developing appropriate measures for reducing or eliminating those hazards. 

Source: Safety+Health Magazine February 2016

Washington – A recent agreement between the Departments of Labor and Justice will launch a “new world of worker safety” by holding managers and supervisors criminally accountable for violations of the law, agency officials announced Dec. 17.

The two departments signed a memorandum of understanding that pools their resources toward the prosecution of individuals who willfully disregard labor and environmental statutes, according to John Cruden, assistant attorney general for the DOJ’s Environment and Natural Resources Division, who spoke at a press conference moments after the memo was signed.

For the past several years, OSHA and DOJ have worked with each other on certain cases, but the new agreement formalizes that relationship.

This cooperation could lead to hefty fines and prison terms for employers and individuals convicted of violating a number of related laws. For example, a roofing contractor recently pleaded guilty to violating an OSHA law, lying to inspectors and attempting to cover up his crime; he could be sentenced up to 25 years in prison.

“Strong criminal sanctions are a powerful tool to ensure employers comply with the law and protect the lives, limbs and lungs of our nation’s workers,” OSHA administrator David Michaels told reporters at the press conference.

Deborah Harris, DOJ’s Environmental Crimes Section chief, said prosecutions would be open to “the ones making the decisions that lead to the deaths of others,” which could include people in the corporate office, as well as managers and supervisors.

Readings are 20.9/0/0/0…so it must be safe for entry, right? Not necessarily!

After completing an interesting confined space standby job for Roco, I wanted to caution rescuers about the possibilities of atmospheric hazards within a confined space – despite what the atmospheric monitor says!

For this particular job, the atmosphere in the workspace never varied on the 4-gas monitor readings. The readings were consistently 20.9% for O2; 0 for LEL; 0 for H2S; and 0 for CO. However, this entry required the use of air-purifying respirators even though there were no visible signs of anything unusual – no odor, no product warning signs, no indication that there may be an inhalation hazard in the space.

This particular space was located at a public water facility. It was a 70-ft. deep concrete metering pit with six consecutive 12-ft x10-ft levels. It had concrete floors and walls with a vertical ladder that accessed each level. Although the space was not designed to store any product, in this case, we still had an atmospheric hazard.

The purpose of the entry was for remediation of mercury contamination on the concrete surface. The gross cleanup of liquid mercury had been performed years prior, but further action was required to eliminate vapor hazards still present in the lower chambers.

During the first phases of the entry, vapor levels that exceeded 40,000 ng/m3 (nano-grams per cubic meter) were detected. The more frequently updated ACGIH Threshold Limit Value is only 25,000 ng/m3. The work environment in this space routinely approached twice this level, even though there were no visible signs of liquid mercury. The source of the toxic atmospheric hazard was invisible and odorless – mercury vaporizing from the concrete surfaces.

Mercury is only one example of a toxicant that can produce a hazardous atmosphere in confined spaces that will not be indicated on a typical 4-gas meter or atmospheric monitor. Many rescuers assume that their 4-gas meter will detect all atmospheric conditions that may present a risk to their health or safety, but this is just not true. There are a wide variety of agents or toxicants besides mercury that will not be detected and whose presence may require other controls or the use of respiratory protection. This mistake could be deadly, or leave rescuers with chronic health issues.

In this scenario, for example, if you were an off-site rescuer responding to the above described space in an emergency situation. Without someone on site to inform you of the possible hazard, you would have no indication that any hazards were present. Many times as municipal rescuers we respond to, shall we say, shady locations where unauthorized storage or illegal dumping of hazardous products has taken place; there are no SDS, placards, or signage. Personnel on scene may not know, or may not want to relay vital information about a space of any products within the space.

Rescuers Beware: It's important to play the role of “detective” when planning or preparing to make a confined space entry.

Oftentimes, there are placards or signs on tanks or storage containers to start the investigation into what hazards may be present – and SDS for additional information. However, as rescuers, we often fall into a state of “false security” with our 4-gas meter readings.

While much of our training may include “Go/No Go” scenarios for rescue teams, the use of respiratory protection is usually based on one of the “Big 4” readings on our atmospheric monitors. Unfortunately, this may only serve to reinforce the notion that a 4-gas monitor will always provide the “complete” information of what may be going on inside a confined space. We get dependent on these monitors to tell us if it’s safe to enter without respiratory protection – and there may be much more to the story!

OSHA’s Respiratory Standard [1910.134 (d)(1)(III)] specifies "Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.” 

In the above statement, if you substitute Team Leader for “employer” and “Rescue Team” for employee, you may find that you cannot “identify or reasonably estimate the employee exposure.” Therefore, rescuers would need to use SCBA/SAR and other PPE until you can completely identify what hazards are in the space even though typical monitoring devices are telling us that all is well.

While your standard 4-gas meter is an important screening tool – it is NOT a "catch all" for every atmospheric hazard.

Remember that NIOSH statistics indicate that 40%-60% of confined space entry fatalities are (would-be) rescuers, including both dedicated on-site standby teams and off-site professional rescuers (municipalities) who attempt to perform confined space rescues.

But let’s take this a step further. If you ask most rescuers at what O2 level does an atmosphere become dangerous, they will say below 19.5%. I know from my initial hazmat/confined space training on 4-gas monitors included oxygen displacement. It was so elegantly described to me as “if your monitor shows a decrease in oxygen, it is telling you that something else has pushed out that percentage of oxygen and replaced it with some other agent.” Now, it would be up to you to figure out what else is in the air.

For example, normal breathing air is 20.9%. To get a reading of 19.5% means that about 1.4% of “something else” has displaced the oxygen. Then, depending on what that “something else” is, could require the use of respiratory protection. Hey, wait, the good news keeps coming, and I am getting in way over my head on this science stuff, but my high school chemistry teacher should still be proud. Ambient air is made up of about 79% nitrogen and other gases and 21% oxygen. So, using fingers and toes mathematics, that equals about a 4:1 ratio of nitrogen to oxygen.

In other words, if we have a 1% displacement of oxygen from the breathing air, it will be accompanied by about a 4% displacement of nitrogen (both gases displace at about the same rate). Therefore, instead of it being about a 1.4% percent of an unknown product in our breathing air, it could be as much as 5.6% or more! And, depending on what that product is, it could already be at its IDLH level.

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Project Scientist Spencer Pizzani of Weston Solutions provides this insight.

Rescue tripods provide a mobile and rapidly deployable high-point anchor option for confined space emergencies. Like any piece of equipment, however, it has its limitations. It is important that your team becomes proficient with this tool in training to ensure fluid deployment during a live rescue. 

There are two primary topics to review regarding rescue tripod operations: Set-Up and Rigging. Here’s a quick drill to help you and your team become more proficient in its use.

Set-Up

1. Find an area to review your tripod operations. Ideally, train over a potential rescue space, keeping in mind safety around any open spaces. As with any training exercise, always use proper PPE and take proper fall protection precautions. If you don’t have access to potential spaces or are training in a municipal environment, improvise with a closed street manhole or create a mock-up opening with wood or cardboard.

2. Deploy your tripod. While you are deploying it, discuss the following with your team:

a. When do you setup the tripod in a rescue operation? Prior to rescuer entry? During packaging stage? During extrication stage?

b. Do we setup the tripod over the space or in a safe area, then move the tripod over the space?

c. What type of patient packaging will be done and at what height will the tripod need to be in order to clear packaging out of space?

d. Tripod strengths at different height settings. Is height more important or strength?

e. Can the legs of the tripod be different lengths or rest on different elevated surfaces?

f. Should the tripod be tied down so it won’t tip?

g. Keeping resultant forces within the legs of the tripod to prevent tipping.

h. Insure correct assembly, including the use of the tripod’s chain to prevent overspreading the legs of the tripod.

Now that your tripod is assembled, move on to rigging.

Rigging

Rig each of the following systems and raise and lower a load/weight. This shows the pros and cons of operating each system. Show how the resultant forces can be applied by the haul position or by patient movement outside the tripod footprint. In most cases, there are three rigging options for tripod operations. Rig each, while discussing each method’s strengths and weaknesses.

1. Block and Tackle System

a. Often pre-rigged and therefore rapid to deploy.

b. Will the length of the collapsed system create height constraints to remove the victim from the space?

c. Does the height of the tripod create any issues operating the cam of the system?

d. Rope length vs depth of space; what strength M/A will you be able to build?

e. Can the haul team keep resultant haul forces within the legs or footprint of the tripod to prevent tipping, or do we need to have a change of direction pulley?

2. Single Main Line with COD (change of direction) within the Tripod’s Footprint

a. Better option when the tripod’s height and victim clearance are concerns.

b. Enables the lower/haul team to operate remote of the space.

c. Necessitates an anchor point within the tripod’s footprint and an anchor point for the main line.

d. Allows for reaching greater depths than a block and tackle system.

e. Single line entering the space and allows for attachment of patient air bottle.

f.  Takes more time to rig.

3. Pass-Through Method

a. A solution when the block and tackle or single main line techniques will not work (no anchor point within footprint of tripod available).

b. Increased Mechanical Advantage (6x1).

c. Requires two remote in-line anchor points on opposite sides of the space.

d. Two traveling lines in the space.

e. Eliminates concerns with haul-resultant forces.

f. Most complicated of the three systems.

A properly deployed rescue tripod can be a game changer for a confined space rescue. As with any piece of equipment, continuous training with the device and its associated techniques is necessary to maintain “proficiency,” which translates into safety and efficiency! Always, train hard so that your team will perform when the call comes!

 

Next in this series: QUICK DRILL #11 - Patient Packaging (Single Rescuer)

 

Depending on the manufacturer, you will find varying specifications for the service life of rescue equipment. For example, Petzl specifically defines the “potential” service life of plastic or textile products to be no longer than 10 years. It states "indefinite" for metallic products. CMC, on the other hand, does not give specified times for their equipment stating, “The service life of equipment used for rescue depends greatly on the type of use and the environment of use. Because these factors vary greatly, a precise service life of the equipment cannot be provided.” However, in reference to harnesses, CMC cites ASTM F1740-96 as the industry standard for service life. SMC follows along the lines of CMC when stating the amount of time a product can stay in service.

Although the definition of “equipment lifespan” is very broad depending on the manufacturer, each will provide specific instructions on proper inspection of equipment and detailed explanations on when to retire the item.

Most manufacturers follow the same general guidelines for removing equipment from service. Several general identifiers that pertain to all equipment are shown below.

REASONS FOR EQUIPMENT RETIREMENT INCLUDE:

• Item fails to pass any pre/post use or competent person inspection.
• Item has been subjected to a major fall or load.
• Item is constructed of plastic or textile material and is older than 10 years.
• You cannot determine the complete full-use history of item.
• You are not certain or have lost confidence in the equipment.

Most manufacturers will provide service for equipment items that are repairable. However, most caution against this because the cost of repair typically exceeds the cost of replacement. Any repairs attempted outside of the manufacturer may void any warranty and will release the manufacturer from any liability or responsibility. In addition, all manufacturers recommend destroying equipment once it has been retired from service to prevent items from inadvertently being recycled back into active service gear.

Regardless of the stated service life, the condition of equipment–as determined through inspection by a qualified party – is a key factor in determining whether or not a piece of equipment is fit for service.

Manufacturers also provide indicators for different types of equipment that require it to be retired from service. These are not only capturing the general conditions mentioned above, but also bring in conditions that are specific to each category of equipment. It is important to identify these specific conditions as they are vital to the dependability and functionality of each component.

Harnesses:

Harnesses are one of the most vital components of life safety equipment. Without a certified harness in serviceable condition, the best life safety rope and hardware in pristine condition will do little to protect the user. All individuals who are required to wear harnesses to perform duties should be trained and authorized in the inspection process. Harnesses should be inspected before and after use as well as once annually by an individual deemed a competent person by the facility or department.

Since harnesses are a nylon product, they fall under the guidelines set forth by ASTM consensus standard F1740-96 and have a service life of 10 years. Manufacturers also state that hard or excessive use – as well as the conditions when a harness is used – may significantly reduce its service life. It is important to conduct routine inspections as well as keep records of harness use. This “usage” history could indicate signs that would require the equipment to be retired early.

Here are some conditions to help identify when it’s time to retire your life safety harness:

• The harness has surpassed 10 years since the manufacture date.
• Webbing shows signs of cuts, significantly worn or frayed areas, soft or hard spots.
• Webbing shows signs of discolored or melted fibers.
• Stitching shows signs of pulled threads, abrasion or breaks.
• Hardware shows signs of damage, sharp edges, excessive wear or improper function.
• If the harness has been subjected to shock loads, fall loads, or abuse.
• If there is any doubt about the integrity of the harness.
• If the harness demonstrates any of these conditions, it should be removed from service and destroyed.

Life Safety Rope, Webbing, Anchor Straps, Accessory Cord:

Since these products are nylon or textile based as well, they fall under the same inspection process as harnesses. A complete inspection of life safety rope and associated products includes not only a visual inspection but a tactile (or touch) inspection as well. The tactile inspection should be done with tension on the rope, webbing or strap.

The inspector is looking to identify any of the following conditions:

• Chafed, glazed or discolored surfaces (these areas should receive a more thorough inspection).
• Abrasions or cuts in the sheath where the core is exposed.
• Variation of diameter of the rope that could indicate potential damage to the core fibers.
• Soft or hard spots that could indicate core damage or that the fibers have been over stressed.
• If the rope has been subjected to shock loads, fall loads or abuse.

If any of these conditions are noted, then the item should be retired and destroyed immediately. It is important to remember that an accurate history should be maintained for all life safety rope products. The date of manufacture should be identified and recorded as products are being put into service. Equipment inspectors or users should ensure that these products do not exceed their service life. As with harnesses, the amount, type and conditions of use can drastically reduce the service life of these products.

Carabiners:

Since carabiners are metallic, they do not fall under the ASTM service life recommendation of 10 years. As long as these products are in serviceable condition and properly maintained, they have an infinite service life. Even though they do not have a dedicated service life term, it is still important to conduct the same pre/post use and annual inspections.

Some conditions that would require the equipment, such as carabiners, to be retired from service include:

• Carabiner has been dropped a significant distance.
• Exposed to heat sufficient enough to alter the surface appearance.
• Cracks, distortion or deep gouges.
• Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
• Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
• Gate does not line up when closed.
• Gate action does not return to closed position when opened and released.
• Locking mechanism does not fully engage.
• Complete history of use cannot be determined.

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items even though the service life of the product is infinite.

Pulleys:

Pulleys, as with carabiners, are metallic in construction and do not have a service life recommendation. They will also have an infinite service life as long as they are in serviceable condition and are properly maintained. Pulleys fall under the same inspection requirements as carabiners. 

Below are some conditions that would require such equipment to be removed from service:

• Pulley has been dropped a significant distance.
• Exposed to heat sufficient enough to alter the surface appearance.
• Cracks, dents or elongation at the carabiner hole on side plates.
• Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
• Deep scratches or gouges to side plates or sheave(s).
• Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
• Side plates that do not line up at the carabiner hole.
• Elongation of the side plates at the sheave pin.
• Side plates that do not move freely.
• Sheave does not turn freely or significantly rubs against side plate.
• If the item has been subjected to shock loads, fall loads or abuse.
• If the history of use or manufacture date cannot be determined.

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items even though the service life of the product is infinite.

Descent control devices:

Descent control devices, if metallic, do not have a service life recommendation. If the device is constructed of plastic or other textile material, it will have a service life not to exceed 10 years.

conditions that would require this equipment to be removed from service:

• Cracks, deformations or elongation to any portion of the device.
• Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
• Deep scratches or gouges to any portion of the device.
• Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
• Excessive wear to friction surfaces or cam (see wear indicator on some devices).
• If the device has been subjected to shock loads, fall loads or abuse.
• If the history of use or manufacture date cannot be determined.

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items throughout their service life.

Ascenders:

As with previously mentioned equipment, the same inspection procedures apply to ascenders. 

 remove from service if you find:

• Cracks, deformations or elongation to any portion of the device.
• Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
• Deep scratches or gouges to any portion of the device.
• Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
• Fouled teeth on cam (handled type ascenders).
• Excessive wear to surface of cam.
• Damage to rivets (if applicable).

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items throughout their service life.

Service history is an extremely important part of ensuring life safety equipment is properly maintained and that service life is not exceeded. Not only does this help rescue teams control inventory and operational capability of equipment by documenting each use and inspection, it also assists the teams in forecasting budget costs for the replacement of items that are nearing the end of their service life.

Maintaining records of the manufacturer’s information received when purchasing new equipment is vital to identifying and keeping track of the manufacture date. It is also important to keep this information on file for the exact procedures for inspecting and removing equipment from service. If the manufacture date of equipment, such as life safety rope and harnesses, cannot be identified; it poses extreme liability for agencies or facilities whose teams may potentially be operating with equipment that has passed its service life. It could also create a compromise in the safe operation of the equipment. Also, if record-keeping of equipment inspection and use is not a primary focus, it could potentially expose team members to operating with unsafe equipment due to abuse or excessive/extreme conditions that go undetected.

All team members should be qualified and knowledgeable enough to perform pre- and post-use inspections of equipment. It is crucial that all members document each use of equipment, denote any deficiencies, and report to the proper person. One person should be designated to perform the competent person annual inspection. This person should have complete knowledge of the equipment and inspection procedures as well as the authority to keep or remove equipment from service as they see fit. If team members are unable to fill this role, a qualified third party with applicable manufacturer certifications in competent person inspection should be brought in to assist in determining the condition and estimated service life of rescue equipment. For assistance from our rescue equipment professionals, call us at 800-647-7626.

Additional Resources

Gear Inspection Checklist (download)

Cleaning Your Rope…Here’s What the Experts Have to Say

Guidelines for Permanent Marking of Rescue Hardware