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Confined Space Incident Log

Wednesday, October 12, 2022

Companies with active safety and health programs that train workers to identify hazardous conditions and use required protective measures can prevent serious and fatal injuries.

Father and Two Sons Killed in Grain Silo

Centre County siloIn Centre County, PA, three family members died in a grain silo incident. A father, age 47, and his sons ages 14 and 19 all died after becoming trapped inside a silo. The family members reportedly died from asphyxiation due to gasses in the silo. Neighbors said it was a ripple effect with one going in to help the next when they all eventually succumbed to the hazardous atmosphere inside the space.


Tankers Can Be Death Traps

A 48-year-old worker entered a tanker-tailer in Lemont, IL, to inspect it as part of an annual U.S. Department of Transportation requirement and was overcome by exposure to bleach and chlorine gas. The worker was found unconscious in the tanker-trailer; however, he later died of his injuries.

An OSHA investigation determined that the worker’s employer had failed to:

  1. identify and evaluate atmospheric hazards in the confined space,
  2. train workers on the confined space program, and
  3. ensure employees filled out a confined space permit before entry into a confined space.

OSHA also found that the employer failed to equip the worker rescuing the unconscious employee with a retrieval system, implement its own procedures for summoning rescue and emergency services and numerous other violations of its permit-required confined space regulations.

The company was also cited for failing to provide fall protection to an employee working on top of tanker trailers and providing training on fall hazards, respirators, and hazard communication.

The Chicago regional office established a Regional Emphasis Program in 2021 due to the dangers involved in inspecting tanker-trailers. The program is designed to reduce the risks tank cleaning workers face.

“In recent years, OSHA has investigated instances in which workers suffered tragic injuries because employers failed to follow appropriate procedures for ensuring healthy atmospheric conditions inside a confined space and use of adequate respiratory protection before allowing workers to enter tanks,” explained the OSHA Area Director.

Roco Rescue CS Attendant Requirements

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Rescue Compliance…Is Your Team Ready?

Saturday, October 1, 2022

We’re often asked by plant managers or rescue team supervisors about how they can make sure their rescue team is ready and in compliance should a confined space emergency occur at their site. Our answer usually revolves around practice, practice, practice; but here are a few other recommendations that you may want to consider.


training class

First of all, make sure you and your team are speaking the same language when it comes to rescue techniques and equipment. Consistency is key in having an organized response to a confined space emergency. We always recommend that customers evaluate and choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) can result in confusion for team members as to what techniques and equipment are supposed to be used – especially during a rescue!


If you have permit spaces at your site, then we assume OSHA compliance is a priority. OSHA’s Permit-Required Confined Space standard (1910.146) is a performance standard and is based on operational capabilities – as is OSHA’s Confined Spaces in Construction (1926 Subpart AA). While minimum practice requirements are once annually for each team member in the applicable representative spaces, the standard goes far beyond this in terms of proving that your team can function in a safe, timely and effective manner. Have you documented your annual rescue practice requirements in the relevant confined space types? Have you conducted an evaluation of your team’s performance in realistic confined space scenarios? Has your team prepared recommended preplans for the permit spaces on site?

Make sure you and your team are speaking the same language when it comes to rescue techniques and equipment.

There are other national consensus standards to take into consideration as well. This includes the National Fire Protection Association (NFPA) rescue skills requirements of NFPA 1006. This standard provides an excellent means of documenting individual proficiency of your team members. If there is an incident and OSHA were to investigate, would you be able to document the individual skills proficiency of your team members? Remember, if it’s not documented – with OSHA, it doesn’t exist!


Team members should be trained to an appropriate level based on the potential scenarios they may be called to respond. Do your personnel routinely work at height? Is there a potential for IDLH atmospheres? Know the hazards that your team may face and make sure they are adequately prepared. For overall team proficiency, it’s important to determine what credentials or level of skills you expect of your individual rescue personnel.

Ideally, all team members would be certified minimally to the Confined Space Rescue Technician level (NFPA 1006) along with the third-party certification to back it up. Of course, all should be CPR certified at a minimum. Additional medical training may be required depending on what level of patient care you intend to provide. And, with these certifications, come recertifications and continuing education, which must be completed as appropriate.

“Can you document your team’s competency and prove that your team members are capable of functioning in a safe, timely and effective manner?”

It's also important to check your team’s training records and make sure everyone is “up to par” with their training currency and skill level. Do you have a particular goal or level that you want your team to strive for, achieve, and maintain? Determining an overall goal for your team is significant in planning for and achieving long-term results. If you’re counting on your team to be ready and prepared, we strongly suggest that all team members be trained to the same proficiency level.


Here’s where the rubber meets the road – how capable is your team of performing a confined space rescue? In the worst of circumstances, can your team safely rescue a patient in a confined space filled with obstacles and unforeseen hazards? Do they possess the technical skills and equipment to perform a rescue safely and timely?

One of the best ways to determine the capability of your team is via simulated, realistic rescue practice drills in the representative confined spaces they may be called to respond. Adding a time limit – without compromising safety – can increase the perceived pressure and further simulate a real rescue. It’s an excellent way to see how your team would respond in an actual emergency situation and correct any deficiencies discovered.

Roco offers two great methods for evaluating rescue team competency. One is a Roco Team Performance Evaluation and the other is our annual Rescue Challenge event. Both offer realistic scenarios conducted under the guidance of experienced instructors along with a critique or debrief of each evolution. Each scenario is graded for various rescue and medical components. With each, comes a Team Performance Report to provide documentation of rescue capabilities.


If you plan to take your rescue personnel to the level of Rescue Technician, Roco has several options. The quickest way of reaching this certification to NPFA 1006 is by attending our Fast-Track™ Confined Space Rescue Technician course, which is a 70-hour program. This course meets the needs of municipal and industrial emergency responders with a mix of confined space and rope rescue. The class is geared for confined space rescue with additional rope technician skills needed for elevated or high angle rescue. The certification process includes a written exam and performance skills testing and is valid for a period of two years.

“Establish training goals for the team as well as individual team members, so that every training session stays on track and is productive.”

An alternative path to certification includes attending Roco’s Urban/Industrial Rescue Essentials™ 50-hour course and then completing the certification process in a Confined Space Rescue Technician 40-hour program. In either method, your personnel will receive consistent training and be certified to the same level of competency.

Training Cycle for Compliance

Once all team members have reached the appropriate training level, skills maintenance and ongoing proficiency become the norm for continuing compliance. Again, OSHA 1910.146 is a performance and capabilities-based standard that includes minimum annual rescue practice requirements for each team member.

Because our certification is valid for two years, we recommend a rotating cycle. Once Rescue Technician certification is achieved, the following year would include a Roco Team Performance Evaluation – or the attendance of Roco’s Rescue Challenge event. Both events provide graded rescue scenarios, which are debriefed by evaluators to correct any deficiencies found. Each of these options includes a Team Performance Evaluation report, which provides excellent documentation for compliance. The alternative year would include attendance of a Roco Recertification program.

This cycle of training works well in documenting that you have met the minimum requirements of OSHA while also meeting the skills requirements of NFPA. The supporting documentation provided offers a realistic “snapshot” of where your team stands in terms of competency and proficiency. This information can then be used as a tool to design internal drills that correct any discrepancies while getting the most from your all too limited practice time.


Training CycleConclusion

Rescue skills are extremely perishable, and if not used or practiced routinely, they can be quickly lost. For an effective rescue, team members must be confident in their skills, their equipment and their other team members. This requires regular practice that is realistic and practical. Make sure your rescue team is ready for an actual emergency – as you know, lives are on the line.


Confined Space Rescue Chart


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Roco QUICK DRILL #15 - Personal Skills Challenge (Advanced)

Thursday, September 15, 2022


 Each participant would be given all necessary equipment to complete the required tasks. Depending on the number of participants, and equipment on hand, evaluators would build the desired number of lanes to operate. Once participants have had a chance to look over the equipment, and ask any questions, evaluators would give each a set time to complete all tasks (e.g., 15 minutes). 

Once time is started, each participant would complete the following:

  1. Build a fixed line system (evaluators would run a safety line and have the participant focus on main line systems only) and rappel down a single floor.
  2. Once on the deck, participants would hook up a patient/package to the main line.
    1. Patient can be a manikin in a Sked/stokes or a live victim in a harness.
    2. It could be an option to have the participant actually package the patient (would add more time to scenario, but would be good practice).
    3. Any other package could be used in place of a patient, this is up to the organizers.
  3. Once the patient/package is secured to the main line (again, the participant is not responsible for a secondary line), the participant would ascend back up to the starting point using their preferred method. 
  4. Upon completion of the ascending portion, the participant would disconnect the fixed line system and create a hauling system to bring the patient/package up the single floor. 
    1. Evaluators/other participants would assist with transitioning the patient/package over the edge for safety.
    2. Participants could either be allowed to choose a high or low-point anchor, or be given directions to use a specific anchor. This is up to the evaluator.
    3. Tag line personnel could be provided if necessary.
  5. Once the patient/package has been placed securely on the deck, the participant would transition the hauling system to a lowering system and lower the patient/package back to the starting point.
    1. As with the hauling system, evaluators/other participants would assist with transitioning the patient/package over the edge until system is loaded. 
    2. Participants could either be allowed to choose a high or low-point anchor, or be given directions to use a specific anchor. This is up to the evaluator.
    3. Tag line personnel could be provided if needed.
  6. When the patient/package is securely back to the starting point, the exercise is complete. Evaluators will then critique/discuss the participant’s performance.

NOTICE: Based on the physical condition of participants, the heights and time limits may need to be adjusted. The basis of the exercise is to have an individual build a system to rappel, reach a patient, attach the patient to the system, ascend, and convert to a lowering system. 


Check out more Roco QUICK DRILL Challenges


How Do I Choose a Qualified Rescue Service?

Thursday, September 1, 2022

ConSpaceType2-22smIf entering permit-required confined spaces is performed at your worksite, then this is a question you absolutely should be asking yourself. And if you are, that is a good thing; it implies knowledge of OSHA’s requirement that an organization must provide for the safety of their personnel working in confined spaces.

Asking the question of “who” should provide your confined space rescue services means you are on the right track. You are aware of OSHA 1910.146 and have established that you are dealing with a permit-required confined space entry.

OSHA designates entries as permit-required when the space has one or more of the following characteristics:

  1. Contains or has the potential to contain a hazardous atmosphere
  2. Contains a material that has the potential for engulfing an entrant
  3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section
  4. Contains any other recognized serious safety or health hazard[i]

If a space at your facility where work is to be performed meets any of the above conditions, then OSHA clearly requires that you “develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue.”[ii]

“Rescue available” means the rescue team is available to be called out when some type of incident occurs. “Rescue standby” implies that the rescue team is standing by near the entrance to the space, ready to go at a moment’s notice.

There are basically three options available to most organizations for the provision of a confined space rescue team: (1) local emergency services, (2) an in-house team, or (3) a contracted rescue service. Each of the three rescue options available are all viable choices; and all, when implemented appropriately, have merit. However, there are many factors to consider, and due diligence must be performed to determine the most effective choice.  

Local Emergency Services

qualified rescue service2Upon learning that using local emergency services is potentially an allowable confined space rescue option, many organizations see this as the easy choice and quickly check that box. They are thrilled that they are not having to spend any money or devote any personnel to the task. These entities may also secretly wonder what all the hubbub is about regarding confined space rescue, but they very well may learn the hard way should an incident occur.

While there are local emergency services that have top-notch rescue capabilities, many (or perhaps most) are not that well equipped and/or trained to enter confined spaces for rescue purposes. If you are considering local emergency services to provide confined space rescue for permit-required entries, then there is homework that must be done before you check that box. This process should begin with a meeting with the local emergency services to assess the following:

  1. Are they trained and certified to perform confined space rescue?
  2. Are they properly equipped to provide this service?
  3. Are they available to respond/standby when entries are being made?

While some emergency services organizations may be well trained and adequately equipped to provide rope rescue in a high-angle environment, most do not have the right training and equipment for confined space rescue. Determining this level of detail requires serious due diligence to confirm, and as described later in this article, OSHA requires that you do this.

Aside from training and equipment, you must determine if the local emergency services are available to perform confined space rescue or standby services. This highlights the distinction between rescue available and rescue standby. “Rescue available” means the rescue team is available to be called out when some type of incident occurs. “Rescue standby” implies that the rescue team is standing by near the entrance to the space, ready to go at a moment’s notice.

While there are local emergency services that have top-notch rescue capabilities, many (or perhaps most) are not that well equipped and/or trained to enter confined spaces for rescue purposes.

Deciding which level of response is necessary is a function of the hazard(s) of the space. If the space is considered low hazard where the response is likely to be due to a medical issue with the entrant—e.g., heat stress, sprain, strain, etc.—then having a rescue team available to respond to the scene is permissible. However, if the space imparts a high degree of risk to the entrant(s)—an IDLH atmosphere, for example—then the rescue team should be on standby (literally standing by) outside of the space, ready to render immediate aid. Making this determination of rescue available vs. rescue standby applies to all situations, whether you are using local responders, in-house teams, or you contract out the service.

Although local emergency services are in the business of responding to emergencies (meaning they will come when you call), being on standby does not necessarily fit into those responsibilities—i.e., they may not be able to provide this service. And even if you are only requesting them as rescue available, they still may not be able (or willing) to obligate their trained members to always be available. Think about it: that is essentially asking their rescue-qualified members not to respond to other calls during the entry.

If using local emergency services is a route you want to seriously consider, then OSHA has a research assignment for you. (Note: this evaluation applies any time you are using an outside organization for rescue services.) You must evaluate:

  1. Response Time
    OSHA requires response in a “timely manner.” OSHA notes that “timely” depends on the hazard(s) present and refers to the Respiratory Protection Standard (1910.34) that requires standby persons when employees are wearing respiratory protection while working in an IDLH environment.
  1. Training and Equipment
    The prospective team must have the requisite training and equipment to proficiently perform rescue in the particular space(s) where entry will be made.[iii]

When selecting the local emergency services as your rescue team, it is imperative that the local emergency services know they have been selected for this role. If you have been performing your due diligence, this should be a foregone conclusion. But all too often, companies just check the box by their local responders and never let them know they have been designated for this role until an incident occurs. Should an accident happen where someone is injured, this is asking for a poor—if not disastrous—rescue outcome, as well as large fines from OSHA.

If you perform a really thorough assessment of the local emergency services, your findings will probably mimic those of many other organizations that have performed the same exercise—most local responder agencies are not trained, equipped, and/or available to provide standby or rescue services for confined space entries, period. The situation looks far bleaker for this option when you consider that they will be needed for every permit-required entry. It is a far bigger task than most local emergency response organizations want to deal with.

Also, while a written agreement with the local agency is not necessarily required by the regulation, it certainly would make it easier to document that an agreement to respond was in place – and that the department had an understanding of the scope of services to be provided at the employer’s site (i.e., confined space rescue). Here is a sample for you to download.

In-house Teams

qualified rescue service3When contemplating the utilization of in-house teams, it is important to note the composition of most. It is the rare organization that staffs personnel whose sole job it is to provide confined space rescue and standby services. Most in-house teams consist of personnel who have other jobs, e.g., operators, engineers, maintenance persons, etc., who are trained to provide rescue and thus called out for standbys or actual emergencies.

There are numerous pros to using in-house personnel. They know the facility and the processes; they should have a good understanding of the hazard(s); it does not add to the payroll, and they are only needed when there is a risky entry or an actual rescue. Further, they are often additionally motivated because it is their colleagues whom they are serving. An in-house team makes good sense if the organization frequently conducts permit-required entries.

But an in-house team carries with it many attendant requirements, some of which can be challenging to manage. Training can be tricky. While OSHA does not specify the number of personnel that should be on a rescue team, the average is probably three to six members. This number can go up or down depending on the complexity (or lack thereof) of the scenario. Regardless, there must be enough people trained such that all shifts are covered, and allowances must be made for those staff persons being on vacation, out sick, etc. In addition to initial training, all team members must receive, at the minimum, annual rescue practice that covers the types of permit-required spaces they may encounter.[iv]

An in-house team makes good sense if the organization frequently conducts permit-required entries.

Along with adequate training and practice comes the equipping component. Confined space rescue is an equipment-intensive prospect. In addition to the PPE that OSHA mandates you provide employees, there is the myriad other gear that is required: ropes, harnesses, and hardware that is standard for all rope rescues, plus the confined-space-specific kit such as a tripod, SKED, air monitors, ventilation fans, and ducting. In addition to the acquisition of this equipment, it must be inspected on a regular basis with the inspection results documented and maintained.

When the training, staffing, and equipment responsibilities are taken together, significant behind-the-scenes activity is required to make an in-house system work efficiently.

Contracted Rescue Services

qualified rescue service5This brings us to the third option—contracted rescue services. If an organization infrequently performs permit-required entries, this option makes good sense. And it can be a far less expensive option than training, staffing, and equipping an in-house team.

There is a hybrid approach to making an exclusive decision between in-house or contracted rescue services. With a hybrid approach, the organization has an in-house team for their typical or routine entries but uses a contracted provider for long-duration projects or instances where there are multiple simultaneous entries being conducted that outstrip the resources of the in-house team.

The pros to using contract rescue services is that the organization avoids the significant effort and resource requirements of an in-house team. They are only needed during the entry, and when it is complete, they depart and the pay meter quits ticking. There is no training of personnel, no equipment to purchase, and no need to reorganize shifts and/or pay overtime to cover staffing. The possible con is that quality rescue services are not exactly cheap, so there will be an expense involved which can be significant if the services are required for an extended period. You will also have to perform due diligence about the prospective service’s capabilities, just as you would with the local emergency services. In Appendix F of 1910.146, OSHA provides non-mandatory guidance on the selection criteria for selecting a rescue service. Roco also has a Confined Space Compliance Guide that offers additional information.

With a hybrid approach, the organization has an in-house team for their typical or routine entries but uses a contracted provider for long-duration projects or instances where there are multiple simultaneous entries being conducted that outstrip the resources of the in-house team.

It is important to note that by selecting a third party to perform rescue services, the confined space and the activities that occur in and around it remains your responsibility. This means that you cannot contract out your OSHA exposure/liability should an accident occur during a rescue attempt. At the end of the day, it is still your space. You still need to make sure that the process is being followed and that safety is being provided.

qualified rescue service4Regardless of which option you choose for confined space rescue services, it is important that you do it right. If you are contracting out the provision of rescue, you are obligated to thoroughly investigate the provider’s credentials and client references. You can be assured that when an accident happens, OSHA will perform a forensic review of your documentation and your policies, as well as those of your rescue service. If you have skipped a step or only addressed them in cursory fashion, OSHA will discover it and potentially issue citations and fines. But one should never lose sight of the fact that the real loser in this scenario is the employee who receives poor or delayed care during the emergency.



[i] OSHA 1910.146(b), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)

[ii] OSHA 1910.146(d)(9), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)

[iii] 1910.146(k), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)

[iv] OSHA 1910.146(k)(2)(iv), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)


Confined Space Rescue Chart


Additional Resources




K9 Partners in Rope Access

Friday, August 26, 2022

K9 Rope1

Throughout history, dogs have played a vital role in humans’ lives. Evidence of dogs coexisting and serving as companions to humans begins as early as 12,000 B.C. Today dogs continue to serve crucial roles in the military, law enforcement, and search and rescue (SAR), in addition to other more domestic duties.

With current technology, humans have become more mobile in modern times, so have their trusty companions. Dogs can now be found with their partners fast-roping out of helicopters, climbing up and rappelling down cliffs, or at the extreme end of the spectrum, parachuting out of planes.

All of these skills require a high level of training and experience for both dogs and humans alike. Military, police, and SAR working dogs, or K9s, must first go through rigorous obedience and job-specific training before moving on to advanced mobility skills such as rappelling and fast-roping.

Working dog teams provide unique capabilities that require an investment of time, effort, and money to develop. Like any important investment, K9s and the capabilities they provide should be protected. Any high angle rope work is high-risk. To mitigate this risk, using proper equipment and receiving professional training is paramount. 

All of these skills require a high level of training and experience for both dogs and humans alike.

The first step to ensure the safety of K9s (and their handlers) during high-risk evolutions like rappelling is to utilize appropriate, properly fit, climbing or CE/UIAA certified equipment. Some organizations will dictate the specific gear K9 teams use while others allow their K9 teams to pick the gear that works best for their mission. For high angle rope access (climbing and rappelling), each K9 handler should have at a minimum: climbing or tactical helmet, correctly sized and rated harness, a means to descend rope (belay/rappel device), a means to ascend rope (mechanical ascender or prusik cords), safety lanyard, and several locking and non-locking carabiners.

K9 Rope3Finding a CE/UIAA certified harness for your K9 partner will be challenging or nearly impossible. However, dogs do need a properly fitting harness that is rated to a minimum breaking strength of at least 10 times the dog’s weight. Many working dogs wear vests that have a harness built in which can be acceptable, but plastic buckles that are prevalent on many K9 vests don’t cut it for rope access work.

Additionally, there are many ways to attach the dog to the handler (or the rope itself), but again, any straps, cords, or carabiners need to be rated for climbing. For fast roping, the K9 team will need a fast rope descent device and the handler will need a helmet, harness, and gloves. One last piece of gear that some dogs may need for their safety, as well as the safety of their handlers, is a muzzle.

Any high angle rope work is high-risk. To mitigate the risk, using proper equipment and receiving professional training is paramount. 

The second step to buy down risk and protect the investment that a K9 team provides during high angle rope access is to get professional training. It is also crucial that the dog has a high level of obedience before starting high angle rope work. Typically, the first order of business is to get the dog used to the harness and being suspended by hanging or hoisting the dog, gradually increasing the time the dog is suspended. Using treats or some other type of reward will help put the dog at ease. Done right, most working dogs will look forward to donning their harness.

This is also when you may want to introduce a muzzle in the same way (if the dog is not already muzzle trained). The use of a muzzle is not necessary for all dogs but is a good idea for high drive/high energy dogs or dogs that get nervous or agitated being suspended in a harness. The last thing handlers want while they are suspended by a rope is an agitated dog biting them, the rope, or any other equipment thus putting the K9 team at greater risk. Repetition is key; being deliberate and consistent with techniques in multiple environments and using rewards will ensure the dog is properly trained and socialized for the task.

K9 Rope2Once the dog is accustomed to the harness and being suspended, most of the dog’s training is done. For climbing and/or rappelling, the training curriculum a handler should undergo includes knot tying, anchor building, ascending and descending rope, belaying, and building and using mechanical advantage systems for hauling. Once a handler is confident and competent on the rope, the dog can be introduced.

Military, law enforcement, and SAR K9 teams possess incredible capabilities that save lives.

Dogs are very attuned to their handlers, so if the handler is overly nervous the dog will sense that and feed off it. Additionally, there are several ways to position a dog while rappelling. The dog’s position is dictated by the situation and terrain. Some positioning such as to the side or between the legs will reassure the dog and enable the handler to negotiate obstacles more effectively.

Dogs will continue to accompany their human partners to places and in ways that weren’t previously thought possible. Military, law enforcement, and SAR K9 teams possess incredible capabilities that save lives. With the proper training and equipment, they can provide these capabilities in terrain and environments that can only be accessed with rope. Roco Rescue can provide both the professional training and the equipment necessary for K9 rope access be it by fast rope or climbing and rappelling.


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