“Up until now, requesting or researching OSHA Letters of Interpretation or checking with other safety professionals was the means to get a clearer picture of ‘how’ to accomplish safe and compliant confined space entry. NFPA's Guide for Safe Confined Space Entry (NFPA350) helps to bridge that area from regulation to compliance. It is a ‘must have’ resource for safety professionals, confined space owners/workers and rescuers as well,”  states, Dennis O'Connell, Director of Training for Roco Rescue, who served as an alternate committee member for NFPA 350.

Here's more from NFPA on their new guide...

Every year, confined space incidents result in worker deaths, injuries, and serious illnesses. The danger is widespread because all facilities can have confined spaces - from commercial buildings and hospitals to public works, utilities, and chemical/industrial facilities. By U.S. law, employees must comply with applicable regulations such as OSHA's 29 CFR 1910.146 and 29 CFR 1926 Subpart AA to ensure personnel safety. However, these regulations tell you 'what' to do, not 'how' to identify, evaluate, and control confined space hazards or conduct rescue response.

NFPA has just introduced NFPA 350: Guide for Safe Confined Space Entry and Work. This all-new guide is essential for anyone who enters confined spaces, along with facility managers, code officials, and safety personnel. NFPA 350 explains how to protect workers who enter into confined spaces for inspection or testing, or to perform associated work. Provisions address the full range of special hazards, including those present in water treatment, petrochemical, and agricultural facilities. It provides information to assist companies that need to comply with OSHA's Permit-Rquired Confined Spaces (29 CFR 1910.146) among other standards. In addition, NFPA 350 helps fire service and emergency services personnel develop and evaluate plans for confined space rescue in conjunction with NFPA 1670: Standard on Operations and Training for Technical Search and Rescue Incidents.

This guide will help you be prepared to recognize, evaluate, and control confined space entry hazards. Follow practices developed by experts for: 

• • Identification of Confined Spaces
• • Evaluation of Hazards
• • Atmospheric Monitoring
• • Hazard Elimination and Control
• • Ventilation
• • Rescue and Rescue Planning
• • Confined Space Personnel Duties, Responsibilities, and Competencies
• • Pre-Entry Evaluation Forms and Permits
• • Management of Change
• • Prevention Through Design
• • OSHA Alternate Entry Procedures and Reclassification (Annex C)

As an added note, NFPA 350 looks at all confined spaces from a different prospective- i.e., all spaces are treated as "permit required" until it is proven that entry is safe or the proper precautions have been taken. This guide's impact in confined space work and rescue will be significant in reducing risk and meeting compliance issues. For more information, visit NFPA.org.

“A Trench is a Trench is a Trench”

An employee of a cemetery in Farmingdale, New York, was seriously injured on May 7, 2015, when the walls of the grave opening in which he was working collapsed and buried him up to his waist.

An inspection by the Long Island Area Office of the U.S. Department of Labor’s Occupational Safety and Health Administration found that the excavation and its support systems lacked adequate protection against cave-ins and the excavation had not been inspected to identify such deficiencies. Other hazards included damaged equipment and the placement of excavated soil on the edge of the unprotected trench. These conditions exposed employees to the hazards of cave-in, engulfment and struck-by injuries.

This worker literally came close to an early grave because the cemetery failed to provide proper excavation protections. 

“This cave-in could have been prevented if proper and legally required trenching safety procedures had been followed by the employer,” said Anthony Ciuffo, OSHA’s Long island (NY) area director. “It is imperative that cemeteries ensure that workers at all its cemeteries are protected against cave-in hazards and ensure that an incident such as this does not happen again in the future.”

OSHA cited the company on Nov. 5, 2015, for two willful and three serious violations of workplace safety standards.

Roco Comments from Dennis O’Connell, Director of Training:

You may think of this is an unusual circumstance, a once in a lifetime event. Sorry, but you’re wrong. During my tenure as a rescuer in NYC, I responded to a number of these jobs, and they present some additional hazards that are not associated with most trench rescue jobs.

You can call it what you want, but a grave is a trench. And the location can make a big difference in terms of hazards presented. For example, I have a house in NY and one in Louisiana – in South Louisiana, we try to bury people above ground, if possible! However, in places like NY, cemetery space is so limited. It’s like high-rises in the city, our cemetery family plots bury multiple family members usually 3 on top of the other, which is referred to as a triple depth grave. This pushes the grave depth to about 8 feet for the first entombment.

So, no matter what you call it – a trench is a trench, and we need to follow OSHA 1926.651-652 requirements for protecting workers. Let’s look at some of the grave/trench basics before we move on to the specific grave hazard. If we dig an excavation that is longer than it is wide, it is a considered a trench – if it is 4’ or deeper, you need to have a ladder or other means of egress for workers; if it is 5’ or deeper, you need to install a protective system.

You must have a Competent Person, as defined by OSHA, to determine what system is adequate and that it is installed properly. They must also inspect the trench and surrounding area for hazards before workers can enter the trench. Of course, there’s a lot more to digging a trench and the responsibilities of the competent person but you get the idea.

Also, just because a trench is only 7’ long and 3’ wide, this does not change the rules or responsibilities associated with digging a trench. If you’re digging a trench, you need to have that competent person; you need to understand the requirements of 1926.651-652; and you need to know who will respond if you have a trench emergency. Keep in mind, most municipal departments, especially volunteer departments, do not have the training or equipment to respond to a trench collapse.

Ok, the added hazard to a grave collapse rescue is the headstone at the end of the grave – depending on the size, they can weigh over 1,000lbs. If it has fallen in the grave on top of the victim, then you will need to use technical rescue techniques and equipment to lift and free the victim. If it is still on the edge, you will need to support, stabilize or remove it before rescuers can work under it. So, even an innocent grave, can be the scene of a complicated technical trench rescue.

Bottom line… if you are digging trenches for whatever reason, or you have contractors digging trenches on your property, you need to be aware of the requirements of 1926.651-652, have a “competent person,” and identify who you are going to call if a collapse happens.

FYI, you need to have 2.9 feet of soil above the casket top. Some say that it’s a public health law. Between you and me, I think it’s to keep Zombies from escaping!

Here is an OSHA fact sheet to help you better understand some of the requirements. OSHA Fact Sheet - Trenching and Excavation Safety

In our opinion, the new OSHA regulation for Confined Spaces in Construction (Subpart AA of 1926) was worth the wait! This new standard is well thought out and includes some significant as well as subtle differences from the General Industry Permit Required Confined Space Standard 1910.146.

In this article, we will point out additional requirements for compliance for construction activities involving confined spaces. With the exception of residential construction, the final rule became fully enforceable as of October 2, 2015.   

These additional requirements instituted by OSHA are due to the dynamic nature of the construction environment. Dynamic in terms of the continuously evolving configuration of the workplace, and also in the diverse and ever-changing makeup of employers and employees depending on the phase of construction. We feel the most significant differences are not complete shifts in an administrative or operational approach to conducting safe permit required confined space operations, but more of an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.

“We believe the new standard offers an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.”

Please pay particular attention and review 1926 Subpart AA for requirements to ensure clear communication and coordination between the varied entities that work in or adjacent to the construction areas that have confined spaces. The lack of accurate communication and coordination continues to be a cause of confined space fatalities.

The need to communicate with the controlling contractor and entry employers regarding any operations that may have introduced a hazard into a confined space is of paramount importance. The failure to do so has repeatedly led to disaster for unsuspecting follow-on entrants into those confined spaces. Likewise, understanding and communicating the types of operations adjacent to, or in the proximity of confined spaces that may negatively affect that entry operation, must be coordinated and communicated.

Also, several new roles and responsibilities have been added to the confined space regulations. One of the most important new roles is that of the “competent person” for confined spaces.

Having a dedicated individual (Competent Person) who has the expertise and background to perform this critical function will undoubtedly result in lives saved.

OSHA has also added clarification to the need to ensure that the designated confined space rescue service is not only available at the time entry operations commence, but also that rescue service must now agree to notify the entry employer if a situation arises that renders them unable to respond to an emergency.

So let’s take a look at some of the particulars of these new requirements and clarifications.

Get all the details of OSHA Confined Spaces in Construction: Subpart AA of 1926

Due to their relative simplicity, belay systems rarely see the dedicated training that is often given to the other elements of rescue, such as mechanical advantage or patient packaging. Just because you can rig a 540 Belay Device or tie a Munter Hitch does not necessarily mean you are proficient in their use.

It is important that the belayer can choose the proper belay system for the anticipated load and situation as well as understand the pros and cons of each system. Rescue teams must also be able to properly rig the system, troubleshoot any problems that might arise, catch the load and be able to safely transition from the "catch" to an emergency lowering system, if needed. 

There is a certain degree of finesse and anticipation involved with efficient belaying. It is an important skill only acquired through practice. Allotting more time to belay-specific training will provide payoff in smoother, safer operations during your next rescue.

1. As a team, discuss the belay needs of your environment (type of device or hitch, need for confined space rigging, high-point/low-point usage, one-person/two-person loads, etc.).

2. Divide your team into pairs and have each pair rig a specified device or hitch as a horizontal ground station.

3. While one member operates the device, the other attaches to the working end of the belay line and walks backwards to simulate a moving load. The team member on the line can also simulate a sudden load being applied to the rope at random intervals for the belayer to catch by pulling quickly on the working end of the rope.

4. If using the 540 Belay Device, develop proficiency in releasing a "stuck" load.

5. When using a Munter, work on body/hand position and tying off the Munter with a mule knot and releasing the mule knot while under load.

6. With tandem prusiks, practice converting to a lower system.

7. No matter what device or system, focus on maintaining a steady rate of rope progress through the device, while maintaining the proper amount of slack in the system (maximum 18 inches).

8. Have members switch positions and/or devices as they work on proficiency.

9. If time and training space allow, rig simple lower/haul scenarios where the emphasis will be on belay practice. In these scenarios, focus on the following:
       • Communication between the Rescue Master and the Belayer.
       • Maintaining the appropriate amount of slack in the belay system (no more than 18 inches).

Efficient belay skills are often taken for granted. Be sure to master the use of these critical, lifesaving systems!

 

Next in this series: QUICK DRILL #10 - Tripod Quick Drill