Construction is well underway on expansions and improvements to the Roco Training Center (RTC.) The goal is to add new confined space shapes and configurations in order to simulate an even wider variety of scenarios that rescuers may face in the real world. 

An additional two-story container configuration is being erected east of the pipe rack module. This will add 10 vertical confined spaces, 2 horizontal confined spaces, and 7 more student platforms for staging rescue equipment and training evolutions. The new area will be under a covered roof, making rescue training on the prop a bit more user-friendly in our south Louisiana climate!

Nearly complete is the new stairway on the south side of the prop that will provide additional access to the structure and more anchor points for rescue students taking courses at RTC. With these new features, the prop is increasing its student capacity by approximately 33 rescuers per day.

Last year a boiler simulator was added which focuses on extremely tight (12" x 15") horizontal confined spaces found at many industrial settings, old and new.

"Roco is constantly surveying our students to find out what their particular problem spaces are," said Dennis O'Connell, Director of Training for Roco. "We try to duplicate those confined spaces at RTC, so students can practice the skills they will need if a problem occurs at their site. This way, they get a more accurate experience."

The anticipated completion date for the additions to RTC is April 15, 2015. It is sure to add a few more challenges for Roco students who are familiar with the prop, as well as a few more conveniences.

READER QUESTION:
Our company procedures require an on-site rescue capability for permit- required confined space entry operations during normal Monday-Friday “day shift” operations, but for entries other than during that shift, we rely on an off-site rescue service. Shouldn’t the rescue capability, specifically the rescue response time, be the same no matter when the permit required confined space entries are being made?

ROCO TECH PANEL ANSWER:
Yes; and no, not necessarily.

Yes, if the nature of any known or potential hazards that may affect the entrants in the permit space, and the configuration of the confined space are the same during regular M-F day shift as they would be during off-shift entries, then the answer is yes. The rescue capability regarding response time, manning, equipment, and overall performance capability should be the same.

No, not necessarily. For example, if the nature of the known or potential hazards of a permit space entered during the day shift requires a shorter response time, or if the configuration of the space requires a higher level of rescue expertise, rescuer PPE, number of rescue personnel, or if there is any other factor that may require a different performance capability than the requirements of the day shift entries, then no, the same rescue capability would not necessarily be required.

This is because OSHA 1910.146 is a performance-based standard. For confined space rescue, specifically regarding what would be considered “prompt rescue,” the performance standard will be most influenced by the nature of the potential and known hazards and how quickly the hazards will affect the authorized entrants, as well as the complexity of providing effective rescue from the particular permit-required confined space.

To demonstrate this point, here are some extracts from OSHA 1910.146 Permit Required Confined Space Regulation Section K, the Summary and Explanation of the Final Rule, and also from OSHA 1910.146 Appendix F.

From 1910.146 (k)(1)(i)“Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

Note to paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.”

From the Summary and Explanation of the Final Rule (1910.146) “OSHA has therefore decided to promulgate the requirement it proposed for "timely" rescue, a requirement that was not opposed by any rulemaking participant, rather than to define precisely what is timely. That determination will be based on the particular circumstances and hazards of each confined space, circumstances and hazards which the employer must take into account in developing a rescue plan. OSHA has added a note to paragraph (k)(1)(i) to clarify this point.”

From 1910.146 Appendix F, A. Initial Evaluation, II, 1. “What are the needs of the employer with regard to response time (time for the rescue service to receive notification, arrive at the scene, and set up and be ready for entry)? For example, if entry is to be made into an IDLH atmosphere, or into a space that can quickly develop an IDLH atmosphere (if ventilation fails or for other reasons), the rescue team or service would need to be standing by at the permit space. On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutes might be adequate.”

The response time of the rescue service is also different than the time needed to provide rescue. Response time generally means the time it takes for the rescue service to arrive on scene. From that time forward, the rescue service must perform a size-up, identify and don PPE, set up rescue systems, and perform many other tasks before initiating entry rescue. Any need to provide victim packaging or to deliver breathing air to the victim will add to the total time it takes to complete the rescue.

Therefore, it is imperative that the employer ensures that the measure of “Prompt Rescue” is driven by the nature of the known or potential hazards of the permitted confined space as well as the complexities of the configuration of the space and how those will effect the time required to the setup the rescue system.

Roco provides confined space rescue services for a variety of industries and is confronted with a very wide range of hazards associated with the entry operations and a vast range of space configurations. The determination on the rescue team’s posture is based primarily on the answer to the following questions.

• 1.  How quickly will the entrants be overcome by the known or potential hazard(s) of the space, and /or how quickly will the entrants suffer permanent injury if exposed to those hazards?
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• 2.  If non-entry retrieval systems are not employed due to the system not contributing to an effective rescue, or the retrieval system creates a greater hazard, how much time would be needed to arrive on scene, set up an entry rescue system to support the entrant rescuer(s) and the victim(s)?

These are just two of the primary questions that we consider for our CSRT operations. If the nature of the known or potential hazards would require a near immediate rescue of the entrant(s), we would assume a “Rescue Standby” posture where the rescue systems are pre-rigged, the entrant rescuers are already in appropriate PPE or have it available to be quickly donned, and the rescue effort can be initiated in a very short time in an effort to meet that “Prompt Rescue” performance benchmark.

It is vitally important that the employer honestly evaluates the nature of the hazards or potential hazards of the permitted confined spaces that they plan on entering. This can be accomplished by reviewing product SDS (Safety Data Sheets), understanding the nature of the hazards that are not included in the SDS, and always considering worst case scenarios. Additionally, the employer must include an evaluation of the time it would take the rescue service to arrive on scene as well as the additional time to safely assess the situation and setup the required rescue systems prior to initiating rescue.

The answer to the question of a different rescue capabilities based on the “day shift” or “night shift/week-ends” can only be answered by performing a thorough assessment of the permitted spaces. And, on a case by case basis, determine if the rescue capability for that particular entry operation does indeed meet the spirit of “Prompt Rescue.” 

At times, it may be necessary to use a single rope split between two different rescue systems. This can be useful when all ropes are being used for other purposes, such as taglines, extending anchors, etc. Being proficient in using a single rope between two systems helps spread the resources and may be more than just another tool in your toolbox. Someday, it could be crucial to a successful rescue!

Here’s the drill:

1.  Choose an elevated location that is less than one half the length of the rope – plus, allow a good margin of extra rope. For example, if using a 150 ft. rope, you could use a platform that is about 40 feet high.

2.  Select two appropriate anchor points near each other. One will be for the main line; the other for the safety.

3.  Build a lowering system using one end of the rope and the main line anchor. Anchor the descent control device and prepare for a lower.

4.  Build your safety line using the other end of the rope and the second anchor.

5.  Lower the rescuer, package your patient, and recover them both.

6.  Try doing this using different descent control devices and different types of systems (piggy back vs. Z-rig). Play "what if" and problem solve.

Tips/Hints:

•  Pre-measure your lines. We say start where you want to end up! This drill is nothing more than lowering the end knots to the ground to assure you have enough rope to do the lower. It also allows you to inspect the rope for damage before life loading the lines.

•  If you do this with both ends of your rope and you have enough rope to reach from the ground to your two anchor points independently, you now know you have enough rope for both the mainline and safety line system.

•  Any additional line left between the two systems can be used to extend anchor points, rigging or build mechanical advantage systems.

•  Many times we use this technique of splitting rope from a single rope bag as our safety/retrieval line for rescue entrants during confined space rescue. We use rope bags that allow us to work from either end of the rope easily. We take two different color ropes usually 125 ft., tie them together, and load the bag from both ends with the knot in the middle (double fisherman). This allows us to run safety lines to two rescuers out of one bag. Since each rope is a different color it helps with line management, communications, identification and emergency retrieval. If your rescue scenarios require entrants to advance more than 125 ft., then longer ropes can be substituted. The rope can also be used as a single 250 ft. safety line provided you have knot passing capabilities.

•  Manage your ropes! Without good rope management, your work area can easily turn into a tangled mess.

This drill forces rescuers to think ahead and “outside the box” in order to allocate appropriate lengths of rope for each system or how to better use limited equipment resources. It is an excellent exercise in efficiency, rope management, and housekeeping – while demonstrating the importance of each when managing this type of system.

Next in this series: QUICK DRILL #7 - Anchor Selection and Rigging

READER QUESTION:

If Appendix F is non-mandatory, then why is it relevant to my PRCS program?

ROCO TECH PANEL ANSWER:

Questions often arise about the application of Appendix F of OSHA’s Permit Required Confined Spaces standard. Those questions usually focus on the “non-mandatory” characterization of the appendix. The question most often asked is:

“If it’s non-mandatory, why should I even bother with it?”

The answer is simple: even though Appendix F itself is “non-mandatory,” the methods for compliance in the appendix all relate to mandatory requirements of the standard. Appendix F is simply a non-mandatory method for complying with mandatory requirements.

The trick when evaluating the methods of compliance outlined in Appendix F is to match the particular non-mandatory provision of the appendix with the corresponding mandatory requirement of the standard. Then the employer can either use the method suggested in the appendix, or devise its own method to comply with the mandatory requirement.

For example, with regard to outside rescue services, Appendix F paragraph A(3) asks the question: “If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately?”

This provision does not create a mandatory requirement, but it does prompt the employer to take into account mandatory requirements of the standard. OSHA 1910.146(j)(3) makes it mandatory for the entry supervisor to terminate the entry and cancel the permit as required by paragraph (e)(5) of the standard.

Paragraph (e)(5) requires the entry supervisor to cancel the entry permit when “a condition that is not allowed under the entry permit arises…” If the particular entry requires rescue service availability and the rescue service suddenly becomes unavailable during the entry, that would be “a condition that is not allowed under the entry permit” requiring the entry supervisor to cancel the permit.

So although there is no provision that specifically states that the rescue service notify the employer if it becomes unavailable, from a practical standpoint the employer cannot comply with the requirement that it cancel the permit and terminate the entry when a condition not allowed under the entry permit arises unless such a notification system is in place. This is just one example of how the provisions of non-mandatory Appendix F provide a method to comply with mandatory requirements.

When considering the provisions of non-mandatory Appendix F, the employer would be wise to determine which mandatory provisions the method stated in the appendix addresses. Of course, the employer is free to choose some other method to comply with the mandatory provision and does not necessarily have to follow the method suggested in the appendix. In that sense, the appendix is “non-mandatory.” But, nonetheless, the employer must comply with the underlying mandatory provision, and take any steps necessary to do so.

Related Information

Evaluating Your Rescue Service

In January 2004, an explosion at the West Pharmaceutical Company in Kingston, NC killed 6 workers and injured 34 others. Two firefighters were injured during the response to the incident.  One month later, an explosion and fire occurred at the CTA Acoustics manufacturing facility in Corbin, KY, killing 7 workers. In February 2008, an explosion at the Imperial Sugar Company facility in Wentworth, GA, killed 13 workers and injured 42 others. Three very different types of facilities with very different products, but with one thing in common—dust!

The Chemical Safety Board reported that there were 281 explosions of combustible dust in the United States between 1980 and 2005. These explosions resulted in 199 deaths and 718 injuries. And these are just the actual explosions. There are countless more combustible dust environments just waiting for the right (or wrong) conditions to align to become the next fatal explosion. The fact is that with the exception of silicon or sand, every kind of dust is potentially combustible to some degree.

Combustible dusts are measured on a “deflagration index,” (see box) which measures the relative explosion severity compared to other dusts. They range from such seemingly innocuous items such as dust from powdered milk and egg whites that can create “weak explosions,” to dusts from items such as magnesium and aluminum that can result in “very strong explosions.” But I think we can all agree that no explosion, even a “weak” explosion, is a good explosion—especially if it occurs during rescue operations. 

As rescuers, you should already be familiar with the “fire triangle.” To understand the danger of combustible dusts, you should also be familiar with the “dust explosion pentagon.” The dust explosion pentagon consists of the following:

-       Combustible Dust (Fuel)

-       Ignition Source

-       Oxygen

-       Dispersion of dust (suspension)

-       Containment of the dust in a confined or semi-confined area (Enclosures/Building/Confined Space)

Rescuers should be on the lookout for any appreciable accumulation of dust when sizing up a rescue situation. Keep in mind that your atmospheric monitor containing a sensor for combustible gases is not effective for detecting a hazard from combustible dust.  

Always remain aware that in a suspended state, dust becomes explosive. Dust explosions occur when combustible dust is present, forms a dust cloud in an enclosed environment, and is exposed to oxygen and an ignition source. The explosion occurs as a result of the rapid burning of the dust cloud, which creates a rapid pressure rise in the enclosed area or confined space. 

A dust pile that may burn while an ignition source is being applied, then go out immediately or shortly after the ignition source is removed, can become lethally explosive when scattered and suspended in the air. 

Always consider the potential for combustible dust in any rescue situation, particularly when ventilation of an enclosure, building, or confined space is considered. A “safe” area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations.

This article was written by Robert Aguiluz, who is currently an Administrative Law Judge for the State of Louisiana. He is also an attorney who specializes in Occupational Safety and Health Law, and regulatory and compliance issues. He is a former Certified Safety Professional and Roco Rescue Instructor with over twenty years’ experience in both industrial and municipal emergency response and rescue.
 

Combustible Dust Considerations for Emergency Responders:

1.  Know your response area and the types of industry that may have the potential for combustible dust. If you are performing standby rescue duties, meet with the SH&E management team to learn about any combustible dust hazards at their facility.

2.  Become familiar with the “deflagration index” for various types of materials. See sample Chart below.

Examples of Kst Values for Different Types of Dust

3.  Consider the effect of ventilating a space that has accumulations of combustible dust.

        •  Will you cause the dust to become suspended?
        •  Will the suspended moving dust create a static charge/discharge and become a source of ignition?
        •  Can your ventilation equipment become a source of ignition?

4.  Is there information to review on the SDS (Safety Data Sheet) regarding the material’s potential to become combustible dust?

HELPFUL LINKS:

OSHA Quick Card: Prevent Dust Explosions

“Firefighting Precautions at Facilities with Combustible Dust”

“Hazardous Communication Guidance for Combustible Dust”

“Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions”

“NFPA 654: Standard for the Prevention of Fire and Dust Explosions”