Roco’s new Hierarchy of Fall Protection Safety Poster provides guidance on how to protect your workers from fall hazards by illustrating a series of steps in making safer choices as job duties are approached. It clearly explains the need for employers to make every attempt to abate fall hazards at their work sites by starting with the most protective level of fall protection. OSHA and ANSI references are used to emphasize the need for proper training and “fallen or isolated worker-at-height” rescue pre-plans when appropriate.

This safety poster will provide a quick reminder that oftentimes working at height is more hazardous simply because more “protective steps” in the hierarchy were never considered.

By displaying this poster in strategic areas, we hope it will encourage all workers to take every opportunity to make work-at-height even safer. After all, for those of you who know Roco…there’s a safe way, and a SAFER way!

Click the picture to download the PDF version of the NEW Hierarchy of Fall Protection Safety Poster.

Roco is excited to announce that beginning in 2014, we will offer a ProBoard/IFSAC option conducted by the Carrol L. Herring Fire & Emergency Training Institute for select Roco courses at the Roco Training Center (RTC) in Baton Rouge. Students choosing the ProBoard option will complete both a written and skills exam. Upon successful completion of this certification process, they are then eligible to be entered into the ProBoard’s certification registry.

The first Roco course to offer FETI’s accredited certification testing will be our Fast-Track 80™ course to be held on February 20-22 & 24-28, 2014. There is an additional charge of $100.00 per student, and advance registration is required. Call us at (800) 647-7626 to register and reserve spaces or get more information.

The ProBoard is an internationally recognized professional organization that represents the fire service and related emergency response fields. The ProBoard accredits organizations, such as the Carrol L. Herring Fire & Emergency Training Institute, that provide certification testing to the National Fire Protection Association’s (NFPA) professional qualification standards. The International Fire Service Accreditation Congress (IFSAC) is a peer driven, self-governing system that accredits both public fire service certification programs and higher education fire-related degree programs.

Visit ProBoard's website  or watch their video about the benefits of seeking fire service certifications through a ProBoard accredited entity.

Here's a video from Roco's Rescue Tech II training course conducted at Marathon Petroleum in Robinson, IL on August 19-23, 2013. The local NBC affiliate (WTWO) produced the feature which shows how plant responders train and prepare for confined space rescue emergencies. Roco instructors Chad Roberson and Bobby Kauer led the training. Thanks to all involved for sharing this video!

To submit a story or video about your rescue team or training experiences, please email us at: RescueTalk@RocoRescue.com. We want to hear from you.

NOTICE: If you are involved in any kind of confined space work or rescue, you need to read this document and offer your comments. This applies to anyone who may work in or near confined spaces, both industrial and municipal.

At a meeting earlier this month, NFPA’s Guide for Safe Confined Space Entry and Work (Draft) was approved for public comment by the NFPA Standards Council.

This document is designed as a “best practices” guide for those who work in and around confined spaces. As with any document that attempts to be all inclusive, it may work well for some while negatively affecting others. Therefore, it is very important that "WE" the public, the people who will be using this type of document in real world applications, offer our feedback. Now is the time to offer comments and suggestions. Comments as to what may or may not be feasible for your organization or what may have been overlooked in this document are a vital part of this NFPA process.

As contributing members for this document, we are encouraging you to take the time to make your suggestions in order to create a practical guide that will be user friendly and provide for greater safety when working in confined spaces. As you read it, please keep in mind that it is currently listed as a “Best Practices Guide.” However, this does not mean that at some point in the future it won’t possibly become an NFPA Standard.

This document could eventually affect the way you do your job, so it’s very important to all of us for it to be a safe, practical best practices guide. Every comment or suggestion must be addressed by the sub-committees. So, whether you agree or disagree, the time to offer your input is NOW!

Public comment will be accepted online until January 3, 2014. Go to www.nfpa.org/350. In order to comment, you must log in with your email and password – or you can quickly create an account.

Click here to download the PDF version. (Note: Download may take up to 3 minutes depending on your computer.)

READER QUESTION:
Is a new construction manhole considered a permit required confined space with the following activities being performed inside the space: overhead rigging, cutting welding, working off of six foot (6') step ladders? The task being performed is installation of new steam and condensate piping. Entry into the manhole vault is through a thirty six inch (36") round manhole opening into a vault. The vault is sixteen feet (16') deep. Entry is made by descending a twenty foot (20') extension ladder placed into the manhole opening. No other entry holes or exit holes. A 2000 cfm air mover is also in use for ventilation of the space. The area inside is congested with piping and valves being installed. Would this be considered a permit required confined space and would a rescue team be required?

ROCO TECH PANEL RESPONSE:
The answer to this question is complicated, and without actually seeing the space and without having familiarity of all the specifics surrounding the construction of the space, we cannot give you a definitive answer. However, there are several things you must consider when evaluating the situation.

You must determine whether the space falls under General Industry (29 CFR 1910) or Construction (29 CFR 1926) requirements. If the work is considered “maintenance,” the General Industry standards are applicable. If it is considered “Construction,” the Construction standards are applicable. OSHA generally considers any work that entails “keeping equipment in its existing state, i.e. preventing its failure or decline,” as “maintenance” work covered by the General Industry standard, even if the work is construction “type” work. 

From your description, it appears that the installation of new steam and condensate piping is part of the initial “construction” of the vault. However, other factors could affect that determination, such as whether the new steam and condensate lines are actually part of maintenance of an already existing piece of equipment. In that case, the vault itself may be new, but the work on the lines might be maintenance. 

If the General Industry standard applies, OSHA takes the position that the PRCS standard (29 CFR 1910.146) does not apply to welding, cutting, and brazing activities as long as the hazards introduced by the welding are the only hazards in the space, and the protective measures of Subpart Q - Welding, Cutting and Brazing, are adequate to prevent a hazard from developing. 

The protective measures of the welding standard would be applicable to the work in this space, specifically the following paragraphs of Subpart Q: 1910.252(a)(4)(i), 1910.252(b)(4)(i) to 1910.252(b)(4)(vii), 1910.252(c)(4), 1910.252(c)(9), and 1910.252(c)(10). All other hazards must be considered when making the determination of whether the PRCS standard applies. For example, if piping or other equipment will be lowered into the vault from overhead while workers are in the space, there would be a potential physical hazard not covered by Subpart Q that might require the space to be classified as a PRCS.

The General Industry standard for welding, cutting, and brazing activities does have certain requirements that are similar to some of the PRCS requirements. 

For example, it requires that where a welder enters a confined space through a manhole or other small opening means shall be provided for "quickly" removing him in case of an emergency. If harnesses or "safety belts" are used for this purpose, they have to be attached so that the welder's body cannot be jammed in a small exit opening. It also requires that "an attendant with a preplanned rescue procedure shall be stationed outside to observe the welder at all times and be capable of putting rescue operations into effect."

The General Industry welding standard also has certain specific ventilation requirements for spaces that are less than 10,000 cubic ft per welder, or in confined spaces where there are partitions or other obstructions that would obstruct cross ventilation. The minimum rate for such ventilation is 2,000 cfm per welder. It is important to keep in mind that the 2,000 cfm per welder is the actual air movement provided by the air mover, not the rated air movement. The ventilation must be configured to ensure that the air mover is not recirculating contaminated air back into the space. This would usually involve moving the air mover away from the entry point when there is a single opening, and ducting the air into the space. However, the use of ducting reduces the actual air movement. For example, an air mover rated at 2,000 cfm maximum will not actually be moving 2,000 cfm with 50’ of ducting having a 90 turn into the space. Each foot of ducting and each turn in the ducting reduces airflow. You stated that a 2,000 cfm air mover is being used. It is important to conduct the calculations for your ventilation configuration to determine whether you are actually moving the minimum 2,000 cfm. 

Until OSHA issues its final rule on confined space safety for the construction industry (ruling is expected in 2013), there is no detailed standard at this time. However there is a construction standard for welding that has specific requirements for welding, cutting, and brazing in confined spaces (29 CFR 1926.353). The rescue requirements are the same as for the General Industry welding standard. Additionally, the Construction welding standard requires that if sufficient ventilation cannot be obtained without blocking the means of access, the employees in the confined space must be provided with airline respirators, and there must be an employee outside the space assigned to maintain communication with the employees in the space and to provide assistance in an emergency. 

Obviously, to us, rescue capabilities are always at the top of the list. If the decision is made to follow the General Industry standard and consider the vault to be PRCS, then rescue capabilities and a plan need to be put in place. Depending on the conditions that exist in and around the space, rescue retrieval may be an option, such as a tripod and winch system with retrieval line attached to the entrant. In your description, however, you mention that internal elements that may hinder the ability to do external retrieval. If this is the case, then some type of internal rescue capability will be needed. 

When it comes to the response time, we think Appendix F 1910.146 explains it best… 

"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."

Thank you for your question, and we hope this information has been helpful. If we may be of further service, please don’t hesitate to contact us.


NOTICE: 
The information provided on our website or by our Tech Panel is a complimentary service for our readers. It is a general information resource for rescuers and is not intended as legal advice in any way. Because standards and regulations are typically performance based, and compliance with those standards and regulation is often dependent on the specific circumstances and conditions at hand, it is always important to carefully review all relevant standards and regulations, and to follow the proper protocols specific to your company or agency.