QUESTION: What is required for making multiple confined space entries, and can an Attendant/Hole Watch monitor more than one entry at a time?

ANSWER: Good question! And, the answer is YES according to OSHA 1910.146. However, each space must be evaluated on its own merits with all regulations and requirements applying to each individual entry. Here we will provide some tips when considering one Attendant for multiple entries. This is also where preparing comprehensive rescue preplans becomes essential, and we'll start there.

Suggestions for Writing Rescue Preplans

1.  One of the first things is to identify and categorize the space as “permit-required” or “non-permit required.” You’ll need to carefully consider the possible hazards based on the information gathered.

2.  Once you’ve identified the hazards, you’ll want to consider what actions might be taken to eliminate or control the hazard to allow for a safe entry. OSHA 1910.146 defines "acceptable entry conditions" as the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.

3.  Next, you would need to consider the type of work that is going to take place inside the space. A very important question to ask... could the work create its own hazard? (An example would include hot work being performed inside the space.) Then, what about rescue capabilities and requirements? Next, you’ll need to determine whether the entry should be considered “Rescue Available” or “Rescue Stand-by?”

Roco uses the terms “Rescue Available” or “Rescue Stand-by” to better prepare for safe entry operations and in determining more specific rescue needs for that particular entry. Here’s the way we use these distinctions...Rescue Available would be your normal entry that is NOT considered an IDLH (Immediately Dangerous to Life and Health)entry. In this case, a 10-15 minute response time for a rescue team would generally be sufficient to satisfy OSHA regulations and is typical during turnarounds where multiple entries are taking place.

On the other hand, we use Rescue Stand-by when a more immediate need is anticipated, such as with a hazardous atmosphere or potentially hazardous atmosphere. For example, with an IDLH entry, it may require the team to be standing by just outside the space in order to reach the patient in a timely manner (i.e., how long can you live without air...3 to 4 minutes?)  Or, how quickly can the entrant be engulfed where there is a potential engulfment hazard?  OSHA 1910.134 requires a standby person or persons capable of immediate action with IDLH atmospheres. (See reference below.)

OSHA Reference 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.

Regarding multiple entries, this Rescue Stand-by status could certainly limit the number of entries that could take place due to the availability of qualified responders and equipment. You must also consider that if you’re doing an entry that requires Rescue Stand-by and are called to respond to a rescue from a Rescue Available space, the entrants at the Rescue Stand-by entry must be evacuated before the team can respond. And, if there is only one rescue team, all other entries must stop during a rescue, as the team is no longer available.
Can an Attendant cover more than one confined space entry at the same time?

According to OSHA (see below), attendants can cover multiple spaces as long as they meet the responsibilities and duties at each entry site. If the spaces are “Rescue Available” and are in close proximity, this may be possible. However, without seeing the spaces and if they are on different levels as you mentioned, it could be very difficult for an Attendant to meet all of the requirements OSHA defines for Attendants.

OSHA Notes regarding Attendants and Multiple Entries...
NOTE to 1910.146(d)(6): Attendants may be assigned to monitor more than one permit space provided the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored. Likewise, attendants may be stationed at any location outside the permit space to be monitored as long as the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored.

1910.146(d)(7) If multiple spaces are to be monitored by a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendant's responsibilities under paragraph (i) of this section;

Once all these critical factors have been reviewed, you will need to consider the following when writing a rescue plan for an identical space:

    Internal configuration
    Elevation
    Portal Size

For hazards and LOTO procedures, you may be able to use the same rescue plan to cover those spaces. An example would be in doing ten (10) ground-level entries into 6-ft deep manholes, each with a 24” round, horizontal portal with a valve at the bottom. The rescue plan may be identical for all of these entries with the same description and hazards. However, on the rescue plan, you would need to allow for any unexpected hazards such as a possible change in atmosphere. This would be needed to be detected and properly handled by the responders at the time of the incident.

So, these are some of the basics you need to consider when writing a rescue preplan for confined spaces and for determining if (and when) an Attendant can effectively monitor multiple spaces.

If you have questions concerning these topics, please feel free to contact Roco at 800-647-7626.

Since 1999, Roco has had the opportunity to train and equip rescue teams in Kuwait. The first team that we trained was the Kuwait National Petroleum Corporation (KNPC) Fire Officers that were assigned to three refineries located south of Kuwait City.  In 2001, Ratqa Contracting was tasked with providing a Technical Rescue Team at the same refineries and Roco provided the Technician Level training for this new team.

The Ratqa Rescue Team is comprised of contracted Filipino’s with the oversight of a Kuwaiti Rescue Officer. Management is committed to making sure the team receives Rescue Technician recertification every two years from Roco.

Two of our instructors from New Mexico, Tim Robson and Rich Pohl, have been the predominant instructors for this 19 member team over the years.  Both agree that this is one of the most competent and dedicated rescue teams they have ever taught.

On a recent recertification trip, Rich and Tim were made aware of an event by Lead Rescue Officer/Coordinator Mohammed Al-Raqum and Fire Officer Khalid Al-Habri. Both officers wanted to recognize the efforts of the team for an exemplary response to an unfortunate event. Both Rich and Tim thought this would be the perfect forum to recognize this excellent Rescue Team.

In October 2011, the team was responsible for the removal of 4 victims that had succumbed to H2S in a PRCS that was 15-feet deep by 20-feet wide. The space was extremely congested and had over 15 different process lines. It included a 5-ft diameter by 20-ft high tank. The workers had originally entered the space to remove a skillet blind when there was an accidental release of H2S.  During the investigation, it was determined that KNPC policies and procedures had not been adhered to and the entry team did not have a permit nor did they perform atmospheric monitoring prior to entering the space.

The Ratqa Rescue Team on duty at the time of the incident was located approximately 10 minutes away at a neighboring refinery. Immediately, the Rescue Team Leader terminated their current standby operations and responded within 6 minutes to the scene by utilizing a “short cut” which minimized response time by 4 minutes.

Upon arrival, the Rescue Team did a scene size-up and then created a response plan with the Rescue Officer, which took approximately 3 minutes (atmospheric readings detected 120 ppm of H2S). Two vertical hauling systems were anchored, and Rescuer 1 donned an SCBA and made entry. Three victims were removed within 6 minutes via tied full-body harnesses and were found to be pulseless. Because of this, the Rescue Officer and Rescue Team Leader decided to convert to a “body recovery” mode for the 4th victim. Rescuer 1 was relieved and sent to rehabilitate. Rescuer 2 donned an SCBA and made entry into the space. Considerable time was needed to extricate the 4th victim due to numerous process lines that ranged in diameter from ½” to 4 inches. From initial dispatch to termination of recovery took 51 minutes. In addition, the outside temperature was 101 degrees Fahrenheit at the time.

Rescue Response Timeline:
Initial Dispatch to arrival on scene – 6 minutes
Scene Size-up / Hazard Recognition / Rescue Plan – 3 minutes
Rescuer 1 enters space and removes 3 victims – 6 minutes
Rescuer 1 exits space / Response-mode revised to Recovery mode– 21 minutes
Rescuer 2 enters and removes entrapped 4th victim – 15 minutes
Outside Temperature: 101-degrees F
Overall Time: 51 minutes

We commend the team for its rescue response capabilities and for dealing with this unfortunate incident in such a timely and professional manner. It has been our pleasure to work with these emergency responders over the years.

"The concept of LOTO is a great one and it works. As rescuers, we have to take the common industrial application and expand it to ensure that the rescue scene is safe and that we are controlling hazards at the point of contact with the victim or in a space where something has gone very wrong," says Dennis O'Connell, Chief Instructor and Director of Training for Roco Rescue.

Although commonly referred to as the “Lock-out/Tag-out” (LOTO) standard, the actual title of 1910.147 is “The Control of Hazardous Energy.” This title probably better describes it's true purpose -- and there's no doubt that the understanding of this concept has saved many lives and prevented countless injuries.

The LOTO standard “covers the servicing and maintenance of machines and equipment in which the energizing or start-up of the machines or equipment, or release of stored energy, could harm employees.” It establishes OSHA’s minimum performance requirements for the control of such hazardous energy [Ref: 1910.147(a)(1)(i)].

The general concept of LOTO is that energy sources affecting the area in which servicing or maintenance is occurring are identified and locked in the “Off” position, or in the case of mechanical hazards, linkages are disconnected for the duration of the work. Some type of lock or device is placed on the equipment by those performing the work.

However, we’ve found that if you ask different people to define LOTO, you will get a variety of answers. Not only will you get different definitions, you’ll also get varying information as to how and when LOTO is to be used and who is actually allowed to place locks or controls during the LOTO process. OSHA CFR 1910.147(b) has a very narrow and specific definition of who can perform lock-out or tag-out operations. That definition does not include rescuers; and, actually, there is good reason for that.

If you ask emergency responders about LOTO, you’ll generally find that their definition has been expanded well past the “control of hazardous energy” to cover most rescue operations. This expanded safety mindset serves to protect both the rescuer(s) and the victim(s) from additional harm following an incident. Rescuers usually define LOTO as “making the scene safe; or controlling and keeping machinery from moving or shifting during a rescue.”

Unlike standard LOTO, which is usually a systems’ approach, rescuers are generally trying to control the environment near an entrapped victim. As rescuers, we often act outside the parameters of a LOTO procedure that may already be in place. Because rescuers would best be defined under “affected employees” in a rescue where a LOTO procedure is in place, we need to understand what OSHA CFR 1910.147(b) says about “authorized employees” and “affected employees.”

Authorized employee. A person who locks out or tags out machines or equipment in order to perform servicing or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section.

Caveman translation: A person that the employer says has the systems or mechanical knowledge and authority to safely lockout/tagout a machine or space.

Affected employee. An employee whose job requires him/her to operate or use a machine or equipment on which servicing or maintenance is being performed under lock-out or tag-out, or whose job requires him/her to work in an area in which such servicing or maintenance is being performed.

Caveman translation: I have to work in an area where LOTO is in place.

A nice definition can be found in 54FR36665 in the promulgation of the Control of Hazardous Energy Standard...

“...an ‘affected employee’ is one who does not perform the servicing... but whose responsibilities are performed in an area in which the energy control procedure is implemented and servicing operations are performed under that procedure. The affected employee does not need to know how to perform lock-out or tag-out, nor does that employee need to be trained in the detailed implementation of the energy control procedure. Rather, the affected employee need only be able to recognize when the energy control procedure is being implemented, to identify the locks or tags being used, and to understand the purpose of the procedure and the importance of not attempting to start up or use the equipment, which has been locked out or tagged out.”

There is good reason for these prohibitions. Improperly performed LOTO can be just as dangerous, if not more so, than no LOTO at all. Allowing LOTO to be performed by personnel who are not familiar with the processes and equipment to be locked out increases the chances of improper lock-out. The requirement that only employees actually performing the servicing and maintenance of equipment are allowed to lock out equipment is less of a concern for rescuers than may first appear – and here’s why.

Typically, the person being rescued from a space that has hazardous energy sources is someone who has already performed LOTO. If that person performed LOTO properly and the reason for the rescue is something other than exposure to a hazardous energy source, the rescuers are not exposed because the victim obviously cannot remove his lock while he is being rescued. If the victim performed the LOTO improperly and the rescuers discover the error, the rescuers can then lock-out the equipment as they see fit or as the rescue needs dictate without violating the standard because they are not locking out the equipment as part of the LOTO program. They are locking the equipment out as part of making the area safe for rescue operations.

The Consequences: Worker's Amputation in Turkey Shackle Leads to $318,000 Proposed Fine

OSHA initiated an inspection after the July 20, 2011, incident, in which the employee’s arm allegedly became caught in an energized turkey shackle line while the employee was working alone in a confined space.

 Jan 24, 2012 - OSHA cited the company for 11 safety violations at its Wisconsin facility after a worker’s arm was amputated below the shoulder while the individual was conducting cleaning activities in a confined space. Proposed fines total $318,000. “The company has a legal responsibility to follow established permit-required confined space regulations to ensure that its employees are properly protected from known workplace hazards,” said Mark Hysell, director of OSHA’s Eau Claire Area Office.

  “Failing to ensure protection through appropriate training and adherence to OSHA regulations led to a worker losing an arm.”

OSHA initiated an inspection after the July 20, 2011, incident, in which the employee’s arm allegedly became caught in an energized turkey shackle line while the employee was working alone in a confined space. Afterward, the employee had to walk down a flight of 25 stairs and 200 feet across the production floor to get the attention of a co-worker for assistance.

Four willful violations involve not following OSHA’s permit-required confined space regulations in the carbon dioxide tunnel room, including failing to ensure that workers isolated the carbon dioxide gas supply line and locked out power to the shackle line prior to entering the room to conduct cleaning activities, verify that electro-mechanical and atmospheric hazards within the room were eliminated prior to workers entering the space, test atmospheric conditions prior to allowing entry, and provide an attendant during entries to the room.

Seven serious violations involve failing to provide fall protection, provide rescue and emergency services equipment, develop procedures to summon rescue and emergency

services, provide confined space entry procedures, prepare entry permits for the confined space, train employees and supervisors in entry permit procedures, and ensure that the entry supervisor performed required duties. This spells T-R-O-U-B-L-E.

Another Six-Figure OSHA Fine for LOTO Death

 Dec 14, 2011 - OSHA announced it has cited a Missouri recycling facility for 37 safety and health violations following an inspection opened after a worker died from injuries sustained June 12 when he entered a baling machine to clear a jam and the machine became energized. Proposed fines total $195,930.

 Twenty-two serious safety violations have been filed, including failing to lock out and tag out the energy sources of equipment and install adequate machine guarding; fall protection; exits; flammable liquids; fire extinguishers; powered industrial trucks; and welding and electrical equipment. Eight serious health violations were cited, as was a one repeat safety violation relating to defective powered industrial trucks that were not taken out of service. The company was cited in April 2010 for a similar violation, according to OSHA.

As rescuers we need to be aware that the LOTO standard applies to general industry operations and DOES NOT apply to the following:

•     Construction;
•     Agriculture;
•     Shipyards;
•     Marine Terminals;
•     Long shoring;
•     Installations under the exclusive control of electric utilities for the purpose of power generation, transmission and distribution, including related equipment for communication or metering;
•     Oil and gas well drilling and servicing;
•     Exposure to electrical hazards from work on, near, or with conductors or equipment in electric-utilization installations, which is covered by subpart S of the general industry standards;
•     Hot tap operations;
•     Continuity of service is essential;
•     Shutdown of system is impractical.

For some of the above operations, applicable regulations provide for procedures specific to the industry which, if followed, should provide proven effective protection for employees. However, rescuers need to be aware that activities in these areas not covered by OSHA’s LOTO standard could have uncontrolled energy sources. As we often say, “if everything had been done properly, we probably wouldn’t be responding as rescuers.”

In accordance with OSHA regulations, a LOTO program is a documented plan for safe work practices when dealing with energy sources. Prior to work commencing, potential sources of hazardous energy must be identified and controlled. Under certain circumstances where energy sources cannot be “locked out,” warning tags may be used. As responders, we do not have the luxury of studying blueprints and schematics to identify how to isolate the hazard. In fact, we’re most often responding to incidents that had a LOTO system in place that turned out to be ineffective or improperly used.

Rescue Scenario Examples

Rescuers were called to an incident in which a worker was trapped inside a confined space (a taffy mixing machine) that was supposed to be locked out. The machine suddenly activated; however, and the worker was seriously injured by the mixing blades. Employees on scene who initially locked out the equipment could not figure out where they erred – and they didn’t know how to prevent it from reoccurring as rescuers prepared to enter the space.

Not wanting to become victims themselves, the rescuers quickly considered several options to make the vessel safe for entry. They considered tying the blades so they couldn’t move, or wedging the blades against the side walls of the vessel, or disconnecting the motor. Because the patient was bleeding profusely, time was critical and all of these options would have taken too long. The rescuers ultimately opted to kill the power to the entire building, making the space safe for rescuers to enter. Fortunately, it was an option in this case. It may not have been an option where doing so would require shutting down an entire operating unit in a refinery or other industrial facility.

Another Incident during a Roco CSRT Stand-by

Another case of LOTO “gone bad” occurred during a Roco CSRT stand-by job at a local industrial plant. After LOTO had supposedly been performed, one of our team members happened to push the “Start” button as a test on a hyper bar in a tank – it turned “On!” Further investigation revealed that electrical work had been done in the area and the fuse lock-out was moved to another box adjacent to its original location. No one had notified the workers or changed the written protocol. Workers were locking out the wrong circuit! Had this been a rescue, how would rescuers control the hazard without knowing where the problem was with the LOTO?

Often overlooked, but another huge consideration for rescuers, is stored energy. OSHA identifies these hazards and provides a pretty good list of examples to be aware of when responding. It includes stored or residual energy in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc. Rescuers need equipment and techniques to control, restrain, dissipate, and immobilize these hazards. We also need the skills to manually isolate the area where the victim is located.

For general work operations, referring to LOTO as the placing of locks or tags or the removal of key controls may be sufficient. However, for rescuers, this alone may not provide adequate protection if those controls do not work or were never used.

From a rescuer’s viewpoint, our definition and options for effective LOTO needs to include other equipment and techniques that provide a safe area for rescue operations and to prevent further harm to the victim. This includes equipment that is used every day in the municipal rescue world that may not typically be found in an industrial facility. This includes equipment such as hydraulic spreaders and high pressure air bags. Even simple tools, such as metal wedges, can be used to isolate and protect the hand or arm of a victim trapped in a piece of machinery. The key is to determine your current capabilities and to identify what you may need prior to an incident occurring.

Municipal and industrial rescuers get called to a wide variety of rescues – each with its own unique problems and solutions. As we all know, the number of ways people can get themselves in harm’s way is unlimited! In all entrapment incidents, however, it is essential that we protect both the victim and ourselves from further injury and limit our exposure to the hazards that are present. In every incident, rescuers must first identify the hazards and try to eliminate or control them in every way possible.

Many times, as rescuers, we find ourselves using rudimentary “lock out” techniques. For example, when responding to stuck, occupied elevators in New York, we would access the control room, pull the power disconnect and use our handcuffs to lock it in the disconnect position. This was to prevent someone from turning the power back on while we were working in the shaft to free the victims from the elevator.

On more serious elevator rescues where the cables were slack, additional lock-out was achieved by using rated rescue rope/chains or cables to secure the elevator car so that it could not move up or down. Even during auto extrications, we would disconnect the battery to reduce the chances of an airbag deploying as well as not positioning ourselves between a rigid surface and an airbag.

Machine entrapment rescues are another all too common situation in which responders need to isolate the area at the point of contact with the patient to prevent further movement. In some cases, we have used wood or metal wedges to prevent further crushing, or chains, hydraulic tools, or cables to lock the machinery in place. And, rescuers beware... sometimes what sounds like a simple solution – such as turning off a machine – can do more harm if the machine normally recycles before coming to a resting position.

In Conclusion

From these examples, you can see that rescuers need to look deeper into their toolbox of techniques for creative options to isolate energy sources in order to protect themselves as well as the victim. And, this doesn’t just apply to municipal rescuers either. Industrial rescue teams are very likely to be called when an emergency like this occurs within your facility. In order to be proactive and prepared, take the time in advance to evaluate your response capabilities as well as that of local responders in your immediate area. Every minute is critical for that person trapped or injured.

Pat Furr reviews the importance of following OSHA safety standards for fall protection, and the steps an employer can take to ensure a safe work environment by providing high quality training. In the recent article by Mark Stromme, published in ISHN and on this blog, he addresses several myths regarding compliance with OSHA Fall Protection in the construction industry. Fact is, this wisdom applies to industry across the board.

OSHA Fall Protection Standards for Industry

It does not take long for an employer to realize that understanding the OSHA 29 CFR 1926 Subpart M standard is no quick and easy task. Fully adhering to this standard requires employers to complete a number of assessments, including the following:

    •    Evaluating areas that workers are exposed to fall hazards
    •    Developing work practices that eliminate or reduce the exposure to those fall hazards
    •    Selecting and installing suitable fall protection equipment
    •    Training employees on proper use of the equipment
    •    Inspecting and maintaining the equipment
    •    Developing rescue plans
    •    Re-evaluating the entire program on a regular basis

There’s no doubt, this can be a very daunting task – especially with all the other safety responsibilities we must deal with on a daily basis. But, I wanted to demonstrate that there is much more to providing a safe work environment for employees than handing them a harness and an energy absorbing lanyard.

Fall Protection Competent Person Essentials

One of the most important steps an employer can take towards developing an effective comprehensive fall protection program is to provide top quality training to their selected fall protection competent persons. By selecting the right person(s) for this position, the employer is assigning a degree of authority and expectations that the competent person will be very well versed in all there is to know about fall protection.

A common question we get from our former Competent Person students has to do with proper use of fall protection equipment. This is a critical function of the Competent Person, to provide the authorized persons training on the proper use of the selected fall protection equipment. As good as the equipment has become with modern materials, increased strength requirements, and functionality, we still are seeing equipment failures when subjected to forces they were not designed to see. If the authorized user is using the equipment outside the manufacturers’ instructions for use, that means the training has fallen short. No pun intended.

Roco's Fall Protection protocol challenges employers and current competent persons to ratchet up their diligence in providing high quality training to the folks that are counting on them. Employers must seek out truly effective Competent Person training programs and avoid programs that are more interested in selling product than delivering the instruction that the students need. Once the employer is satisfied that the competent person has the appropriate level of knowledge and experience, they complete written documentation attesting to such as described in the following article.

Now the ball is in the Competent Person’s court. With support from the employer, it is of paramount importance that the competent person continues educating themselves on everything “Fall Protection.”  Divide time between the OSHA and ANSI standards, new product information, fall protection “Walkabouts” at your facility, to include rescue provisions, and continuous monitoring of the work practices of the authorized persons.

There is always the need for continued fall protection training at every level. Make sure your team is properly trained and equipped to avoid injuries, fatalities, penalties or both. Check out Roco courses for Fall Protection/Competent Person by clicking here.

As an employer with permit-required confined spaces, you’ll need to determine if your rescue team or selected rescue service can truly “walk-the-walk” when it comes to confined space rescue. OSHA’s Permit Required Confined Space Standard (1910.146) is “performance-based” – meaning it’s all about capabilities when the stakes are high.Conducting a performance evaluation of your rescue service is a vital component in determining their true capabilities as well as fully meeting the performance requirements of 1910.146.

The Dilemma

Determining the adequacy of the team’s rescue capability can present a dilemma for many employers. That is, does the employer have the depth of understanding in technical rescue required to administer an accurate, meaningful performance evaluation? Do they know what to look for in terms of proper equipment use, efficiency, compliance with industry standards, and required safety systems – just to name a few. If not, is it then possible that the team may not be able to affect rescue when the need arises?

As we know, it’s quite easy to demonstrate a rescue capability for a very “straight forward” situation. This is what we call a “Dog and Pony Show.” They tend to be very controlled and scripted to ensure that everything goes smoothly. Unfortunately, when there’s an actual emergency, it seems the victims never get a copy of the script. Unless the rescue team or service is prepared for the “other than straight forward” rescue, the operation has little chance of going smoothly. There are still way too many incidents involving injury or death to would-be rescuers that can be directly attributed to lack of proficiency in the type of rescue being attempted.

The Guidance

Fortunately, Appendix F (Non-Mandatory) of 1910.146 provides guidance for employers in choosing an appropriate rescue service. It contains criteria that may be used to evaluate the capabilities both of prospective and current rescue teams. For all rescue teams or services, the evaluation should consist of two components:

An initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform permit space rescues of the kind needed at the facility and whether such rescuers can respond in a timely manner.

A performance evaluation, in which employers measure the performance of the team or service during an actual or practice rescue.

Another way to break down these two evaluation components is something like this… 
(1) The initial evaluation is to determine if the rescue service can “talk-the-talk”; and, (2) the performance evaluation is to determine if the rescue service can “walk-the-walk.”

During the initial evaluation the employer should interview the prospective rescue service or team to determine response times, availability, a means to summons in the event of an emergency, reciprocal communications should the service/team become unavailable, whether they meet the requirements 1910.146 paragraph (k)(2), and whether they are willing to perform rescue at the employer’s workplace.

Additionally during the initial evaluation the employer should determine if the rescue service/team has the necessary equipment to perform rescues. This includes both technical rescue equipment and if a space may pose a significant atmospheric hazard which requires entry rescue, does the team/service have adequate supplies of SCBA [or SAR].

ROCO NOTE:  Another aspect often overlooked is HazMat capabilities… does the team have the proper training and PPE to protect themselves from the particular hazards they may face? Can they deal with de-con issues that may result from exposure? Or, as the employer, will you provide the appropriate PPE and decon?

Finally, the employer should evaluate if the rescue team/service has the technical knowledge for vertical rescues in excess of five feet, the knowledge of rope work or elevated rescue, if needed, and the necessary skills for medical evaluation and patient packaging. Other than the visual and/or physical review of the rescue equipment; and, if necessary, emergency breathing air, the initial evaluation of the team/service is primarily completed through interviews and a review of training documents. In other words, can the team or service “talk-the-talk”?

Therefore, it is simply not enough for an employer to rely on the initial evaluation. While it’s a good start in narrowing the field of prospective rescue team/services, it is incumbent on the employer to determine if the rescue service can indeed walk-the-walk.  And the only way to ensure that is to complete a performance evaluation during an actual or practice rescue from the actual or representative types of spaces that they may be summoned to.

The Third Party Advantage

Performance evaluations can be administered to a prospective rescue service, or as a periodic evaluation of current rescue services. As an option, an employer may choose to use a third party that has extensive experience in this type of rescue.

This is especially beneficial when employers may not have the in-house expertise necessary to administer an accurate evaluation, or for employers who are more comfortable with having a third party evaluation as a documented, independent, and unbiased record of the rescue service/team’s capabilities.

As an independent evaluator, Roco has conducted these team (TPE) and individual (IPE) performance evaluations for many years using specific grading criteria. It is a valuable tool for the employer to ensure and document that the selected rescue team/service (whether an outside service or in-plant team) has the required proficiencies for rescue at their facility. These TPE/IPEs also provide a degree of refresher training that will help bring the team/individual up to the level they need to be.

In rare instances, our recommendation may be that the team requires more than spot training in order to meet an acceptable level of proficiency. Another benefit of third party TPE/IPEs is that it may be an opportunity for the evaluator to recommend minor changes in equipment or techniques that would enhance the capability of the team. In fact, Section B of Appendix F states,

“As part of each practice session, the service should perform a critique of the practice rescue, or have another qualified party perform the critique, so that deficiencies in procedures, equipment, training, or number of personnel can be identified and corrected.”

Another area where third party evaluations are beneficial is when contractors will be providing their own rescue capability. Some host employers mistakenly believe that theyare relieved of all responsibility when the contractor’s employees are performing the entries. But 1910.146(c)(8) and (9) place reciprocal responsibilities on both employers to each other. This includes the host employer informing the contractor that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146, and the contractor informing the host employer of the permit program it will be following.

Although this paragraph of the standard lacks specific direction, it certainly contemplates that the host employer cannot turn a “blind-eye” to deficiencies in the program presented by the contractor – including insufficient rescue capabilities. A team performance evaluation would be helpful in determining the contractor’s ability to provide rescue services for their employees. While some host employers may be qualified to evaluate contractor’s technical rescue capabilities, that is usually not the case.

Keeping Skills Fresh

Employers must also realize that technical rescue skills are very perishable. While a team or individual can successfully complete rescue training and attain a high degree of proficiency, regular practice is crucial to maintaining these skills. Unfortunately, all too often, the time and resources required to maintain this level of proficiency are not provided. How quickly these skills erode will vary. However, even with the most experienced rescuers, they will eventually lose their edge if practice time is not provided. For newer rescuers that complete their training but don’t the chance to practice fairly soon, their skills can erode at an incredibly fast rate.

The degree of difficulty for the anticipated rescues must also be considered. When more complex rescues are involved, teams may require even more training and practicetime to maintain their level of expertise. And, while a training certificate is good to have, the only way an employer can truly know if the rescue team/service meets the OSHA performance requirement for confined space rescue is by completing a properly administered performance evaluation.

For all those employers who have workers entering confined spaces to work, we hope that you will carefully consider this rescue evaluation process – it could save a life or even prevent multiple fatalities. For you rescuers out there, we hope that you will do everything you can to maintain and increase your proficiencies – so when the time comes, you can walk-the-walk with pride in a job well done.

If you would like additional information on a documented Team Performance Evaluation for your rescue service, please contact Roco at 800-647-7626.