Question:  If I close and Lockout/Tagout the main valve on the natural gas line supplying a boiler unit – does this satisfy OSHA’s requirement for eliminating the hazard of a permit required confined space?

Answer:  No, it does not. You are asking a question that we address quite often and it reveals some misconceptions regarding “eliminating” or “isolating” the permit space from hazards. Lockout/Tagout (LOTO) procedures are covered in OSHA’s 1910.147 “Control of Hazardous Energy (Lockout/Tagout).

” Many times this regulation is incorrectly referenced when addressing permit space hazards that are not covered by this regulation.
OSHA’s 1910.147 LOTO regulation applies to the control of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. It does not apply to engulfment hazards (liquid or flowable solids), flammable gasses, or other gasses that may be toxic or oxygen displacing.

It is important to understand this distinction because the use of isolation procedures appropriate for the hazards addressed in 1910.147 may not be effective in eliminating other hazards.  “Isolation,” as defined in the Permit Required Confined Space regulation (1910.146) spells out the various measures required to eliminate hazardous energies as covered in the LOTO regulation as well as the types of hazards that are not addressed in that regulation.  You will note that 1910.146 cites LOTO as a means to isolate all sources of energy (emphasis added), but outlines other methods used to isolate the other hazards such as hazardous materials. These isolation procedures include the process by which a permit space is “removed from service” and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

By closing and placing a LOTO device on a single valve of a natural gas feed line, you may have controlled the hazard but you have not eliminated it. To provide true isolation (elimination), you will have to employ such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; or a double block and bleed system.

Download the LOTO tip sheet from NIOSH.

Here’s an “ON THE ROAD” segment by Roco Chief Instructor and Director of Training, Dennis O’Connell.

I just got back from Beaumont, Texas, where I taught our new 50-hour Industrial Rescue I/II. In this class, we focus on preparing responders for the unique challenges of industrial rescue – whether you’re a member of an industrial team or a municipal firefighter who may respond to plants or manufacturing facilities.

And if you’ve taken ROCO classes in the past couple of years, you know we’re constantly updating our techniques and equipment as we try to find safer and more efficient ways to do rescue.

It’s been a number of years since ROCO has conducted training in Beaumont and it was good to be back. The BEST Complex offers excellent facilities for industrial and municipal emergency response training – both in firefighting and rescue. The multiple confined space props and 6-story training tower make it an ideal place to conduct high angle and confined space rescue classes. These training props give students realistic anchoring and industrial confined space rescue situations that enhance the techniques taught during the class.

Roco’s Industrial Rescue I/II class provides rescue skills and techniques to handle the vast majority of rescues a team would face in a plant or refinery. The class covers both inert rescue procedures as well as on-air IDLH entry rescue. The first three days are dedicated to skills and techniques while the last two include a variety of scenario-based exercises using the skills learned. One of the nice things about the Beaumont facility is the ability to practice rescues from all six types of confined spaces as referenced in OSHA 1910.146 as well as practicing rescue from height which is often overlooked during confined space training.

This particular class consisted of a mix of firefighters and industrial plant and refinery workers – some brand new to the rescue world and others with a lot of experience. Some of the more experienced rescuers took the class as a “back to basics” review and to meet their annual “confined space types practice” for the year. However, even the experienced rescuers in the class found a few new ways to use the equipment and get the job done.

Most of the students were from the local Beaumont-Port Arthur area, but we did have students from other parts of Texas and some as far away as Alaska. I think the Alaskans were ready to head back to the “minus 30 degree” weather north of the Arctic Circle after experiencing a week of temperatures hovering around 100 degrees!

For our readers who may use Petzl GriGri 2’s, we wanted to make you aware of this recall. Please check the serial number of your device to see if it’s in this range. You will also need to contact Petzl as indicated below. As noted, this does not apply to the previous generation GriGri.

NOTICE FROM PETZL
As a measure of precaution Petzl has decided to take the following actions:

Increase the mechanical strength of the handle on all GRIGRI 2’s since serial number 11137. Recall all GRIGRI 2’s with the first five digits of the serial number between 10326 and 11136, and replace with a new revised GRIGRI 2. Petzl will pay for all shipping costs to complete this replacement.

If you have a GRIGRI 2 (D14 2O, D14 2G, D14 2B) with the first five digits of the serial number between 10326 and 11136, stop use immediately and contact Petzl America to initiate an exchange.

Contact Petzl America in one of two ways:

•     By phone: 1 (800) 932-2978 (toll free)
•     By email: grigri2recall@petzl.com

The previous generation GRIGRI is not concerned by this recall.

Well, maybe not half the time, but certainly some fraction of the time.

In How to Haul a Victim in Half the Time: Part 1, we covered ways to reduce the time needed to haul a rescue package by taking advantage of changes of direction.

Here, we want to address OSHA and ANSI guidance regarding retrieval systems – specifically mechanical devices used for rescue.

OSHA 1910.146(k)(3) states “To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.

Additionally, OSHA follows the ANSI Z117-1-1989 approach that was in effect at the time of OSHA 1910.146 promulgation, which states, “A mechanical device shall be available to retrieve personnel from vertical type PRCS’s greater than 5 feet in depth.” It also adds, “In general, mechanical lifting devices should have a mechanical advantage adequate to safely rescue personnel.”

Subsequent revisions to ANSI Z117 included the recommendation that “The mechanical device used should be appropriate for rescue service.” The revised standard adds,“Mechanical lifting devices should have a mechanical advantage of at least four to one and the capacity to lift entrants including any attached tools and equipment.”

Two key points that must be considered: (1) OSHA follows the ANSI approach that was in effect at the time 1910.146 was promulgated which did not recommend a minimum mechanical advantage ratio; and, (2) The rule makers intended to leave a degree of latitude for the rescue service to select a lifting device that is most appropriate for the particular situation encountered.

Roco’s rule of thumb is… the mechanical device used should be appropriate for rescue service – and the employer should not use any mechanical device that could injure the entrant during rescue, which would include a mechanical device with too great a mechanical advantage (MA) for the number of people operating the system. Here’s a guideline we use for determining the proper number of rescuers for a particular system – it should take some effort to haul the victim, but not so much effort that it wears the rescuers completely out. And, it should not be too easy, or you won’t as readily feel if the victim gets hung-up.

Because 1910.146 is a performance-based regulation, it does not specify the rescue procedures that are most appropriate for any given PRCS. It leaves this to the responding rescue service based on their assessment of the PRCS in terms of configuration, depth, and anticipated rescue load. Current ANSI Z117 recommends that the MA “should” be at least four to one. Notice that it does not state “shall” and thus the discretion of the rescue service is taken into account. A generic recommendation of a 4:1 is a good start but should not be considered as a catch-all answer to the problem of lifting the load. Even a 4:1 may not be enough if the person doing the hauling is not strong enough and may require a greater M/A in order to remove the load from the space.

Must we always use a minimum MA of 4:1, or could there be justification in using an MA below the 4:1 ratio when there is a need to provide a faster means of hauling the rescue package? Consider the possibility of reducing the mechanical advantage ratio when there is plenty of haul team members. If you have 4 haul team members for a 250 pound rescue package, do you really need that 4:1 MA? Consider going with a 3:1 or even a 2:1, especially if the throw is short and the haul is long. However, keep in mind that the package will be traveling much faster by reducing the MA – so it is imperative that a “hole
watch” be assigned to monitor the rescue package and be ready to call an immediate “STOP” should the package become hung up.

Caution: If you’re using a piggyback system, make sure the haul team does not outpace the individual taking in the mainline slack through a ratchet device. Should a lot of slack build up in the mainline and the haul team lose control of the haul line, the resulting free-fall of the load could spell disaster. Of course we always encourage the use of a safety (belay) line, but on rare occasions the urgency of the rescue may warrant not using a safety line on the victim.

Ultimately it is the employer’s responsibility to evaluate the selected rescue service’s ability to provide prompt and effective rescue. If the rescue service is able to demonstrate their capability using an MA that is less than the current ANSI recommendation, then that would meet the performance-based nature of the standard. In reality, by using a reduced MA, the time required to extricate the rescue package can be cut by 1/3 to 1/2 depending on the situation. In certain emergencies, that saved time could very easily mean the difference between a successful rescue and a body recovery.

Roco Rescue, Inc. and the Beaumont Emergency Services Training Complex (BEST Complex) have announced a partnership to deliver more options in rescue training for fire departments and industry.

In addition to open-enrollment rescue training, Roco’s private courses will also be available.

Upcoming Roco events scheduled at BEST include:

Oct 5-6,  2011 – Rescue Challenge
Dec 5-8, 2011 – Rescue IV-Advanced Rescue Scenarios

The partnership marks a return for Roco to the Southeast Texas facility. For many years, BEST (the former Beaumont Fire/Rescue Training Center) provided a great venue for Roco’s rope rescue and confined space training programs. The location is convenient and economical for many clients in the Texas industrial corridor and surrounding states.

Based on the early success of the partnership, both Roco and BEST say they will be adding more dates and courses to the 2012 open-enrollment training schedule. New offerings will include Confined Space, High Angle, Structural Collapse and Trench Rescue. This will provide additional training options for municipal and industrial rescue teams in the area. It’s a win-win-win.

For more information about Roco training at the BEST facility, contact  Aimee Sims at Roco (800-647-7626).