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?
- 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.”