Simply put, No. We get this question all the time. Sure, with proper vetting of the rescue service and mutual agreement, you can list 911 as your rescue plan within your Permit Required Confined Space Entry program. However, there are clear precautions that must be taken and put into place.

In the world of OSHA Standard language, we have a clear answer in this case. OSHA 1910.146, Appendix F spells it out very clearly.

“The employer should meet with the prospective rescue service to facilitate the evaluations required by 1910.146(k)(1)(i) and (k)(1)(ii). At a minimum, if an off-site rescue service is being considered, the employer must contact the service to plan and coordinate the evaluations required by the standard. Merely posting the service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

You cannot get a much clearer answer than that from an OSHA Standard. And, keep in mind, while Appendix F is listed as “non-mandatory,” this does not mean that you do not have to comply with it. Using the method described is the non-mandatory part.

So, no, you cannot simply list 911 as your rescue service. You can however make an agreement with a private or municipal rescue service to provide that service provided you have evaluated the service to determine that they can perform the confined space rescue services needed for your facility.

If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying you so that the entry operation can be canceled?

For the employer, this is where an evaluation of the rescue service comes into play. OSHA 1910.146 Appendix F clearly outlines the need for employers to evaluate a prospective rescue service before relying on their services.

Once that occurs, one of the biggest challenges is determining how to make sure the municipal rescue service is available when you need them. Will they be available when you are ready to make entry, and what if the rescue service gets another call? If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying you so that the entry operation can be canceled?

Evaluating Rescue Response Capabilities

According to OSHA, the rescue service must be evaluated for:

• Ability to respond in a timely manner considering the hazards identified.
• Proficiency with rescue-related tasks and equipment.
• Ability to function appropriately while rescuing entrants from types of permit spaces identified.

The rescue service selected must be:

• Capable of reaching the victim(s) in a timely manner appropriate for the hazards identified.
• Equipped and proficient in performing the needed rescue services.
• Willing to provide the service. Employers may not rely on an outside service that is unwilling to provide rescue services.

Appendix F provides a valuable means to ensure that both the rescuers and the employer know the requirements and that proper agreements are in place prior to confined space entry operations. Roco Confined Space Compliance Guide and Types Chart includes Appendix F along with information and checklists for conducting an (A) Initial Evaluation, and (B) Performance Evaluation.

Critical factors include response time and availability. According to OSHA, the response time must be appropriate for the types of known or potential hazards affecting the confined spaces at the employer’s facility – and the rescue service must be available to respond in a timely manner during entry operations.

It is the employer’s responsibility, both morally and legally, to engage with the rescue service that is being considered. If you have identified an off-site team as the contracted rescue service in your confined space program, which includes municipal rescue, it is crucial that you take all the necessary steps to vet the agency as being a good fit to protect your employees. To document the arrangement, a written agreement is highly recommended. Click here to view a Sample Agreement to Provide Rescue Response.

Confined Spaces Require Special Rescue Skills and Equipment

Other than larger municipal departments, it is rare for local emergency responders to have the required confined space rescue resources including specialized training and equipment. Any shortfalls in an effective response must be addressed by the employer or confined space owner. This includes training, equipment, staffing, or other requirements to ensure a response appropriate for the types and hazards of the spaces onsite. Any rescue service would need to be trained and equipped in advance to face the many hazards and obstacles of permit-required confined space rescue.

OSHA states in section (d)(4) of 1910.146 that “the Employer shall provide rescue and emergency equipment needed to comply with paragraph (d)(9) of this section, except to the extent that the equipment is provided by rescue services…” This is where an employer and a public safety agency may enter a cooperative arrangement beyond what is expected of the emergency responder's normal response duties.

Conclusion

With careful planning, thorough communications, and proper training and equipment, relying on a private or municipal rescue response for confined space rescue can work. As an employer, it is your responsibility to make sure the rescue service is adequately prepared, equipped, and willing to provide confined space rescue services.

Additional OSHA References:

1910.146(d)(9) Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue;

1910.146(k)(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of 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;

1910.146(k)(2)(i) Provide affected employees with the personal protective equipment (PPE) needed to conduct permit space rescues safely and train affected employees so they are proficient in the use of that PPE, at no cost to those employees;

1910.146(k)(2)(ii) Train affected employees to perform assigned rescue duties. The employer must ensure that such employees successfully complete the training required to establish proficiency as an authorized entrant, as provided by paragraphs (g) and (h) of this section;

1910.146(k)(2)(iii) Train affected employees in basic first-aid and cardiopulmonary resuscitation (CPR). The employer shall ensure that at least one member of the rescue team or service holding a current certification in first aid and CPR is available; and

1910.146(k)(2)(iv) Ensure that affected employees practice making permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed.

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.

Additional Resources

• Confined Space Types Chart (pictured here) 
• Evaluating Your Rescue Service 
• Agreement to Provide Rescue Response
  
• Requirements for Rescue Plans

ANSWER: As a Paramedic, I strongly feel that having your rescue personnel trained to the EMR (Emergency Medical Responder) level is extremely beneficial for any industrial site. While EMR training is not required, it can truly make the difference in a life-or-death situation. From my personal experience, we found time and time again how this extra medical care made all the difference when responding to an incident.

Not only is the skill-level of first responders critical in an industrial emergency – many times the industrial site is fairly isolated. This can increase response times when rapid, critical care is so vital. Plant access and finding the exact location may also present potential delays to medical care. With EMRs initially on scene with your rescue team, you can know that your personnel are receiving a higher level of care when it matters most.   

To clarify, an Emergency Medical Responder (EMR) is a well-versed medical responder who can attend to basic needs in a critical need situation. EMR’s are nationally certified or state-licensed medical responders generally tasked with providing immediate emergency care to the sick and injured before an ambulance or higher level of care arrives.

While basic first aid and CPR may be the minimum required for rescue personnel OSHA 1910.146(k)(2)(iii), an EMR is trained to provide more enhanced care – particularly, inside a confined space or for a worker who is stranded at height. Plus, they can be there almost immediately with your rescue team to provide aid. The EMR can help with airway protection, bleeding control, mechanical ventilation, symptom recognition and support of vital functions until more advanced care is reached.

So, minimally, someone on your team needs to be certified in first aid and CPR training. And, while the techniques taught in most nationally recognized First Aid and CPR courses are great for lay folk responding in environments tamer than the industrial setting – the skills, clinical knowledge, and logistic awareness taught in the typical EMR class are a far better fit for confined space rescuers. If you’re looking to give your organization the greatest peace of mind and the best chance to avoid tragedy, we highly recommend EMR training.

Key Medical Questions for ERT Coordinators include:

• Based on hazards identified at your facility, what types and degrees of injuries could patients sustain while at your facility?
• What is the estimated response time for EMS/Fire Department? Is the service familiar with your facility and the potential hazards? Chemical, Mechanical, etc.
• How will EMS access your site, or will the patient be taken to a staging area?
• If air medical transport is necessary, has the facility coordinated a landing zone with EMS/Fire/Sheriff's office?
• Who at the facility will assess the patient and give the information about the patient's condition to EMS?
• Where is the nearest emergency room? Is the ER familiar with your facility and the potential hazards? Chemical, Mechanical, etc.
• What types of drills can your facility conduct, with or without EMS/Fire, to better prepare facility personnel for an emergency?

Prior to coming to work for Roco Rescue, Chris Warrick worked the street as a paramedic for three years, and then three years as a paramedic instructor. He was the section leader for “Cardiology” as well as “Anatomy and Physiology,” and “EMS Operations” at various times. Chris holds an AAS in Paramedicine from South Louisiana Community College and is also certified to teach BLS and ACLS through the American Heart Association. He is also a licensed EMS educator in Louisiana. As a Paramedic, Chris has responded to hurricanes: Harvey, Michael, Laura, Delta, and Ida. As Medical Program Manager for Roco Rescue, Chris oversees medical protocols, procedures, equipment, and education alongside our medical director. 

Follow Chris 

Additional Resources

• What to Look for When Choosing Medical Training for Emergency Response and Rescue Teams

• Emergency Medical Responder Course

• First Aid CPR and AED Training Course

We were so excited to see all the applicants for our Fire Department Scholarship Program – we decided to pick 10 instead of 1! The following individuals were selected to attend a Roco Urban/Industrial Rescue Essentials™ Course at no charge at the Roco Training Center in Baton Rouge. 

Roco Rescue hopes that this free training will help broaden the range of skills in confined space and rope rescue for firefighters and their departments.

Click button below if you are interested in applying for the next Fire Department Scholarship Program selection.

Offer valid for USA-based emergency responders only based on space availability. Must be 18 years or older and physically fit to participate in hands-on rescue exercises. Offer is valid for limited time and subject to change without notice. 

Roco Rescue was the proud recipient of a support and dedication award from the Baton Rouge Fire Department recently in a ceremony conducted at the Roco Training Center in Baton Rouge. Fire Chief Michael Kimble and Paul Stockstill presented the plaque to Chris Carlsen, Director of Training for Roco Rescue, along with several Roco Instructors.

“We wanted to give Roco something to thank them for all that they have done to help BRFD bring their rescue training to the next level,” Chief Kimble said. He added, “We share a common mission to keep emergency responders trained to respond safer and more effectively.”

Roco will continue its efforts to maximize support for municipal emergency responder wherever we can. Roco has the unique opportunity to influence not only the regulatory frameworks that shape the rescue industry, but also the techniques that are used by emergency responders on a daily basis.

This plaque from the BRFD acknowledges Roco’s on-going efforts to support emergency responders and is therefore very special to us. It is an honor to be recognized.

Your company has a strong safety culture with outstanding employee participation. Everyone is committed to safety and goes out of their way to do things in the safest way possible. As a safety professional, everything is great in your world until suddenly, a “near-miss” report lands on your desk. Supervisors, managers, and company executives are now concerned, worried, or even stressed out about the fact that something unsafe just happened at their company! Many would-be quick to speculate that a near miss is a bad thing; however, as a safety professional, you know that this is not necessarily the case. The reality is, a near-miss or “good catch” report can be one of the most valuable tools for improving your company’s safety program.

What is a Near Miss?

According to OSHA, a Near Miss is an unplanned event that did not result in an injury, illness, or damage – but under different circumstances, could have. Your company may have another term for a near miss such as “close call,” “good catch,” “narrow escape,” “near hit,” “cliffhangers,” or a number of other terms. However, at the end of the day, these are all near misses. Near misses are caused by the same things as accidents: unsafe conditions and/or unsafe behaviors. Near misses are often precursors to accidents and should not be ignored. In fact, according to the National Safety Council (NSC), 75% of all accidents are preceded by one or more near misses.

Heinrich’s Law and Bird’s Safety Triangle

In 1931, Herbert Heinrich published Industrial Accident Prevention: A Scientific Approach where he proposed a concept that would eventually become known as “Heinrich’s Law.” Heinrich’s law states that for every accident that causes a major injury, there are 29 accidents that cause minor injuries and 300 accidents that cause no injury (i.e., near misses).

Years later, Frank Bird analyzed nearly 2 million incident reports from over 300 companies and used his findings to amend and expand upon Heinrich’s theory. Bird developed the “Safety Triangle” (depicted here) which states that for every fatality, there will be 10 serious accidents, 30 minor accidents, 600 near misses, and an unknown, but significant number of unsafe acts. The important thing to take away from this is that near-miss reports should be taken seriously, investigated, and used to prevent future incidents.

Near Miss Reported – Now What?

A Near Miss report is submitted. You’re thankful that it wasn’t an injury report, but you also realize that this could have easily been one under different circumstances. You also realize that this is a potential precursor to something worse, so now what? The answer – Root Cause Analysis. There are many different models to choose from when conducting RCAs. The “5-why” is one of the most popular choices due to its simplicity; it is also recommended in ANSI Z-10 Standard for Occupational Safety and Health Management Systems. There are other formats that are equally effective such as the fishbone diagram, also known as the Ishikawa diagram, Failure Mode and Effects Analysis (FMEA), scatter plots, and many others. What format or method you choose is not as important as actually performing RCAs in the first place. The key takeaway here is, use whatever format you are most comfortable with, as long as you ensure that RCAs are performed when necessary.

There’s almost always a deeper root cause to why a near-miss occurred. While there may be an obvious reason on the surface level, by digging a little deeper into the situation, you may find that there’s more than meets the eye. Correcting the immediate cause may help to resolve the symptom of the problem, but not the problem itself.

For example, a worker at your facility slips in a puddle of water on the floor and falls. The worker is not injured and as a result, a near-miss report was submitted. The investigation should not conclude with “employee slipped in puddle and fell – instructed employee to be more aware of their surroundings.” An effective root cause analysis would instead look for deeper issues, such as:

• Why was the puddle there in the first place?
• Where there changes in the environment, weather, conditions, or a process?
• What was the source of the water?
• What tasks were being performed when the water was spilled?
• Why was the water not cleaned up?
• How long was the water there?
• Was the spill reported?

By performing a root cause analysis, you may learn that it was raining on the day of the near-miss and that the roof in your warehouse has developed a leak, causing a puddle of water to form, creating the unsafe condition that led to the incident. Simply instructing the employee to be more aware of the surroundings may prevent them from slipping again; however, it will not prevent the unsafe condition from reoccurring. The true root cause needs to be addressed; the roof must be repaired.

OSHA provides a great resource for Root Cause Analysis here.

Improving Your Company’s Near Miss Program

You’ve received a near miss, conducted an investigation, identified a true root cause, and took corrective action to eliminate it; now you see the tremendous benefit of near-miss reporting. Then ask what can you do to improve your company’s near-miss program?

1. Keep the reporting process simple.

Consider implementing google forms, phone applications, or even a universal near-miss email address. The key is to make the process to submit a near-miss as easy, quick, and painless as possible. For example, many companies now create QR codes that can be scanned, taking personnel right to the form to complete and submit. This can all be done for free with readily available resources around the internet.

2. Train employees on the importance of near-miss reporting.

If employees don’t recognize the importance of near-miss reporting, they will have no interest in doing so. Ensure that employees know the benefits of near-miss reporting.

3. Keep near-miss reports non-punitive.

No one wants to willingly broadcast their mistakes, especially if they will be punished for doing so. Punishing an employee who submits a near-miss report is a sure-fire way to send a message that safety may not rank as high on the priority list as you claim. This is also a guaranteed way to discourage employees from participating in the program. On the other hand, when near-miss reporting is rewarded, it can change their mindset.

4. Incentivize the program.

Even if employees know the benefits of a near-miss program and know that it will be non-punitive, they may still need a little encouragement to do so. Consider implementing a periodic drawing for all who submit near-miss reports. Alternatively, consider highlighting the best near-miss submitted for the month to promote quality participation.

5. Celebrate and communicate your success.

Perhaps the most important part of a successful near-miss program is communicating your findings and celebrating your success. Communication should be transparent but does not have to be so transparent that it includes every detail of the situation. Include highlights of the near-miss and the corrective actions that will be taken to prevent them in the future. Communicating your findings could help prevent other incidents as well.

Summary

When your employees know they can openly report an incident or mishap without being reprimanded, it can encourage more open communications and improved safety awareness. Most certainly, it gives you the opportunity to take corrective action and prevent a more serious injury, or worse. Actively promoting employee involvement via near-miss reporting will provide a boost to your overall safety program and result in a safer worksite for everyone. A “good catch” is a good catch for all concerned.

Chris McGlynn is a dynamic safety leader who serves as the Director of Safety at Roco Rescue and is dedicated to amplifying the company's safety success. As a Certified Safety Professional, Confined Space and Rope Rescue Technician, and Paramedic, Chris leverages his expertise to provide employees with the necessary tools, training, and support to work safely and efficiently. He also oversees Roco Safety Services, offering high-caliber safety professionals for special projects and turnarounds. As the VPP Coordinator, Chris ensures that Roco maintains its status as an OSHA VPP Star Worksite, continuing the company’s unwavering commitment to excellence in safety and health. Roco has been an OSHA VPP Star Worksite since 2013.

Follow Chris 

Additional Resources

• Want a Safer Workplace? Get Employees Involved!

• How to Make an Impact as Safety Professionals