By Pat Furr, Roco Chief Instructor/VPP Coordinator 

It is still happening out there, folks. Fatalities are still occurring during permit required confined space entries. Unfortunately, workers are dying because the permit space (or the entrant) was not properly prepared prior to entry. And, tragically, many of these fatalities are the would-be rescuers, who are trying to aid their co-workers! Most often, these would-be rescuers are authorized attendants or passersby that reacted improperly and took heroic, but inappropriate action. Or they may have been professional rescuers, who were not trained or equipped for this type of rescue.

In nearly every case, these fatalities are completely preventable - simply by properly preparing the permit space prior to entry by isolating or if needed, controlling all hazards. However, should an emergency arise, the rescue service must be prepared to respond to these types of emergencies. This includes proper training and equipment to ensure a successful rescue and that everyone involved goes home safe and sound.

Considering Rescue Service Options

In a previous article, we outlined the three primary ways that an employer can ensure there is a proper confined space rescue service in place as part of their written permit required confined space program. These options include:

(1) an in-house rescue team made up of host employees;

(2) a third party contracted rescue service, or

(3) relying on 911 emergency responders.

All three options have their benefits and their shortcomings. However, it is critically important that the employer focus on the entrant’s safety more than any other consideration, be it monetary, personnel, equipment, or any other resource when deciding what type of rescue service to employ.

I get around…(no, not the Beach Boys’ song). I travel extensively visiting a variety of private and governmental sector work sites, and I also do the trade show/lecture circuit. In my travels, I hear all sorts of variations to the “confined space rescue service” theme. Many employers use in-house rescue teams and accept the funding and time commitments required to keep this capability proficient in the needed skills. Some employers rely on a third party professional rescue service to meet this requirement. Sometimes these third party agreements are for the short term such as during turnarounds, or even for sustaining operations as imbedded contractors. Still other employers rely on 911 public safety responders for their confined space rescue needs.

All three options can and do work, but the one option that I hear having only a cursory vetting process in many cases is the 911 option. At times, I have asked an employer to describe the extent of the agreement between their facility and the 911 responders. That’s when I typically hear an answer such as, “Well, all our employees know the phone number to dial.” That’s when I offer to buy coffee so we can have a little chat. This article will focus on using 911 as your confined space program rescue service.

Before I go any further, I want to say that in my view, our 911 emergency responders are true heroes. And many times, I feel they are under-appreciated. Until a major national disaster hits, many of us are guilty of overlooking the risks that these men and women take on a regular basis. I also think it’s important for employers to understand the extensive set of skills, and wide variety of skills, that emergency responders are required to master in order to perform their primary job responsibilities.

Extensive Skill Requirements for Municipal Responders

For example, firefighters are required to maintain a wide variety of special skills, such as pump operations, ventilation, PPE, emergency vehicle driving, along with medical skills such as advanced airway management, pharmacology, advanced cardiac life support and…are you getting the picture? The skills and knowledge required to perform technical rope rescue is a specialty not typically included in a firefighter’s job description unless they are assigned to a heavy technical rescue (HTR) squad.

NFPA 1006 (2013 edition, with next one coming in 2017) lists all the specialty areas that a rescue service may be called on to master. The first set of requirements is established by the department’s authority having jurisdiction (AHJ) and may include such things as a minimum level of physical fitness, HAZMAT training, emergency medical care training, and several other requirements. Then, there is what used to be referred to as “core skills” now known as Job Performance Requirements. These requirements are extensive before even addressing any of the 19 different technical rescue specialty areas such as: swift water rescue, trench rescue, machinery rescue, structural collapse rescue, wilderness rescue, and the list goes on. Also included in this list is confined space rescue.

In Albuquerque, New Mexico, where I live, we are fortunate to have a dedicated HTR squad within our fire department that is trained, equipped, and staffed 24/7. This team is called upon to respond to flash-flood rescues in our many arroyos, mountain rescue in the peaks east of the city, vehicle entrapments on two interstate highways as well as our surface streets, and may also be called to an employer’s work-site to perform a variety of rescues there. This could be anything from trench rescue to – you guessed it – confined space rescue.

CS Emergencies Require Special Skills and Equipment

It is fairly rare that municipal responders are provided the resources (including specialized training and equipment) to safely and effectively respond to confined space rescue emergencies. Rarer still, for these responders to have been afforded the opportunity to practice in the types of confined space rescues that may be required in their local industrial corridors. Any rescue service would need to be trained and equipped in advance to handle the many hazards and obstacles of permit required confined spaces.

It is the employer’s responsibility, both morally and legally, to engage with the 911 service that is being considered as their confined space rescue service.

Appendix F of 1910.146 is a very valuable means to ensure that both the rescuers and the employer know what the requirements are and that proper agreements are in place prior to confined space entry operations. 

Roco has provided a sample for you to download.

Any shortfalls must be addressed. This may include lack of training, equipment, staffing, or many other requirements necessary to ensure a response appropriate for the types and hazards of the spaces onsite.

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 already expected of the 911 responder's normal duties.

Funding through grants and other resources has become very lean in the last several years. As public safety budgets are trimmed down, both career and volunteer fire departments must make budgetary decisions that in many cases result in sacrificing emergency service capabilities beyond firefighting and emergency medical services. This would mean that many of the technical rescue capabilities outlined in NFPA 1006 are not within the means of many fire departments. The impact on an employer may be that they lose a previously established ability to rely on a 911 agency for their confined space rescue needs, or they may not be able to rely on that rescue service option during the development of their permit required confined space program.

However, we also understand that it is becoming more and more common for employers to provide rescue equipment and/or funding for rescue training specific to the needs of the employer’s confined space program. Various state and local requirements may differ, but generally this can be accomplished by having the employer set up a grant with monies being donated for specific training or equipment purchases. Depending on the local ordinances, equipment can be directly transferred from the employer to the 911 agency through a simple agreement that outlines its intended purpose and ownership. There may be tax advantages to the employer while benefiting the community as well. Bottom line...there are critical steps to take before relying solely on a local 911 agency.

Evaluating Rescue Response Capabilities

Appendix F of 1910.146 clearly explains the need for employers to evaluate a prospective rescue service before depending upon their services. It states,

“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.”

Other critical factors include response time and availability. Response time is generally extended when relying on an offsite rescue service such as 911. 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. Relevant factors include:

(1) Location of the rescue team or service relative to the employer's workplace

(2) Quality of roads and highways to be traveled

(3)  Potential bottlenecks or traffic congestion that might be encountered in transit

(4) Reliability of the rescuer's vehicles, and the training and skill of its drivers

And, what about the availability of the rescue service? Is it unavailable at certain times of the day or in certain situations? What is the likelihood that key personnel of the rescue service might be unavailable at times? If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the entry operation can be aborted immediately?

In fact, these considerations also apply to any of the three means of providing a confined space rescue service, be it an in-house service, a contracted service, or a 911 emergency response. However, response times and availability are typically crucial limitations in relying on 911 for confined space rescue.

Careful Planning Required!

If you have identified 911 as the rescue service written into your confined space program, it is crucial that you take all the necessary steps to vet the agency as being a good fit to protect your employees. 

In addition to all requirements of Appendix F, it is of utmost importance to pay particular attention to the service’s ability to respond in a time appropriate for your needs, and to ensure that reliable two way communications are in place. The 911 dispatch will be notified when entry operations are to commence; and, just as importantly, the 911 dispatch will notify the employer when the service is not able to respond to an emergency so entry operations can be immediately aborted.

With careful planning, thorough communications, and proper training and equipment, relying on 911 response for confined space rescue can work. Unfortunately, in some instances, the outcome is tragic with loss of life not only to the entrants, but also to the unprepared 911 responders who had little clue as to what they were about to encounter. As an employer, it is your responsibility to make sure the rescue service is adequately prepared!

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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)(l)(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.

In January 2004, an explosion at the West Pharmaceutical Company in Kingston, NC killed 6 workers and injured 34 others. Two firefighters were injured during the response to the incident.  One month later, an explosion and fire occurred at the CTA Acoustics manufacturing facility in Corbin, KY, killing 7 workers. In February 2008, an explosion at the Imperial Sugar Company facility in Wentworth, GA, killed 13 workers and injured 42 others. Three very different types of facilities with very different products, but with one thing in common—dust!

"A 'safe’ area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations."

The Chemical Safety Board reported that there were 281 explosions of combustible dust in the United States between 1980 and 2005. These explosions resulted in 199 deaths and 718 injuries. And these are just the actual explosions. There are countless more combustible dust environments just waiting for the right (or wrong) conditions to align to become the next fatal explosion. The fact is that with the exception of silicon or sand, every kind of dust is potentially combustible to some degree.

Combustible dusts are measured on a “deflagration index,” (see box) which measures the relative explosion severity compared to other dusts. They range from such seemingly innocuous items such as dust from powdered milk and egg whites that can create “weak explosions,” to dusts from items such as magnesium and aluminum that can result in “very strong explosions.” But I think we can all agree that no explosion, even a “weak” explosion, is a good explosion—especially if it occurs during rescue operations. 

As rescuers, you should already be familiar with the “fire triangle.” To understand the danger of combustible dusts, you should also be familiar with the “dust explosion pentagon.” The dust explosion pentagon consists of the following:

-       Combustible Dust (Fuel)

-       Ignition Source

-       Oxygen

-       Dispersion of dust (suspension)

-       Containment of the dust in a confined or semi-confined area (Enclosures/Building/Confined Space)

Rescuers should be on the lookout for any appreciable accumulation of dust when sizing up a rescue situation. Keep in mind that your atmospheric monitor containing a sensor for combustible gases is not effective for detecting a hazard from combustible dust.  

Always remain aware that in a suspended state, dust becomes explosive. Dust explosions occur when combustible dust is present, forms a dust cloud in an enclosed environment, and is exposed to oxygen and an ignition source. The explosion occurs as a result of the rapid burning of the dust cloud, which creates a rapid pressure rise in the enclosed area or confined space. 

A dust pile that may burn while an ignition source is being applied, then go out immediately or shortly after the ignition source is removed, can become lethally explosive when scattered and suspended in the air. 

Always consider the potential for combustible dust in any rescue situation, particularly when ventilation of an enclosure, building, or confined space is considered. A “safe” area can become a ticking bomb if ventilation results in the suspension of otherwise stable dust accumulations.

This article was written by Robert Aguiluz, who is currently an Administrative Law Judge for the State of Louisiana. He is also an attorney who specializes in Occupational Safety and Health Law, and regulatory and compliance issues. He is a former Certified Safety Professional and Roco Rescue Instructor with over twenty years’ experience in both industrial and municipal emergency response and rescue.
 

Combustible Dust Considerations for Emergency Responders:

1.  Know your response area and the types of industry that may have the potential for combustible dust. If you are performing standby rescue duties, meet with the SH&E management team to learn about any combustible dust hazards at their facility.

2.  Become familiar with the “deflagration index” for various types of materials. See sample Chart below.

Examples of Kst Values for Different Types of Dust

 

3.  Consider the effect of ventilating a space that has accumulations of combustible dust.

        •  Will you cause the dust to become suspended?
        •  Will the suspended moving dust create a static charge/discharge and become a source of ignition?
        •  Can your ventilation equipment become a source of ignition?

4.  Is there information to review on the SDS (Safety Data Sheet) regarding the material’s potential to become combustible dust?

HELPFUL LINKS:

OSHA Quick Card: Prevent Dust Explosions

“Firefighting Precautions at Facilities with Combustible Dust”

“Hazardous Communication Guidance for Combustible Dust”

“Combustible Dust in Industry: Preventing and Mitigating the Effects of Fire and Explosions”

“NFPA 654: Standard for the Prevention of Fire and Dust Explosions”

The following article was featured in the July 2014 issue of ISHN, and authored by Roco's own Chief Instructor Pat Furr.

Have you ever wondered who that person is who hovers around the portal of a permit space while workers are in the space? What does a Confined Space Attendant (often referred to as the “Hole Watch”) do anyway? What may seem like a cushy job is actually a critical safety responsibility. Here’s why:

First, OSHA instituted regulations regarding Permit-Required Confined Spaces (1910.146) due to the high number of serious injuries and deaths in confined spaces. Entering these spaces is dangerous business, and the attendant serves as the “safety watchman” for entrants as well as those who may casually try to enter. This also applies in an emergency situation when others may be tempted (but unqualified) to enter the space to rescue a co-worker.

OSHA requires that the attendant be able to safely and effectively perform the duties required in Section (i) of 1910.146. (See “Duties of the Confined Space Attendant”) Once a permit is issued and work begins, the attendant needs to be aware of his or her surroundings and be diligent in monitoring the space and entrants at all times. This individual is not there to be a “gofer” for workers inside the space.

Get real

If entrants need assistance or an emergency situation develops inside (or outside) the space that requires entrants to be evacuated, the attendant is the “vital link”. Unfortunately, it is common practice to fill the Hole Watch position with the least experienced or greenest person on the crew. Many times, this person has no idea what is expected of them. They also may not be aware of potential hazards inside the space or hazards that may be introduced as work is performed. Often, these individuals are not experienced in industrial environments and are not properly trained in the OSHA-required duties. And, in most cases, they don’t realize how critical their duties could become in an emergency when split-second decisions are required.

Train your attendants

It is unrealistic to expect a new employee to perform these duties without receiving appropriate training and being granted the authority to take action as needed. In 1910.146(d)(8), OSHA is specific in its requirements for the various roles involved in conducting safe permit entry operations. Employers are required to provide adequate training and ensure that personnel are capable of performing their duties. At minimum, the regulation requires employers to ensure that each Hole Watch/Attendant knows and understands the following safety precautions:

(1) Hazards that may be faced during entry, including information on the mode, signs or symptoms, and consequences of exposure to those hazards;

(2) Possible behavioral effects of hazard exposure for the authorized entrants.

Additional duties and responsibilities include:

(1) Continuously maintaining an accurate count of entrants in the permit space.

(2) Performing non-entry rescues as specified by the employer’s rescue procedure.

One of the most critical duties of the attendant is to be able to effectively communicate with entrants and take appropriate actions in an emergency. Communications are required to monitor the status of the entrants and to ensure that there are no signs of exposure to hazards. The attendant must recognize this need and be able to order evacuation of the space. Most importantly, the confined space attendant can perform NO duties that might interfere with their primary duty to monitor and protect the entrants.

Prevent fatalities

Employers must ask themselves, “Will the person designated as the “Hole Watch” be able to react in an effective manner when the pressure is on? Will they be able to initiate a non-entry rescue in an emergency situation?” Again, we witness too many instances where the “Hole Watch” has little or no knowledge of the responsibilities assigned, while some have had virtually no training whatsoever. Sometimes it seems they are there for no other reason than to fill a square to meet an OSHA requirement.

Many times the lack of understanding regarding confined space hazards, combined with the lack of a clear understanding of emergency actions to be taken (as well as actions to avoid) can lead to confined space fatalities, both for the entrants as well as the attendant.

We urge employers to take a serious look at the selection and training of confined space attendants. These individuals must be capable, responsible and properly trained as spelled out in the OSHA standard. When things go wrong in a confined space, the actions (or inaction) of the attendant can be the difference between life and death for the entrants. They must have the knowledge, the tools and the experience to function as an effective, and ultimately safe, “Hole Watch.”

 

Additional Resources

• Attendant Safety Requirements Poster (pictured here)
• Confined Space Entry Checklist
• Common Causes of Confined Space Fatalities
• Limitations of Atmospheric Monitors

 

 

Don't Miss the Rescue Team Event of the Year!

2014 Roco Rescue Challenge
October 8-9, 2014 
RTC - Roco Training Center

Rescue teams from across the country will participate in realistic confined space rescue exercises designed by Roco’s top instructors. And, although Challenge is more of a learning event than a competition, trophies will be awarded to the teams with top scores for individual skills proficiency and the infamous “Yellow Brick Road” rescue-relay scenario.

Roco Rescue Challenge meets the annual rescue practice requirements of 1910.146 while providing realistic practice drills in all six confined space types. Written documentation will be provided to each team following the event.

All rescue teams are welcome and observer registration is available.This two-day event definitely puts industrial rescue teams to the test! The event is limited to six (6) teams only, so reserve space NOW!

To register your team, join us as an observer, or receive more information CALL 800-647-7626.

CHECK OUT THE 2013 Roco Rescue Challenge Video

Benefits
- Learn from participating in realistic rescue scenarios.
- Gain confidence in your skills and teamwork abilities.
- Enjoy excellent training while interacting with rescue pros.

- Share ideas, experiences, and techniques with teams from across the nation.

OSHA Compliance
- Document your team’s confined space response capabilities.
- Meet annual practice requirements in varying confined spaces types.
- Confirm individual skills proficiency. 

Download Challenge Site Sheet 2014