NOTICE: If you are involved in any kind of confined space work or rescue, you need to read this document and offer your comments. This applies to anyone who may work in or near confined spaces, both industrial and municipal.

At a meeting earlier this month, NFPA’s Guide for Safe Confined Space Entry and Work (Draft) was approved for public comment by the NFPA Standards Council.

This document is designed as a “best practices” guide for those who work in and around confined spaces. As with any document that attempts to be all inclusive, it may work well for some while negatively affecting others. Therefore, it is very important that "WE" the public, the people who will be using this type of document in real world applications, offer our feedback. Now is the time to offer comments and suggestions. Comments as to what may or may not be feasible for your organization or what may have been overlooked in this document are a vital part of this NFPA process.

As contributing members for this document, we are encouraging you to take the time to make your suggestions in order to create a practical guide that will be user friendly and provide for greater safety when working in confined spaces. As you read it, please keep in mind that it is currently listed as a “Best Practices Guide.” However, this does not mean that at some point in the future it won’t possibly become an NFPA Standard.

This document could eventually affect the way you do your job, so it’s very important to all of us for it to be a safe, practical best practices guide. Every comment or suggestion must be addressed by the sub-committees. So, whether you agree or disagree, the time to offer your input is NOW!

Public comment will be accepted online until January 3, 2014. Go to www.nfpa.org/350. In order to comment, you must log in with your email and password – or you can quickly create an account.

Click here to download the PDF version. (Note: Download may take up to 3 minutes depending on your computer.)

 

Report submitted by John Voinche', Sr. Vice President/COO, Roco Rescue

In July, a group of Roco instructors conducted a Confined Space Rope Rescue demonstration for OSHA representatives from Washington, DC. These agency officials represented both General Industry and Construction. This demo was used to clarify our concerns about a pending Letter of Interpretation (LOI) concerning Individual Retrieval Lines in confined spaces that was brought to our attention last year. Here is a little background…

Last July (2011), we brought you a story entitled, “What’s the talk about individual retrieval lines?”  At the heart of the issue was a pending LOI from OSHA regarding how retrieval lines are used inside confined spaces. [Note: This LOI is pending and has not been published in the Federal Register.]

Here’s the question to OSHA from a gentleman in Maryland which initiated the LOI…

“Does OSHA 1910-146 (k)(3) require that each individual entrant, including workers and/or rescuers, entering into a confined space be provided with an independent retrieval line or can more than one entrant be connected to a single retrieval line?”

The proposed answer from OSHA stated that each entrant should have an “individual” retrieval line, despite the fact that the word “individual” is not included in this section of the standard [1910.146 (k)(3)(i)].
 
Roco then wrote a letter to OSHA requesting clarification about the forthcoming LOI. A portion of our letter stated that, “This pending interpretation is different from our understanding of what’s required by the regulation. While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.”


One of the techniques being used is a “single retrieval line” for multiple entrant rescuers. The first rescuer to enter the space is attached to the retrieval line via an end-of-line Figure 8 on a Bight. Any subsequent rescuers enter the space attached to the same retrieval line using mid-line Butterfly knots. In our opinion, this satisfies the intent of the regulation in that each entrant is attached to a retrieval line.

However, in the case of multiple entrants, requiring “individual” lines as mentioned in the proposed LOI may represent an entanglement hazard. This, in effect, may cause entrants to opt out of using retrieval lines due to potential entanglement hazards (which is allowed by the standard if entanglement hazards are a concern). So, in our opinion, this effort to bring more clarity to the issue may further complicate the matter.
 
Again, we believe the single retrieval line method described above is one way to rescue entrants while satisfying the intent of the standard at the same time. More background is available by reading our original story.

Fast-forward back to July 2012… the demonstration lasted about four hours. During this time, Roco demonstrated numerous retrieval line techniques as well as the “pros and cons” for each system. There was a great deal of discussion back and forth on how this pending letter of interpretation could affect rescuers and entrants – and their ability to perform their jobs safely and efficiently.
 
We would like to thank OSHA for allowing us to offer our feedback concerning this topic. We also want to say a special thanks to the Baltimore Fire Department for allowing us to use their training facilities. We don’t know when a final LOI will be issued, but we will keep you posted!

“It is our experience that the victims, would-be rescuers, and co-workers either fail to adhere to their emergency plans or simply do not have a plan in place, with catastrophic results... In the last year alone, we have responded to three confined space rescues.”- Battalion Chief Jack Wise of the Los Angeles Fire Department

Joint Effort for Confined Space Awareness Education

The California Department of Industrial Relations' Division of Occupational Safety and Health (Cal/OSHA) joined forces March 28 with the Los Angeles Fire Department to urge employers and employees to prepare properly for working in confined spaces. Officials from both agencies participated in a news conference where LAFD personnel gave a confined space rescue demonstration and potential hazards were explained.

Cal/OSHA launched a statewide confined space education and awareness campaign in February after seven confined space deaths and numerous injuries in 2011. Illustrating the variety of industries where confined spaces are common, those deaths occurred at a Fortune 500 pharmaceutical facility, a winery, a paint manufacturing plant, and a recycling center.

“Today's event with the Los Angeles Fire Department helps raise awareness of the hazards associated with working in confined space environments and the need for employers to have an effective emergency response plan in place before a critical situation arises,” DIR Director Christine Baker said. “As a national leader in workplace safety, Cal/OSHA is working with labor, employers, and public safety officials to eliminate this type of preventable fatality in the workplace.”

Some of the 2011 fatalities involved potential rescuers attempting to aid someone who had collapsed in a confined space. “These confined space deaths and serious injuries were all preventable had safety practices been in place. It is even more tragic that, in many cases, workers attempting to rescue their co-workers also fall victim,” said Cal/OSHA Chief Ellen Widess. “Confined spaces can be deceptively dangerous. Employers need to assess if they have such a hazard, identify and mark those spaces, [and] provide employee and supervisor training and on-site rescue plans and equipment.”

Cal/OSHA has posted extensive information about confined space hazards on its website at http://ohsonline.com/articles/2012/03/30/la-fire-department-boosts-confined-space-awareness.aspx

A study on the “reliance of municipal fire departments for confined space response” has been funded by a legal settlement following the deaths of two workers in a confined space incident in California.Research by the University of California, Berkeley, indicates that employers may be relying too heavily on local fire departments for confined space rescue.

These findings indicate that local fire departments may not have the resources to provide the specialized training needed for confined space rescue, especially when "response and rescue" times are such critical factors.

Key Points from Study

•  Confined space incidents represent a small but continuing source of fatal occupational injuries;

•  A sizeable portion of employers may be relying on public fire departments for permit-required confined space response; and,

•  With life-threatening emergencies, fire departments usually are not able to effect a confined space rescue in a timely manner.

Municipal Response Statistics

The study includes some very interesting statistics about fire department response times, rescue times, and capabilities. It also shows that rescue times increase dramatically when hazardous materials are present. For example, according to the report, fire department confined space rescue time estimates ranged from 48 to 123 min and increased to 70 and 173 min when hazardous materials were present.

According to the report, “estimates made by fire officers show that a worker who experiences cardiac arrest, deprivation of cerebral oxygen, or some other highly time-critical, life-threatening emergency during a confined space entry will almost certainly die if the employer’s emergency response plan relies solely on the fire department for rescue services.”

Researchers proposed that a more appropriate role for fire departments would be to support a properly trained and equipped on-site rescue team and to provide life support following a rescue.

Information excerpted from, “Confined Space Emergency Response: Assessing Employer and Fire Department Practices,” by Michael P. Wilson, Heather N. Madison & Stephen B. Healy (2012). This study was published in the Journal of Occupational and Environmental Hygiene (Feb 2012) and is available for purchase from Taylor & Francis Online.

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.