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.

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.

As anyone who has ever been summoned to an industrial site for a confined space rescue, or has taken the opportunity to practice rescue drills in these facilities knows, sometimes the working area for the rescue team can be a tad cozy.  By “cozy” we mean cramped.  If there is the need for a haul of the rescuers or victim after a lower, these cramped conditions can cause multiple problems.  Consider it a challenge to overcome, and use your rope rescue know-how to come up with an efficient solution that will not only reduce congestion at the working area, but will most likely provide for a much faster haul of the rescue package.

First of all, if the space lends itself to a vertically mounted block and tackle, the problem is greatly reduced.  However, if there is no overhead anchor available and the use of a portable overhead anchor such as a tripod is not feasible then a “lane” for the haul team may be necessary.  At times, even the use of a vertically mounted block and tackle may require a solution to a congested working area.

Sometimes we are confronted with a very short throw between the mechanical advantage anchor point and the edge of the portal.  This may cause multiple resets of the haul system, be it a piggyback system or a Z-Rig.  These short throws with multiple resets will really slow down the progress of hauling the rescue package and can become a significant hazard when the need for rapid retrieval is needed.

If the opportunity presents itself, take advantage of a simple change of direction on the haul system.  At times, a single 90-degree change of direction can convert a short 3-4 foot throw into a throw many times longer.  We see this all the time on catwalks, yet it is often overlooked by our rescue teams when we throw scenario-based training evolutions at them.  Yes, it does require some extra equipment which typically amounts to a single sheave pulley, a carabiner, and a utility strap.  It also adds some frictional losses at that directional pulley, but the advantage gained by extending the throw from 3-4 feet to 20 or more feet, far outweighs the disadvantages of extra equipment, added friction, and time needed to make the change.

If a single change of direction doesn’t quite solve the short throw problem, consider two, or even more changes of direction in order to position the haul team in an area thatthey can “walk the haul” using their leg strength instead of being bunched up and using their arm strength only.  Of course, it gets to a point where too many changes of direction exhausts the equipment cache or creates so much friction that any advantage is lost.

As in any rescue situation, a good cohesive team is a great benefit.  If the situation causes the team to be bunched up on top of each other, remember to scan the area for an opportunity to open things up a bit.  Sometimes that change of direction does wonders for the ability of the team to take full advantage of their strength in numbers, and creates a situation where if needed, speed can be a lifesaver.

The author, Pat Furr, reporting for duty...

“The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal, should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.”

Here at Roco, we’re often asked for an explanation of the difference between “calibration” and “bump testing” of portable atmospheric monitors. There seems to be some confusion, specifically regarding bump testing. Some folks believe that bump testing and calibration are the same thing. Others think that bump testing is no more than allowing the monitor to run its “auto span function” during the initial startup sequence – or by running a “manual auto span” in order to zero out the display if there is any deviation from the expected values.

To preface this explanation, it is important that the user maintain and operate the monitor in accordance with the manufacturer’s instructions for use. There are some general guidelines that apply to all portable atmospheric monitors and some of the information in this article is drawn from an OSHA Safety and Health Information Bulletin (SHIB) dated 5/4/2004 titled “Verification of Calibration for Direct Reading Portable Gas Monitors.”

Considering that atmospheric hazards account for the majority of confined space fatalities, it is absolutely imperative that the instruments used to detect and quantify the presence of atmospheric hazards be maintained in a reliable and ready state. Environmental factors such as shifts in temperature, humidity, vibration, and rough handling all contribute to inaccurate readings or outright failure of these instruments. Therefore it is critical to perform periodic calibration and pre-use bump testing to ensure the instruments are capable of providing accurate/reliable information to the operator.

Calibration of the monitor involves using a certified calibration gas in accordance with the manufacturer’s instructions. This includes exposing the instrument sensors and allowing the instrument to automatically adjust the readings to coincide with the known concentration of the calibration gas. Or, if necessary, the operator will manually adjust the readings to match the known concentration of the calibration gas.

In addition to using a certified calibration gas appropriate to the sensors being targeted, do not ever use calibration gas that has passed its expiration date. The best practice is to use calibration gas, tubing, flow rate regulators, and adapter hoods provided by the manufacturer of the instrument.

The frequency of calibration should also adhere to the manufacturer’s instructions for use; or, if more frequent, the set protocol of the user’s company or facility. Once the monitor has been calibrated, it is important to maintain a written record of the results including adjustments for calibration drift, excessive maintenance/repairs, or if an instrument is prone to inaccurate readings.

Each day prior to use, the operator should verify the instrument’s accuracy. This can be done by completing a full calibration or running a bump test, also known as a functional test. To perform a bump test, use the same calibration gas and equipment used during the full calibration and expose the instrument to the calibration gas. If the readings displayed are in an acceptable range compared to the concentrations of the calibration gas, then that is verification of instrument accuracy. If the values are not within an acceptable range, then a full calibration must be performed and repairs/replacement completed as necessary.

Modern electro-mechanical direct reading atmospheric monitors have come a long way in recent years in terms of reliability, accuracy, and ease of use. But they are still relatively fragile instruments that need to be handled and maintained with a high degree of care. The fact that we rely on these instruments to detect hazards that may be colorless, odorless, and very often fatal should be reason enough to motivate us to complete a very strict schedule of instrument calibration/maintenance and pre-use bump testing.

For more information on this subject, please refer to the November 20, 2002 ISEA position Statement “Verification of Calibration for Direct Reading Portable Gas Monitors Used In Confined Spaces”; “Are Your Gas Monitors Just expensive Paperweights?” by Joe Sprately, and James MacNeal’s article as it appears in the October 2006 issue of Occupational Safety and Health magazine.

New for 2011! Practical skills training with a focus on compliance, but without the certification testing.

We’ve had many requests for a course that provides the skills, techniques and problem-solving scenarios for industrial rescue without the NFPA certification testing. Focusing on OSHA compliance, Roco’s new Industrial Rescue I/II will prepare rescuers and rescue teams for industrial confined space and elevated rescue as well as “rescue from fall protection.” Here’s more…

INDUSTRIAL RESCUE I/II (50 Hours)
This course offers a very practical, hands-on approach to industrial rescue that will provide the skills necessary to meet OSHA compliance guidelines for a competent rescue team or rescue team member.

Participants will be taught safe, simple and proven techniques that will allow them to effectively perform confined space and elevated rescues from towers, tanks, vessels and other industrial structures. Rescues from simulated IDLH atmospheres requiring the use of Supplied Air Respirators and SCBA will also be practiced. This course is designed for all rescuers, both industrial and municipal, who may be required to handle confined space rescues in industrial settings. It also includes Rescue from Fall Protection (rescue of suspended workers) as well as OSHA Authorized Entrant, Attendant and Supervisor training.

The problem-solving scenarios can be used to document annual practice requirements in representative spaces as required by OSHA 1910.146 and as referenced in NFPA 1006. For training conducted at Roco’s training facility, scenarios will be completed in all six (6) types of confined spaces. At other sites, the number of types completed will depend on the availability of practice spaces.

OSHA 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.

NFPA 1006 A.3.3.38 Confined Space Type
Figure A.3.3.38* shows predefined types of confined spaces normally found in an industrial setting. Classifying spaces by “types” can be used to prepare a rescue training plan to include representative permit spaces for simulated rescue practice as specified by OSHA. (*Roco Confined Space Types Chart)