Refineries, plants and manufacturing facilities have a wide range of permit-required confined spaces – some having only a few, while others may have hundreds. Some of these spaces may be relatively open and straightforward while others are congested and complex, or at height. With this in mind, are all your bases covered? Can your rescue team (or service) safely and effectively perform a rescue from these varying types of spaces? Or, are you left exposed? And, how can you be sure?
With a large number of permit spaces on site, it would be impossible for a rescue team to practice in each and every one. Plus, in most cases, the spaces are operating, functioning units within the plant. Because of this, section (k) of 1910.146 allows practice from “representative” spaces. This is where the Roco Confined Space Types Chart can make the process easier.
Using OSHA guidelines for determining representative spaces, the Roco Types Chart is designed to assist employers and rescue teams plan for various types of permit spaces.The chart allows you to categorize permit spaces into six (6) confined space types, which can then be used to prepare rescue plans, determine rescue requirements, conduct practice drills or evaluate a prospective rescue service.
Classifying and Typing Your Spaces
Over the decades, we’ve seen just about every type of confined space configuration out there. And, while there may be hundreds of permit spaces on site, most of them will fit into one of these six types and require the same (or similar) rescue plan. Of course, there are always unique situations in addition to physical characteristics, such as space-specific hazards or specialized PPE requirements, but this chart can be a valuable tool in the planning and preparation for confined space rescue operations.
We’ve also learned that it is imperative to understand the physical limitations of space access and internal configuration as well as how this affects equipment and technique choices for the rescue team. Referring to the Roco Types Chart and practicing simulated rescues from the relevant types of spaces will help identify these limitations in a controlled setting instead of during the heat of an emergency.
We can all agree that during an emergency is NOT the time to learn that your backboard or litter will not fit through the portal once the patient is packaged.
Portals less than 24-inches will require a higher level of expertise and different packaging and patient movement techniques.Once the various types have been determined, pay particular attention to spaces identified as Types 1, 3, or 5. Again, these spaces have the most restrictive portals (24-inches or less) and are considered “worst case” regarding entry and escape in terms of portal size. This is very important because it will greatly influence the patient packaging equipment and rescuer PPE that can be used in the space.
Accessibility and Internal Configuration
Lastly, the internal configuration of a space must be carefully considered for rescue purposes. This will be discussed more in the following section on Appendix F.
Remember, rescue practice from a representative space needs to be a “true” representation of the kind of rescue that may be required in an emergency.1910.146 Appendix F – Representative Spaces
In Appendix F, OSHA offers guidelines for determining Representative Spaces for Rescue Practice. OSHA adds that “teams may practice in representative spaces that are ‘worst case’ or most restrictive with respect to internal configuration, elevation, and portal size.” These characteristics, according to OSHA, should be considered when deciding whether a space is truly representative of an actual permit space.
(1) Internal Configuration
What’s inside the space? If the interior is congested with utilities or other structural components that may hinder movement or the ability to efficiently package a patient, it must be addressed in training. For example, will the use of entrant rescuer retrieval lines be feasible? After one or two 90-degree turns around corners or around structural members, the ability to provide external retrieval of the entrant rescuer is probably forfeited. For vertical rescue, if there are offset platforms or passageways, there may be a need for directional pulleys or intermediate haul systems that are operated inside the space.
What about rescues while on emergency breathing air? If the internal configuration is so congested that the time required to complete patient packaging exceeds the duration of a backpack SCBA, then the team should consider using SAR. Will the internal configuration hinder or prevent visual monitoring and communications with the entrant rescuers? If so, it may be advisable to use an additional authorized rescuer as an “internal hole watch” to provide a communication link between the rescuers and personnel outside the space.
What if the internal configuration is such that complete patient packaging is not possible inside the space? This may dictate a “load-and-go” type rescue that provides minimal patient packaging while providing as much stabilization as feasible through the use of extrication-type short spine boards as an example.
If the portal is 4 feet or greater above grade, the rescue team must be capable of providing an effective and safe high angle lower of the victim; and, if needed, an attendant rescuer. This may require additional training and equipment. For these situations, it is important to identify high-point anchors that may be suitable for use, or plan for portable high-point anchors, such as a “man lift” or some other device.
(3) Portal Size
Here again, the magic number is 24 inches or less for round portals or in the smallest dimension for non-round portals. It is a common mistake for a rescue team to “test drive” their 22-to-23-inch wide litter or backboard on a 24-inch portal without a victim loaded and discover that it barely fits. However, the problem arises when a victim is loaded onto the litter. The only way the litter or backboard will fit is at the “equator” of the round portal. This will most likely not leave enough room between the rigid litter or backboard and the victim’s chest, except for our more petite victims.
For rescuers, it is already difficult to negotiate a portal while wearing a backpack SCBA. For portals of 24 inches or less, it’s nearly impossible. If the backpack SCBA will not fit, it is time to consider an airline respirator and emergency escape harness/bottle instead. Warning: Do NOT under any circumstances remove your backpack SCBA in order gain access to a confined space through a restricted portal or passageway. It is just too easy for a mask to become displaced.
(4) Space Access – Horizontal vs. Vertical
Most rescuers regard horizontal retrievals as easier than vertical. However, this is not always the case. If there are floor projections, pipe work or other utilities, even just a grated floor surface, it may create an incredible amount of friction or an absolute impediment to the horizontal movement of an inert victim. In this case, the entrant rescuers may have to rely on old-fashioned arm and leg strength to maneuver the victim.
Putting the Roco Types Chart into Practice
The Roco CS Types Chart can assist by first providing a way to classify and type your different kinds of spaces. This information can then be used to design training/practice drills as well as annual performance evaluations to make sure your rescue service is capable of rescue from the varying representative spaces onsite. Of course, this applies whether you use an in-house rescue team, a contracted rescue service, or a local off-site response team. Otherwise, how do you know if you truly have your bases covered? Don’t take that chance. If an incident occurs and the rescue personnel you are depending on are not capable of safely performing a rescue, your company could be culpable.
In section (k), OSHA requires employers to evaluate the prospective rescue service to determine proficiency in terms of rescue-related tasks and proper equipment.
Our congratulations to the Burlington (Iowa) Fire Department on a successful grain bin rescue that happened in their community back in May of this year (2018). The incident was reported on Firehouse.com.
The Burlington Fire Department responded to an incident with a man trapped up to his neck inside a corn grain bin in a rural area. Upon arriving at the scene, the initial ambulance unit spoke with the victim’s son who told them that his father was buried up to his armpits inside the bin. The son had thrown a rope down to his father to prevent slipping further down into the corn. Fortunately, the victim remained calm and was able to communicate with the responders.
The bin, designed to hold up to 30,000 bushels of corn, was two thirds full on that morning.Responders used a Res-Q-Throw Disc typically used in water rescue to lower an O2 bag with an attached non-rebreather mask to the victim.
To reduce weight on the roof of the structure, one of the deputies and the son came down from the structure.Crews soon realized that the only way to rescue the gentleman was to set up a rope system and lower a responder into the bin. The aerial was put in place to assist this operation. An incident command vehicle was set up a short distance behind the aerial, offering excellent visibility to the Incident Commander.
Throughout the process, the ground team kept the rescuer on a short leash to prevent him from falling into the grain himself.
A 4-gas atmospheric monitor with an extra-long sampling tube was used to test the air inside the bin to make sure the rescuer and victim were not in an IDLH atmosphere. The meter was monitored continuously throughout the rescue operation by fire personnel who was positioned on an extension ladder on the exterior of the bin near the opening. He also functioned as a safety officer for operations inside the bin and on the roof and relayed communications for the rescuer inside the space.
A neighboring fire department had brought a special grain rescue auger that was lowered into the bin. The rescuer inserted the auger inside the rescue tube and slowly removed the corn from around the victim’s chest. After the tube was secured around the victim, the IC had called for two relief cuts to be made in the bin – one cut near the victim and the other directly opposite it on the other side of the bin, which was used to empty the bin of corn. Crews used K-12 saws to cut a large triangular opening in the bin wall. The second opening was made by forcing open a door in the side of the bin near the victim. These doors, which swung inward, could only be opened after a significant amount of grain spilled from the cut made on the other side of the bin.
Local road crews which had been on site brought a large-end loader and a smaller skid loading to the scene and used them to push large amount of corn away from the openings in the walls, which enabled a continuous flow of corn.
In approximately 2-1/4 hours after crews arrived on scene, the victim was able to walk from the bin. He refused air transport but consented to ground ambulance transport where he was treated for minor injuries.
Again, our congratulations to the Burlington Fire Department as well as all the agencies involved in making this a successful rescue.
The department noted several lessons learned which include:
• Grain bin rescue is a high hazard, low frequency event. The department recognized the importance of its training in ropes and rope operations as well as training with specialized rescue equipment.
• It was determined that the roofs of the grain bins hold far less weight than originally surmised.
• The aerial platform was a key factor in the rescue operation. It was used as an anchor point and for staging equipment. Physical limitations and maximum load-bearing capability must be carefully considered and even more especially when ropes are being utilized. Weight and angles of the aerial must be factored into the operation.
by Dennis O'Connell, Director of Training/Chief Instructor
Having been involved in training for 30 years, I have had the opportunity to observe how various organizations in many different fields approach confined space entry and rescue. And, when it comes to training for Entrants, Attendants and Entry Supervisors, the amount of time and content varies greatly.Most often, training programs treat the three functions as separate, independent roles locked into a hierarchy based on the amount of information to be provided. However, it’s critical to note, if any one of these individuals fails to perform his or her function safely or appropriately, the entire system can fail – resulting in property damage, serious injury or even death in a confined space emergency.
Before I go any further, I have also seen tremendous programs that foster cooperation between the three functions and use more of a confined space “entry team” approach. This helps to ensure that the entry is performed safely and efficiently.
It also allows all parties to see the overall big picture of a safe entry operation.In this model, all personnel are trained to the same level with each position understanding the other roles as well. This approach serves as “checks and balances” for confirming that:
• The permit program works and is properly followed;
• The permit is accurate for the entry being performed;
• All parties are familiar with the various actions that need to occur; and,
• The team knows what is expected of each other to ensure a SAFE ENTRY!
However, I am often surprised to find that Entrant and Attendant personnel have little information about the entry and the precautions that have been taken. They are relying solely on the Entry Supervisor (or their foreman) to ensure that all safety procedures are in place. If you have a well-tuned permit system and a knowledgeable Entry Supervisor, this may be acceptable, but is it wise? As the quality of the permit program decreases, or the knowledge and experience of the Entry Supervisor is diminished, so is the level of safety.
In my opinion, depending exclusively on the Entry Supervisor is faulty on a couple of levels. First of all, the amount of blind trust that is required of that one person. From the viewpoint of an Entrant, do they really have your best interest in mind? And, we all know what happens when we “ass-u-me” anything! Plus, it puts the Entry Supervisor out there on their own with no feedback or support for ensuring that all the bases are covered correctly. There are no checks and balances, and no team approach to ensuring safety.Looking at how 1910.146 describes the duties of Entrant, Attendant and Entry Supervisor tends to indicate that each role requires a diminishing amount of information. However, we believe these roles are interrelated, and that a team approach is far safer and more effective. To illustrate this, we often pose various questions to Entrants and Attendants out in the field. Here is a sample of some of the feedback we get.
We may ask Entrants…Who is going to rescue you if something goes wrong? Has the LOTO been properly checked? At what point do you make an emergency exit from the space? What are the acceptable entry conditions, and have these conditions been met? How often should the space be monitored? Typically, the answer is, “I guess when the alarm goes off, or when somebody tells me to get out!”
These are very real scenarios. Scary, but true. It often shows a lack of knowledge and cooperation between the three functions involved in an entry. And, that’s not even considering compliance!We ask, would it not be better to train your confined space entry team to the Entry Supervisor level? Wouldn’t you, as an Entrant, want to know the appropriate testing, procedures and equipment required for the entry and specified on the permit? Would it not make sense to walk down LOTO with the Attendant and Entrant? This would better train these individuals to understand non-atmospheric hazards and controls; potential changes in atmosphere; or, how to employ better air monitoring techniques. All crucial information.
More in-depth training allows the entry team to take personal responsibility for their individual safety as well as that of their fellow team members. It also provides multiple views of the hazards and controls including how it will affect each team member’s role. Having an extra set of eyes is always a good thing – especially when dealing with the hazards of permit spaces. Let’s face it, we’re human and can miss something. Having a better-trained workforce, who is acting as a team, greatly reduces this possibility.
Many times, we find that the role of Attendant is looked upon as simply a mandated position with few responsibilities. They normally receive the least amount of training and information about the entry. However, the Attendant often serves as the “safety eyes and ears” for the Entry Supervisor, who may have multiple entries occurring at the same time. In reality, the Attendant becomes the “safety monitor” once the Entry Supervisor okays the entry and leaves for other duties. So, there’s no doubt, the better the Attendant understands the hazards, controls, testing and rescue procedures – the safer that entry is going to be!
As previously mentioned, training requirements for Entrant, Attendant and Supervisor are all over the board with little guidance as to how much training or how in-depth that training should be. Common sense tells us that it makes better sense to train entry personnel for their jobs while raising expectations of their knowledge base.
OSHA begins to address some base qualifications in the new Confined Spaces in Construction standard (1926 Subpart AA) by requiring that all confined spaces be identified and evaluated by a “competent person.” It also requires the Entry Supervisor to be a “qualified person.” Does the regulation go far enough? We don’t think so, nor do some of the facilities who require formal, in-depth training courses for their Entrant, Attendant and Entry Supervisor personnel.
• Competent person: “One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.”
• Qualified person: “One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.”
So, do yourself a favor…go out and interview your Entrants and Attendants on a job.Find out how much they do (or don’t) understand about the entry and its safety requirements. Do not reprimand them for not knowing, as it may not be their fault. It may be a systemic deficiency and the training mentality of distributing a hierarchy of knowledge based on job assignment.
Simply put, we believe that arming the entry team with additional information results in safer, more effective confined space operations. After all, isn’t that what it’s all about? GO TEAM!
Safe Entry Workshop: Entrant, Attendant & Entry Supervisor is now available. See the full course description for details.
Author's Bio: Dennis O'Connell has been a technical rescue consultant and professional instructor for Roco Rescue since 1989. He joined the company full-time in 2002 and is now the Director of Training and a Chief Instructor. He currently is responsible for Roco's training curriculum to include Confined Space & High Angle, Trench Rescue, Structural Collapse and Instructor Development. Dennis has played a key role in the development of Roco's Rescue Technician certification programs to NFPA 1006. Prior to joining Roco, he served on the NYPD Emergency Services Unit (ESU) for 17 years. He was a member of NY's Task Force 1 and has responded to numerous national disasters such as the World Trade Center and the Oklahoma City bombing.
There are countless injuries and deaths across the nation when workers are not taught to recognize the inherent dangers of permit spaces. They are not trained when "not to enter" for their own safety. Many of these tragedies could be averted if workers were taught to recognize the dangers and know when NOT to enter a confined space.
While this incident happened several years ago, it emphasizes the senseless loss of life due to a lack of proper atmospheric monitoring and confined space training. Generally, the focus for training is for those who will be entering spaces to do the work. However, we also must consider those who work around confined spaces – those who may be accidentally exposed to the dangers. Making these individuals aware of the possible hazards as well as to stay clear unless they are properly trained.Note: This case summary from the New York State Department of Health goes on to say that the DPW had a confined space training program but stopped the training after the last trainer retired.
CASE SUMMARY - TWO (2) FATALITIES
A 48-year-old male worker (Victim I) employed by the Department of Public Works (DPW) and a 51-year-old male volunteer firefighter (FF Victim II) died after entering a sewer manhole located behind the firehouse. In fact, the Fire Chief was on scene because he had been called by the DPW general foreman to unlock the firehouse and move the firetruck so it would not be blocked by the DPW utility truck working at the manhole. Another firefighter also arrived to offer assistance, he later became FF Victim II.
The manhole was 18 feet deep with an opening 24-inches in diameter (see photo above). Worker Victim I started climbing down the metal rungs on the manhole wall wearing a Tyvek suit and work boots in an attempt to clear a sewer blockage. The DPW foreman, another firefighter and FF Victim II walked over to observe. They saw Victim I lying on the manhole floor motionless. They speculated that he had slipped and fallen off the rungs and injured himself. The Fire Chief immediately called for an ambulance.Meanwhile, FF Victim II entered the manhole to rescue Victim I without wearing respiratory protection. The other firefighter saw that FF Victim II fell off the rungs backwards while he was half way down and informed the Fire Chief. The Fire Chief immediately called for a second ambulance and summoned the FD to respond. FD responders arrived within minutes.
The Assistant Fire Chief (AFC) then donned a self-contained breathing apparatus. He could not go through the manhole opening with the air cylinder on his back. The cylinder was tied to a rope that was held by the assisting firefighters at the ground level. The AFC entered the manhole with the cylinder suspended above his head. He did not wear a lifeline although there was a tripod retrieval system. He secured FF Victim II with a rope that was attached to the tripod.
FF Victim II was successfully lifted out of the manhole. The AFC exited the manhole before a second rescuer entered the manhole and extricated Victim I in the same manner. Both victims were transported to an emergency medical center where they were pronounced dead an hour later. The cause of death for both victims was asphyxia due to low oxygen and exposure to sewer gases.
• Firefighters were not trained in confined space rescue procedures.
• FD confined space rescue protocol was not followed.
• Standard operating procedures (SOPs) were not established for confined space rescue.
The DPW had developed a permit-required confined space program but stopped implementing it in 2004 when the last trained employee retired. They also had purchased a four-gas (oxygen, hydrogen sulfide, carbon monoxide and combustible gases) monitor and a retrieval tripod to be used during the training. It was reported that a permit-required confined space program was never developed because DPW policy “prohibited workers” from entering a manhole. However, the no-entry policy was not enforced. Numerous incidents of workers entering manholes were confirmed by employee interviews.
This incident could have been much worse. Training is the key, whether it’s just an awareness of the dangers in confined spaces or proper entry and rescue procedures. In this case, the victims had no C/S training even though they may have to respond to an incident, and the worker had not had on-going training through out his career. Periodic training to keep our people safe and aware of proper protocols is key to maintaining a safe work force.
Unfortunately, training is usually one of the first things to be cut when the budget gets tight; however, after an incident, it usually becomes the primary focus. Often the lack of training is determined to be a key element in the tragedy.Investing in periodic training for the safety of your workforce includes spending the time and money to keep your trainers and training programs up to speed and in compliance. The old saying, “closing the barn doors after the horses escaped,” is no way to protect your people – a little investment in prevention goes along way in preventing these tragedies.
One last comment on my biggest pet peeve – proper, continuous air monitoring. This one step can reduce the potential of a confined space incident by about 50%! Don’t take unnecessary chances that can be deadly.
Dennis O'Connell has been a technical rescue consultant and professional instructor for Roco Rescue since 1989. He joined the company full-time in 2002 and is now the Director of Training and a Chief Instructor. Prior to joining Roco, he served on the NYPD Emergency Services Unit (ESU) for 17 years.