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Confined Space Rescue Compliance Myths and Misunderstandings

Thursday, July 1, 2010

Myths and Misunderstandings
How often have you heard the statement “I will just call 911 if we have a confined space emergency”?  Let’s dispel some common myths and misunderstandings regarding confined space rescue compliance.

In accordance with OSHA 1910.146 (d)(9) an employer that will have personnel entering Permit Required Confined Spaces at their workplace must “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.

Meeting this requirement can be accomplished in several ways…

    - Develop an in-house rescue team made up of host employees.
    - Contract with an outside third party rescue team.
    - Coordinate with local emergency services (“911”).

Whatever way an employer chooses, there are specific evaluation criteria that must be met according to 1910.146 (k)…

  1. The rescue team must be capable of responding in a timely manner and reaching the victim(s) within an appropriate amount of time based on the hazards of the confined space.  On-site teams (in-house or third party contracted teams) are generally better able to meet this requirement.
  2. The team must be equipped and proficient in performing the type(s) of rescue that may be encountered.  Can they walk the walk, or just talk the talk?
  3. The employer shall ensure at least one member of the rescue team is currently certified in CPR/First Aid.
  4. The employer shall also ensure that the designated rescue team practices making permit space rescues at least once every 12 months from the actual spaces or representative spaces in regards to opening size, configuration, and accessibility. Representative spaces shall simulate the types of permit spaces from which rescue is to be performed.

Non-Mandatory Appendix F – Rescue Team/Rescue Service Evaluation Criteria

These are some but not all of the requirements of an initial and periodic performance evaluation of the rescue team:

  1. At a minimum, if an offsite rescue team is being considered, the employer must contact the service to plan and coordinate the evaluation of the team based on 1910.146 (k).  Merely posting the service’s phone number or planning to rely on “911” to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.
  2. Can the rescue team respond in an appropriate amount of time based on the hazards of the space?  For known IDLH hazards or hazards that can quickly develop into IDLH conditions, on scene rescue standby is required.  For non- IDLH hazards, a response time of 10-15 minutes may be adequate.
  3. Will the offsite rescue team be available to respond to a confined space incident or is there a potential they will be out of service on a separate incident and unable to respond?
  4. If necessary, can the rescue service properly package and retrieve victims from a permit space that has a limited size opening (less than 24 inches in diameter) or from a space that has internal obstacles or hazards? Does the service have the capability to provide rescue from an elevated location using high angle rescue techniques?

What are three levels of protection required by OSHA for confined space entrants?

Thursday, June 24, 2010

The three levels of protection required by OSHA for confined space entrants are:

1) Hazard Awareness

2) Retrieval Equipment

3) Rescue Services

Does the confined space entrant need to use a harness and lifeline or retrieval system even when a trained rescue team is on site?

Wednesday, June 9, 2010

Yes. A retrieval system should be used whenever an entrant enters a permit space, unless the retrieval system creates a greater hazard to the entrant or does not contribute to the rescue effort.

Middletown, OH Confined Space Incident – FF’s Down

Wednesday, June 9, 2010

Friday, May 7, 2010 A 32-year-old city worker is dead after being overcome by fumes this morning while checking a sewer outside of a business on Yankee Road, according to police.

Meanwhile, two firefighters who attempted to rescue the public works employee were hospitalized after the accident about 8 a.m. today, May 7, in front of Air Products and Chemicals Inc., 2500 Yankee Road, according to police.

Jabin Lakes died after falling into a manhole during an inspection, according to Police Maj. Mark Hoffman. [More...]

Firefighters went into rescue Lakes and were overcome with something in the shaft, he said. It is not clear what the substance is, according to Hoffman.

Fire Marshal Bob Hess was taken to Atrium Medical Center in Middletown and Capt. Todd Wissemier was taken to Miami Valley Hospital in Dayton, according to Hoffman.

The manhole is estimated to be about 20 to 30 feet deep and 20 to 22 inches wide, Hoffman said.

Mayor Larry Mulligan could not discuss details of the incident but said the city will hold a press conference today at 2 p.m. in council chambers, One Donham Plaza.

A coroner’s investigator is at the scene as well as fire rescue units from West Chester Twp., Fairfield and Franklin. The deceased man is still in the hole at 9:55 a.m.

Shortly before 10 a.m., crews were performing air quality tests on the manhole, Hoffman said. He said there does not appear to be any hazard to the general public in the area. At 10:12 a.m., crews on scene were requesting a chemist from AK Steel be sent to the manhole.

Air Products officials were in a meeting regarding the incident and couldn’t be reached for comment. The Allentown, Pa.-based company provides oxygen to AK Steel’s Middletown Works.

Hoffman said Lakes and two other city workers were inspecting the sewer about 8 a.m. because Air Products was interested in tapping into a main line. When the manhole cover was opened, Lakes was overcome by fumes and fell into the hole, he said.

The workers called 911 and fire crews arrived shortly thereafter, Hoffman said.

South Dakota Wheat Growers Assoc. Fined $1.6M After Fatality

Wednesday, June 9, 2010

The U.S. Department of Labor’s Occupational Safety and Health Administration has fined the South Dakota Wheat Growers Association of Aberdeen, S.D., more than $1.6 million following the Dec. 22, 2009, death of a worker at the company’s McLaughlin, S.D., grain handling operation.

The worker suffocated after being engulfed by grain in one of the facility’s bins. OSHA’s investigation found that five additional workers were also at risk of being engulfed when they were sent into the bin to dig the victim out.

OSHA proposed $1,610,000 in fines for 23 alleged willful violations of the grain handling and confined space standards, including:     
    - Failing to prohibit workers from walking on top of clumped grain;
    - Failing to prohibit entry into the grain bins where the buildup of grain existed;
    - Failing to shut off and lock out equipment to prevent grain from moving through the bin while workers were inside;
    - Failing to equip workers with grain engulfment protection;
    - Failing to provide observers equipped to provide assistance;
    - Failing to train workers;
    - Failing to issue permits to control entry into grain bins;
    - Failing to test the atmosphere;
    - A lack of rescue equipment;
    - And failing to implement an emergency action plan prior to entry.

The death in South Dakota follows a similar May 2009 death of a 17-year old employee of Tempel Grain LLP in Haswell, CO. That worker also suffocated after being engulfed by grain. OSHA issued $1,592,500 in fines for 22 alleged willful and 13 alleged serious violations in that case.

OSHA has implemented a regional emphasis inspection program in the grain handling industry to address the serious hazards associated with grain bins and confined spaces, and operators and industry associations have been sent letters announcing the program. OSHA’s area offices covering Colorado, Montana, North Dakota and South Dakota are also providing assistance to help grain storage facilities comply with safety standards.

The company has 15 business days from receipt of all OSHA citations to pay the penalties, request an informal conference with OSHA’s area director or contest the findings before the independent Occupational Safety and Health Review Commission.

Source: OSHA

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