Comments by Dennis O'Connell, Roco Director of Training & Chief Instructor

The following “OSHA Fatal Facts” is another example of simple safety procedures not being followed or having no procedures in place.

Whether you’re in the refinery, chemical plant, agriculture, shipyards, construction or municipal fields, all of us have an obligation to protect ourselves, our employees and those we work with.

In this case, a fairly harmless looking tank and product resulted in another confined space fatality. As I’ve said many times before, using proper air monitoring techniques is probably the one thing you can enforce that would have the greatest impact on reducing fatalities. This tragic story is another example.

It’s also important to note that while there are different standards for different industry segments, they all attempt to lead us down the same path in using appropriate safety precautions – particularly, in this case, when entering confined spaces. We must remember that these specific standards have all grown from the General Duty Clause, as cited in this article. Basic and to-the-point, the General Duty Clause provides protection from hazards not covered in the more industry specific standards.

I know most of us are used to dealing with more spectacular-looking confined spaces with much more hazardous products; however, this one was just as deadly. It drives home the point…

a confined space is a confined space, no matter how benign it may appear, regardless of whether it’s located at the workplace or the homestead.

If it meets the definition of a confined space, it should be treated as a potential “permit-required confined space” until it is proven that there are no hazards present, or the hazards have been properly addressed.

(Click here to OSHA Fatal Facts)

There continues to be a misconception that a confined space attendant (or “hole watch”) is a menial task to be assigned to the greenest, most inexperienced personnel on the job. That’s a dangerous assumption, and it has been a contributing factor in many confined space fatalities.

In fact, the attendant or hole watch should have a solid understanding of the permit space to be entered. This includes knowing the particulars of any known or potential hazards as well as other pertinent knowledge and skill sets. If you are assigned this crucial role, I hope you understand that the entrant(s) are relying on you. Your performance may have a significant bearing on the outcome, both good and bad.

Do you know everything you need to know in order to perform your duties as a confined space attendant? Don’t assume that you will learn everything you need to know after a two- or three-minute pre-job briefing.

Being an attendant or "hole watch" is a critically important role and failure to properly perform these duties has led to multiple fatalities – both for the entrants and the attendants themselves.

Do understand the known and potential hazards of the confined space. Do take the time to review the SDS (MSDS) for any and all materials or gasses that may be encountered. Do learn what the signs and symptoms of exposure may be. Then, if you detect any of them in the entrant’s behavior or appearance, you can order immediate evacuation.

Don’t gloss over this valuable and readily accessible information only to wonder what caused the entrant(s) to lose consciousness. The SDS (MSDS) provides information on route of exposure; and very importantly, the signs and symptoms of exposure. Don’t miss the opportunity to save the day, and perhaps a life, by learning these early warning signs. This allows evacuation of the space before entrants are no longer able to do so on their own.

Do learn the proper operation of any testing equipment, such as atmospheric monitors. It is also important to understand the limitations of this equipment as well.

Do keep track of all authorized entrants in the space. For entries with multiple entrants, don’t rely on your memory alone. Do use some sort of log or entry roster as a reliable means to accurately identify who is in the space.

Do make sure that you have a reliable means to communicate with the entrants. Do test that means of communication at the very limits of the space to ensure it works. Don’t wait until there is an incident to learn that you cannot alert the entrants, or you cannot hear that their status has changed. If you haven’t heard from the entrants in a while, it can be tempting to go into the space to check on them. This very situation has led to many fatalities in which the attendant was overcome by the same hazard as the authorized entrant(s). At that point, there is no longer anyone available to call for help.

Don’t accept the job assignment until you have been briefed by the entry supervisor on all the planned activities both inside and outside the space. Do remember that oftentimes activities outside the space can create a hazard for the entrants inside the space. Carbon monoxide and spills of hazardous materials are just a couple of examples.

Don’t allow any activities to take place inside or outside the space that are prohibited and are not consistent with the conditions stated on the entry permit, especially if they may create a hazard to the entrants. If those activities were not coordinated and told to you by the entry supervisor, do evacuate the space and call the entry supervisor for guidance.

Don’t leave the space or perform other duties that may interfere with your primary duty of monitoring and protecting the entrants.

Do remain diligent, remember that you are the critical link between the entrants and the rescue service.

Do know how to contact rescue services should they be needed. Don’t wait until it is too late to call for help. Do summons rescue as soon as you determine that the entrants may need assistance escaping from the space. Just remember, you can’t turn back the clock and buy back the time that entrants may have needed to survive. It’s a whole lot easier to turn around the rescue service if it is not needed.

Don’t allow unauthorized persons to approach or enter the permit space. If you are unable to warn them away, do order the evacuation of the authorized entrants. Do immediately inform the entry supervisor of the situation.

Do perform non-entry rescue (retrieval) when needed and if authorized by your employer. Do perform a thorough pre-entry inspection on the retrieval rescue equipment. Do make sure it is appropriate for the type of rescue that may be needed. Do learn and practice the proper operation of the retrieval equipment. Don’t wait until there is an emergency to try and figure it out. Don’t attempt entry rescue unless you are authorized, trained and equipped to do so. Don’t attempt entry rescue until you are relieved by another authorized attendant. Remember, you cannot leave the space unattended!

Don’t take your responsibilities lightly. Do ask the right questions of the entry supervisor and your authorized entrants. Do realize that they are all counting on you. Do ask to be briefed by the entry supervisor regarding any coordination that has been made with other work groups in the area. Do remember that many attendants have perished attempting heroic but ill-advised and unauthorized rescue attempts.

Do remember that your authorized entrants are relying on you. Do take the initiative to learn everything you need to know and how to operate any equipment in support of your entrants. As the hole watch, you are the critical link that can make or break a successful entry operation.

Written by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

Additional Resources

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

 

 

Join us in Bismarck, ND, for Roco’s Industrial I/II course at the Safety Council’s new training facility. The NDSC has an indoor confined space rescue prop designed with input from Roco Rescue. Click here (or the picture) to download the flyer information.

This course is for industrial and municipal rescuers who handle confined space and high angle rescues in industrial environments. Course dates are November 13-17, 2017.

Call the NDSC at 800-932-8890 for more information; or contact Roco at 800-647-7626. We will also be conducting additional Roco courses at the NDSC in 2018.

By Dennis O'Connell, Roco Director of Training & Chief Instructor

I am often asked by plant managers or rescue team supervisors about getting their team on the right track as far as training and competency is concerned. Here are a few tips for doing just that…

First of all, I always recommend that they choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) adds to the confusion of team members as to what techniques and equipment are being used – especially during a real rescue!

I then suggest that the team’s training records be reviewed in order to determine what level of training has been completed. I also strongly recommend getting everyone to the same level; especially if your facility is what I refer to as an “island unto itself.” In other words, do you have nearby facilities or other local agencies who can offer additional manpower, equipment, etc. in an emergency – or, are you fairly isolated?

Same Page, Same Language
If your facility is somewhat isolated, getting all your rescue team members on the same page, talking the same language, and at the same level of training is extremely important. You may have some experienced rescuers who have completed a variety of courses from different providers and are trained to different levels. Is this previous training properly documented should you be asked about it and to what levels? Having everyone on the same level – with the same basics under their belt – is key to performing a timely and successful rescue
And, do you have a particular goal or level you want your team to strive for, achieve, and maintain? Determining your overall goal for the team is significant in planning for and achieving results. Haphazard training “just for the sake of training” is not necessarily a good thing, and it tends to generate complacency among team members. Besides the obvious, your team “needs to be able to perform a rescue should the need arise.”

Is It Documented?
Take a look at how the training was conducted, documented and what standards were met, if any. And, if you have permit spaces or personnel working at height, I’m assuming that OSHA compliance is a given, but what about meeting requirements of the National Fire Protection Association (NFPA) for rescuers; namely, NFPA 1006 and 1670.

If there is an incident and OSHA or some other regulatory organization were to investigate, how would you provide the documentation that your team is capable of doing what is required of them? Remember, if it can’t be documented, it doesn’t exist!

Using NFPA 1670 (“team” standards) and NFPA 1006 (“individual rescuer” standards) as a basis for the team’s training level will help to provide the needed documentation and add to the credibility of your team’s capabilities. Ideally, all your team members should be certified to the Confined Space Rescue Technician level (NFPA 1006) along with the documentation to back it up.

Because NFPA’s Confined Space Rescue Technician includes confined space and high angle (elevated) rope techniques, I don’t necessary suggest that industrial clients be required to achieve “Rope Rescue Technician.” The added skills of Rope Rescue Technician include less-seldom-used techniques in industrial rescue such as rope ascension and traverse. Do make sure, however, that the course you choose for Confined Space Rescue Technician incorporates some (not all) of the high angle skills you would need to perform elevated rescue at your site.

A Mix of Confined Space and Rope Rescue
If you have a variety of experience and training levels among your team members, it’s important to get them consistently trained and all trained to the same level. Of course, I would recommend Roco’s Fast Track 80™ course, which includes a two-year certification. This course was designed to meet the needs of industrial facilities with a mix between “confined space” and “rope” technician skills needed. The class is geared for confined space rescue with some of the additional rope technician skills needed for elevated or high angle rescue. The class efficiently gets the rescuer to the Confined Space Rescue Technician level in only 80 hours using both performance-based and written testing.

Of course, the next challenge is getting the entire team trained to the same level. It’s not going to be easy to get an entire team released for training all at once – thus compromising the availability of rescue personnel onsite should an emergency arise. Therefore, you may have to run a couple of classes to get everyone certified – or send some of your team (or new team members) to an open-enrollment course.

Testing to the NFPA 1006 Professional Qualifications standard is conducted on the last day of the Fast Track 80™ class. Note: If some of your personnel have already completed this class, they can join the class for the last four days in order to be recertified. This will allow the new members and more experienced team members to work together in realistic practice scenarios. It will help get everyone on the same page as far as techniques plus give the experienced personnel a 3-day refresher and practice time before re-certification testing.

Training Cycle for Compliance
Once all team members are trained to the same level, I recommend going to a two-year rotation. For example, once everyone is certified, the next year would be a Roco Team Performance Evaluation (TPE) where we come for two-to-three days and run teamed-based evaluations using multiple rescue scenarios. Each scenario is critiqued by evaluators to adjust any problems found along the way. The TPE would be followed by a written report to document the scenarios conducted as well as discrepancies found and corrected. The following year would be Re-certification to NFPA 1006 (three-to-four-day session) that includes Individual Performance Evaluations (IPE) where team members would refresh personal skills as well as run several scenarios before testing for re-certification to Confined Space Technician level.

This rotation will help with OSHA compliance by meeting the minimum annual practice requirements as well as by providing a performance evaluation of rescue services as stated in Note to paragraph (k)(1) from 1910.146: “Non-mandatory Appendix F contains examples of criteria which employers can use in evaluating prospective rescuers as required by paragraph (k)(1) of this section.”

In addition, both OSHA 1910.146 and 1926.1211 require timely and capable rescue services for permit spaces. They also require minimum annual rescue practice in the applicable types of confined spaces as well as proficiency for team members. This cycle of training works well in documenting that you have met these minimum requirements while also meeting the requirements of NFPA.

The TPE supporting documentation also provides a “snapshot” of where your team and its individual rescuers stand in terms of competency. This information can then be used as a tool to design internal drills that correct any discrepancies while getting the most from your “all too limited” practice time.

I hope these recommendations are helpful in planning for the success of your rescue team – especially when it’s all on the line during an emergency situation. If you have any questions, don’t hesitate to call me at 800-647-7626 or send an email to info@rocorescue.com.

We all know that initial safety training is a crucial element of our programs that aim to keep our employees protected from harm at work. For any and all hazards (or potential hazards} to which we expose our workers, we must ensure they understand the nature of the hazards and how to protect themselves.

Initial safety training and proper safety equipment, combined with good old-fashioned experience, goes a long way in ensuring a safe work environment. But, at times, we must provide re-training for our employees – and there are many reasons for this.

For example, if our employees demonstrate a lack of knowledge or acceptable performance in regards to any particular hazard, we must provide re-training. If the process or equipment changes, we must provide re-training. If new safety equipment (includes systems as well) is brought into the program, we must re-train our employees on its proper use. And, finally, if there are changes to safety legislation or best-known practices, we need to re-train.

It seems that every week a new piece of fall protection equipment is brought to market – and for the most part, these emerging technologies make work-at-height safer than ever before. Additionally, these newer fall protection items tend to be lighter, more comfortable, easier to operate, and can even perform multiple safety functions. This is all great news, but not every item/system is right for the varied situations encountered at our workplaces. But when we do introduce a new piece of fall protection equipment to our workforce, it nearly universally calls for some degree of re-training. The manufacturer’s instructions for use may be a great starting point to satisfy this training, but it is always a good idea to provide some degree of formal training on the equipment, and then document that training.

The extent of this re-training is dependent on the complexity of the new equipment and the authorized person’s general knowledge base. Sometimes the user manual does not cover all the points that the re-training should convey. For example, harness-mounted self-retracting lifelines are becoming more and more prevalent in the work-at-height environment. In addition to the standard training for pre-use and periodic inspections, proper mounting, operating capabilities and limitations, at least one other point of training seems to be required. The worker cannot walk too quickly away from their anchorage lest they engage the arresting mechanism which abruptly stops the worker in their tracks. This may at times create a new hazard by jerking the worker off balance or causing them to drop objects they may have been carrying. I have even heard some tales of individuals suffering minor injuries due to the sudden stop. So, even though you may not find this point of training in the user’s manual, it comes with experience and should be included in the re-training for this type of new equipment.

Another reason to provide re-training for fall protection has to do with an observed deficiency in an authorized person’s knowledge or performance regarding fall protection. Now this can become a little tricky to find the root cause of the deficiency. Is it truly a lack of knowledge on the authorized person’s part, or is it a disregard for required procedures? Sometimes it's a mix of both. No matter the primary cause of the deficiency, if that authorized person is to remain on that job, it is incumbent on the employer to provide proper re-training. And I will say it again, document that re-training!

We have recently had a significant legislative change to the general industry standard for fall protection. On Nov. 18, 2016, OSHA 1910 Subpart D “Walking-Working Surfaces” was published and became effective on Jan 18, 2017. The major changes to this final rule have to do with physical changes to existing and future structures regarding the phase-in of ladder safety systems, eliminating the outdated general industry requirements for scaffolds and adopting the construction industry’s scaffold standards' guidance on the use of rope descent systems and qualified climbers, as well as some other changes. But the most significant changes that will drive training and re-training requirements is the added flexibility of using personal fall protection systems for authorized persons. These personal fall protection systems include fall restraint, work positioning, and personal fall arrest systems (PFAS). OSHA has eliminated the mandate to use guardrail systems as the primary fall protection method and now allows the general industry employer to determine the fall protection method that they feel is best suited for the nature of the work at height. And this now includes personal fall protection which was not addressed prior.

For general industry employers, who prior to the new Subpart D did not allow their employees to use personal fall protection systems other than in accordance with 1910.66, the option to do so now will be deemed compliant. And, of course, this will require initial training and re-training for the use of personal fall protection equipment and systems. Additionally, employers that introduce the authorized use of work positioning and personal fall arrest systems to their workplace will also have to provide training on rescue of these workers if they are relying on an in-house rescue capability.

In the years I have been involved with safety and rescue training, one subtlety that I observe is this:

Oftentimes an employer or their employees do not realize they have a training deficiency until after they've gone through the training.

This is certainly true when it comes to rescue training. At the conclusion of nearly every rescue class I teach, at least one of the students says they never realized what all was involved in rescue and what the limitations of certain rescue systems were. And this is consistent with my interviews and reviews of rescue programs when I am asked to perform needs assessments at various facilities. Unless you have a background in technical rescue, it is very difficult to visualize the systems, skills, and equipment required to safely access and rescue a fallen/suspended victim.

Both OSHA and ANSI require employers to provide "prompt rescue" of employees they authorize to work at height while using personal fall arrest systems. OSHA has published a Safety and Health Information Bulletin recognizing suspension trauma as a workplace hazard affecting workers that use personal fall arrest systems. Many employers address rescue of fallen/suspended workers in their fall protection programs, but stop at merely developing written policies that may fall well short of the requirements needed at the time of an incident. This falls back to my earlier point that an employer that has a limited background and understanding of the complexities of performing rope rescue, especially if it requires technical skills beyond the simplest rescue, may not understand what the true requirements are for their facility. Sort of like that general saying last year that “We don’t know what we don’t know.” So, training for rescue is a subcategory of fall protection training that does not have as much easily accessed guidance and resources to rely on as a guide.

Quality training will include several of the points that I have detailed so far. The training will be pretty specific to the job with very little time spent on irrelevant material. The training will be of the type that best transfers the information in either a vocational or academic manner. The training will close the gaps that have been identified and arm the employer and the students with a better understanding of what is truly required to perform the job, which is especially true for rescue. But finally, the training should be delivered in such a manner that it captures the students’ interest. The best outcome of training, the classes where the student finishes with the highest level of retention, understanding and performance, are the classes that compel the students to engage in the learning.

I think it is a safe assumption to say that we have all sat through classes wondering when and hoping for the class to end. Looking at our watch is one thing, but when we are tapping it to see if it is even still working is a really bad sign. I am not suggesting that educators have to provide entertainment, but there is a demonstrated positive difference in classes delivered by an engaging trainer as compared to a very dull, monotonous trainer.

In addition to seeking an engaging trainer, it is important for the trainee to take some ownership in the learning process as well. This is where the adult learner has an advantage over younger learners. We as adults generally understand that the training will result in a better understanding of the job requirements and in many cases is a factor in career progression.

I encourage you to seek out the training that your employees need. Or, as an employee yourself, seek out quality, applicable training. Review the course syllabi and determine if it will close those knowledge and skills gaps that you have identified. Always back up those fancy sales brochures by reaching out to others to get their opinion on their experiences with the training in the past. Also, remember to consider re-training as needed and always document. These things are important for the overall quality and credibility of your safety training programs.

Article by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.