Non-Entry Confined Space Rescue…Are You Sure?

Tuesday, May 07, 2019
by Pat Furr, Safety Officer & VPP Coordinator

There are three generally accepted types of confined space rescue: self-rescue, non-entry retrieval, and entry rescue. Just as with the hierarchy of hazard mitigation, confined space rescue should be approached with an ascending hierarchy in mind. 

  1. Self-rescue is typically the fastest type and eliminates or at least greatly reduces the chance that anyone else will be put at risk. For these reasons, it is the first choice, but it is unrealistic to think that an entrant would be able to rescue themselves in all situations.
  2. Non-entry retrieval is the next choice. OSHA stipulates that non-entry retrieval must be considered as a means of rescue – more on that shortly.
  3. Entry rescue is the last choice, largely because it exposes the rescuers to the same hazards that the original entrant faced.

Non-Entry Confined Space Rescue…Are You Sure?

OSHA recognizes the inherent danger of entry rescue, which is why the organization mandates “retrieval systems or methods shall be used whenever an authorized entrant enters a permit space.” However, OSHA goes on to qualify this statement with two very important exceptions. OSHA requires non-entry retrieval, “unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”  Let’s examine each of these two provisions more closely... 

  1. Non-entry retrieval is required “…unless the retrieval equipment would increase the overall risk of entry.” For example, if the retrieval line would create an entanglement hazard that would impede the entrant’s ability to exit the space, then the retrieval system should not be used and entry rescue should be the choice.
  2. And non-entry retrieval is required unless the equipment “…would not contribute to the rescue of the entrant.” The key here is that the non-entry method employed must be viable. It must work when called into action.

For non-entry retrieval systems, we are relying on that retrieval line to exert forces on the entrant to pull them out of the space without help from any other device or human intervention within the space. It must perform without someone inside the space maneuvering the victim or otherwise providing assistance to the retrieval system. It has to work independently of any other forces other than what is generated from outside the space. This extremely important point is often overlooked and has resulted in many fatalities. Sadly, many of those fatalities were the would-be rescuers that attempted entry rescue when the retrieval system failed to do its intended job.

Situations that may render the retrieval system useless would be any configuration or obstruction inside the space that would prevent the system from pulling the victim clear of the space in an unimpeded manner. This could be pipework or obstructions on the floor for a horizontal movement. Likewise, pulling an unconscious victim around corners may render a retrieval system ineffective. If the entrant moves over any edge and down into a lower area offset from an overhead portal even at moderate angles, the retrieval system will probably not be able to pull an inert victim up and over that edge, even if the drop were only a foot or so.

It must be clearly understood that retrieval systems may quite possibly be applying forces on a limp human body, which, as harsh as this sounds, becomes a sort of anchor. It requires a very thorough and honest evaluation of where the entrant will be moving in the space in order to perform their planned work, and what obstructions or structural configurations are in that path. If there is any possibility that the system will not be able to pull an unconscious, inert victim along that path, then the retrieval system is NOT viable.

Human Nature vs The Best Laid Plans - An Example

Okay, so you have done a thorough and honest evaluation of the space, its configuration, and internal obstructions and determined that there is a clear path from the entrant’s “planned” work area, which is offset ten feet from the overhead portal eight feet above. Clearly, the retrieval system will be able to pull the victim out of the space should the need arise. Enter human nature, and with that comes bad decisions. Murphy’s Law has a very nasty way of changing things for the worse. 

What if, in the course of the planned work, our entrant drops his wrench down into a sump immediately adjacent to his work zone but further from the overhead portal? The fixed ladder down into the sump is only five feet and he can clearly see the wrench stuck in the sludge below. He asks for slack on the retrieval line, climbs down into the sump, bends down to grab his wrench and is nearly immediately rendered unconscious due to an undetected atmospheric hazard. 

The attendant/rescuer sees that the entrant’s head and shoulders do not reappear and within several seconds calls to ask if he is ok, only to hear no answer. He calls several more times, but still no answer. He begins to haul with the retrieval system, which consists of a wire rope winch mounted to a tripod.  The cable becomes tight and the tripod shudders and shifts slightly, then all progress stops. The would-be rescuer tries with all his might to pull the entrant’s limp body up and over the 90-degree concrete edge, but cannot. 

In a panic, the attendant/rescuer climbs down into the space and over to the sump where he sees the entrant pulled tightly against the wall of the sump but not off the floor. He climbs down into the sump to attempt to lift the entrant’s 200-pound limp body up and over the five-foot wall. As soon as he bends down to cradle him, the hazardous atmosphere overcomes him also. Two fatalities later, we wonder how our non-entry rescue retrieval system could have failed us. It would not have, had human nature not interfered and caused two people to make bad decisions. 

That story was intended to point out that things do not always go according to plan. Not only do we humans make bad decisions on occasion, but we also have accidents due to trips, slips, and falls that may send us to an area that the retrieval system may not work. Conditions inside the space may change in such a manner that it affects the retrieval system. 

For all these reasons I implore you to evaluate the capability of the retrieval system to work not only when things go according to plan, but also to evaluate the system based on the “what ifs.” For the “what ifs” that involve bad decisions, that is a matter of training and communicating to the entry team why they cannot deviate from the work plan, even to fetch that dropped wrench. For the “what ifs” that include trips, slips, falls, or equipment failures, it may be time to consider a back-up plan, which may include an entry rescue capability. 


Pat Furr
Pat Furr

Pat Furr is a chief instructor, technical consultant, VPP Coordinator and Corporate Safety Officer for Roco Rescue, Inc. As a chief instructor, he teaches a wide variety of technical rescue classes including Fall Protection, Rope Access, Tower Work/Rescue and Suspended Worker Rescue. In his role as technical consultant, he is involved in research and development, writing articles, and presenting at national conferences. He is also a member of the NFPA 1006 Technical Rescue Personnel Professional Qualifications Standard. Prior to joining Roco in 2000, he served 20 years in the US Air Force as a Pararescueman (PJ).

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Rescuing the Rescuer: When Things Go Wrong During a Rescue

Friday, February 15, 2019
by Brad Warr, Chief Instructor

The day before 40-year-old Phoenix firefighter Brett Tarver got separated from his crew and ran out of air at the Southwest Supermarket fire, the fire service felt confident in its ability to rescue a downed firefighter. That all changed when Tarver was found unresponsive thirty minutes after his mayday was broadcast over the radio. The tragic loss of Brett Tarver on March 14, 2001, left the firefighting community wondering what it had missed.

The ensuing years of self-examination and evaluation of rapid intervention techniques and operating procedures resulted in the development of NFPA 1407: Standard for Training Fire Service Rapid Intervention Crews.
Rescuing the Rescuer: When Things Go Wrong During a Rescue
Released on December 5, 2009, the document provided a framework for fire departments to train, equip and deploy their personnel in the event of mayday. A decade later, firefighters are more prepared than at any time in history to launch a rescue operation when a brother or sister firefighter calls that mayday.

While firefighter rapid intervention techniques have continued to improve, confined space rapid intervention has not received quite as much analysis and focus for improving techniques and guidelines, despite the fact that more than 60% of confined space fatalities occur among would-be rescuers. Perhaps this is why Roco Rescue’s course “Rescuing the Rescuer: When Things Go Wrong During a Rescue”, which is being offered at the North Dakota Safety Council’s (NDSC) upcoming 2019 Annual Safety & Health Conference, sold out in a matter of days. The industry – whether they are firefighters, emergency responders, or industrial workers, recognizes the vital importance of a subject that is truly a matter of life or death.

About the Course
Taking lessons learned from both successful and unsuccessful rescues of downed firefighters, students attending “Rescuing the Rescuer” will apply those lessons to the world of confined space rescue. The day-long session will bring together rescuers of all experience levels seeking strategies for effectively responding to what nearly everyone agrees is the most stressful call a rescuer will ever receive.

The course will emphasize the following:

    • - Having a plan before something goes wrong is the only chance you have.
    • - Simple systems are easier to use in a stressful situation than complex systems.
    • - There are no systems that can replace a clear-thinking, highly-trained rescue technician.

While NFPA 1407 gives a clear picture of the responsibilities of a firefighter during a mayday, the picture is not nearly as clear for rescuers responding to the mayday call or loss of contact with a rescuer inside a confined space. The sometimes-murky relationship between OSHA and NFPA standards will be explored including a review of both the construction and general industry OSHA confined space standards (1926 Subpart AA and 1910.146).

Tackling a Rarely-Explored Topic

Although training for a downed rescuer is a topic that is rarely visited in rescue training due to time constraints and the extensive requirements rescue technicians already must meet in order to carry their title, Roco Rescue believes it is a topic that shouldn’t be overlooked. The popularity of the course in North Dakota demonstrates that this is a subject of extreme interest to the safety industry.

This is the first time Roco Rescue has offered the course in this format, but it most likely won’t be the last. Subscribe to our newsletter to be the first to learn about new course offerings. Safety professionals interested in this training who are unable to attend the sold-out course in North Dakota may also wish to explore Roco Rescue’s advanced tech level course, FAST-TRACK 120™.

Rescuer fatalities have declined in recent years, but they aren’t declining quickly enough. Let’s do our part to ensure that workers in the safety and rescue fields make it home to see their families when their work is done.

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Brad Warr

Brad Warr is a Chief Instructor for Roco Rescue and a Captain at the Nampa Fire Department. Brad joined Roco Rescue in 2003, teaching a wide variety of technical rescue classes including rope rescue, confined space rescue, trench rescue, and structural collapse. Brad became a firefighter for the Nampa Fire Department in 1998 and was promoted to Captain in 2006. Before joining the fire department, Brad worked for three years as an Emergency Response Technician for a large computer chip manufacturer in Boise, Idaho, where he was responsible for OSHA compliance, emergency medical response, confined space/rope rescue response and hazardous materials response.

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Rescue Challenge 2018

Friday, November 02, 2018
Rescue Challenge 2018Seven challenging rescue scenarios awaited participating teams at Roco Rescue Challenge 2018 recently held in Baton Rouge. Multiple training props at and near the Roco Training Center (RTC) were used to create the realistic problem-solving scenarios, which included both props at the RTC as well as the training tower and the “industrial prop” at the Baton Rouge Fire Department. These facilities provided a wide variety of rescue scenarios and rigging environments for the teams during the two-day event.

Challenge teams were required to successfully complete scenarios in all six (6) Confined Space Types based on OSHA-defined criteria in addition to Rescue from Fall Protection and Extrication. The scenarios were designed to meet OSHA1 and NFPA2 requirements for annual practice and evaluation of team capabilities as well as the individual rescuers. Participating teams received third party testing of the scenarios and individual rescuer skills along with documentation to back up the testing. Following Rescue Challenge, each team receives a complete report of the scenarios along with their scores, strengths and weaknesses as well as debriefing notes from the instructor evaluators.Rescue Challenge 2018

Speaking of evaluators, this year featured some of Roco’s top instructors who hailed from Idaho to New York. These individuals are passionate about teaching rescue and improving the performance of their students. No doubt they’re a big part of why the event is so successful and so effective in honing the teams’ skills. In fact, this year’s event was dedicated to the memory of one of our long-time instructors and original Roco Rangers, Mr. Doug Norwood.

Rescue Challenge 2018All Challenge scenarios are designed to have teaching goals that require different rescue and rigging skills. They included simulated IDLH rescue entries with the use of SAR and SCBA equipment. Also included were single-person and multi-casualty scenarios with a mix of manikins and live victims/evaluators as patients.

Challenge consisted of three different testing criteria to include:
1. Seven rescue scenarios;
2. Individual Performance Evaluations (IPE); and,
3. A Team Performance Evaluation (TPE).

Here is a quick break down of the two-day event:

DAY ONE
Station#1 – CS Types #3, #4 & #6
A worker fell approximately 8 ft. while working on a motor in a fan plenum on a cooling tower. The worker fell through the fan to the cooling pipes below and suffered from heat exhaustion and a possible broken/dislocated hip. Access and egress to the patient and ground was through a series of ladder cages at approximately the 50 ft. level.

Station #2 – Rescue from Fall Protection
A worker who was painting on top of a 50 ft. dome column tower fell onto his fall protection system. Access by the technical rescue team was over the top of the dome to the far side of the tower where rescuers needed to transfer the patient from his system to the rescuer’s system before descending to safety.

Rescue Challenge 2018Station #3 – CS Types #3 & #2
Three workers were trapped in a “Stack” elevator that jumped off its track. The scenario simulated rescue from a height of 300 ft. requiring knot-passing techniques.

Station #4 – CS Type #4
A reenactment of an OSHA confined space incident where two entrants were injured in a flash fire in a confined space, which required on-air entry using SCBA.

Station #5 – CS Type #4
The rescue of an unconscious worker from a column vessel with multiple internal trays, requiring that the patient be lowered approximately 40 ft. to the ground.

Rescue Challenge 2018DAY TWO
Station #6 – CS Type #5
A worker was trapped under a piece of machinery (2000lbs+) in a containment vault. Teams used rescue airbags and cribbing to raise and extricate the individual from under the object before completing a low-point confined space rescue from a vertical-entry confined space.

Station #7 – CS Types #1 & #3
Report of a worker down in a low O2 atmosphere in a boiler expansion tank. Teams were forced to ascend a vertical temporary ladder approximately 10 ft. inside a 24-in. tube to access the individual while wearing SAR due to low levels of oxygen.

Station #8 – Individual Performance Evaluation (IPE) 
Individual team members were evaluated on their ability to perform patient packaging, knots, rigging, and mechanical advantage.

Station #9 – Team Performance Evaluation (TPE) 
Teams moved a patient along a multi-stage track referred to as the “Yellow Brick Road.TM” This scenario requires the teams to perform different packaging, raising and lowering techniques in order to move successfully to the next problem-solving station.

Scoring was very tight this year with all teams scoring between 85% to 90% overall. Roco scoring is based on the following: 90% and above “superior rescue team;” 80%-89% “excellent rescue team;” and 70%-79% “capable rescue team.” Scores below 70% require the teams to redo the scenario once it is critiqued and any safety concerns are addressed.

Rescue Challenge 2018We also had numerous observers at this year’s Challenge both from the municipal and industrial sectors. They reported that they were able to see “first hand” the benefits of Rescue Challenge, and that they are planning on sending teams for next year’s event.
  
One observer commented that the format and location allowed teams to get out of their comfort zones and have a good look at how they would respond to an actual incident at their facility.
Some of the exceptional performances this year included:
Shell-Convent, LA: Overall highest average of 90% for all scenarios.
Valero-Wilmington, CA: 1st place IPE station.
CF Industries-Donaldsonville, LA: 1st place TPE station.
Two Louisiana teams (International Paper-Bogalusa and Shell-Norco) tied for “Top Score” on a single scenario scoring 490 out of 500 possible points.

If you missed this year’s Rescue Challenge, join us next year on October 23-24, 2019, in Baton Rouge. Every year our instructors devise new surprise obstacles to challenge teams with hurdles they’ve never tackled before.
Is your team “Rescue Challenge ready?”

1OSHA 1910.146 Permit-Required Confined Spaces
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.

2NFPA 1006 Technical Rescue Personnel Professional Qualifications
1.2.6* Technical rescue personnel shall remain current with the general knowledge, skills, and JPRs addressed for each level or position of qualification. Technical rescue personnel shall remain current with technical rescue practices and applicable standards and shall demonstrate competency on an annual basis.
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018 Rescue Challenge 2018
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Safe Confined Space Entry - A Team Approach

Wednesday, September 26, 2018

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.

Roco Rescue CS EntryMost 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.


Roco CS Entry Supervisor & AttendantIn 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!”

When we talk to Attendants about their duties, we often find they only know to “blow a horn” or “call the supervisor” if something happens, or if the alarm on the air monitor goes off. We also ask…What about when the Attendant has an air monitor with a 30 ft. hose, and there is no pump? Or, if you have three workers in a vertical space and the entire rescue plan consists of one Attendant, a tripod and a winch, plus no one in the space is attached to the cable – what happens then?
  
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.

Roco Rescue Remote MonitoringMany 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.
 
OSHA 1926.32 DEFINITIONS:
• 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!

Additional Resources:
• Download our Confined Space Entry Quick Reference Checklist. This checklist reiterates the value of approaching permit-required confined space entries as a team. In addition to OSHA-required duties and responsibilities for the three primary roles, we have included our recommendations as well. These are duties that we feel are important for the individual(s) fulfilling that role to be knowledgeable and prepared to perform if need be.

Safe Entry Workshop: Entrant, Attendant & Entry Supervisor is now available. See the full course description for details.

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Dennis O'Connell

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.

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