Multiple Confined Space Entries

Tuesday, May 08, 2012

Multiple Confined Space EntriesQUESTION: What is required for making multiple confined space entries, and can an Attendant/Hole Watch monitor more than one entry at a time?

ANSWER: Good question! And, the answer is YES according to OSHA 1910.146. However, each space must be evaluated on its own merits with all regulations and requirements applying to each individual entry. Here we will provide some tips when considering one Attendant for multiple entries. This is also where preparing comprehensive rescue preplans becomes essential, and we'll start there.

Suggestions for Writing Rescue Preplans

Multiple Confined Space Entries1.  One of the first things is to identify and categorize the space as “permit-required” or “non-permit required.” You’ll need to carefully consider the possible hazards based on the information gathered.

2.  Once you’ve identified the hazards, you’ll want to consider what actions might be taken to eliminate or control the hazard to allow for a safe entry. OSHA 1910.146 defines "acceptable entry conditions" as the conditions that must exist in a permit space to allow entry and to ensure that employees involved with a permit-required confined space entry can safely enter into and work within the space.

3.  Next, you would need to consider the type of work that is going to take place inside the space. A very important question to ask... could the work create its own hazard? (An example would include hot work being performed inside the space.) Then, what about rescue capabilities and requirements? Next, you’ll need to determine whether the entry should be considered “Rescue Available” or “Rescue Stand-by?”

Roco uses the terms “Rescue Available” or “Rescue Stand-by” to better prepare for safe entry operations and in determining more specific rescue needs for that particular entry. Here’s the way we use these distinctions...Rescue Available would be your normal entry that is NOT considered an IDLH (Immediately Dangerous to Life and Health)entry. In this case, a 10-15 minute response time for a rescue team would generally be sufficient to satisfy OSHA regulations and is typical during turnarounds where multiple entries are taking place.

On the other hand, we use Rescue Stand-by when a more immediate need is anticipated, such as with a hazardous atmosphere or potentially hazardous atmosphere. For example, with an IDLH entry, it may require the team to be standing by just outside the space in order to reach the patient in a timely manner (i.e., how long can you live without air...3 to 4 minutes?)  Or, how quickly can the entrant be engulfed where there is a potential engulfment hazard?  OSHA 1910.134 requires a standby person or persons capable of immediate action with IDLH atmospheres. (See reference below.)

OSHA Reference Note to Paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

Regarding multiple entries, this Rescue Stand-by status could certainly limit the number of entries that could take place due to the availability of qualified responders and equipment. You must also consider that if you’re doing an entry that requires Rescue Stand-by and are called to respond to a rescue from a Rescue Available space, the entrants at the Rescue Stand-by entry must be evacuated before the team can respond. And, if there is only one rescue team, all other entries must stop during a rescue, as the team is no longer available.
Can an Attendant cover more than one confined space entry at the same time?

According to OSHA (see below), attendants can cover multiple spaces as long as they meet the responsibilities and duties at each entry site. If the spaces are “Rescue Available” and are in close proximity, this may be possible. However, without seeing the spaces and if they are on different levels as you mentioned, it could be very difficult for an Attendant to meet all of the requirements OSHA defines for Attendants.

OSHA Notes regarding Attendants and Multiple Entries...
NOTE to 1910.146(d)(6): Attendants may be assigned to monitor more than one permit space provided the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored. Likewise, attendants may be stationed at any location outside the permit space to be monitored as long as the duties described in paragraph (i) of this section can be effectively performed for each permit space that is monitored.

1910.146(d)(7) If multiple spaces are to be monitored by a single attendant, include in the permit program the means and procedures to enable the attendant to respond to an emergency affecting one or more of the permit spaces being monitored without distraction from the attendant's responsibilities under paragraph (i) of this section;

Once all these critical factors have been reviewed, you will need to consider the following when writing a rescue plan for an identical space:

    Internal configuration
    Elevation
    Portal Size

For hazards and LOTO procedures, you may be able to use the same rescue plan to cover those spaces. An example would be in doing ten (10) ground-level entries into 6-ft deep manholes, each with a 24” round, horizontal portal with a valve at the bottom. The rescue plan may be identical for all of these entries with the same description and hazards. However, on the rescue plan, you would need to allow for any unexpected hazards such as a possible change in atmosphere. This would be needed to be detected and properly handled by the responders at the time of the incident.

So, these are some of the basics you need to consider when writing a rescue preplan for confined spaces and for determining if (and when) an Attendant can effectively monitor multiple spaces.

If you have questions concerning these topics, please feel free to contact Roco at 800-647-7626.
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When should I retire my rescue rope?

Monday, October 24, 2011

When should I retire my rescue rope?Unfortunately, there’s not a reasonably priced “non-destructive” test to determine a particular rope’s strength. Your best bet is to have trained personnel using the rope, keep good rope use logs and inspect the rope after every use. It’s always best to refer to your rope manufacturer for proper care, inspection and replacement, so that’s what we did.

Here’s what Steve Hudson, President of PMI Rope, had to say.
He first referenced the product literature that’s included with PMI rope that states:

RETIRE IMMEDIATELY:
- Any rope whose strength may have been compromised during use.
- Any rope which is subjected to uncontrolled or excessive loading.
- Any rope which is greater than 10 years old, regardless of history and usage.
- Any rope whose history and past usage you are uncertain about.

While these are simple statements, I realize that it is difficult to determine what is “excessive loading” or what is “compromised.” And, if you think it’s hard to look at a rope after an operation and tell if it was compromised or not – think how hard it is for us at the factory to know without being there or having the rope to look at.

Unfortunately, there’s not a reasonably priced “non-destructive” test to determine a particular rope’s strength. Your best bet is to have trained personnel using the rope, keep good rope use logs and inspect the rope after every use. Anytime you have lost faith in what you know about the rope’s condition, for any reason, you should retire it.

A PMI rope, if properly cared for, should last at least 5 years of regular rescue training use and longer than that with intermittent use. By 10 years, it’s simply time to replace it. There are just too many things in the environment that the rope might pick up and are potentially harmful to the yarn.

And, as always, when in doubt, throw it out… CUT RETIRED ROPE into short lengths which will discourage future use – or discard it entirely. A retired rope should not be stored, kept or maintained in such a way that it could inadvertently be used as a lifeline. In some cases, when only a single point or a small area of a rope has been damaged and the remainder of the rope is in good condition, the user may elect to cut that section out of the rope and continue to use the remaining sections. This is a judgment call and such a decision is left to the user’s discretion.

Again, never take chances – if you’re not sure about the integrity of a rope, throw it out!

Quick Reference for Rope Retirement:

  •     Extensive Use (e.g. Roco’s training rope) – replace every two (2) years or as needed.
  •     Occasional Use (e.g. once a month) – replace every five (5) years or as needed.
  •     Regardless of Use – replace every ten (10) years.
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Can I use my training rope for rescue?

Tuesday, October 18, 2011

Can I use my training rope for rescue?We're often asked about using training rope for rescue purposes, so here's what we discovered...

The short answer is yes. However, NFPA 1500 provides some additional guidelines.

NFPA 1500 Standard on Fire Department Occupational Safety and Health Program (2007 Edition)
7.16.3* Life safety rope used for rescue at fires or other emergency incidents or for training shall be permitted to be reused if inspected before and after each such use in accordance with the manufacturers’ instructions and provided that the following criteria are met:

(1) The rope has not been visually damaged by exposure to heat, direct flame impingement, chemical exposure or abrasion.

(2) The rope has not been subjected to any impact load.

(3) The rope has not been exposed to chemical liquids, solids, gases, mists or vapors of any material known to deteriorate rope.

7.16.3.1 If the rope used for rescue at fires or other emergency incidents or for training does not meet the criteria set forth in 7.16.3(1), 7.16.3(2), or 7.16.3(3) or fails the visual inspection, it shall be destroyed.

7.16.3.2 If there is any question regarding the serviceability of the rope after consideration of the criteria listed in 7.16.3, the rope shall be taken out of service.

(*) Asterisk indicates that explanatory material is included in Annex A. While Annex A is not a part of the requirements of the NFPA document, it is included for informational purposes only.
Annex A (NFPA 1500)

A.7.16.3 Life safety rope can be significantly weakened by abrasion, misuse, contamination, wear, and stresses approaching its breaking strength, particularly impact loading. Because there is no approved method to service test a rope without compromising
its strength, rope rescue and training operations should be carefully observed and monitored for conditions that could cause immediate failure or result in undetectable damage to the rope. If a rope has been used in a situation that could not be supervised or where potential damage could have occurred, it should be removed from service and destroyed.

It is important that ropes be inspected for signs of wear by qualified individuals after each use. If indications of wear or damage are noted, or if the rope has been stressed in
excess of the manufacturers’ recommendations or has been impact loaded, it should be destroyed. The destruction of the rope means that it should be removed from service and altered in such a manner that it could not be mistakenly used as a life safety rope. This alteration could include disposal or removal of identifying labels and attachments and cutting the rope into short lengths that could be used for utility purposes.

The assignment of disposable life safety ropes to members or to vehicles has proven to be an effective system to manage ropes that are provided for emergency use and are used
infrequently.

Special rescue teams, which train frequently and use large quantities of rope, should include members who are qualified to manage and evaluate the condition of their ropes and determine the limitations upon their reuse.
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Is relying on my local fire department in compliance with OSHA 1910.146?

Tuesday, September 13, 2011

Is relying on my local fire department in compliance with OSHA 1910.146?Often the question comes up about using a local fire department for confined space rescue coverage in an industrial facility; and if it would be in compliance with OSHA 1910.146? In addition to the proper evaluation of the prospective rescue service, we always stress the need for “reciprocal communications” between the rescue service and the employer. For example, if the rescue service becomes unavailable at any time during a PRCS entry, the rescue service agrees to contact the employer so that the entry can be immediately suspended until the rescue service is once again available to respond in a timely manner.


The following is from an OSHA Letter of Interpretation dated 5/23/08.

Scenario: An employer evaluates and selects a local fire department using the guidance provided in Appendix F of the PRCS standard, Rescue Team or Rescue Service Evaluation Criteria (Non- mandatory). The employer has determined that the local fire department is adequately trained and equipped to perform permit space rescues of the kind needed at the facility. The employer has also made a performance evaluation of the service in which the employer has measured the performance of the team or service during an actual or practice rescue. However, the local fire department cannot guarantee that the rescue team will not be sent on another call during the employer’s permit-space entry operations. In other words, they have the ability to respond in a timely basis, unless another call prevents them from doing so.

Question: If the employer selects this local fire department as its off-site rescue service, would the employer be in compliance with 1910.146(k)(1)?

29 CFR 1910.146(k)(1) provides:

(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of his section, shall:

(i) Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

Note to paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, 1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

(ii) Evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified;

(iii) Select a rescue team or service from those evaluated that:

(A) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;

(B) Is equipped for and proficient in performing the needed rescue services;

(iv) Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and

(v) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

Note to paragraph (k)(1): 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.

The employer must evaluate and select an off-site rescue service that has the capability to respond in a timely manner to the particular hazards at issue and to the types of emergencies that may arise in the employer’s confined spaces. The criteria employers can use in evaluating and selecting a service include determining whether the service is unavailable at certain times of the day or in certain situations, the likelihood that key personnel of the rescue service might be unavailable at times, and, if the rescue service becomes unavailable while an entry is underway, whether the service has the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately.

Compliance may require the employer to be in communication with the off-site rescue service prior to each permit space entry. In the scenario described, the employer must ensure close communication with the rescue service during entry operations so that if the rescue service becomes unavailable while an entry is underway, the employer can instruct the attendant to abort the entry immediately. Entry operations cannot resume until the entry supervisor verifies that the rescue service is once again able to respond in a timely manner.

ROCO COMMENTS:

It’s important to note that the off-site service must be willing to perform rescues at the employer’s workplace. As referenced in Appendix F (5)… For off-site services, is the service willing to perform rescues at the employer’s workplace? (An employer may not rely on a rescuer who declines, for whatever reason, to provide rescue services.)

Also, while a written agreement with the local agency is not necessarily required by the regulation, it certainly would make it easier to document that an agreement to respond was in place – and that the department had an understanding of the scope of services to be provided at the employer’s site (i.e., confined space rescue).
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Cleaning Your Rope…Here’s What the Experts Have to Say

Wednesday, July 27, 2011

Cleaning Your Rope…Here’s What the Experts Have to SayWe are often asked, “How should I maintain my rescue equipment – especially rope?”

So, we went to our friends at CMC and PMI for the answers.  Keep in mind, however, you should always follow your rope manufacturer’s care and cleaning instructions.

CMC offers their rope cleaning suggestions: Rinse off muddy or especially dirty rope or web with water. Scrub any tough spots with a nylon bristle brush. Soak the rope in a tub of water with a mild detergent.

Woolite or other mild detergents that are safe for nylon may also be used. The rope can be rinsed using a rope washer or placed directly into the washing machine. Washing rope and webbing in a top-loading washing machine is the easiest method. Run the empty machine through a cycle with plain water to rinse any harsh detergents from the machine before starting. Use cold water and the appropriate amount of detergent.

Double the rope (or web) and “daisy-chain” it. This keeps single lines from tangling or getting caught in the agitator. Put the rope in the machine and wash on the gentle cycle. If the rope bag needs washing, put it in with the rope. During the rinse cycle, add a small amount of Downy fabric softener. (No more than one ounce of Downy to 3 gallons of water.) The fabric softener replaces the lubricant the rope loses during use and washing.  Air dry the rope and webbing in a cool, shaded place. Do NOT dry nylon products in the sun because of the damaging effects on nylon from prolonged exposure to ultraviolet rays. If necessary, ropes can be stuffed into the bags wet. The ropes may mildew but this does not adversely affect the rope. Rope that has come into contact with blood or other body fluids can be cleaned using a chlorine bleach per your department’s protocols for contaminating equipment.

PMI offers special precautions about cleaning exposed rope:

In cases where equipment may be exposed to blood‐borne pathogens or other infectious substances, we’re often asked about appropriate methods for cleaning ropes. Certain authorities recommend specific concentrations of household bleach for disinfecting gear that has been exposed to certain contaminants, so naturally customers often wonder at what concentration their PMI rope will experience deterioration. While PMI cannot speak to the subject of infectious diseases, or what solution might neutralize a given hazardous substance, we are happy to provide at least some guidance regarding the effect of bleach on rope fibers.

Specifically, PMI has found that a mixture of 1 part household bleach (with active ingredient of Sodium hypochlorite at 5.25% concentration) with 9 parts room temperature tap water and a 10 minute or less exposure time, immediately followed by a thorough rinse of room temperature water appears not to cause any appreciable harm to nylon or polyester ropes. PMI cannot, however, speak to whether or not such a mixture will truly disinfect your rope from contaminants.

Precautionary Note:  PMI’s testing suggests that a “single disinfection” of ropes using the above recommended method will not cause appreciable harm to nylon or polyester ropes. However, if this process is repeated multiple times, the damage will inevitably become appreciable, and this damage is not necessarily detectable through visual inspection.

Remember, ropes are a critical element of the life safety system, and it can be difficult to make subjective decisions about the strength of rope without actually testing it to failure. The prudent course of action is to discard any rope about which there is any doubt.
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