READER QUESTION:
Our company procedures require an on-site rescue capability for permit- required confined space entry operations during normal Monday-Friday “day shift” operations, but for entries other than during that shift, we rely on an off-site rescue service. Shouldn’t the rescue capability, specifically the rescue response time, be the same no matter when the permit required confined space entries are being made?

ROCO TECH PANEL ANSWER:
Yes; and no, not necessarily.

Yes, if the nature of any known or potential hazards that may affect the entrants in the permit space, and the configuration of the confined space are the same during regular M-F day shift as they would be during off-shift entries, then the answer is yes. The rescue capability regarding response time, manning, equipment, and overall performance capability should be the same.

No, not necessarily. For example, if the nature of the known or potential hazards of a permit space entered during the day shift requires a shorter response time, or if the configuration of the space requires a higher level of rescue expertise, rescuer PPE, number of rescue personnel, or if there is any other factor that may require a different performance capability than the requirements of the day shift entries, then no, the same rescue capability would not necessarily be required.

This is because OSHA 1910.146 is a performance-based standard. For confined space rescue, specifically regarding what would be considered “prompt rescue,” the performance standard will be most influenced by the nature of the potential and known hazards and how quickly the hazards will affect the authorized entrants, as well as the complexity of providing effective rescue from the particular permit-required confined space.

To demonstrate this point, here are some extracts from OSHA 1910.146 Permit Required Confined Space Regulation Section K, the Summary and Explanation of the Final Rule, and also from OSHA 1910.146 Appendix F.

From 1910.146 (k)(1)(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.”

From the Summary and Explanation of the Final Rule (1910.146) “OSHA has therefore decided to promulgate the requirement it proposed for "timely" rescue, a requirement that was not opposed by any rulemaking participant, rather than to define precisely what is timely. That determination will be based on the particular circumstances and hazards of each confined space, circumstances and hazards which the employer must take into account in developing a rescue plan. OSHA has added a note to paragraph (k)(1)(i) to clarify this point.”

From 1910.146 Appendix F, A. Initial Evaluation, II, 1. “What are the needs of the employer with regard to response time (time for the rescue service to receive notification, arrive at the scene, and set up and be ready for entry)? For example, if entry is to be made into an IDLH atmosphere, or into a space that can quickly develop an IDLH atmosphere (if ventilation fails or for other reasons), the rescue team or service would need to be standing by at the permit space. On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutes might be adequate.”

The response time of the rescue service is also different than the time needed to provide rescue. Response time generally means the time it takes for the rescue service to arrive on scene. From that time forward, the rescue service must perform a size-up, identify and don PPE, set up rescue systems, and perform many other tasks before initiating entry rescue. Any need to provide victim packaging or to deliver breathing air to the victim will add to the total time it takes to complete the rescue.

Therefore, it is imperative that the employer ensures that the measure of “Prompt Rescue” is driven by the nature of the known or potential hazards of the permitted confined space as well as the complexities of the configuration of the space and how those will effect the time required to the setup the rescue system.

Roco provides confined space rescue services for a variety of industries and is confronted with a very wide range of hazards associated with the entry operations and a vast range of space configurations. The determination on the rescue team’s posture is based primarily on the answer to the following questions.

• 1.  How quickly will the entrants be overcome by the known or potential hazard(s) of the space, and /or how quickly will the entrants suffer permanent injury if exposed to those hazards?
• 
  
• 2.  If non-entry retrieval systems are not employed due to the system not contributing to an effective rescue, or the retrieval system creates a greater hazard, how much time would be needed to arrive on scene, set up an entry rescue system to support the entrant rescuer(s) and the victim(s)?

These are just two of the primary questions that we consider for our CSRT operations. If the nature of the known or potential hazards would require a near immediate rescue of the entrant(s), we would assume a “Rescue Standby” posture where the rescue systems are pre-rigged, the entrant rescuers are already in appropriate PPE or have it available to be quickly donned, and the rescue effort can be initiated in a very short time in an effort to meet that “Prompt Rescue” performance benchmark.

It is vitally important that the employer honestly evaluates the nature of the hazards or potential hazards of the permitted confined spaces that they plan on entering. This can be accomplished by reviewing product SDS (Safety Data Sheets), understanding the nature of the hazards that are not included in the SDS, and always considering worst case scenarios. Additionally, the employer must include an evaluation of the time it would take the rescue service to arrive on scene as well as the additional time to safely assess the situation and setup the required rescue systems prior to initiating rescue.

The answer to the question of a different rescue capabilities based on the “day shift” or “night shift/week-ends” can only be answered by performing a thorough assessment of the permitted spaces. And, on a case by case basis, determine if the rescue capability for that particular entry operation does indeed meet the spirit of “Prompt Rescue.” 

READER QUESTION:

If Appendix F is non-mandatory, then why is it relevant to my PRCS program?

ROCO TECH PANEL ANSWER:

Questions often arise about the application of Appendix F of OSHA’s Permit Required Confined Spaces standard. Those questions usually focus on the “non-mandatory” characterization of the appendix. The question most often asked is:

“If it’s non-mandatory, why should I even bother with it?”

The answer is simple: even though Appendix F itself is “non-mandatory,” the methods for compliance in the appendix all relate to mandatory requirements of the standard. Appendix F is simply a non-mandatory method for complying with mandatory requirements.

The trick when evaluating the methods of compliance outlined in Appendix F is to match the particular non-mandatory provision of the appendix with the corresponding mandatory requirement of the standard. Then the employer can either use the method suggested in the appendix, or devise its own method to comply with the mandatory requirement.

For example, with regard to outside rescue services, Appendix F paragraph A(3) asks the question: “If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately?”

This provision does not create a mandatory requirement, but it does prompt the employer to take into account mandatory requirements of the standard. OSHA 1910.146(j)(3) makes it mandatory for the entry supervisor to terminate the entry and cancel the permit as required by paragraph (e)(5) of the standard.

Paragraph (e)(5) requires the entry supervisor to cancel the entry permit when “a condition that is not allowed under the entry permit arises…” If the particular entry requires rescue service availability and the rescue service suddenly becomes unavailable during the entry, that would be “a condition that is not allowed under the entry permit” requiring the entry supervisor to cancel the permit.

So although there is no provision that specifically states that the rescue service notify the employer if it becomes unavailable, from a practical standpoint the employer cannot comply with the requirement that it cancel the permit and terminate the entry when a condition not allowed under the entry permit arises unless such a notification system is in place. This is just one example of how the provisions of non-mandatory Appendix F provide a method to comply with mandatory requirements.

When considering the provisions of non-mandatory Appendix F, the employer would be wise to determine which mandatory provisions the method stated in the appendix addresses. Of course, the employer is free to choose some other method to comply with the mandatory provision and does not necessarily have to follow the method suggested in the appendix. In that sense, the appendix is “non-mandatory.” But, nonetheless, the employer must comply with the underlying mandatory provision, and take any steps necessary to do so.

Related Information

Evaluating Your Rescue Service

READER QUESTION:
Can a patient be lowered in a vertical or horizontal Sked without being lashed to a backboard or without a backboard at all?

ROCO TECH PANEL RESPONSE:
The answer is YES! This is one of the advantages of choosing the Sked stretcher.

It can be used with most (if not all) backboards, with a short spine immobilizer, or with nothing at all.

There are two general considerations in deciding what device to use with the Sked or other flexible litters:

(1) Patient Condition - If spinal injuries or other injuries need the splinting effects or the protection of a backboard, then the victim should be lashed to a backboard. When a backboard is not in place, the Sked will help keep the body in line when tightened; however, the spine can continue to be manipulated up and down as patient is moved over objects or edges which can compromise the spine.

If you are just using the backboard to keep the Sked rigid or protect the patient while placing them over edges, then technically you would not need to lash them to the backboard.

When a confined space is too tight to use a backboard and possible spinal injuries are suspected, or additional protection for placing a patient over an edge is wanted, then a short spinal immobilizer such as the OSS can be used. If a spinal injury is not suspected, then no additional equipment needs to be used with the Sked. It is always good to keep in mind, however, that the thin plastic make-up of the Sked will allow the patient to feel every edge or bump you place or drag them over.

(2) Location - What size portal do you need to get the patient and packaging through in order to perform the rescue? Many times in portals less than 18-inches, the individual pieces of equipment will fit into the space, but once put together they will not fit back out of the space. The Sked was designed for this specific circumstance. The thin plastic construction allows it to fit in places many other litters will not.

The Sked can also be used vertically with the bottom not curled and secured in cases where a hare-traction splint or other injury doesn’t allow securement at the bottom.

The Sked is a very user-friendly device that can be used in a multitude of configurations and for various applications. This is one of the reasons why it is such a popular rescue tool, especially for confined space rescue! Stay safe!

NOTICE: The information provided on our website and by our Tech Panel is a complimentary service for our readers. Responses are based on our understanding of the reader’s inquiry, the equipment and/or the technique in question. All rescue systems should be evaluated by a competent person before use in the support of any human loads. Proper training is required prior to use of rescue techniques or systems discussed. Because standards and regulations are typically performance based and often dependent on specific circumstances, it is important to review all regulations in their entirety and to follow the proper protocols for your company or organization.

READER QUESTION:
Regarding the Roco video/technique for shortening webbing... what is the strength impact on the webbing with this technique? When going from the looping double/basket method to a choker configuration changes the strength quite a bit because of all sorts of twists and bends... would the strength impact be 50%?

ROCO TECH PANEL RESPONSE:
After reviewing your question, we decided to do some “in-house” testing. Of course, it’s unofficial, but here’s what we did and the results are shown below.

Using new 1-inch tubular webbing anchored to a fixed anchor 2 inches in diameter, a “webbing shortening technique” knot was placed in the webbing. The webbing was marked with a felt tip marker on both sides of the knot to measure slippage. A carabiner was placed in the test webbing and attached to the dynamometer by a short piece of 1-inch tubular webbing that was looped, doubled and ran through the attachment opening on the dynamometer. The dynamometer was then anchored to the load.

Unofficial In-House Test Results:

1. Unloaded 20-ft of 1-ft piece of tubular webbing:
   Force applied 3,340 lbf with 2½ inches of slippage in the webbing.
2. Loaded 30-ft webbing of 1-ft piece of tubular webbing:
   Force applied 3,560 lbf with ¾ inch slippage.
3. Loaded 30-ft webbing of 1-ft piece of tubular webbing:
   Force applied 5,080 lbf with 1 inch slippage.
4. Loaded 30-ft webbing of 1-ft piece of tubular webbing:
   Force applied 5,460 lbf with 1 inch slippage.
5. Loaded 40-ft webbing of 1-ft piece of tubular webbing:
   Force applied 5,620 lbf with ¾ inch slippage.
6. Loaded 40-ft webbing of 1-ft piece of tubular webbing:
   Force applied 6,230 lbf with 1 inch slippage.

Tests #1 & #2 were slow tension pulls on the knot. Tests #3 & #6 were dynamic shock loading. Tests #5 & #6 both had failures of the 1-inch tubular webbing anchor at the attachment to the dynamometer. The failed anchor webbing was in a basket looped and doubled configuration and failed at the sharp angle connection on the device.
The test webbing did not fail in any of the tests, but on tests #5 & #6 it showed slight glazing on the inside of the knot when inspected.

Due to the failure of the anchor webbings, we were not able to generate more than the 6,230 lbf force on the system. Based on these unofficial tests, I would feel comfortable using the technique for NFPA General Use loads and would not expect it to weaken the webbing any more than the efficiency loss of any other knot that would be tied into the webbing, including a water knot.

NOTICE: The information provided on our website and by our Tech Panel is a complimentary service for our readers. Responses are based on our understanding of the reader’s inquiry, the equipment and/or the technique in question. All rescue systems should be evaluated by a competent person before use in the support of any human loads. Proper training is required prior to use of rescue techniques or systems discussed. Because standards and regulations are typically performance based and often dependent on specific circumstances, it is important to review all regulations in their entirety and to follow the proper protocols for your company or organization.

 

QUESTION FROM OUR READER:
In the new Stokes lashing video the instructor tied 2 butterfly knots into the webbing. Can this also be done with 2 figure eight knots in the webbing? Also I was looking for the information on Sked lashing, with by-passing the top 2 grommets and starting with the first 2 on the sides.

ANSWER:

The answer to your question about substituting figure-8 knots for butterfly knots in the webbing for the stokes lashing is Yes you can. You could also use two separate pieces of webbing to accomplish the same goal. Check out our Skedco Alternate Lashing Guide for details.