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.

Here's a question for the Roco Tech Panel from one of our readers.
I recently became the ERT trainer. I have introduced the Petzl descender to the group and they love it. The question was brought up about the rating for lowering and raising of patients. What is it limits and can it be used in hauling up a two-person load? The max load the manufacturer says is around 600 pounds, and I am not sure if this is enough to meet what NFPA says. I really enjoyed the video Roco put out on this device, and would really enjoy seeing more on on other equipment.

Answer from the Tech Panel: Yes, you can use the Petzl ID-L (ID with red side plates that is NFPA G-rated) for raising and lowering two-person loads. For the ID-L, 600 lbf. is the “design load-rating requirement” for NFPA 1983 General Use. There are also two other ID versions – one with a yellow/gold side plate (ID-S) that is designed for smaller diameter ropes; and a blue side plate version, which will handle ½” rope like the red side plate but with a 550 lbf. design load.

So, what is the design load? Typically, it is the amount of weight/force a device or a system can handle; or the load that it is designed to handle. Once it has met the design load requirement for NFPA, it is placed in an equipment category and tested accordingly. In the case of the ID, it is tested as a descent control device. According to NFPA, General Use descent control devices shall withstand a minimum test load of at least 22 k/N (4946 lbf) without failure. I know what you’re thinking, “Hey, that’s not anywhere near the 9000 lbf we’re used to hearing for General Use?” NFPA requires that rope and carabiners be rated at 8992 lbf with pulleys and some other auxiliary items at 8093 lbf. Rope grab device shall withstand a minimum test load of at least 11 k/N (2473 lbf) without sustaining permanent damage to the device or rope to meet General Use. So, there is a wide range of strength requirements in NFPA 1983 depending on what category an item is tested in.

You must also consider that NFPA 1983 is a manufacturer’s standard and provides strength requirements for equipment to be classified as (T)-Technical Use (300lbf working load) – or (G)-General Use (600lbf working load). Rescuers must also refer to the manufacturer’s recommendations for use. However, an NFPA 1983 G-rating provides a quick field reference to the working load and confirms that a piece of equipment has been tested accordingly. This is important because OSHA will most likely look at this if there is an incident.

To answer your question, the manufacturer (Petzl) allows the ID to be used for the lowering and raising of two-person loads. If you have any other questions or need more information, please let us know – we’ll be glad to help. Check out our latest additions to our Video Resources for other great information!