Because it is important to keep our readers and students updated, we wanted to share the following information with you. Please note that this issue is not resolved as of this time, and we have a letter submitted to OSHA for clarification. However, we wanted to keep you in the loop so that you can make better decisions when it comes to your rescue preplanning and operations.

It has recently come to our attention that there is a pending OSHA Letter of Interpretation (LOI) regarding the requirement for an “individual retrieval line” for each entrant. This pending interpretation is different from our understanding of what’s required by the regulation (1910.146). While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.

As mentioned above, Roco has submitted a detailed letter to OSHA for a clarification, stating our position that the use of individual lines for entrants in all cases is problematic for a number of reasons. Although OSHA’s response in its letter of interpretation is ambiguous as to its applicability to entry rescue operations, in our commitment to follow the intent of all OSHA standards, Roco is assuming that OSHA’s response was intended to apply to all entries, including rescue entries. Therefore, we will teach and use “individual lines” for the time being until we get further clarification from OSHA.

Question to OSHA:
In a request for clarification, a gentleman from Maryland had asked this question, “Does OSHA 1910-146 (k)(3) require that each individual entrant, including workers and/or rescuers, entering into a confined space be provided with an independent retrieval line or can more than one entrant be connected to a single retrieval line?”

OSHA’s Response:
OSHA’s response in the LOI states, “OSHA 1910.146(k)(3)(i) requires that each authorized entrant into a permit-required confined space must have a chest or full-body harness attached to their ‘individual’ retrieval line or life line to ensure immediate rescue of the entrant.”

Roco Note: It is important to note that “individual” retrieval line is not used in (k)(3)(i); it simply refers to “a” retrieval line. The standard states, “Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant’s back near shoulder level, above the entrant’s head, or at another point….”

Additional Roco Comments:
First of all, OSHA’s Permit-Required Confined Spaces Standard is, for the most part, a “performance-based” standard, meaning that it generally provides a result that is to be met, but leaves the manner by which that result is to be obtained to the judgment of the employer. This is particularly true of the rescue and retrieval requirements, as the specific circumstances and conditions of each entry or rescue will dictate what equipment and techniques may be required. However, this pending Letter of Interpretation (LOI) regarding the use of retrieval lines in Confined Spaces crosses over into the area of specific equipment and techniques that must be used.

Consistent with the performance-based nature of the standard, Roco has taught for years a technique that uses a single retrieval line for multiple entrants as an option to reduce line entanglement hazards during a rescue. The use of this technique was based on testimony given to OSHA prior to the Permit Required Confined Spaces Standard (29CFR 1910.146) being published, and indeed our interpretation of the intent of the standard. The particular technique in question is a common practice for rescuers in which one retrieval line is used and multiple entrant/rescuers are attached at different intervals with butterfly knots to reduce entanglement hazards during a rescue (see example below.)

This pending interpretation would put restraints on techniques used by rescuers when entanglement issues could be a problem. It would result in the management of multiple retrieval lines in the space which could affect the effectiveness of the rescue or result in an increased danger to the entrants and/or rescuers. In effect, this OSHA interpretation could cause an “all or nothing” response regarding the use of retrieval lines for rescuers and entrants. This LOI would eliminate the opportunity of using an external rescue technique for certain situations.

Paragraph (k)(3)  allows entrants to forgo using a retrieval line in certain situations –
“To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”

The technique in question is an option that falls between each individual having an “individual” retrieval line, and having to opt out of using a retrieval line at all, and it allows for external retrieval to still be an option in many cases. And, as most of you know from personal experience, for most confined space portals only one individual can pass through at a time anyway. Even with multiple retrieval lines, it is still a “one at a time” event.  A shared retrieval line allows the same to take place.

It is Roco’s position that the rescue and retrieval techniques used in rescue should be performance based to allow for the ever-changing conditions and problems that are unique to rescue. We also feel this pending LOI could affect the safety and ability of rescuers to adjust to these situations. However, until this issue is clarified, Roco will not teach or use the technique of having multiple rescuers/entrants attached to the same retrieval line in consecutive order using midline knots as their attachment points.

We recently received a question about  what constitutes a prompt and capable rescue response for fallen workers at height suspended by their Personal Fall Arrest System (PFAS).

Question:  My question concerns guidance on the number of rescue/standby team members needed for response to “worker at heights” type incidents. We work in a chemical plant, so it’s basically areas such as columns, etc.

Answer:  OSHA guidance for rescue of fallen workers utilizing personal fall arrest systems (PFAS) is quite vague in that it calls for “prompt rescue.” For more definitive guidance on the subject, ANSI Z359.2 Para E6.1 recommends that contact with the rescue subject (communication or physical contact) should occur as soon as possible after the fall. The recommended goal for rescue subject contact should be less than six minutes. What constitutes “prompt rescue” can vary depending on the circumstances. The type of potential hazards identified in the Fall Hazard Survey report should determine rescue planning.

For example, if the work area exposes the worker to an IDLH condition such as energized equipment, then the Fall Hazard Survey should trigger the “Rescue Plan” to include a near immediate rescue provision because of the potential of worker electrocution leading to a fall and subsequently, a suspended victim. In a situation like this, it is imperative that prompt rescue would provide a means to have the rescue subject in a position that allows CPR in less than 6 minutes — and preferably much faster than that! The only way to respond this quickly is to have a “Stand-by Rescue” posture where the rescue system and personnel are pre-rigged and ready to initiate the rescue immediately.

For other situations, if communications with the rescue subject are established in six minutes or less, and it is determined that the victim is relatively unharmed (alert and oriented, good airway and breathing, and no signs of active bleeding) then the urgency is reduced and a more measured approach to the rescue could be employed. There is still the potential for suspension trauma to develop over a range of several minutes, so a “prompt” but measured rescue would still be necessary.

With this in mind, it is important for an employer with workers at height to complete a Fall Hazard Survey report to determine the most appropriate way to abate any fall hazards. If the use of PFAS is necessary, that triggers the need to complete fallen worker Rescue Preplans. The employer will need to identify the rescue assets and ensure they are available, equipped, and trained to perform safe and prompt rescue for any situation that they may be summoned to at the employer’s facility. For rescuers outside the employer’s workforce, it is important to thoroughly vet the prospective rescuers to make these assurances.

This information was provided by Pat Furr, Roco Chief Instructor and Technical Consultant. He regularly assists Roco customers in identifying opportunities to improve their fall protection programs and can guide safety professionals in the completion of Fall Hazard Survey reports. Roco can also assist in the development of fallen worker Rescue Preplans. For help with selecting the proper equipment or training, call us at 800-647-7626.

Question:  If I close and Lockout/Tagout the main valve on the natural gas line supplying a boiler unit – does this satisfy OSHA’s requirement for eliminating the hazard of a permit required confined space?

Answer:  No, it does not. You are asking a question that we address quite often and it reveals some misconceptions regarding “eliminating” or “isolating” the permit space from hazards. Lockout/Tagout (LOTO) procedures are covered in OSHA’s 1910.147 “Control of Hazardous Energy (Lockout/Tagout).

” Many times this regulation is incorrectly referenced when addressing permit space hazards that are not covered by this regulation.
OSHA’s 1910.147 LOTO regulation applies to the control of electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other energy. It does not apply to engulfment hazards (liquid or flowable solids), flammable gasses, or other gasses that may be toxic or oxygen displacing.

It is important to understand this distinction because the use of isolation procedures appropriate for the hazards addressed in 1910.147 may not be effective in eliminating other hazards.  “Isolation,” as defined in the Permit Required Confined Space regulation (1910.146) spells out the various measures required to eliminate hazardous energies as covered in the LOTO regulation as well as the types of hazards that are not addressed in that regulation.  You will note that 1910.146 cites LOTO as a means to isolate all sources of energy (emphasis added), but outlines other methods used to isolate the other hazards such as hazardous materials. These isolation procedures include the process by which a permit space is “removed from service” and completely protected against the release of energy and material into the space by such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; a double block and bleed system; lockout or tagout of all sources of energy; or blocking or disconnecting all mechanical linkages.

By closing and placing a LOTO device on a single valve of a natural gas feed line, you may have controlled the hazard but you have not eliminated it. To provide true isolation (elimination), you will have to employ such means as: blanking or blinding; misaligning or removing sections of lines, pipes, or ducts; or a double block and bleed system.

Download the LOTO tip sheet from NIOSH.

ASTM F1740 provides very comprehensive guidelines for users of rescue rope.  The title “Standard Guide for Inspection of Nylon, Polyester, or Nylon/Polyester Blend, or Both Kernmantle Rope” indicates it is specifically intended to guide the user in the inspection of these rescue ropes, and is not intended to be a guide in the selection and use of rescue ropes.

However, the information included in F1740 is not to be considered the only criteria for evaluating the serviceability of rescue rope.

One of the first considerations the user needs to address is the selection of an experienced individual who is deemed qualified to perform and document the rope inspections.

While F1740 does provide excellent guidelines, the user and/or the Authority Having Jurisdiction (AHJ) may feel it necessary to augment the information in F1740 with additional training.

Fortunately, our friends at PMI Rope have produced a very comprehensive webinar on Rope Care which includes specific information on  rope inspections. This 61 minute webinar is presented by Mr. Steve Hudson, president of PMI Rope. Steve has an unsurpassed background and knowledge base regarding the manufacture and use of rescue rope and his presentation should more than satisfy your need to augment F1740.

Click here for a link to PMI’s webinars. Use the scroll down on the left and select the 3/2/10 presentation titled “Rope Care.” The information that addresses rope inspection begins at the 24:30 time mark of the presentation.

RocoRescue.com offers PMI rescue rope for rescue professionals. Please contact Roco at 800-647-7626 if you have any further questions.

We get many calls asking about the “life expectancy” of rope, harnesses and other nylon products. Of course, there are many factors involved and no one “set in stone” answer, but a lot depends on how much you use your harness and the ways you use it. Even where you store your gear is a factor.

For example, for emergency responders working in industrial environments, atmospheric exposures may be a key consideration for nylon products even while in storage. Another consideration is “when” the harness or rope was made… manufacturing parameters change as technology improves and you may just want a product that’s been tested to the latest standards. However, as with all of your rescue equipment, it’s important to account for its use as well as to follow the manufacturer’s instructions.

Never take chances when there’s any doubt about the serviceability of a life safety product. For more details on the service life of nylon products, our harness manufacturer, CMC Rescue, has provided the following information:

The service life of a rescue harness is closely related to the life of a rescue rope – both are used in the same environments, both are made from nylon or polyester, and both receive similar levels of inspection and care. Since harnesses are worn on the body, they are generally better protected than the ropes. On the other hand, harnesses rely on the stitching to hold them together, and due to its small diameter, the thread can be more susceptible to abrasion, aging, and chemical damage than web or rope.

The fall protection industry recommends 2 to 3 years as a service life for a harness or belt in use. They recommend 7 years for the shelf life. The military was using 7 years as a service life for nylon products. The Climbing Sports Group of the Outdoor Recreation Coalition of America says that a climbing harness should last about two years under normal weekend use. At this time, the rescue industry does not have a recommended service life for harnesses.

Through the ASTM consensus standards process, the rescue industry set 10 years as the maximum service life for a life safety rope, see ASTM Standard F1740-02 Guide for Inspection of Nylon, Polyester, or Nylon/Polyester Blend, or both Kernmantle Rope. The guide stresses that the most significant contributing factor to the service life of a rope is the history of use. A rope that is shock loaded or otherwise damaged should be retired immediately. Hard use would call for a shorter service life than would be acceptable for a rope that sees very little use.

If we apply the same analysis to the rescue harness, then the actual use and the conclusions drawn from inspection would be the significant criteria for retirement. We do know that with any use, a rope will age, and thus a harness is likely to do the same, so a 10-year maximum service life may well be appropriate for harnesses as well assuming inspection has not provided any reason for early retirement.

As with ropes, if the harness has been subjected to shock loads, fall loads, or abuse other than normal use, the harness should be removed from service. If there is any doubt about the serviceability of the harness for any reason, it should be removed from service.

Additional Resources

Quick-Connect Harness Buckle Safety

Service Life Guidelines for Rescue Equipment

Guidelines for Permanent Marking of Rescue Hardware