We had this question from a reader and wanted to post for all to read.

Would a proper tailboard briefing conducted before a confined space entry be sufficient for identifying hazards that may be encountered by the entrants or the rescue team?

It’s true that a tailboard briefing should be an integral part of the larger overall preplanning for a confined space entry. However, well in advance of the entry, a detailed “hazard analysis” of the space should be performed.

A hazard analysis is used to identify the types of hazards, lock-out/tag-out needs, PPE required for entry, method of entry and important rescue considerations. In fact, OSHA requires these written assessments to be completed prior to an entry being made and the confined space permit acts as a secondary written assessment performed at the time of the entry. Here are some OSHA references concerning this topic…

1910.146(c)(5)(ii)(H)
The employer shall verify that the space is safe for entry and that the pre-entry measures required by paragraph (c)(5)(ii) of this section have been taken, through a written certification that contains the date, the location of the space, and the signature of the person providing the certification. The certification shall be made before entry and shall be made available to each employee entering the space or to that employee’s authorized representative.

1910.146(d)(2)
Identify and evaluate the hazards of permit spaces before employees enter them;

1910.146(d)(3)
Develop and implement the means, procedures, and practices necessary for safe permit space entry operations;

The tailboard briefing should be used to confirm or reinforce the information already gathered in the hazard analysis. Because it deals with an individual space at the time of entry, the tailboard briefing is also a very useful tool in finding out if conditions have changed since the hazard analysis was completed.

So, the bottom line… having a detailed hazard analysis for each space that includes a detailed rescue preplan allows a rescue team to review and prepare for potential problems well in advance. Reviewing this information at a tailboard briefing just prior to the entry helps to remind everyone of the possible hazards, the proper precautions, and the potential solutions should an emergency occur.

We received an interesting question about pre-rigged systems from one of our subscribers. The TechPanel had some helpful comments to share, so we have re-posted the info here. It’s a great topic.

Things to consider about leaving systems pre-rigged

First of all, whether to pre-rig systems or not depends a lot on the types of rescues you will be doing. Pre-rigged systems make sense for most industrial and municipal teams who have rope equipment designated specifically for rescues. However, it makes less sense for climbers and wilderness personnel who will be using the same equipment for multiple uses and putting systems together based on a specific need. This also reduces the amount and weight of equipment they must carry, which is a big concern. However, it also requires a high level of proficiency in a variety of systems in order to build systems safely and in a timely manner.

What is a “pre-rigged system”?

• “Plug-n-Play” – These are systems that come pre-built and seem to require little training to operate. These “Plug-n-Play” systems may work for a specific location or type of rescue but may not work in every situation. Training for these systems should address what to do if the device/system malfunctions, or if it will not work for the type of scenario you may be faced with. These are things like the Petzl Jag or CMC Aztek.
• “Customized Pre-rigged Systems” – These are customized pre-rigged systems that rescuers build for site-specific needs and their team’s needs using existing equipment and training.

Confined space and rope rescue can be broken down into three core tasks: (1) Lowering, (2) Safety line Belay, and (3) Mechanical Advantage/Retrieval systems. You can build pre-rigged systems that make sense for your specific needs. Many of the teams we work with have adopted a three-bag system.

For example, one rope bag is designated for “Lowering” along with the typical equipment needed for a lowering system (i.e. descent control device, carabiners, anchor straps, padding). This will provide a pre-rigged system that will handle most of your lowering needs. You may decide to supplement that with another anchor strap and a pulley for a high-point directional, etc.

Your “Safety line/Belay” bag can be set up the same way with enough carabiners and shock absorbers attached to the rope bag to allow for at least two rescuers and a victim.

The third bag of rope (“Mechanical Advantage/Retrieval”) with a simple, pre-built Block-n-Tackle hauling system and its own anchor straps will give your team an “immediate means of retrieval” for either the main line or a safety line retrieval. With a few additional pieces of hardware, you will be able to handle the vast majority of urban rope/confined space rescue scenarios.

We find that for industrial rescue teams or municipal fire and police rescue squads, these pre-rigged systems make sense. They save set-up time and get a rescuer to the victim as quickly as possible, which is especially critical for an IDLH emergency.

Many times teams will arrange their equipment so that it’s easier to inventory rather than what’s the fastest way to deploy it. For example, if you have twenty carabiners, why not have them attached to a rapid deployment bag type system rather than in a hardware bag that a team member will have to go through and pick out what is needed?

Our best advice would be to look at your team’s response area and consider the types of rescues that may be needed. You can then customize and build pre-rigged systems that make sense for your team. “Plug-n-Play” systems may handle most of your rescue situations or they may be part of a larger pre-rigged rescue system like the one described above. Using a “pre-rigged systems” approach saves time, cuts down on confusion, and uses equipment more efficiently – especially when the pressure is on.

Still have your doubts? Try out some of our Quick Drills in your next team training session and compare your times between your current kit configuration and a pre-rigged setup.

This question was submitted by Thomas Vitti from the Chevron Fire Dept. in Salt Lake City, Utah.

In the event of an actual rescue is a safety line necessary?

Good question… the answer is YES and NO. This question falls into somewhat of a gray area. Much depends on what type of rescue you’re doing; who the safety line is for; and, most importantly, the function of the safety line. Here, we’ve put together our ideas in relation to OSHA regulations, interpretations and our own rescue experience. Then, of course, there’s our motto… “There’s a safe way and a SAFER way,” which we always keep in mind.

Most of the time, the answer for rescuers is YES. Again, one of the most important questions in determining the answer is the function of the safety line during the particular rescue. In most instances, the safety line functions as fall protection, and OSHA requires that all employees be protected from fall hazards. That includes employees performing rescue.

As a rescuer, it is expected that you would be capable of designing a rescue system that maintains two points of contact and meets all fall protection requirements. For example, if you (the rescuer) are being lowered into or out of a space, you would be on a single system (one point of contact) and will therefore need another point of contact (safety line) to act as your second point of contact and fall protection. In this instance, your safety line functions as your fall protection. Once you’ve been lowered to the bottom of a confined space, and you move away from the portal, your safety line then functions as an external retrieval line. However, if it will not contribute to your rescue (or will make it more hazardous), according to OSHA 1910.146, the line is not necessary.

Is a safety line required for the person being rescued (i.e., the victim)? For the most part, YES – it should be part of the preplan for that particular type of rescue. While OSHA requires that all employees be protected from fall hazards, if the patient’s condition is critical (heart attack, suspended unconscious, IDLH atmosphere, etc.) and set-up time for the safety line would cause a delay in getting the proper medical treatment, the rescue team may be justified in not using a safety line for the victim/patient. Additionally, certain circumstances may not require the application of a safety line system for the victim. For instance, if an employee falls and is suspended by a fall arrest system, you don’t need to add another safety line to do the rescue.

Roco’s recommendation…  YES, a safety line is always required for a rescuer – even in a confined space,  where it can also be used for communication purposes. Safety lines for the victim/patient are also highly recommended when the victim will be suspended. But we also realize that there may be life or death circumstances when “quickness of rescue” is more important than the added precaution of using a safety line on the patient. Because Fed OSHA does not specifically address this issue, in certain circumstances, it may be justifiable not to do so.

It is understood that there are unexpected emergency events with many possible mitigating factors to deal with – making it impossible to regulate every potential scenario. So, this leaves some room for judgment based on the circumstances. But if your “justification” is that you did not have sufficiently trained personnel or sufficient equipment to employ a safety line (fall protection) system, OSHA is likely to conclude that you were not properly prepared to perform rescue for your particular work environment.

OSHA does not dictate how a rescue is to be performed. OSHA’s only performance standard for a rescue team is that they are capable of performing rescues in a safe, efficient and timely manner. That’s why we emphasize preplanning, preparing and practicing for the most likely scenarios at your site. Rescue preplans allow teams to plan for safe, effective rescue systems that would include fall protection as part of the plan – in fact, the safety line system could be pre-rigged, bagged and ready to go. The importance of preplanning for rescue is also addressed in OSHA 1910.146(k)(1)(v), which refers to providing 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. (Of course, “representative spaces” are also acceptable.)

As a final note, where OSHA does not have a specific regulation that addresses a particular hazard or means of protection, it may cite an employer for violating the General Duty clause – which requires an employer to provide a workplace free of recognized hazards. In citing under the General Duty clause, OSHA can reference national consensus standards, such as ANSI and NFPA, to establish a recognized hazard and acceptable means of protection. These consensus standards can also be invaluable resources for compliance guidance.

Note: It is always important to follow your company’s policies and procedures concerning emergency response operations as well as all relevant standards and regulations for your industry.

Reader Jeff Machen had a question concerning how much training to give attendants on air monitoring equipment; especially when they may only be working a week long shut down? Here’s our reply from CSRT Manager Bryan Rogers.

When you’re dealing with temporary labor, it is difficult to ensure that they are well trained on something as complex as atmospheric monitoring. We checked with several equipment manufacturers, and they don’t set a specific amount of training required, but leave it up to the customer’s internal company policy and/or person(s) issuing the monitor.

We also spoke to a few of our instructors who work at different plants and refineries. The majority of these companies require a company employee to perform the initial monitoring and then again after a break in work greater than 30 minutes. In addition, they review with the attendant what to look for and what to do if there are changes in the readings or an alarm sounds. One company provides a four-hour PowerPoint presentation on monitoring and attendant responsibilities.

OSHA does not indicate a time frame for this training either. However, it does require that persons be capable of safely performing the tasks assigned. Therefore, I would say your best bet would be to cover as much of the manufacturer’s instructions as possible along with reviewing the most common problems such as…

    - Calibration conversions
    - Turning on the monitor (or “field zeroing”) in the presence of contaminates
    - Negative LEL or negative toxic readings
    - Contaminated sampling hoses
    - Clogged filters

Lastly, I would stress to the attendants the importance of contacting a supervisor if they have any questions or concerns - and, if they get any unusual results from the monitor… “Do not hesitate to have everyone exit the space while the results are investigated!”

"Most likely the loaded section of the line is catching on the anti-error catch where the load line enters the body of the ID. This is a safety feature of the ID to prevent free-falling loads if the ID is loaded backwards. To prevent the rope from jamming, consider positioning yourself between the ID and the load facing the anchor. Hold both sections of rope oriented towards the load. Pull on the left section of rope while allowing the right section to drag through your hand. This will keep the rope clear of the anti-error catch." ~Roco Chief Instructor Pat Furr.