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Open Trenches…It’s Only a Matter of Time!

Monday, January 3, 2022

You’ll spot them everywhere – from a local utility company working in your neighborhood to your workplace at an industrial or manufacturing facility during construction. It’s way too common to see an open trench unattended and unprotected. And, as we know, it’s only a matter of time until it collapses.Trenches-SantaFe-01

More and more of our customers are asking questions to address safety-related concerns. For example, who’s signing off on the trench project? Is the person you have signing off that a trench is constructed properly and safe for entry trained to know what to look for? Do they have the authority to act (competent person), or are they assuming that the contractor is “doing the right thing”? It is all too common that supervisors are signing off on trench permits without having any trench safety training or experience. Therefore, they cannot be considered competent persons.

Of course, this is troubling. It’s troubling due to the hazards involved and the personnel who will be entering the trench. A trench collapse happens in seconds, making an escape very unlikely once the soil starts moving. Due to the weight of the soil and the speed of the collapse, most do not survive.

Trench safety starts with the Competent Person. If none are available, who is watching out for the safety of the entrants? Not just anybody will do. According to 1926.650(b), the Competent Person is “one who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.” Who on your site is responsible for this? Do they have the authority to correct hazards immediately?

Hopefully, we’ve convinced you of the importance of a trained and experienced Competent Person. Now, what about rescue in case the worst does happen? You’ve got an extremely hazardous situation – is your rescue service prepared for this? Your emergency response team may be trained for most emergencies, but what about this one?

Trench is one of the most dangerous rescue disciplines. It requires special knowledge, such as soil classification, hazard analysis and mitigation, understanding tabulated data, and the proper installation of shoring and shielding systems, just to name a few. It also requires specialized equipment that many response organizations simply don’t possess. This seems to be true for most municipal and industrial teams. With specialized training and equipment required for safe operations, it’s a commitment that most rescue teams just can’t make.

With trench rescue, timeliness is everything. Although it is often a slow and tedious process, proper training and equipment can be the difference between a rescue and a body recovery. Don’t ignore this hazard that may be located on your street or worksite. Take a careful look around, we think you’ll be surprised with the number of trenches and excavations that are occurring on a daily basis.

Did You Know?

After researching many of the questions we have received concerning trench operations, we came across this OSHA Letter of Interpretation that was reviewed most recently on November 8, 2018.
Note: It is always important to review all standards and regulations in their entirety.

Here are some excerpts:

1. Can workers enter a trench with water accumulation if the workers are protected from cave-in by shoring, shields or sloping, and the water level is controlled?

Paragraph .651(h) of 29 CFR 1926 allows workers to work in a trench with water accumulation, provided adequate precautions have been taken to protect employees against the hazards posed by water accumulation. The precautions necessary to comply with the standard vary with each situation, and the precautions you listed, such as additional shoring and control of the water level may not, in all cases, provide the required employee protection. 

2. The Stairways and Ladders Standard requires that a stairway or ladder shall be provided at points of access where there is a break in elevation of 19 inches or more. The Excavation Standard requires a ladder or other means of access and egress when the trench is 4 feet or more. Which of these requirements is applicable to trenching operations?

Be advised that since the specific excavation standard also addresses means of access and egress, the more general requirement in the stairways and ladders subpart is not applicable. A ladder, stairway, ramp or other safe means of access is required only when the trench is four feet or more in depth. Paragraph 651(c)(2) also states…as to require no more than 25 feet (7.62 m) of lateral travel for employees.

3. Must rescue equipment be available at every trenching jobsite that is located near or passes by a gas station, refinery, gas line, sewer main, etc.? Can a contractor rely on the local rescue squad since they are probably better equipped to handle a rescue?

Emergency rescue equipment is required to be readily available where a competent person determines, based on the conditions at each jobsite, that hazardous atmospheric conditions exist or may reasonably be expected to develop during work in an excavation.

In regard to whether a contractor can rely on a local rescue squad instead of providing the rescue equipment, please be advised that many emergency situations associated with the hazards involved with hazardous atmospheres in trenches would normally require an immediate response within a few minutes or even seconds.

A rescue squad would be unable to provide the necessary response and therefore could not be used to comply with 1926.651(g)(2).

4. If a contractor has several of the same make and model trench shields at a jobsite, does he have to have separate manufacturer's tabulated data on hand for each specific shield? We have been told that the shields and the data sheets must have the same serial number in order to be in compliance.

Be advised that only one set of tabulated data is required for each different shield design. If a contractor uses several shields of the identical make and model, only one set of tabulated data would be required for them.

5. Do excavations greater than 20 feet have to be designed by an RPE (Registered Professional Engineer) or can manufacturer's tabulated data be used in lieu of an RPE? For example, a contractor may have boxes rated for depths greater than 20 feet.

Protective systems that are designed using a manufacturer's tabulated data can be used in trenches deeper than 20 feet provided the use is within the limits of the data, including depth limitations and soil type. It should be noted that all tabulated data, by definition (1926.650), must be approved by an RPE.

6. We clearly understand that a ladder has to be secured, but we are not sure how. Contractors have informed us that compliance officers have told them that they cannot secure a ladder to the shoring system or in some cases the trench shield. These same contractors have been told to secure the ladder by driving a stake into the ground and to tie the ladder off to the stake. This alternate method presents three different problems: 1) It is not always possible to drive a stake through concrete or asphalt sidewalks or pavement; 2) This method creates a tripping hazard next to the trench; 3) Some contractors believe that driving a stake could create a stress crack. Please clarify these requirements for us?

Paragraphs 1926.1053(b)(6) and (7) address ladder footing displacement which is not normally a problem in trenches. If a ladder needs to be secured against tipping, it may be secured to a shield or member of a protective structure provided the ladder does not alter the effectiveness of the protective system.

7. Does the competent person have to be standing by the trench at all times during the work shift or can he/she go off site for short periods of time, such as lunch, meeting, or maybe to pick up supplies at the local builder’s supply store? Can the competent person move around the jobsite away from the trench? Often the foreman is the competent person and he may have other responsibilities at the jobsite.

It is not normally necessary for a competent person to be at a jobsite at all times. However, it is the responsibility of a competent person to ensure compliance with applicable regulations and to make those inspections necessary to identify situations that could result in possible cave-ins, indications of failure of protective systems, hazardous atmospheres, or other hazardous conditions, and then to ensure that corrective measures are taken. Consistent with these goals, the competent person may perform other duties.

8. Must an RPE approve all work when digging below a footing, foundation, retaining wall, sidewalk or pavement? We recognize the need for an RPE to design a system to support buildings and structures. However, we don't agree that an RPE is needed to layout a system to support sidewalks, pavement, and in some cases small structures like a small retaining wall. It is often very difficult to find an RPE who is willing to take on small incidental projects.

An RPE approval is not required when the excavation is not "reasonably expected to pose a hazard to employees." In situations where it is reasonably expected to pose a hazard, an RPE approval is not required when a support system, such as underpinning, is provided to ensure the safety of employees and the stability of the structure, or the excavation is in stable rock.

9. At what point and under what conditions would OSHA consider a trench a confined space?

Under normal circumstances, a trench would not be considered a confined space. The excavation standards address the hazards associated with employees entering potentially harmful atmospheres by requiring atmospheric testing and controls where hazardous atmospheres exist or could reasonably be expected to exist.

10. Some compliance officers are telling contractors that they must use a penetrometer or shearvane to estimate the compressive strength of soil and that the thumb test is unacceptable. Keeping in mind that these are field tests. We realize that the thumb test is not accurate, but neither is the penetrometer that many compliance officers swear by. What is OSHA's interpretation for using a thumb test versus an instrument?

Be advised that the thumb penetration test is one of the acceptable methods of estimating soil compressive strength. The compressive strength can be determined by laboratory testing, or estimated in the field using a penetrometer, shearvane, thumb penetration tests, as well as by other methods.

Source: OSHA Letter of Interpretation: Construction standards addressing excavations (reviewed November 8, 2018)

Additional Resources

If you’re concerned that your rescue service may not be adequately prepared, give us a call or check out these resources for more information on how to keep you and your personnel safe around trenches.

Trench Safety Webinar

Trench Safety & Rescue Articles: Read More

Trench Training: Competent Person | Trench Rescue Technician

Recorded Webinar: Staying Safe in the Trenches

 

Sometimes, Timing IS Everything.

Tuesday, May 25, 2021

Whether you’re a comedian telling jokes or a quarterback throwing a fade route to your favorite receiver, timing is key. And when you’re rescuing a worker who’s fallen into a fast-moving river, timing becomes an incredibly critical issue. In an instant, a Roco marine standby boat and rescue team can mean the difference in life or death for a fallen worker. What’s more, OSHA requires prompt retrieval during construction projects over or near water, and that’s just what Roco teams can provide.  

Roco Rescue Marine Standby Rescue-2

As part of Roco Rescue’s CSRT Services Division, Roco marine standby crews spend hundreds of hours each year on the waterways of the Baton Rouge-New Orleans industrial corridor, ensuring the safety of those working on structures above the water. According to Brad Duplessis, CSRT Director for Roco, “By far, the majority of our marine standby work is on the Mississippi River near a dock or facility under construction, but our teams are mobile and can work most anywhere in the U.S. In fact, we recently quoted a project on the Ohio River.”

Many companies performing construction work over or near waterways may not realize that a boat or skiff in the water for rescue is actually an OSHA requirement. OSHA 1926.106(d) states, “At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.” In fact, according to one OSHA letter of interpretation (LOI 6/13/90), the retrieval of an employee from the water is required no more than three to four minutes from the time they entered the water. Depending upon hazards present, rescue could be required even sooner. Another OSHA LOI (12/5/03) states, “As a skiff supplies a backup to potential failures of fall protection devices, the use of fall protection systems is not a substitute for the skiff.”

Simple Premise. Complicated Process. 

The concept is simple. Roco Rescue places a boat on-site to monitor projects where work is being performed over water. The Roco team, consisting of a boat operator and a lead rescuer, is there to closely monitor the site and immediately retrieve anyone that falls in the water. If the worker falls and is hanging from scaffolding or dangling from the side of a structure, it is the duty of the site rescue team to assist. But the minute a worker falls into the water, Roco Rescue’s marine standby team springs into action – and that’s when the process becomes both dangerous and complicated.

“Our eyes are constantly on the water,” explained Devin Payne, Roco CSRT Logistics Manager, who also works marine rescue standby.

“The minute a worker falls in, our two-person team goes to work striving to get that person out of the water as quickly as possible. One team member maneuvers the boat and the other uses equipment like life rings, ropes, grab poles or a davit arm, which is a specialized winch.”

“There are a number of factors at play, plus the fact that the person needing rescue may be injured or unconscious,” said Denver Payne, Roco CSRT Regional Manager (and twin brother of Devin).

“Most people don’t realize the dangers of river water, the intricacies that go into rescue or the potential hazards that stand in our way.”

Current: River water on the Mississippi generally moves at a rate of approximately 30 knots, which is just under 30 miles per hour. Rivers at flood stage can move even faster. At this rate, an individual that falls in can be swept away ending up hundreds of feet from the water entry point in a matter of seconds. For this reason, Roco Rescue boats observe closely from just downstream, ready to pull workers from the water as quickly as possible.

Temperature: Many would assume that river water, especially during southern summers, hovers around the 80-degree mark. However, in actuality, the average temperature of river water is 64-70 degrees, which can lead to the rapid onset of hypothermia. The Mississippi River averages 58 degrees during the spring and early summer due to the snowmelt coming down from the north. At this temperature, hypothermia can set in at an even faster rate.

Debris: Rivers have an unbelievable amount of debris such as tree limbs, logs, trash and more, much of which may not be visible from the surface. A worker may fall on a piece of debris or have debris strike him moving 30 mph, which can render him unresponsive during a rescue.

Visibility: Underwater visibility in a river is zero. If someone falls in without a personal floatation device, he could go under immediately making the rescue even more challenging.  

Boat Traffic: The river is shared by a number of additional boats and barges of varying sizes. Maneuvering the Roco boat between traffic can also be challenging. In addition, a person being swept away at 30 mph who is slammed into the side of a parked barge or a moving boat can experience great bodily harm.

Roco Rescue Marine Standby Rescuers-1

 

Special Equipment. Specially Trained Personnel.

Although the OSHA standard does not identify specific training for the rescue boat personnel, all Roco marine standby personnel are First Responder/CPR/First Aid trained, certified EMR or higher, and most are EMTs. Each member has passed a Boater’s Education Course along with specialized Roco Rescue training developed in conjunction with the U.S. Coast Guard and EBR Sheriff’s Department. Roco boats are fully equipped with first aid kits, AEDs and oxygen for prompt emergency care. These twin-engine crafts are safer and float lower in the water, making rescue access easier. Each boat is equipped with everything needed for rescue including a davit arm strong enough to lift 400 pounds. Our specialized navigation system allows for work during periods of low visibility as well.

We remind all companies who have personnel performing construction activities over or near the water, please make sure you are OSHA compliant and have a boat onsite to provide timely rescue. For additional safety and to ensure the highest level of service, rely on Roco Rescue. For more information on our marine rescue standby services, please contact us via phone at 800-647-7626 or email us at info@RocoRescue.com.

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Trench Deaths = Manslaughter?

Monday, March 8, 2021

In a grim reminder about the dangers of trench and excavation work, this article from Safety+Health Magazine also serves as a warning to employers. “The court’s decision sends a message to business owners that they can be held criminally accountable and face felony charges if they knowingly fail to protect their workers.”

The owner of Alki Construction LLC has been charged with second-degree manslaughter after an employee was buried while replacing a residential sewer pipe in a trench that had inadequate shoring and was missing a ladder.

Remember to ensure that you have a properly trained Trench Competent Person on site, and check out OSHA's Trenching and Excavation Safety Fact Sheet as a reminder when scheduling trench work.

 

Evaluating Your Rescue Service

Wednesday, January 22, 2020

 Evaluating your rescue service helps ensure that the team you have selected has the knowledge, technical skills, and capabilities required to meet your company’s specific needs. In addition, a team evaluation helps fulfill the performance requirements outlined in OSHA 1910.146 and 1926.1211. If you doubt the importance of selecting a competent and properly trained rescue team, consider this disturbing statistic: more than 60% of confined space fatalities occur among would-be rescuers.

2012_Chal_h_112OSHA 1910.146 Appendix F (non-mandatory) provides a great roadmap for employers when choosing and evaluating a confined space rescue team. It contains criteria that may be used to evaluate the capabilities of both prospective and current rescue teams. (Note: Although Appendix F is “non-mandatory”, the standards of 1910.146 are not. Appendix F is OSHA’s recommended method for compliance. Learn why you should pay close attention to Appendix F, even though it is “non-mandatory.”) 

The Two Components Of A Rescue Service Evaluation:

  1. An initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform permit space rescues of the kind needed at the facility and whether such rescuers can respond in a timely manner; and
  2. A performance evaluation, in which employers assess the skills of a prospective rescue team or rescue service during an actual or practice rescue.

Step 1: Initial Evaluation

The initial evaluation considers:

  • A team’s technical skills as evidenced by documented training
  • Number of personnel
  • Availability
  • Timeliness based on the hazards inherent in the space
  • Whether they meet the requirements of 1910.146 (k)(2) with regards to access to personal protective equipment (PPE), training in both technical rescue and first aid/CPR, and practice in representative permit-required confined spaces at least once per year
  • The ability to notify the employer when they are unable to respond – which is of particular importance for employers using 911 as their rescue service
  • and more (see Section A, Initial Evaluation in OSHA 1910.146 Appendix F)

Step 2: Performance Evaluation

Once employers have selected one or more rescue services that meet their criteria on paper, employers should provide the rescue service access to their worksite and ask them to perform in various scenarios of the employer’s choice. Performance evaluations should be administered to a prospective rescue service, as well as to periodically evaluate your current rescue service.

Consider Using A Third Party To Evaluate Your Rescue Service

Employers may opt to use a third party to evaluate their prospective rescue service. Third-party evaluations provide a number of added benefits:

  • They are useful when employers may not have the in-house expertise necessary to administer an accurate evaluation, or for employers who prefer having a third-party evaluation as a documented, independent, and unbiased record of the rescue service/team’s capabilities.
  • They provide an opportunity for the evaluator to recommend minor changes in equipment or techniques that would enhance the capability of the team.
  • In cases where contractors will be providing their own rescue capability, third-party evaluations help ensure that all parties are doing their due diligence where permit space entry is required. Some host employers mistakenly believe that they are relieved of all responsibility when a contractor’s employees are performing the entries. But 1910.146(c)(8) and (9) place reciprocal responsibilities on host and contractor. This includes the host employer informing the contractor that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146, and the contractor informing the host employer of the permit program it will be following.

Taking the time to ensure that the rescue service you choose has the proficiencies and equipment to perform the specific types of rescue required at your facility could not only prevent injuries, it could even save lives.

If you would like additional information on utilizing Roco Rescue’s documented Team Performance Evaluation for your rescue service, please call 800-647-7626.

 


 

Non-Entry Confined Space Rescue…Are You Sure?

Tuesday, May 7, 2019

There are three generally accepted types of confined space rescue: self-rescue, non-entry retrieval, and entry rescue. Just as with the hierarchy of hazard mitigation, confined space rescue should be approached with an ascending hierarchy in mind. 

  1. Self-rescue is typically the fastest type and eliminates or at least greatly reduces the chance that anyone else will be put at risk. For these reasons, it is the first choice, but it is unrealistic to think that an entrant would be able to rescue themselves in all situations.
  2. Non-entry retrieval is the next choice. OSHA stipulates that non-entry retrieval must be considered as a means of rescue – more on that shortly.
  3. Entry rescue is the last choice, largely because it exposes the rescuers to the same hazards that the original entrant faced.

Non-Entry Confined Space Rescue…Are You Sure?

OSHA recognizes the inherent danger of entry rescue, which is why the organization mandates “retrieval systems or methods shall be used whenever an authorized entrant enters a permit space.” However, OSHA goes on to qualify this statement with two very important exceptions. OSHA requires non-entry retrieval, “unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”  Let’s examine each of these two provisions more closely... 

  1. Non-entry retrieval is required “…unless the retrieval equipment would increase the overall risk of entry.” For example, if the retrieval line would create an entanglement hazard that would impede the entrant’s ability to exit the space, then the retrieval system should not be used and entry rescue should be the choice.
  2. And non-entry retrieval is required unless the equipment “…would not contribute to the rescue of the entrant.” The key here is that the non-entry method employed must be viable. It must work when called into action.

For non-entry retrieval systems, we are relying on that retrieval line to exert forces on the entrant to pull them out of the space without help from any other device or human intervention within the space. It must perform without someone inside the space maneuvering the victim or otherwise providing assistance to the retrieval system. It has to work independently of any other forces other than what is generated from outside the space. This extremely important point is often overlooked and has resulted in many fatalities. Sadly, many of those fatalities were the would-be rescuers that attempted entry rescue when the retrieval system failed to do its intended job.

Situations that may render the retrieval system useless would be any configuration or obstruction inside the space that would prevent the system from pulling the victim clear of the space in an unimpeded manner. This could be pipework or obstructions on the floor for a horizontal movement. Likewise, pulling an unconscious victim around corners may render a retrieval system ineffective. If the entrant moves over any edge and down into a lower area offset from an overhead portal even at moderate angles, the retrieval system will probably not be able to pull an inert victim up and over that edge, even if the drop were only a foot or so.

It must be clearly understood that retrieval systems may quite possibly be applying forces on a limp human body, which, as harsh as this sounds, becomes a sort of anchor. It requires a very thorough and honest evaluation of where the entrant will be moving in the space in order to perform their planned work, and what obstructions or structural configurations are in that path. If there is any possibility that the system will not be able to pull an unconscious, inert victim along that path, then the retrieval system is NOT viable.

Human Nature vs The Best Laid Plans - An Example

Okay, so you have done a thorough and honest evaluation of the space, its configuration, and internal obstructions and determined that there is a clear path from the entrant’s “planned” work area, which is offset ten feet from the overhead portal eight feet above. Clearly, the retrieval system will be able to pull the victim out of the space should the need arise. Enter human nature, and with that comes bad decisions. Murphy’s Law has a very nasty way of changing things for the worse. 

What if, in the course of the planned work, our entrant drops his wrench down into a sump immediately adjacent to his work zone but further from the overhead portal? The fixed ladder down into the sump is only five feet and he can clearly see the wrench stuck in the sludge below. He asks for slack on the retrieval line, climbs down into the sump, bends down to grab his wrench and is nearly immediately rendered unconscious due to an undetected atmospheric hazard. 

The attendant/rescuer sees that the entrant’s head and shoulders do not reappear and within several seconds calls to ask if he is ok, only to hear no answer. He calls several more times, but still no answer. He begins to haul with the retrieval system, which consists of a wire rope winch mounted to a tripod.  The cable becomes tight and the tripod shudders and shifts slightly, then all progress stops. The would-be rescuer tries with all his might to pull the entrant’s limp body up and over the 90-degree concrete edge, but cannot. 

In a panic, the attendant/rescuer climbs down into the space and over to the sump where he sees the entrant pulled tightly against the wall of the sump but not off the floor. He climbs down into the sump to attempt to lift the entrant’s 200-pound limp body up and over the five-foot wall. As soon as he bends down to cradle him, the hazardous atmosphere overcomes him also. Two fatalities later, we wonder how our non-entry rescue retrieval system could have failed us. It would not have, had human nature not interfered and caused two people to make bad decisions. 

That story was intended to point out that things do not always go according to plan. Not only do we humans make bad decisions on occasion, but we also have accidents due to trips, slips, and falls that may send us to an area that the retrieval system may not work. Conditions inside the space may change in such a manner that it affects the retrieval system. 

For all these reasons I implore you to evaluate the capability of the retrieval system to work not only when things go according to plan, but also to evaluate the system based on the “what ifs.” For the “what ifs” that involve bad decisions, that is a matter of training and communicating to the entry team why they cannot deviate from the work plan, even to fetch that dropped wrench. For the “what ifs” that include trips, slips, falls, or equipment failures, it may be time to consider a back-up plan, which may include an entry rescue capability.

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