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Rescue Compliance…Is Your Team Ready?

Saturday, October 1, 2022

We’re often asked by plant managers or rescue team supervisors about how they can make sure their rescue team is ready and in compliance should a confined space emergency occur at their site. Our answer usually revolves around practice, practice, practice; but here are a few other recommendations that you may want to consider.

Consistency

training class

First of all, make sure you and your team are speaking the same language when it comes to rescue techniques and equipment. Consistency is key in having an organized response to a confined space emergency. We always recommend that customers evaluate and choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) can result in confusion for team members as to what techniques and equipment are supposed to be used – especially during a rescue!

Compliance

If you have permit spaces at your site, then we assume OSHA compliance is a priority. OSHA’s Permit-Required Confined Space standard (1910.146) is a performance standard and is based on operational capabilities – as is OSHA’s Confined Spaces in Construction (1926 Subpart AA). While minimum practice requirements are once annually for each team member in the applicable representative spaces, the standard goes far beyond this in terms of proving that your team can function in a safe, timely and effective manner. Have you documented your annual rescue practice requirements in the relevant confined space types? Have you conducted an evaluation of your team’s performance in realistic confined space scenarios? Has your team prepared recommended preplans for the permit spaces on site?

Make sure you and your team are speaking the same language when it comes to rescue techniques and equipment.

There are other national consensus standards to take into consideration as well. This includes the National Fire Protection Association (NFPA) rescue skills requirements of NFPA 1006. This standard provides an excellent means of documenting individual proficiency of your team members. If there is an incident and OSHA were to investigate, would you be able to document the individual skills proficiency of your team members? Remember, if it’s not documented – with OSHA, it doesn’t exist!

Credentials

Team members should be trained to an appropriate level based on the potential scenarios they may be called to respond. Do your personnel routinely work at height? Is there a potential for IDLH atmospheres? Know the hazards that your team may face and make sure they are adequately prepared. For overall team proficiency, it’s important to determine what credentials or level of skills you expect of your individual rescue personnel.

Ideally, all team members would be certified minimally to the Confined Space Rescue Technician level (NFPA 1006) along with the third-party certification to back it up. Of course, all should be CPR certified at a minimum. Additional medical training may be required depending on what level of patient care you intend to provide. And, with these certifications, come recertifications and continuing education, which must be completed as appropriate.

“Can you document your team’s competency and prove that your team members are capable of functioning in a safe, timely and effective manner?”

It's also important to check your team’s training records and make sure everyone is “up to par” with their training currency and skill level. Do you have a particular goal or level that you want your team to strive for, achieve, and maintain? Determining an overall goal for your team is significant in planning for and achieving long-term results. If you’re counting on your team to be ready and prepared, we strongly suggest that all team members be trained to the same proficiency level.

Capabilities

Here’s where the rubber meets the road – how capable is your team of performing a confined space rescue? In the worst of circumstances, can your team safely rescue a patient in a confined space filled with obstacles and unforeseen hazards? Do they possess the technical skills and equipment to perform a rescue safely and timely?

One of the best ways to determine the capability of your team is via simulated, realistic rescue practice drills in the representative confined spaces they may be called to respond. Adding a time limit – without compromising safety – can increase the perceived pressure and further simulate a real rescue. It’s an excellent way to see how your team would respond in an actual emergency situation and correct any deficiencies discovered.

Roco offers two great methods for evaluating rescue team competency. One is a Roco Team Performance Evaluation and the other is our annual Rescue Challenge event. Both offer realistic scenarios conducted under the guidance of experienced instructors along with a critique or debrief of each evolution. Each scenario is graded for various rescue and medical components. With each, comes a Team Performance Report to provide documentation of rescue capabilities.

Certification

If you plan to take your rescue personnel to the level of Rescue Technician, Roco has several options. The quickest way of reaching this certification to NPFA 1006 is by attending our Fast-Track™ Confined Space Rescue Technician course, which is a 70-hour program. This course meets the needs of municipal and industrial emergency responders with a mix of confined space and rope rescue. The class is geared for confined space rescue with additional rope technician skills needed for elevated or high angle rescue. The certification process includes a written exam and performance skills testing and is valid for a period of two years.

“Establish training goals for the team as well as individual team members, so that every training session stays on track and is productive.”

An alternative path to certification includes attending Roco’s Urban/Industrial Rescue Essentials™ 50-hour course and then completing the certification process in a Confined Space Rescue Technician 40-hour program. In either method, your personnel will receive consistent training and be certified to the same level of competency.

Training Cycle for Compliance

Once all team members have reached the appropriate training level, skills maintenance and ongoing proficiency become the norm for continuing compliance. Again, OSHA 1910.146 is a performance and capabilities-based standard that includes minimum annual rescue practice requirements for each team member.

Because our certification is valid for two years, we recommend a rotating cycle. Once Rescue Technician certification is achieved, the following year would include a Roco Team Performance Evaluation – or the attendance of Roco’s Rescue Challenge event. Both events provide graded rescue scenarios, which are debriefed by evaluators to correct any deficiencies found. Each of these options includes a Team Performance Evaluation report, which provides excellent documentation for compliance. The alternative year would include attendance of a Roco Recertification program.

This cycle of training works well in documenting that you have met the minimum requirements of OSHA while also meeting the skills requirements of NFPA. The supporting documentation provided offers a realistic “snapshot” of where your team stands in terms of competency and proficiency. This information can then be used as a tool to design internal drills that correct any discrepancies while getting the most from your all too limited practice time.

 

Training CycleConclusion

Rescue skills are extremely perishable, and if not used or practiced routinely, they can be quickly lost. For an effective rescue, team members must be confident in their skills, their equipment and their other team members. This requires regular practice that is realistic and practical. Make sure your rescue team is ready for an actual emergency – as you know, lives are on the line.

 

Confined Space Rescue Chart

 

Additional Resources

 

 

 

How Do I Choose a Qualified Rescue Service?

Thursday, September 1, 2022

ConSpaceType2-22smIf entering permit-required confined spaces is performed at your worksite, then this is a question you absolutely should be asking yourself. And if you are, that is a good thing; it implies knowledge of OSHA’s requirement that an organization must provide for the safety of their personnel working in confined spaces.

Asking the question of “who” should provide your confined space rescue services means you are on the right track. You are aware of OSHA 1910.146 and have established that you are dealing with a permit-required confined space entry.

OSHA designates entries as permit-required when the space has one or more of the following characteristics:

  1. Contains or has the potential to contain a hazardous atmosphere
  2. Contains a material that has the potential for engulfing an entrant
  3. Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross-section
  4. Contains any other recognized serious safety or health hazard[i]

If a space at your facility where work is to be performed meets any of the above conditions, then OSHA clearly requires that you “develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue.”[ii]

“Rescue available” means the rescue team is available to be called out when some type of incident occurs. “Rescue standby” implies that the rescue team is standing by near the entrance to the space, ready to go at a moment’s notice.

There are basically three options available to most organizations for the provision of a confined space rescue team: (1) local emergency services, (2) an in-house team, or (3) a contracted rescue service. Each of the three rescue options available are all viable choices; and all, when implemented appropriately, have merit. However, there are many factors to consider, and due diligence must be performed to determine the most effective choice.  

Local Emergency Services

qualified rescue service2Upon learning that using local emergency services is potentially an allowable confined space rescue option, many organizations see this as the easy choice and quickly check that box. They are thrilled that they are not having to spend any money or devote any personnel to the task. These entities may also secretly wonder what all the hubbub is about regarding confined space rescue, but they very well may learn the hard way should an incident occur.

While there are local emergency services that have top-notch rescue capabilities, many (or perhaps most) are not that well equipped and/or trained to enter confined spaces for rescue purposes. If you are considering local emergency services to provide confined space rescue for permit-required entries, then there is homework that must be done before you check that box. This process should begin with a meeting with the local emergency services to assess the following:

  1. Are they trained and certified to perform confined space rescue?
  2. Are they properly equipped to provide this service?
  3. Are they available to respond/standby when entries are being made?

While some emergency services organizations may be well trained and adequately equipped to provide rope rescue in a high-angle environment, most do not have the right training and equipment for confined space rescue. Determining this level of detail requires serious due diligence to confirm, and as described later in this article, OSHA requires that you do this.

Aside from training and equipment, you must determine if the local emergency services are available to perform confined space rescue or standby services. This highlights the distinction between rescue available and rescue standby. “Rescue available” means the rescue team is available to be called out when some type of incident occurs. “Rescue standby” implies that the rescue team is standing by near the entrance to the space, ready to go at a moment’s notice.

While there are local emergency services that have top-notch rescue capabilities, many (or perhaps most) are not that well equipped and/or trained to enter confined spaces for rescue purposes.

Deciding which level of response is necessary is a function of the hazard(s) of the space. If the space is considered low hazard where the response is likely to be due to a medical issue with the entrant—e.g., heat stress, sprain, strain, etc.—then having a rescue team available to respond to the scene is permissible. However, if the space imparts a high degree of risk to the entrant(s)—an IDLH atmosphere, for example—then the rescue team should be on standby (literally standing by) outside of the space, ready to render immediate aid. Making this determination of rescue available vs. rescue standby applies to all situations, whether you are using local responders, in-house teams, or you contract out the service.

Although local emergency services are in the business of responding to emergencies (meaning they will come when you call), being on standby does not necessarily fit into those responsibilities—i.e., they may not be able to provide this service. And even if you are only requesting them as rescue available, they still may not be able (or willing) to obligate their trained members to always be available. Think about it: that is essentially asking their rescue-qualified members not to respond to other calls during the entry.

If using local emergency services is a route you want to seriously consider, then OSHA has a research assignment for you. (Note: this evaluation applies any time you are using an outside organization for rescue services.) You must evaluate:

  1. Response Time
    OSHA requires response in a “timely manner.” OSHA notes that “timely” depends on the hazard(s) present and refers to the Respiratory Protection Standard (1910.34) that requires standby persons when employees are wearing respiratory protection while working in an IDLH environment.
  1. Training and Equipment
    The prospective team must have the requisite training and equipment to proficiently perform rescue in the particular space(s) where entry will be made.[iii]

When selecting the local emergency services as your rescue team, it is imperative that the local emergency services know they have been selected for this role. If you have been performing your due diligence, this should be a foregone conclusion. But all too often, companies just check the box by their local responders and never let them know they have been designated for this role until an incident occurs. Should an accident happen where someone is injured, this is asking for a poor—if not disastrous—rescue outcome, as well as large fines from OSHA.

If you perform a really thorough assessment of the local emergency services, your findings will probably mimic those of many other organizations that have performed the same exercise—most local responder agencies are not trained, equipped, and/or available to provide standby or rescue services for confined space entries, period. The situation looks far bleaker for this option when you consider that they will be needed for every permit-required entry. It is a far bigger task than most local emergency response organizations want to deal with.

Also, while a written agreement with the local agency is not necessarily required by the regulation, it certainly would make it easier to document that an agreement to respond was in place – and that the department had an understanding of the scope of services to be provided at the employer’s site (i.e., confined space rescue). Here is a sample for you to download.

In-house Teams

qualified rescue service3When contemplating the utilization of in-house teams, it is important to note the composition of most. It is the rare organization that staffs personnel whose sole job it is to provide confined space rescue and standby services. Most in-house teams consist of personnel who have other jobs, e.g., operators, engineers, maintenance persons, etc., who are trained to provide rescue and thus called out for standbys or actual emergencies.

There are numerous pros to using in-house personnel. They know the facility and the processes; they should have a good understanding of the hazard(s); it does not add to the payroll, and they are only needed when there is a risky entry or an actual rescue. Further, they are often additionally motivated because it is their colleagues whom they are serving. An in-house team makes good sense if the organization frequently conducts permit-required entries.

But an in-house team carries with it many attendant requirements, some of which can be challenging to manage. Training can be tricky. While OSHA does not specify the number of personnel that should be on a rescue team, the average is probably three to six members. This number can go up or down depending on the complexity (or lack thereof) of the scenario. Regardless, there must be enough people trained such that all shifts are covered, and allowances must be made for those staff persons being on vacation, out sick, etc. In addition to initial training, all team members must receive, at the minimum, annual rescue practice that covers the types of permit-required spaces they may encounter.[iv]

An in-house team makes good sense if the organization frequently conducts permit-required entries.

Along with adequate training and practice comes the equipping component. Confined space rescue is an equipment-intensive prospect. In addition to the PPE that OSHA mandates you provide employees, there is the myriad other gear that is required: ropes, harnesses, and hardware that is standard for all rope rescues, plus the confined-space-specific kit such as a tripod, SKED, air monitors, ventilation fans, and ducting. In addition to the acquisition of this equipment, it must be inspected on a regular basis with the inspection results documented and maintained.

When the training, staffing, and equipment responsibilities are taken together, significant behind-the-scenes activity is required to make an in-house system work efficiently.

Contracted Rescue Services

qualified rescue service5This brings us to the third option—contracted rescue services. If an organization infrequently performs permit-required entries, this option makes good sense. And it can be a far less expensive option than training, staffing, and equipping an in-house team.

There is a hybrid approach to making an exclusive decision between in-house or contracted rescue services. With a hybrid approach, the organization has an in-house team for their typical or routine entries but uses a contracted provider for long-duration projects or instances where there are multiple simultaneous entries being conducted that outstrip the resources of the in-house team.

The pros to using contract rescue services is that the organization avoids the significant effort and resource requirements of an in-house team. They are only needed during the entry, and when it is complete, they depart and the pay meter quits ticking. There is no training of personnel, no equipment to purchase, and no need to reorganize shifts and/or pay overtime to cover staffing. The possible con is that quality rescue services are not exactly cheap, so there will be an expense involved which can be significant if the services are required for an extended period. You will also have to perform due diligence about the prospective service’s capabilities, just as you would with the local emergency services. In Appendix F of 1910.146, OSHA provides non-mandatory guidance on the selection criteria for selecting a rescue service. Roco also has a Confined Space Compliance Guide that offers additional information.

With a hybrid approach, the organization has an in-house team for their typical or routine entries but uses a contracted provider for long-duration projects or instances where there are multiple simultaneous entries being conducted that outstrip the resources of the in-house team.

It is important to note that by selecting a third party to perform rescue services, the confined space and the activities that occur in and around it remains your responsibility. This means that you cannot contract out your OSHA exposure/liability should an accident occur during a rescue attempt. At the end of the day, it is still your space. You still need to make sure that the process is being followed and that safety is being provided.

qualified rescue service4Regardless of which option you choose for confined space rescue services, it is important that you do it right. If you are contracting out the provision of rescue, you are obligated to thoroughly investigate the provider’s credentials and client references. You can be assured that when an accident happens, OSHA will perform a forensic review of your documentation and your policies, as well as those of your rescue service. If you have skipped a step or only addressed them in cursory fashion, OSHA will discover it and potentially issue citations and fines. But one should never lose sight of the fact that the real loser in this scenario is the employee who receives poor or delayed care during the emergency.

 

References

[i] OSHA 1910.146(b), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)

[ii] OSHA 1910.146(d)(9), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)

[iii] 1910.146(k), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)

[iv] OSHA 1910.146(k)(2)(iv), 1910.146 - Permit-required confined spaces | Occupational Safety and Health Administration (osha.gov)

 

Confined Space Rescue Chart

 

Additional Resources

 

 

 

Ventilation for Confined Space Rescue

Sunday, July 31, 2022

Vent Early, Vent Continuously, and Vent Properly.

During a confined space rescue scenario, performing ventilation can have a huge impact on achieving a positive outcome at the incident. With few exceptions, there is no downside to ventilating in a confined space, but the upsides can be literally life changing.

In the simplest terms, ventilation is the process of circulating air with the goal of removing “bad” air (oxygen-deficient, toxic, explosive, etc.) from a confined space and replacing it with “good” (fresh) air. There are different methods to accomplish this task, but each with the same basic goal. In most cases, ventilation is an attempt only to control or mitigate a hazard rather than eliminate it. If ventilation ceases for any reason, the hazard may rapidly return.

ventiliation 1Ventilation serves several important purposes. It improves the environment for the victim by directly removing or diluting the contaminants in the space. By creating a flow of air, ventilation can improve the ambient conditions of the space which can be extremely helpful for a victim’s status. Lastly, and of equal importance, ventilation also improves the operating conditions for the rescuers, which is critical as well.

Vent Early

If a victim is in a bad air environment, the clock is ticking. Of course, the exact contents of the space ultimately determine survivability, but the point is, there is not much time regardless. And getting rescuers into the space and in contact with the victim may easily take 4 to 6 minutes or much longer. Ventilation, on the other hand, can be quickly activated outside of the space and at work removing contaminants almost immediately. It is one of the single best things rescuers can do early in the incident.

The first step in venting early is understanding the space where rescue will be performed. This is where effective preplanning really pays dividends. After understanding the potential hazards, one of the first pieces of information rescuers will need is the dimensions of the space to be ventilated. Since air is measured in cubic feet, multiply the width times the height times the depth of the space (in feet) to arrive at the cubic feet of air volume.

Ventilation is the process of circulating air with the goal of removing “bad” air (oxygen-deficient, toxic, explosive, etc.) from a confined space and replacing it with “good” (fresh) air.

The next piece of critical information is the size of the fans that will be used for ventilation. Fans are measured in—or rated by—the cubic feet per minute (CFM) they will move. Take the total cubic feet of the space and divide it by the fan’s rated CFM, and you can determine how long it will take to exchange the air in the space. The faster the air can be exchanged, then the lower the toxicity levels, the lower the percentage of lower explosive limits (LEL), the higher the oxygen levels, and the more fresh air is circulating around the victim. So, when it comes to fans, bigger—or at least “bigger” CFMs—is definitely better.

Another important part of the preplanning process is to identify the ventilation openings for the intake and its path to discharge. Ideally, both of these points will not be the entrance from which rescuers expect to effect the rescue. But often this is not the case. When assessing these locations, it is important that the intake air be drawn from a non-contaminated source and that the discharge air will not spread contamination to people or equipment. This is also a good time to consider where and how ducting will be executed.

Preplanning should also take into consideration the interior of the space. Is it a wide-open vessel? Or are there obstructions—such as trays or mixing equipment—that can obstruct airflow and create dead air spaces? The configuration of the space can interfere with ventilation and may require extra or larger fans to adequately move air through it.

ventilation 2At the declaration of an emergency, deploying ventilation and performing air monitoring should occur concurrently with size up. Starting ventilation is like applying a cervical collar at the scene of an automobile accident; it is one of those things you know you are going to perform each and every time. And while it is expected that everyone will be appropriately trained, ventilation can be handled by support personnel while the rescue technicians are readying for entry.

This is the time to gather baseline atmospheric data about the space with air monitoring. Because gases can have varying weights (meaning they may float or sink), OSHA requires measuring intervals of every four (4) feet. As highlighted earlier, this underscores the importance of identifying the space’s dimensions and configuration.

It is highly desirable to monitor the space prior to the commencement of ventilation. Knowledge of the baseline monitoring results better arms the rescue team to deal with the space in terms of their own protection, thus possibly affecting equipment choice(s). With continuous monitoring, the value of ventilation can also be unequivocally realized with increasing oxygen levels, decreasing toxicity, and decreasing percentage of LEL. It is this improvement of the space’s atmosphere, with so little comparative effort, where the beauty and value of ventilation lie.

Vent Continuously

Most industrial standard operating guidelines require five (5) complete air exchanges before entering a confined space. But this is under working conditions. During a rescue, there may not be time for that degree of ventilation to take place. This again highlights the vent early aspect of response.

By venting continuously, you are constantly improving the interior conditions. Ventilation operates under the premise of increasing returns—the longer it is performed, the better the conditions inside of the space. And the conditions will continue to improve so long as ventilation is provided. This is why it is vitally important to never interrupt ventilation once it has begun.

If electric ventilation fans are used, try to ensure they are on an uninterruptible power supply if possible. If generators are being used to supply power, ensure there is ample fuel.

In concert with the continuous ventilation, there should be continuous air monitoring. It is important to continue to identify any areas where readings are not improving. If the ventilation has been set up and sized properly, the air monitoring results should reveal a steadily improving atmosphere (as long as hazards are not actively being introduced into the space). In some instances, remedying problem ventilation areas may be something as simple as adjusting the ducting.

Vent Properly

Ventilation supplies the aforementioned stellar results only if it is done properly. And there can be no question that performing ventilation properly is a matter of both science and mathematics. It is a quantifiable problem.

But in the real world with a relentlessly ticking clock, once the basic dimensions are known, there is also a degree of “voodoo magic” that comes into play with being able to read the space and quickly determine the ventilation inlets, outlets, and configurations inside that may impede airflow. That “magic” comes with training and experience. While most rescuers want to spend their training time performing the glamour skills—such as rigging and patient packaging—it is important to remember that in a bad air situation, it will be ventilation that can have the greatest immediate effects.  In training, teams need to quit only verbalizing that ventilation is set up and actually perform this lifesaving skill.

Setting up ventilation is a great task both for new team members or for those in technician training. The rescue leader or ventilation officer of course decides the ventilation plan, but actually setting up the equipment can be delegated to new or support personnel. It is a crucial task that needs to be completed and provides immediate and tangible results while positively affecting the outcome of the incident.

In the rescue world, ventilation is similar to rope—you need the right size and the right amount.

How to perform ventilation properly can be a course in and of itself and is a topic that carries with it some debate. The debate usually centers around positive pressure ventilation versus negative pressure ventilation. But when applied correctly, both are proven performers in ventilation. It is the proper use of the equipment on hand that actually matters when it comes to performing effective ventilation.

So, while neatly avoiding the ventilation debate or getting too far into the weeds with a how-to course on ventilation, we will address some of the more salient points with ventilation that should be considered. These are the kind of things that, if not done or done wrong, can impede your ventilation efforts and/or create an unsafe environment.

In the rescue world, ventilation is similar to rope—you need the right size and the right amount. Bigger, more powerful ventilation fans move more air, help eliminate dead air spaces, and exchange the air in the space quicker. If larger fans are not available, it is often possible to use multiple fans to increase airflow. Ducting fits into this “rope” category as well—it is paramount to effective ventilation, so it pays to have plenty of it. Fan manufacturers provide guidance on how far ducting can be extended to or from their fans and how it affects the capacity or the amount of air moved.

The next important thing is to be familiar with the equipment. Seeing equipment for the first time at an emergency is unacceptable. This stresses the importance of training with your gear and developing competency with it in advance of an incident. It is also most definitely advisable to follow the equipment manufacturer's instructions with regard to use and cleaning. 

ConfinedSpaceAttendant-01-1Just as important as the fans is a solid air monitoring plan. The rescuers should be aware of the potential atmospheric hazards and have obtained the appropriate monitoring equipment. The air monitoring should continuously measure the entire space with results constantly provided to the vent team; this allows for adjustments if a particular part of the space is not seeing the expected improvements in air quality.

It is also critical to consider the intake air source and the discharge path for exhaust or discharge air. Since fresh air will be sent to the victim, it is imperative that its source be free of contaminants. In the same regard, the hazardous atmosphere from inside the space is also being vented somewhere. This location should be free of personnel and equipment or any other environmental concerns.

If your team is employing positive pressure ventilation, there will almost always be some degree of (and often all of) the exhaust occurring at the rescue opening or portal. This means that the outside team is probably being exposed to the space’s atmosphere. Therefore, air monitoring should be conducted in their vicinity continuously while ventilation is in progress. These crew members may very well need to wear PPE to protect them from the hazard. Neglecting topside air monitoring is a frequently overlooked step that can have dangerous consequences.

Ventilation is a foundation skill that often does not receive the attention it deserves. Short of supplying breathing air directly to the victim, there is no more effective step than ventilation for improving air quality inside of a confined space and ultimately the survivability of the victim. We encourage all rescue teams to include ventilation as a standard part of their rescue training regimen. And when at the actual emergency… vent early, vent continuously, and vent properly.

 

Confined Space Rescue Chart

 

Additional Resources

 

 

 

Trench Deaths Up 68% in 2022!

Thursday, July 21, 2022

The alarming rise in trench-related fatalities has spurred US Department of Labor to announce enhanced nationwide enforcement.

In 2022’s first six months, 22 workers have fallen victim to the deadly hazards present in trenching and excavation work – surpassing 15 in all of 2021 – and prompting the U.S. Department of Labor’s Occupational Safety and Health Administration to launch enhanced enforcement initiatives to protect workers from known industry hazards.

trench1To stress the dangers of disregarding federal workplace safety requirements for trenching and excavation work, OSHA enforcement staff will consider every available tool at the agency’s disposal. These actions will place additional emphasis on how agency officials evaluate penalties for trenching and excavation related incidents, including criminal referrals for federal or state prosecution to hold employers and others accountable when their actions or inactions kill workers or put their lives at risk.

Read the full press release: https://content.govdelivery.com/accounts/USDOL/bulletins/3213baa

 

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.

 

Using a Crane in Rescue Operations

Tuesday, May 31, 2022

We’re often asked, “Can I use a crane as part of my rescue plan?” 

If you’re referring to using a crane as part of moving personnel or victims, the answer is “No, except in very rare and unique circumstances.” The justification for using a crane to move personnel, even for the purposes of rescue, is extremely limited. Therefore, it is very important to understand the “do’s and don’ts” for using a heavy piece of equipment in a rescue operation.

crane3_5.22rev

On the practical side, the use of a crane as a “stationary, temporary high-point anchor” can be a tremendous asset to rescuers. It may also be part of a rescue plan for a confined space –  a top entry fan plenum, for example. The use of a stationary high-point pulley can allow rescue systems to be operated from the ground. It can also provide the headroom to clear rescuers and packaged patients from the space or an elevated edge.

Because of the dangers involved in moving personnel with heavy equipment, OSHA strictly limits its use.

The security of the system's attachment to the crane and the ability to “lock-out” any potential movement are a critical part of the planning process. If powered industrial equipment is to be used as a high-point, it must be treated like any other energized equipment with regard to safety. Personnel would need to follow proper Lock-out/Tag-out procedures [Control of Hazardous Energy 1910.147]. Any equipment used in the rescue operation would need to be properly locked out – (i.e., keys removed, power switch disabled, etc.). You would also need to check the manufacturer’s limitations for use to ensure you are not going beyond the approved use of the equipment.

Because of the dangers involved in moving personnel with heavy equipment, OSHA strictly limits its use. In order to utilize a crane, properly rated “personnel platforms or baskets” must be used. Personnel platforms that are suspended from the load line and used in construction are covered by 1926.1431.
There is no specific provision in the General Industry standards, so the applicable standard is 1910.180(h)(3)(v). This provision specifically prohibits hoisting, lowering, swinging, or traveling while anyone is on the load or hook.

OSHA prohibits the hoisting of personnel by crane or derrick except when no safe alternative is possible. The use of a crane for rescue does not provide an exception to these requirements unless very specific criteria are met.

An OSHA Letter of Interpretation (LOI 1993-02-17) states, “OSHA has determined, however, that when the use ofa conventional means of access to an elevated worksite would be impossible or more hazardous, a violation of 1910.180(h)(3)(v) will be treated as de minimis if the employer has complied with the provisions set forth in 1926.550(g)(3) through (g)(8).”

Note: De minimis violations are violations of standards which have no direct or immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way as any other violation, but are not included on the citation.

Therefore, the hoisting of personnel is not permitted unless conventional means of transporting employees  is not feasible. Or, unless conventional means present even greater hazards (regardless if the operation is for planned work activities or for rescue). Where conventional means would not be considered safe, personnel hoisting operations meeting the terms of this standard would be authorized. OSHA stresses that employee safety, not practicality or convenience, must be the basis for the employer's choice of this method.

However, it is also important to note that OSHA specifically requires rescue capabilities in certain instances, such as when entering permit-required confined spaces [PRCS 1910.146]; or when an employer authorizes personnel to use personal fall arrest systems [PFAS 1910.140(c)(21) and 1926.502(d)(20)]. In other cases, the general duty to protect an employee from workplace hazards would require rescue capabilities. 

Consequently, being “unprepared for rescue” would not be considered a legitimate basis to claim that moving a victim by crane was the only feasible or safe means of rescue.

This is where the employer must complete written rescue plans for permit spaces and for workers-at-height using personal fall arrest systems – or they must ensure that the designated rescue service has done so. When developing rescue plans, it may be determined that there are no other feasible means to provide rescue without increasing the risk to the rescuer(s) and victim(s) other than using a crane to move the human load. These situations would be very rare and would require very thorough documentation. Such documentation may include written descriptions and photos of the area as part of the justification for using a crane in rescue operations.

Bottom line… simply relying on using a crane to move rescuers and victims without completing a rescue plan and very clear justification would not be in compliance with OSHA regulations. It must be demonstrated that the use of a crane was the only feasible means to complete the rescue while not increasing the risk as compared to other means. Even then, there is the potential for an OSHA compliance officer to determine that there were indeed other feasible and safer means.

crane6_5.22WARNING: Taking it a step further, if some movement of the crane  is required, extreme caution must be taken! Advanced rigging techniques may be required to prevent movement of the crane from putting undue stress on the rescue system and its components. Rescuers must also evaluate if the movement would unintentionally “take-in” or “add” slack to the rescue system, which could place the patient in harm’s way. The movement of a crane can take place on multiple planes – left-right, boom up-down, boom in-out and cable up-down. If movement of the equipment must take place, rescuers must evaluate how it might affect the operation of the rescue system.

Of course, one of the most important considerations in using any type of mechanical device is its strength and ability (or inability) to “feel the load.” If the load becomes  entangled while movement is underway, serious injury to the victim or an overpowering of system components can happen almost instantly. No matter how much experience a crane operator has, there is no way he can “feel” if the load becomes entangled. And, most likely, he will not be able to stop before injury or damage occurs. Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is completely lost when energized devices are used to do the work.

For rescuers, a crane is just another tool in the toolbox – one that can serve as a temporary, stationary high-point making the rescue operation an easier task. However, using a crane that will require some movement while the rescue load is suspended should be a last resort! There are simply too many potential downfalls in using cranes. This also applies to fire department aerial ladders. Rescuers must consider the manufacturer’s recommendations for use. What does the manufacturer say about hoisting human loads? And, what about the attachment of human loads to different parts of the crane or aerial?

However, there may be cases in which a crane is the only option. For example, if outside municipal responders have not had the opportunity to complete a rescue plan ahead of time, they will have to do a “real-time” size-up once on scene. Due to difficult access, victim condition, and/or available equipment and personnel resources, it may be determined that using a crane to move rescuers and victims is the best course of action. 

Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is completely lost when energized devices are used to do the work.

Using a crane as part of a rescue plan must have rock-solid, written justification as a demonstration that it is the safest and most feasible means to provide rescue capability. Planning before the emergency will go a long way in providing options that may provide fewer risks to all involved.

So, to answer the question“Can I include the use of a crane as part of my written rescue plan?” 

Well, yes and no. Yes, as a high-point anchor. And, no, the use of any powered load movement will most likely be an OSHA violation without rock-solid justification. The question is, will it be considered a de minimis violation if used during a rescue? Most likely it will depend on the specifics of the incident. However, you can be sure that OSHA will be looking for justification as to why using a crane in motion was considered to be the least hazardous choice.

NOTE: Revised 5/2022. Originally published 10/2014.

 

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