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.

How often have you heard the statement “I will just call 911 if we have a confined space emergency”?  Let’s dispel some common myths and misunderstandings regarding confined space rescue compliance.

In accordance with OSHA 1910.146 (d)(9) an employer that will have personnel entering Permit Required Confined Spaces at their workplace must “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.

Meeting this requirement can be accomplished in several ways…

    - Develop an in-house rescue team made up of host employees.
    - Contract with an outside third party rescue team.
    - Coordinate with local emergency services (“911”).

Whatever way an employer chooses, there are specific evaluation criteria that must be met according to 1910.146 (k)…

1. The rescue team must be capable of responding in a timely manner and reaching the victim(s) within an appropriate amount of time based on the hazards of the confined space.  On-site teams (in-house or third party contracted teams) are generally better able to meet this requirement.
2. The team must be equipped and proficient in performing the type(s) of rescue that may be encountered.  Can they walk the walk, or just talk the talk?
3. The employer shall ensure at least one member of the rescue team is currently certified in CPR/First Aid.
4. The employer shall also ensure that the designated rescue team practices making permit space rescues at least once every 12 months from the actual spaces or representative spaces in regards to opening size, configuration, and accessibility. Representative spaces shall simulate the types of permit spaces from which rescue is to be performed.

Non-Mandatory Appendix F – Rescue Team/Rescue Service Evaluation Criteria

These are some but not all of the requirements of an initial and periodic performance evaluation of the rescue team:

1. At a minimum, if an offsite rescue team is being considered, the employer must contact the service to plan and coordinate the evaluation of the team based on 1910.146 (k).  Merely posting the service’s phone number or planning to rely on “911” to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.
2. Can the rescue team respond in an appropriate amount of time based on the hazards of the space?  For known IDLH hazards or hazards that can quickly develop into IDLH conditions, on scene rescue standby is required.  For non- IDLH hazards, a response time of 10-15 minutes may be adequate.
3. Will the offsite rescue team be available to respond to a confined space incident or is there a potential they will be out of service on a separate incident and unable to respond?
4. If necessary, can the rescue service properly package and retrieve victims from a permit space that has a limited size opening (less than 24 inches in diameter) or from a space that has internal obstacles or hazards? Does the service have the capability to provide rescue from an elevated location using high angle rescue techniques?

The three levels of protection required by OSHA for confined space entrants are:

1) Hazard Awareness

2) Retrieval Equipment

3) Rescue Services

Some subtle and not so subtle changes to NFPA 1006 are included in the most current edition. The 2008 edition is now titled “Standard for Technical Rescuer Professional Qualifications”. Today we’ll address some of the changes that have been made to Chapter 4 and Chapter 5 “Job Performance Requirements” which some folks call “core” requirements. We will also cover some of the changes to the Rope Rescue and Confined Space Rescue specialty areas.

Chapter 4, Technical Rescuer

As in the past, a technical rescuer must perform all of the job performance requirements of chapter 5, and at least one of the technician levels of at least one specialty area. This is analogous to the core plus one concept of previous additions. The change has to do with the new technician levels. For each specialty area there are two levels of qualification.

Level I:  An individual who can identify hazards, use equipment, and can apply limited techniques as identified in this standard.

Level II:   An individual who can identify hazards, use equipment, and can apply advanced techniques as identified in this standard.