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The Importance of Trench/Excavation Safety: A Conversation with Roco Rescue Chief Instructor Tim Robson

Thursday, February 14, 2019

Tim Robson’s involvement with trench rescue started in 1994 when his technical rescue team from the Albuquerque Fire Department responded to what the dispatcher called a trench event.

“When we arrived on the scene, no one was there other than a police officer and a grandmother,” Tim recalls. “She couldn’t find her grandson.”

A company doing trench work in front of her home had offered to pay the woman’s teenage grandson hourly to help them. The teenager was inside the trench when it collapsed.

The Importance of Trench/Excavation Safety: A Conversation with Roco Rescue Chief Instructor Tim Robson

“The company left, and they left him in the trench,” Tim explains. “Unfortunately, it was a fatality. When we found him, he had already succumbed.”

As a result of that experience, Tim understands firsthand the risks involved in trench work and the importance of trench safety. Now, Tim supervises Roco Rescue’s technical rescue teams across the globe and, as a Chief Instructor, leads training courses in – among other things – trench rescue.

Tim is presenting a course on “Managing Excavations” at the North Dakota Safety Council’s 46th Annual Safety & Health Conference later this month. We sat down to talk with Tim recently to find out more about trench safety and why it’s so important.

Roco Rescue: Good afternoon, Tim, and thank you for talking with us today about trench/excavation safety. Let’s start with the overarching question: How dangerous is trench work?

Tim:  Trenching/excavation is one of the major fatality-causing occupations in the U.S. right now, according to the Bureau of Labor Statistics. Of the 130 trench/excavation fatalities that occurred between 2011 and 2016, 80% of those occurred in the private construction industry.

What scares us even more is that the number of fatalities is trending up. In 2014, there were 13 fatalities in trench/excavation. In 2015, that number rose to 25. And in 2016, there were 36 fatalities. So nearly half of the fatalities that occurred over a fifteen-year period happened in 2015 and 2016. Despite the fact that the regulations have gotten stricter, the numbers are trending up.  

The Importance of Trench/Excavation Safety: A Conversation with Roco Rescue Chief Instructor Tim Robson

Roco Rescue: We’re going to touch on the OSHA regulations in a moment. First, please explain why the number of fatalities is trending upwards.

Tim: The increase in fatalities goes hand in hand with the uptick in employment and construction; as the economy improves, there’s more construction and, with that, more trenching and excavation.

In addition to more construction, there’s less space. As a country, we’re building more roads, more buildings, and more infrastructure but we have less physical space to do it in.

And in addition to doing more construction in less space, in our world, we have to do more with less. Ten years ago, there were six people working on a construction trenching job; today, there are 4, and that naturally lends itself to more safety violations.

Roco Rescue: What makes trenches so dangerous?

Tim: First, let me explain the difference between a trench and an excavation: an excavation is wider than it is deep, meaning there’s less chance of dirt collapsing because the vertical walls of the trench are sloping. If my wall slopes away from the bottom of the hole I dug, there’s less chance of that wall falling in.

A trench, on the other hand, is deeper than it is wide. If I have to dig a trench with a perfectly vertical wall, because there’s a road right next to where I’m digging the trench, I can almost guarantee a collapse.

To give readers an idea of the physics and mechanics involved when soil collapses, I often use this analogy: A typical collapse involves a couple of yards of dirt. A couple of yards of dirt collapsing into a 6-foot deep trench has the same force as a pickup truck moving 45 miles an hour. If you’re at the bottom of the trench and the soil falls in on you from 6 feet, you’re getting hit with the same amount of force as a pickup truck traveling 45 miles per hour.

When that force hits you, you can’t survive. And that’s just the force. There’s also the compression and blocked airways that the victim experiences. Every time you take a breath, the soil gets closer to your body so now it’s compressing you and you’re not able to expand your chest wall.

That’s why this is such a big concern for OSHA.

Roco Rescue: Let’s talk more about the OSHA regulations. What is OSHA doing to help reduce the number of fatalities caused by trench collapse?

Tim: Last year, OSHA put out a compliance letter urging the construction industry to improve the safety of their trenching and excavation operations.

OSHA requires that any time someone makes an excavation or trench in the ground as part of their occupation, they have to designate what’s called a competent person. That’s usually someone in a management or supervisory position who is tasked with “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.”

Roco Rescue: Besides designating a competent person, what precautions can supervisors take at work sites to reduce trench injuries/fatalities, and what can workers do to keep themselves safe?

The Importance of Trench/Excavation Safety: A Conversation with Roco Rescue Chief Instructor Tim Robson

Tim: Construction businesses have to meet the OSHA requirements for trench and excavation safety. To make the trench safe takes more time, more manpower and more labor. Ultimately, safety costs money, which is a challenge for small business in particular.

But the implications for failing to meet the requirements comes with an even bigger cost. Worker safety notwithstanding, the Department of Labor and the Department of Justice now agree that if a fatality occurs on a job site due to a willful violation of an employer, it is now a criminal act.

However, workers are equally responsible for their safety. They are also accountable for their actions. If a trained worker willfully gets into that trench, knowing it’s unprotected, they’re just as culpable as the company that put them there.

In short, the employer’s responsibility is to make sure individuals are trained at work and the employee’s responsibility to understand and follow those requirements.

Roco Rescue: What are three things attendees at your upcoming course at the NDSC Annual Conference can expect to take away from your presentation?

Tim: First, don’t take trench and excavation lightly. There’s a risk that comes with saying, “We’ve always done it this way.”

Second, they’ll leave with an understanding of OSHA’s trench/excavation competent person requirements.

Third, they’ll understand the requirements of AHJ (the authority having jurisdiction), which is generally the host employer. The AHJ is the entity that must deem someone a competent person. As an instructor, I don’t have that authority. Taking my class doesn’t qualify someone as a competent person.

Roco Rescue: How will the course you’re giving at the NDSC Annual Conference differ from Roco Rescue’s training courses in trench rescue?

Tim: At the Roco Training Center, we offer open enrollment courses in trench rescue and can even do a private training based on a specific industry. Our courses teach how to construct a trench so that it won’t collapse and, if it does collapse because of some catastrophic event, teaches workers ways to protect themselves.

Both the courses at the Roco Training Center and my course at the NDSC Annual Conference are focused on compliance, but the course at the NDSC is geared toward a broader audience.

Roco Rescue: What’s your final piece of advice for trench workers, Tim?

Tim: It’s simple: until you know it’s safe, don’t get in the trench.

Roco Rescue: Thank you so much for sharing your knowledge and expertise with us, Tim.

For more information about Roco Rescue’s open enrollment or private training courses in trench safety and trench competent person, check out our training options

 

Confined Space Types - Are All Your Bases Covered?

Friday, November 30, 2018

Confined Space Types - Are All Your Bases Covered?Refineries, plants and manufacturing facilities have a wide range of permit-required confined spaces – some having only a few, while others may have hundreds. Some of these spaces may be relatively open and straightforward while others are congested and complex, or at height. With this in mind, are all your bases covered? Can your rescue team (or service) safely and effectively perform a rescue from these varying types of spaces? Or, are you left exposed? And, how can you be sure?

Rescue Practice & Preplanning

With a large number of permit spaces on site, it would be impossible for a rescue team to practice in each and every one. Plus, in most cases, the spaces are operating, functioning units within the plant. Because of this, section (k) of 1910.146 allows practice from “representative” spaces. This is where the Roco Confined Space Types Chart can make the process easier.

Using OSHA guidelines for determining representative spaces, the Roco Types Chart is designed to assist employers and rescue teams plan for various types of permit spaces.

The chart allows you to categorize permit spaces into six (6) confined space types, which can then be used to prepare rescue plans, determine rescue requirements, conduct practice drills or evaluate a prospective rescue service.

First of all, it's important to note that employers are required by 1910.146 and 1926 Subpart AA to allow rescue teams the opportunity to practice and plan for the various types of confined spaces they may be required to respond. This is critical for the success of the rescue, particularly timeliness, as well as for the safety of the rescuers.

Classifying and Typing Your Spaces

So, get out your clipboard, tape measure, some sketch paper, and a flashlight (if safe to do so) in order to view as much of the interior of the space as you can. And, if you absolutely need to enter for typing and/or rescue preplanning purposes, be sure to do so using full permitting procedures. Gaining access to architectural or engineering drawings may also be helpful in determining the internal configuration when actual entry is not feasible. Armed with this information, it is time to “type” the spaces in your response area using the Roco Confined Space Types Chart.

Confined Space Types - Are All Your Bases Covered?

Over the decades, we’ve seen just about every type of confined space configuration out there. And, while there may be hundreds of permit spaces on site, most of them will fit into one of these six types and require the same (or similar) rescue plan. Of course, there are always unique situations in addition to physical characteristics, such as space-specific hazards or specialized PPE requirements, but this chart can be a valuable tool in the planning and preparation for confined space rescue operations.

We’ve also learned that it is imperative to understand the physical limitations of space access and internal configuration as well as how this affects equipment and technique choices for the rescue team. Referring to the Roco Types Chart and practicing simulated rescues from the relevant types of spaces will help identify these limitations in a controlled setting instead of during the heat of an emergency.

We can all agree that during an emergency is NOT the time to learn that your backboard or litter will not fit through the portal once the patient is packaged.

Six General Types

On the Roco Types Chart, you will note that there are six (6) general types identified, which are based on portal opening size and position of portal. Types 1 and 2 are “side” entries; Types 3 and 4 are “top” entries; and Types 5 and 6 are “bottom” entries. There are two types of each based on portal size, which is significant for rescue purposes. Openings greater than 24-inches will allow packaged patients on rigid litters or rescuers using SCBA to negotiate the opening; whereas, openings 24-inches or less will not.

Portals less than 24-inches will require a higher level of expertise and different packaging and patient movement techniques.

Once the various types have been determined, pay particular attention to spaces identified as Types 1, 3, or 5. Again, these spaces have the most restrictive portals (24-inches or less) and are considered “worst case” regarding entry and escape in terms of portal size. This is very important because it will greatly influence the patient packaging equipment and rescuer PPE that can be used in the space.

Accessibility and Internal Configuration

In addition to the “type” of the space based on portal size and location, another key consideration is accessibility or “elevation” of the portal. While the rescue service may practice rescues from Top, Side and Bottom portals – being at ground level is very different from a portal that’s at 100-ft. Here’s where high angle or elevated rescue techniques are normally required for getting the patient lowered safely to ground level.

Lastly, the internal configuration of a space must be carefully considered for rescue purposes. This will be discussed more in the following section on Appendix F.

Remember, rescue practice from a representative space needs to be a “true” representation of the kind of rescue that may be required in an emergency.

1910.146 Appendix F – Representative Spaces

In Appendix F, OSHA offers guidelines for determining Representative Spaces for Rescue Practice. OSHA adds that “teams may practice in representative spaces that are ‘worst case’ or most restrictive with respect to internal configuration, elevation, and portal size.” These characteristics, according to OSHA, should be considered when deciding whether a space is truly representative of an actual permit space.

(1) Internal Configuration

Confined Space Types - Are All Your Bases Covered?

What’s inside the space? If the interior is congested with utilities or other structural components that may hinder movement or the ability to efficiently package a patient, it must be addressed in training. For example, will the use of entrant rescuer retrieval lines be feasible? After one or two 90-degree turns around corners or around structural members, the ability to provide external retrieval of the entrant rescuer is probably forfeited. For vertical rescue, if there are offset platforms or passageways, there may be a need for directional pulleys or intermediate haul systems that are operated inside the space.

What about rescues while on emergency breathing air? If the internal configuration is so congested that the time required to complete patient packaging exceeds the duration of a backpack SCBA, then the team should consider using SAR. Will the internal configuration hinder or prevent visual monitoring and communications with the entrant rescuers? If so, it may be advisable to use an additional authorized rescuer as an “internal hole watch” to provide a communication link between the rescuers and personnel outside the space.

What if the internal configuration is such that complete patient packaging is not possible inside the space? This may dictate a “load-and-go” type rescue that provides minimal patient packaging while providing as much stabilization as feasible through the use of extrication-type short spine boards as an example.

(2) Elevation

If the portal is 4 feet or greater above grade, the rescue team must be capable of providing an effective and safe high angle lower of the victim; and, if needed, an attendant rescuer. This may require additional training and equipment. For these situations, it is important to identify high-point anchors that may be suitable for use, or plan for portable high-point anchors, such as a “man lift” or some other device.

(3) Portal Size

Confined Space Types - Are All Your Bases Covered?

Here again, the magic number is 24 inches or less for round portals or in the smallest dimension for non-round portals. It is a common mistake for a rescue team to “test drive” their 22-to-23-inch wide litter or backboard on a 24-inch portal without a victim loaded and discover that it barely fits. However, the problem arises when a victim is loaded onto the litter. The only way the litter or backboard will fit is at the “equator” of the round portal. This will most likely not leave enough room between the rigid litter or backboard and the victim’s chest, except for our more petite victims.

For rescuers, it is already difficult to negotiate a portal while wearing a backpack SCBA. For portals of 24 inches or less, it’s nearly impossible. If the backpack SCBA will not fit, it is time to consider an airline respirator and emergency escape harness/bottle instead. Warning: Do NOT under any circumstances remove your backpack SCBA in order gain access to a confined space through a restricted portal or passageway. It is just too easy for a mask to become displaced.

(4) Space Access – Horizontal vs. Vertical

Most rescuers regard horizontal retrievals as easier than vertical. However, this is not always the case. If there are floor projections, pipe work or other utilities, even just a grated floor surface, it may create an incredible amount of friction or an absolute impediment to the horizontal movement of an inert victim. In this case, the entrant rescuers may have to rely on old-fashioned arm and leg strength to maneuver the victim.

Putting the Roco Types Chart into Practice

The Roco CS Types Chart can assist by first providing a way to classify and type your different kinds of spaces. This information can then be used to design training/practice drills as well as annual performance evaluations to make sure your rescue service is capable of rescue from the varying representative spaces onsite. Of course, this applies whether you use an in-house rescue team, a contracted rescue service, or a local off-site response team. Otherwise, how do you know if you truly have your bases covered? Don’t take that chance. If an incident occurs and the rescue personnel you are depending on are not capable of safely performing a rescue, your company could be culpable.

In section (k), OSHA requires employers to evaluate the prospective rescue service to determine proficiency in terms of rescue-related tasks and proper equipment.

If you need assistance with confined space typing or rescue preplan preparation, please contact us at info@rocorescue.com or 800-647-7626.

Request your Confined Space Types Chart & Compliance Guide.

Using a Crane in Rescue Operations

Sunday, September 30, 2018
 
Using a Crane in Rescue Operations
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.

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; for example, a top entry fan plenum. 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.

Using a Crane in Rescue OperationsOf course, 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 the Control of Hazardous Energy [Lockout/Tagout 1910.147]. The equipment 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 outside the approved use of the equipment.

Back to using a crane for moving personnel – because of the dangers involved, OSHA severely 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 29 CFR 1926.1501(g). 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 hoisting 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. OSHA has determined, however, that when the use of a conventional means of access to any 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 complies with the personnel platform provisions set forth in 1926.1501(g)(3), (4), (5), (6), (7), and (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’s also important to consider that OSHA specifically requires rescue capabilities in certain instances, such as when entering permit-required confined spaces [1910.146]; or when an employer authorizes personnel to use personal fall arrest systems [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.

Using a Crane in Rescue OperationsThis is where the employer must complete written rescue plans for permit-required confined 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 is 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.

Here’s the key… 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.

WARNING: Taking it a step further, if some movement of the crane (or fire department aerial ladder, for example) is required, extreme caution must be taken! Advanced rigging techniques may be required to prevent movement of the crane from putting undo 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. Movement of a crane can take place on multiple planes – left-right, boom up-down, boom in-out and cable up-down. If movement must take place, rescuers must evaluate how it might affect the operation of the rescue system.

Using a Crane in Rescue OperationsOf 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 hung up on an obstacle 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, when dealing with human loads, 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 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?

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.

Using a crane as part of a rescue plan must have rock-solid, written justification as 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 9/2018. Originally published 10/2014.

Safe Confined Space Entry - A Team Approach

Wednesday, September 26, 2018

Having been involved in training for 30 years, I have had the opportunity to observe how various organizations in many different fields approach confined space entry and rescue. And, when it comes to training for Entrants, Attendants and Entry Supervisors, the amount of time and content varies greatly.

Roco Rescue CS EntryMost often, training programs treat the three functions as separate, independent roles locked into a hierarchy based on the amount of information to be provided. However, it’s critical to note, if any one of these individuals fails to perform his or her function safely or appropriately, the entire system can fail – resulting in property damage, serious injury or even death in a confined space emergency.

Before I go any further, I have also seen tremendous programs that foster cooperation between the three functions and use more of a confined space “entry team” approach. This helps to ensure that the entry is performed safely and efficiently.

It also allows all parties to see the overall big picture of a safe entry operation.
In this model, all personnel are trained to the same level with each position understanding the other roles as well. This approach serves as “checks and balances” for confirming that:

• The permit program works and is properly followed;
• The permit is accurate for the entry being performed;
• All parties are familiar with the various actions that need to occur; and,
• The team knows what is expected of each other to ensure a SAFE ENTRY!

However, I am often surprised to find that Entrant and Attendant personnel have little information about the entry and the precautions that have been taken. They are relying solely on the Entry Supervisor (or their foreman) to ensure that all safety procedures are in place. If you have a well-tuned permit system and a knowledgeable Entry Supervisor, this may be acceptable, but is it wise? As the quality of the permit program decreases, or the knowledge and experience of the Entry Supervisor is diminished, so is the level of safety.


Roco CS Entry Supervisor & AttendantIn my opinion, depending exclusively on the Entry Supervisor is faulty on a couple of levels. First of all, the amount of blind trust that is required of that one person. From the viewpoint of an Entrant, do they really have your best interest in mind? And, we all know what happens when we “ass-u-me” anything! Plus, it puts the Entry Supervisor out there on their own with no feedback or support for ensuring that all the bases are covered correctly. There are no checks and balances, and no team approach to ensuring safety.

Looking at how 1910.146 describes the duties of Entrant, Attendant and Entry Supervisor tends to indicate that each role requires a diminishing amount of information. However, we believe these roles are interrelated, and that a team approach is far safer and more effective. To illustrate this, we often pose various questions to Entrants and Attendants out in the field. Here is a sample of some of the feedback we get.

We may ask Entrants…Who is going to rescue you if something goes wrong? Has the LOTO been properly checked? At what point do you make an emergency exit from the space? What are the acceptable entry conditions, and have these conditions been met? How often should the space be monitored? Typically, the answer is, “I guess when the alarm goes off, or when somebody tells me to get out!”

When we talk to Attendants about their duties, we often find they only know to “blow a horn” or “call the supervisor” if something happens, or if the alarm on the air monitor goes off. We also ask…What about when the Attendant has an air monitor with a 30 ft. hose, and there is no pump? Or, if you have three workers in a vertical space and the entire rescue plan consists of one Attendant, a tripod and a winch, plus no one in the space is attached to the cable – what happens then?
  
These are very real scenarios. Scary, but true. It often shows a lack of knowledge and cooperation between the three functions involved in an entry. And, that’s not even considering compliance!
We ask, would it not be better to train your confined space entry team to the Entry Supervisor level? Wouldn’t you, as an Entrant, want to know the appropriate testing, procedures and equipment required for the entry and specified on the permit? Would it not make sense to walk down LOTO with the Attendant and Entrant? This would better train these individuals to understand non-atmospheric hazards and controls; potential changes in atmosphere; or, how to employ better air monitoring techniques. All crucial information.

More in-depth training allows the entry team to take personal responsibility for their individual safety as well as that of their fellow team members. It also provides multiple views of the hazards and controls including how it will affect each team member’s role. Having an extra set of eyes is always a good thing – especially when dealing with the hazards of permit spaces. Let’s face it, we’re human and can miss something. Having a better-trained workforce, who is acting as a team, greatly reduces this possibility.

Roco Rescue Remote MonitoringMany times, we find that the role of Attendant is looked upon as simply a mandated position with few responsibilities. They normally receive the least amount of training and information about the entry. However, the Attendant often serves as the “safety eyes and ears” for the Entry Supervisor, who may have multiple entries occurring at the same time. In reality, the Attendant becomes the “safety monitor” once the Entry Supervisor okays the entry and leaves for other duties. So, there’s no doubt, the better the Attendant understands the hazards, controls, testing and rescue procedures – the safer that entry is going to be!

As previously mentioned, training requirements for Entrant, Attendant and Supervisor are all over the board with little guidance as to how much training or how in-depth that training should be. Common sense tells us that it makes better sense to train entry personnel for their jobs while raising expectations of their knowledge base.

OSHA begins to address some base qualifications in the new Confined Spaces in Construction standard (1926 Subpart AA) by requiring that all confined spaces be identified and evaluated by a “competent person.” It also requires the Entry Supervisor to be a “qualified person.” Does the regulation go far enough? We don’t think so, nor do some of the facilities who require formal, in-depth training courses for their Entrant, Attendant and Entry Supervisor personnel.
 
OSHA 1926.32 DEFINITIONS:
• Competent person: “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 the authorization to take prompt corrective measures to eliminate them.” 
• Qualified person: “One who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” 

So, do yourself a favor…go out and interview your Entrants and Attendants on a job.
Find out how much they do (or don’t) understand about the entry and its safety requirements. Do not reprimand them for not knowing, as it may not be their fault. It may be a systemic deficiency and the training mentality of distributing a hierarchy of knowledge based on job assignment.

Simply put, we believe that arming the entry team with additional information results in safer, more effective confined space operations. After all, isn’t that what it’s all about? GO TEAM!

Additional Resources:
• Download our Confined Space Entry Quick Reference Checklist. This checklist reiterates the value of approaching permit-required confined space entries as a team. In addition to OSHA-required duties and responsibilities for the three primary roles, we have included our recommendations as well. These are duties that we feel are important for the individual(s) fulfilling that role to be knowledgeable and prepared to perform if need be.

Safe Entry Workshop: Entrant, Attendant & Entry Supervisor is now available. See the full course description for details.

Fatal Trench Collapse Results in Severe Violator Status

Tuesday, September 25, 2018

An Ohio excavating company faces $202,201 in penalties and was placed in OSHA’s Severe Violator Enforcement Program1 after an employee suffered fatal injuries in a trench collapse. 

Inspectors found that the company was working in trenches up to 16-feet deep without adequate cave-in protection. The company failed to: use protective systems to prevent a cave-in; remove accumulating water; properly use ladders to enter and exit the trench; prevent employees from working beneath a suspended trench box; ensure employees wore hard hats; and make provisions for prompt medical attention in the event of injury.

“A trench can collapse in seconds, burying workers under the weight of thousands of pounds of soil,” said Ken Montgomery, OSHA Cincinnati Area Office Director. “This tragedy was preventable, and could have been avoided if the employer had installed required protective systems to prevent a trench cave-in.”

Here's a video showing multiple violations like the ones described here.

1OSHA's Severe Violator Enforcement Program (SVEP) concentrates resources on inspecting employers who have demonstrated indifference to their OSH Act obligations by committing willful, repeated, or failure-to-abate violations. Enforcement actions for severe violator cases include mandatory follow-up inspections, increased company/corporate awareness of OSHA enforcement, corporate-wide agreements, where appropriate, enhanced settlement provisions, and federal court enforcement under Section 11(b) of the OSH Act. In addition, this Instruction provides for nationwide referral procedures, which includes OSHA's State Plan States. This instruction replaces OSHA's Enhanced Enforcement Program (EEP).

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