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.