There are countless injuries and deaths across the nation when workers are not taught to recognize the inherent dangers of permit spaces. They are not trained when "not to enter" for their own safety. Many of these tragedies could be averted if workers were taught to recognize the dangers and know when NOT to enter a confined space.

While this incident happened several years ago, it emphasizes the senseless loss of life due to a lack of proper atmospheric monitoring and confined space training. Generally, the focus for training is for those who will be entering spaces to do the work. However, we also must consider those who work around confined spaces – those who may be accidentally exposed to the dangers. Making these individuals aware of the possible hazards as well as to stay clear unless they are properly trained.

Note: This case summary from the New York State Department of Health goes on to say that the DPW had a confined space training program but stopped the training after the last trainer retired.

CASE SUMMARY - TWO (2) FATALITIES
A 48-year-old male worker (Victim I) employed by the Department of Public Works (DPW) and a 51-year-old male volunteer firefighter (FF Victim II) died after entering a sewer manhole located behind the firehouse. In fact, the Fire Chief was on scene because he had been called by the DPW general foreman to unlock the firehouse and move the firetruck so it would not be blocked by the DPW utility truck working at the manhole. Another firefighter also arrived to offer assistance, he later became FF Victim II.

The manhole was 18 feet deep with an opening 24-inches in diameter (see photo above). Worker Victim I started climbing down the metal rungs on the manhole wall wearing a Tyvek suit and work boots in an attempt to clear a sewer blockage. The DPW foreman, another firefighter and FF Victim II walked over to observe. They saw Victim I lying on the manhole floor motionless. They speculated that he had slipped and fallen off the rungs and injured himself. The Fire Chief immediately called for an ambulance.

Meanwhile, FF Victim II entered the manhole to rescue Victim I without wearing respiratory protection. The other firefighter saw that FF Victim II fell off the rungs backwards while he was half way down and informed the Fire Chief. The Fire Chief immediately called for a second ambulance and summoned the FD to respond. FD responders arrived within minutes.

The Assistant Fire Chief (AFC) then donned a self-contained breathing apparatus. He could not go through the manhole opening with the air cylinder on his back. The cylinder was tied to a rope that was held by the assisting firefighters at the ground level. The AFC entered the manhole with the cylinder suspended above his head. He did not wear a lifeline although there was a tripod retrieval system. He secured FF Victim II with a rope that was attached to the tripod.

FF Victim II was successfully lifted out of the manhole. The AFC exited the manhole before a second rescuer entered the manhole and extricated Victim I in the same manner. Both victims were transported to an emergency medical center where they were pronounced dead an hour later. The cause of death for both victims was asphyxia due to low oxygen and exposure to sewer gases.

Deaths among career and volunteer firefighters continued to be low in 2017 with both at the second lowest level since 1977, when the NFPA study began. There were 60 on-duty firefighter fatalities across the nation in 2017. Of these deaths, 21 were career firefighters and 32 were volunteers. The seven remaining deaths were employees or contractors of federal land management agencies. Sudden cardiac death accounted for the largest share of fatalities with 29 deaths. 

There were 17 deaths at fire scenes (9 structure fires and 8 wildland fires). NFPA also reported that an unusually high number of firefighters (10) were struck and killed by vehicles. Two firefighters were killed and another injured by a drunk driver at the scene of downed power lines.

Guidance for improving and maintaining rescue team proficiency...

We have found that the one thing that seems to be a lagging factor is a "lack of proficiency" in performing the required skills either as individuals or as a team. Having rescue preplans, the newest and best equipment, sufficient manning, and reliable communications are all pieces of the puzzle. But all of that becomes nothing more than window-dressing if the team or individuals on the team are unable to perform their duties safely and effectively. This is such an important consideration that several regulations and standards make a point to remind us that proficiency is a high-interest issue. 

For instance, OSHA 1910.146 paragraph K and Appendix F, as well as 1926.1211, require designated rescuers to practice making permit space rescues at least once every 12 months by means of simulated rescue operations in which they remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. It is our position that this does not even come close to the training time needed to maintain an appropriate level of proficiency. 

Additionally, NFPA 1006 requires rescuers to demonstrate competency on an annual basis. One of NFPA’s recommendations is to attend workshops and seminars, read professional publications, and participate in refresher training as ways technical rescue personnel can update their knowledge and skills. 

I am routinely asked how often a rescue team should practice. And they're always a bit surprised when I do not give them a hard and fast answer such as quarterly or monthly for a minimum of 4 hours. My answer is and will always be, “as often as it takes to ensure you are proficient, as individuals and as a team, to safely and effectively rescue potential victims from any situation you may be called to respond.”

You would be amazed at the spectrum of training schedules that are out there. Some teams practice on a bi-weekly basis and mix in different scenarios to ensure they will not miss any opportunities to improve their skills or to identify any gaps they may have in technique or equipment. Whereas other teams may feel that once a year is all that they need. Knowing how perishable these skills are, we tend to disagree.

It has been our experience that the teams who practice on a very regular basis and really mix it up when they design their training scenarios are the ones who perform best when they come to our facility or we go to theirs for a team performance evaluation (TPE), which can also include an individual performance evaluation (IPE), if desired. The teams and individuals that struggle most during our TPE/IPE visits are the ones that seldom train. And, even though we all call these TPE/IPE visits, we do provide tips and spot training to help correct any deficiencies observed. 

But frequency is no guarantee of excellent performance. It isn’t just about the quantity of training; it must be the quality of training as well. One of the best ways to supplement in-house training is to attend third party refresher training. Or, if it has been a while since a full-on training class, by all means a more extensive and complete training package may be a great option. Roco's annual Rescue Challenge provides an excellent learning experience as well as a way to confirm the true rescue capabilities of your team. 

Technical rescue skills are one of the most perishable skills I have known. Without regular practice and quality training, it is not long before the individual and team skills erode to the point of becoming a liability to the victim and to other team members.

Again, none of us wants to fail - especially on a rescue mission. A good way to avoid this is to dedicate adequate resources to training along with regular refreshers and practice drills. Prepare and practice for your "worst case" scenarios because you just never know when your team may be put to the test. Be ready!

Federal OSHA and other OSHA State Plans do a good job of providing updates on newly recognized hazards in the workplace, as well as reminding us of existing hazards. We need to heed this information as it takes lessons learned the hardest way, and shares it for others that work in the same or similar environments.  No matter what industry our employees are performing their jobs, the fact remains, we are all humans and will suffer the same consequences of exposure to hazards no matter if we are in construction, general, agricultural, or any other industry. 

Often times there are significant differences in the OSHA regulations for identical hazards from one industry to another.  For instance, the height threshold for requiring fall protection in general industry is four feet, whereas the threshold in construction industry is six feet.  Are construction employees able to withstand the impact of a fall better than a general industry worker?  No, the main reason for the difference was due to the rules making process and dialog between OSHA and the industry stakeholders.

If you were to spend some time reading OSHA’s agricultural regulations, you will find that you won’t need much time.  They are pretty lean.  But there is one very important OSHA regulation that must be considered, and that is Section 5 (a)(1), General Duty Clause. 

If a recognized hazard is not addressed in an industry specific regulation, the General Duty Clause is there to protect the employees and the employer MUST comply with it.

For now, there are many instances in the agricultural industry that have no specific regulation addressing the various hazards and thus the General Duty Clause is very important to remember.

Confined spaces are areas large enough for a worker to enter and perform work, have a limited or restricted means of entry or exit; and are not designed for continuous employee occupancy. The following quote is from OSHA Fatal Facts publication No. 16-2018 and provides clear expectations for protecting employees where no specific industry regulation exists. The purpose of this Fatal Facts is to highlight the importance of identifying confined spaces in agricultural workplaces to prevent another fatality.

"The General Duty Clause requires employers to provide employees with workplaces, including confined spaces, which are free from recognized hazards likely to cause death or serious physical harm. Agricultural opera­tions are covered by several Occupational Safety and Health standards including Agriculture (29 CFR 1928) and parts of General Industry (29 CFR 1910), as well as the General Duty Clause of the Occupational Safety and Health Act (section 5(a)(1)). OSHA’s confined spaces standard at 29 C.F.R. 1910.146 does not apply to agricultural operations, but serves as a guide for how to prevent these accidents.”

Comments on this story were made by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

Resources:
Washington State DOL and OSH
Safety+Health Magazine

One of OSHA’s Agency Priority Goals is to reduce trenching and excavation hazards. According to the Bureau of Labor Statistics, excavation and trench-related fatalities in 2016 were nearly double the average of the previous five years. OSHA’s goal is to increase awareness of trenching hazards in construction, educate employers and workers on safe cave-in prevention solutions, and decrease the number of trench collapses.

OSHA plans to issue public service announcements, support the National Utility Contractors Association’s Trench Safety Stand Down, update online resources on trench safety, and work with other industry associations and public utility companies to create an effective public-private effort to save lives. OSHA’s trenching and excavation national emphasis program is also currently under revision. For more information on trench safety, visit OSHA’s safety health topics page.

Over the past few years, Roco has made trench safety a priority goal by dedicating more than 15 articles on this website as well as a podcast to trench-related subjects in an attempt to increase awareness for trench safety and rescue, just as OSHA is doing.

One area we have identified where facilities may be in violation is having personnel who are not “trench” competent persons sign off on trenches. Many times, the company representative is a “Confined Space Competent Person” or “Entry Supervisor,” and we are asking them to sign off that a trench shoring system is adequate when they have little or no training.

Just because you are competent person in one area does not mean you are a competent person in all of them. A confined space knowledge base is not the same as a trench knowledge base.

The OSHA Construction Standard Defines a Competent Person “as someone who is capable of identifying existing and predictable hazards in the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.”