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.”

Now that NFPA 1006 Standard for Technical Rescue Personnel Professional Qualifications (2017 edition) has been in place for a while, it’s a good time to revisit the changes that have been made. While we won’t go into every single change from the previous 2013 edition, we will cover some of the more significant ones – particularly for the specialty areas that we deal with most.

So, let’s get to the big changes right off the bat. As you are probably aware, there was a big disconnect between NFPA 1006 and NFPA 1670 Standards on Operations and Training for Technical Search and Rescue Incidents. While there are technical committees for the development of both 1006 and 1670, very few committee members sit on both committees. The need for a correlating committee became apparent, and it is that correlating committee that coordinated and at times arbitrated changes to both standards in an effort to marry them up.

For example, NFPA 1006 Levels I & II have been replaced with Awareness, Operations and Technician levels to correlate with 1670 performance levels. This change may seem minor, but it allows for (and provides guidance in) training auxiliary personnel to a level of competency to support the Technical Rescue Team. This is reflected in the title change of 1006 from “Standard for Technical Rescuer Professional Qualifications” to “Standard for Technical Rescue Personnel Professional Qualifications.”

This change provides the option to train a team to a level for handling less technical incidents and still meet the standard for that level of proficiency. It also allows for a level of competency to begin a rescue effort while awaiting a more technically trained and equipped team to respond. This aids teams that do not have the manpower, equipment or funding to train to the Technician level by providing performance goals for Operations and Awareness levels.

NFPA 1006-2017 has also added several new specialty areas to include: Floodwater Rescue, Animal Rescue, Tower Rescue, Helicopter Rescue, and Watercraft Rescue. Several new definitions have been added to correlate with NFPA 1670. Clarification is provided by further defining dive operations, search, watercraft, wilderness, and other terms. You will also find that the word “search” (as used in the title of 1670) has been incorporated into many of the specialty areas of 1006 – another attempt to better correlate the two standards.

Again, we have attempted to highlight some of the key changes in NFPA 1006-2017. We think the modifications will make it easier to understand what is required of technical rescuers as well as auxiliary support personnel. As always, we encourage you to read the standard in its entirety. If you have any questions, please call us at 800-647-7626.

There continues to be a misconception that a confined space attendant (or “hole watch”) is a menial task to be assigned to the greenest, most inexperienced personnel on the job. That’s a dangerous assumption, and it has been a contributing factor in many confined space fatalities.

In fact, the attendant or hole watch should have a solid understanding of the permit space to be entered. This includes knowing the particulars of any known or potential hazards as well as other pertinent knowledge and skill sets. If you are assigned this crucial role, I hope you understand that the entrant(s) are relying on you. Your performance may have a significant bearing on the outcome, both good and bad.

Do you know everything you need to know in order to perform your duties as a confined space attendant? Don’t assume that you will learn everything you need to know after a two- or three-minute pre-job briefing.

Being an attendant or "hole watch" is a critically important role and failure to properly perform these duties has led to multiple fatalities – both for the entrants and the attendants themselves.

Do understand the known and potential hazards of the confined space. Do take the time to review the SDS (MSDS) for any and all materials or gasses that may be encountered. Do learn what the signs and symptoms of exposure may be. Then, if you detect any of them in the entrant’s behavior or appearance, you can order immediate evacuation.

Don’t gloss over this valuable and readily accessible information only to wonder what caused the entrant(s) to lose consciousness. The SDS (MSDS) provides information on route of exposure; and very importantly, the signs and symptoms of exposure. Don’t miss the opportunity to save the day, and perhaps a life, by learning these early warning signs. This allows evacuation of the space before entrants are no longer able to do so on their own.

Do learn the proper operation of any testing equipment, such as atmospheric monitors. It is also important to understand the limitations of this equipment as well.

Do keep track of all authorized entrants in the space. For entries with multiple entrants, don’t rely on your memory alone. Do use some sort of log or entry roster as a reliable means to accurately identify who is in the space.

Do make sure that you have a reliable means to communicate with the entrants. Do test that means of communication at the very limits of the space to ensure it works. Don’t wait until there is an incident to learn that you cannot alert the entrants, or you cannot hear that their status has changed. If you haven’t heard from the entrants in a while, it can be tempting to go into the space to check on them. This very situation has led to many fatalities in which the attendant was overcome by the same hazard as the authorized entrant(s). At that point, there is no longer anyone available to call for help.

Don’t accept the job assignment until you have been briefed by the entry supervisor on all the planned activities both inside and outside the space. Do remember that oftentimes activities outside the space can create a hazard for the entrants inside the space. Carbon monoxide and spills of hazardous materials are just a couple of examples.

Don’t allow any activities to take place inside or outside the space that are prohibited and are not consistent with the conditions stated on the entry permit, especially if they may create a hazard to the entrants. If those activities were not coordinated and told to you by the entry supervisor, do evacuate the space and call the entry supervisor for guidance.

Don’t leave the space or perform other duties that may interfere with your primary duty of monitoring and protecting the entrants.

Do remain diligent, remember that you are the critical link between the entrants and the rescue service.

Do know how to contact rescue services should they be needed. Don’t wait until it is too late to call for help. Do summons rescue as soon as you determine that the entrants may need assistance escaping from the space. Just remember, you can’t turn back the clock and buy back the time that entrants may have needed to survive. It’s a whole lot easier to turn around the rescue service if it is not needed.

Don’t allow unauthorized persons to approach or enter the permit space. If you are unable to warn them away, do order the evacuation of the authorized entrants. Do immediately inform the entry supervisor of the situation.

Do perform non-entry rescue (retrieval) when needed and if authorized by your employer. Do perform a thorough pre-entry inspection on the retrieval rescue equipment. Do make sure it is appropriate for the type of rescue that may be needed. Do learn and practice the proper operation of the retrieval equipment. Don’t wait until there is an emergency to try and figure it out. Don’t attempt entry rescue unless you are authorized, trained and equipped to do so. Don’t attempt entry rescue until you are relieved by another authorized attendant. Remember, you cannot leave the space unattended!

Don’t take your responsibilities lightly. Do ask the right questions of the entry supervisor and your authorized entrants. Do realize that they are all counting on you. Do ask to be briefed by the entry supervisor regarding any coordination that has been made with other work groups in the area. Do remember that many attendants have perished attempting heroic but ill-advised and unauthorized rescue attempts.

Do remember that your authorized entrants are relying on you. Do take the initiative to learn everything you need to know and how to operate any equipment in support of your entrants. As the hole watch, you are the critical link that can make or break a successful entry operation.

Written by Pat Furr, Safety Officer & VPP Coordinator for Roco Rescue, Inc.

Additional Resources

• Attendant Safety Requirements Poster (pictured here)
• Confined Space Entry Checklist
• Common Causes of Confined Space Fatalities
• Limitations of Atmospheric Monitors

 

 

By Dennis O'Connell, Roco Director of Training & Chief Instructor

I am often asked by plant managers or rescue team supervisors about getting their team on the right track as far as training and competency is concerned. Here are a few tips for doing just that…

First of all, I always recommend that they choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) adds to the confusion of team members as to what techniques and equipment are being used – especially during a real rescue!

I then suggest that the team’s training records be reviewed in order to determine what level of training has been completed. I also strongly recommend getting everyone to the same level; especially if your facility is what I refer to as an “island unto itself.” In other words, do you have nearby facilities or other local agencies who can offer additional manpower, equipment, etc. in an emergency – or, are you fairly isolated?

Same Page, Same Language
If your facility is somewhat isolated, getting all your rescue team members on the same page, talking the same language, and at the same level of training is extremely important. You may have some experienced rescuers who have completed a variety of courses from different providers and are trained to different levels. Is this previous training properly documented should you be asked about it and to what levels? Having everyone on the same level – with the same basics under their belt – is key to performing a timely and successful rescue
And, do you have a particular goal or level you want your team to strive for, achieve, and maintain? Determining your overall goal for the team is significant in planning for and achieving results. Haphazard training “just for the sake of training” is not necessarily a good thing, and it tends to generate complacency among team members. Besides the obvious, your team “needs to be able to perform a rescue should the need arise.”

Is It Documented?
Take a look at how the training was conducted, documented and what standards were met, if any. And, if you have permit spaces or personnel working at height, I’m assuming that OSHA compliance is a given, but what about meeting requirements of the National Fire Protection Association (NFPA) for rescuers; namely, NFPA 1006 and 1670.

If there is an incident and OSHA or some other regulatory organization were to investigate, how would you provide the documentation that your team is capable of doing what is required of them? Remember, if it can’t be documented, it doesn’t exist!

Using NFPA 1670 (“team” standards) and NFPA 1006 (“individual rescuer” standards) as a basis for the team’s training level will help to provide the needed documentation and add to the credibility of your team’s capabilities. Ideally, all your team members should be certified to the Confined Space Rescue Technician level (NFPA 1006) along with the documentation to back it up.

Because NFPA’s Confined Space Rescue Technician includes confined space and high angle (elevated) rope techniques, I don’t necessary suggest that industrial clients be required to achieve “Rope Rescue Technician.” The added skills of Rope Rescue Technician include less-seldom-used techniques in industrial rescue such as rope ascension and traverse. Do make sure, however, that the course you choose for Confined Space Rescue Technician incorporates some (not all) of the high angle skills you would need to perform elevated rescue at your site.

A Mix of Confined Space and Rope Rescue
If you have a variety of experience and training levels among your team members, it’s important to get them consistently trained and all trained to the same level. Of course, I would recommend Roco’s Fast Track 80™ course, which includes a two-year certification. This course was designed to meet the needs of industrial facilities with a mix between “confined space” and “rope” technician skills needed. The class is geared for confined space rescue with some of the additional rope technician skills needed for elevated or high angle rescue. The class efficiently gets the rescuer to the Confined Space Rescue Technician level in only 80 hours using both performance-based and written testing.

Of course, the next challenge is getting the entire team trained to the same level. It’s not going to be easy to get an entire team released for training all at once – thus compromising the availability of rescue personnel onsite should an emergency arise. Therefore, you may have to run a couple of classes to get everyone certified – or send some of your team (or new team members) to an open-enrollment course.

Testing to the NFPA 1006 Professional Qualifications standard is conducted on the last day of the Fast Track 80™ class. Note: If some of your personnel have already completed this class, they can join the class for the last four days in order to be recertified. This will allow the new members and more experienced team members to work together in realistic practice scenarios. It will help get everyone on the same page as far as techniques plus give the experienced personnel a 3-day refresher and practice time before re-certification testing.

Training Cycle for Compliance
Once all team members are trained to the same level, I recommend going to a two-year rotation. For example, once everyone is certified, the next year would be a Roco Team Performance Evaluation (TPE) where we come for two-to-three days and run teamed-based evaluations using multiple rescue scenarios. Each scenario is critiqued by evaluators to adjust any problems found along the way. The TPE would be followed by a written report to document the scenarios conducted as well as discrepancies found and corrected. The following year would be Re-certification to NFPA 1006 (three-to-four-day session) that includes Individual Performance Evaluations (IPE) where team members would refresh personal skills as well as run several scenarios before testing for re-certification to Confined Space Technician level.

This rotation will help with OSHA compliance by meeting the minimum annual practice requirements as well as by providing a performance evaluation of rescue services as stated in Note to paragraph (k)(1) from 1910.146: “Non-mandatory Appendix F contains examples of criteria which employers can use in evaluating prospective rescuers as required by paragraph (k)(1) of this section.”

In addition, both OSHA 1910.146 and 1926.1211 require timely and capable rescue services for permit spaces. They also require minimum annual rescue practice in the applicable types of confined spaces as well as proficiency for team members. This cycle of training works well in documenting that you have met these minimum requirements while also meeting the requirements of NFPA.

The TPE supporting documentation also provides a “snapshot” of where your team and its individual rescuers stand in terms of competency. 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.

I hope these recommendations are helpful in planning for the success of your rescue team – especially when it’s all on the line during an emergency situation. If you have any questions, don’t hesitate to call me at 800-647-7626 or send an email to info@rocorescue.com.