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

As Director of Training, I get many questions about rescue techniques and regulations from our students and readers. In the past month alone, I have received three inquiries about "timely response for rescue teams" regarding permit required confined spaces (PRCS). So, let's break it down and try to clear the air on this subject. For clarification, we will refer to the General Industry Standard 1910.146; the Construction Standard 1926-1211; and the Respiratory Standard 1910.134.

In 1910.146, OSHA provides guidance on timely response in Subpart K (Rescue and Emergency Services) and again in Non-Mandatory Appendix F (Rescue Team or Rescue Services Evaluation Criteria). Subpart (k)(1)(i) states: "Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified."

This one sentence actually says volumes about response times. The first question to be answered is, "Can the rescue service respond in a timely manner?" It then gives a hint as to what a timely manner should be based on. The second part of the sentence refers to "considering the hazard(s) identified." What this so eloquently says is the response time must be determined based on the possible hazard(s). This means the "known and potential hazard(s)" must be identified for each space to be entered. The hazards discovered -- based on severity, type, how rapidly the hazard could become IDLH or injure the worker, how quickly the need to treat the injury, or how quickly hazards might interfere with the ability to escape the space unaided -- would then be used to determine an acceptable response time. This is why OSHA only alludes to response times and does not set hard and fast times to follow -- it depends on the hazards of that particular space.

Another aspect we need to consider is that "response time" begins when the call for help goes out, not once the team is on scene. It ends when the team is set-up and ready to perform the rescue. So, how long will it take your team to be notified, respond and set-up is a big portion of that acceptable response time calculation. For example, a dedicated onsite fire/rescue team would be able to respond faster than workers who have other responsibilities and need to meet at the firehouse before responding. Or, more quickly than an outside service, such as a municipal department, that would have to respond to the facility, get through the gate, and be led to the scene.

In the note to paragraph (k)(1)(i), it adds: What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA 1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

Here we see OSHA better defining an acceptable response time for IDLH atmospheres -- i.e., immediate action! However, it's important to note this doesn't just refer to low O2...depending on the type of contaminant in the atmosphere, other respiratory equipment such as half- or full-face APRs could be used. It may include a dusty environment where the entrant wears a mask and visibility is less than 5 feet. Technically, that would be considered an IDLH environment. Many people get hung up on the use of SAR/SCBA as the trigger for a standby team, and that is just not the case.

For an IDLH atmosphere where respiratory protection is needed, an adequate number of persons (rescuers) is required to perform a rescue from the type of space involved - ready, trained, equipped and standing by at the space -- ready to take immediate action should an emergency occur. So, when dealing with possible IDLH atmospheres, we are looking at "hands-on" the patient in 3-4 minutes as possibly being an appropriate response time. Basically, this is about how long an entrant can survive without air. The only way to safely make rescue entry in that time frame is to have rescuers standing by, suited up and ready to go!

So, if dealing with an IDLH atmosphere, we revert back to 1910.134. Many people think that that is the only time we need a team standing by ready to take immediate action. I pose the question, "If the hazard is a liquid (engulfment hazard), what would be a reasonable response time?" If the victim is Tarzan or Johnny Weissmuller (okay, Michael Phelps, for you younger people), we may have a longer stay-afloat time. But if a non-swimmer, or in an aerated solution or other engulfment hazard, immediate action may be their only chance of survival! And, what about radiation (time, distance, shielding)? I am sure you can think of a few more possibilities.

And, while OSHA referred to an IDLH atmosphere in this example, it's important to consider other IDLH hazards as well. Here's where we note that the definition of IDLH in the Respiratory Standard (1910.134) differs slightly in Permit-Required Confined Spaces (1910.146). The Respiratory standard specifically refers to an IDLH "atmosphere" while the PRCS standard states the following: Immediately dangerous to life or health (IDLH) means any condition that poses an immediate or delayed threat to life or that would cause irreversible adverse health effects or that would interfere with an individual's ability to escape unaided from a permit space. This includes more than simply atmospheric hazards! 

OSHA NOTE: Some materials -- hydrogen fluoride gas and cadmium vapor, for example -- may produce immediate transient effects that, even if severe, may pass without medical attention, but are followed by sudden, possibly fatal collapse 12-72 hours after exposure. The victim feels "normal" until collapse. Such materials in hazardous quantities are considered to be "immediately" dangerous to life or health.

In Non-Mandatory Appendix F (I hate that non-mandatory language), OSHA gives guidance on evaluating response times under Section A - Initial Evaluation. What are the needs of the employer with regard to response time (time for the rescue service to receive notification, arrive at the scene, and set up and be ready for entry)? For example, if entry is to be made into an IDLH atmosphere, or into a space that can quickly develop into an IDLH atmosphere (if ventilation fails or for other reasons), the rescue team or service would need to be standing by at the permit space. On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions) a response time of 10 or 15 minutes might be adequate.

Not a bad paragraph for a non-mandatory section of the standard! Here they explain what they are looking for in regards to response times. They even take the OSHA 1910.134 IDLH atmosphere requirement for a team standing by at the space a little further by adding "or into a space that can quickly develop into an IDLH atmosphere." It also states if the hazard is mechanical in nature, 10-15 minutes might be adequate. That’s right, "might" not will be, but might be. Again, it depends on the hazard.

Paragraphs 2-7 in Appendix F goes on to describe other conditions that should be considered when determining response times such as traffic, team location, onsite vs. offsite teams, communications, etc. If you have not done so, I highly recommend that you review the not-so-Non-Mandatory Appendix F. It is also important to note that while it's not mandatory to follow the exact methods described in Appendix F, meeting the requirements are! OSHA also uses the word "should" in Appendix F, not following the OSHA recommendations could certainly lead to some hard questions post incident.

OSHA 1926 Subpart AA Confined Spaces in Construction closely mirrors 1910.146. In this relatively new standard, they simplified the definition of timely response and omitted Non-Mandatory Appendix F, which helps to eliminate the confusion of the "non-mandatory" language, and included the requirements right in the standard, which is good. However, 1910.146 really gives you a better idea of what timely would be for different situations through the notes in Section (k) and Appendix F.

Section 1926.1211 of the Construction Standard for Rescue and Emergency Services (a)(1) states: Evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. This is immediately followed by: Note to paragraph 1926.1211(a)(1). What will be considered timely will vary according to the specific hazards involved in each entry. For example, OSHA1926.103, Respiratory Protection (for construction) requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.

In closing, these regulations are driving you in the same direction for identifying what a timely response would be...THERE IS NO SET TIME FRAME! Each space must be evaluated based on potential hazards and how quickly rescue would need to take place. I hope this will make you take a closer look at "how and what" you consider a timely response. An employer's PRCS program must identify and evaluate the rescue resources to be used. It is then up to the entry supervisor to make sure the identified rescue service is available to respond in a timely manner, which can literally mean life or death for the entrants.

The following article was written by Russell Warn and published in ISHN magazine (ishn.com), December 2016. Roco comments have been added to the article and are noted in red.

Working in confined spaces presents a unique and dangerous challenge in combatting the unseen – oxygen deficiency, poisonous or explosive gases, and other hazardous substances are among the most frequent causes of accidents associated with work in confined spaces and containers.

From 2005-2009, the Bureau of Labor Statistics reported nearly two deaths per week, or roughly 96 per year, could be attributed to confined space, with about 61 percent occurring during construction repair or cleaning activities.

With conditions subject to change in a moment’s notice, taking steps to protect against life-threatening dangers should always be a top priority in confined spaces. Performing a thorough clearance measurement is a demanding — yet crucial — task that dictates the safety environment, and should not be taken lightly. To help guide you along your road to enhanced safety, outlined below are several best practices based on frequently asked questions.

When should I perform a clearance measurement?

Conduct clearance measurements immediately before operations begin. Environmental factors such as temperature and air flow can change the atmosphere, causing readings to fluctuate. One shift’s measurement taken at 7 a.m. is not representative of the conditions when work operations commence for another shift at 4 p.m. New clearance measurements must be taken immediately to account for the nine hours of changing temperatures and ventilation patterns, depicting the accurate readings of present conditions.

Roco Comment: In addition to pre-entry clearance measurements, entry into permit spaces during construction activities requires "continuous atmospheric monitoring" unless the entry employer can demonstrate that equipment for continuous monitoring is not commercially available or periodic monitoring is sufficient. Ref. 1926.1203 (e)(2)(vi), 1926.1204 (e)1)(ii), and 1926.1204 (e)(2). Additionally, Roco believes that for "ALL" permit entry operations, it is advisable to provide continuous atmospheric monitoring no matter what the industry activity entails.

What’s the importance of zero-point adjustment?

When performing clearance measurements, it’s crucial to determine the reference point of the gas detector by calibrating the zero-point. The zero-point ensures that the indicated values correspond to the actual existing gas concentrations. In order to determine that the actual zero-point has been found, calibrate equipment in an environment where the hazardous substance is not present, such as fresh air environments. With every scientific test, no matter the field, a control group, which serves as a starting point of reference, permits for the comparison of results to show any contrasting changes. The zero-point calibration acts as such, allowing workers to identify the presence, or lack thereof, of different gas concentrations.

Where do I measure/take the sample?

When it comes to measuring samples, there are four things to keep in mind: the physical properties of gases, and the type and shape, temperature and ventilation patterns of the confined space.

Know the differences between light and heavy gases. Clearance measurement experts must have a strong working knowledge of hazardous substances’ properties, as they play a role in where measurements should be taken. For example, if a sample is pulled from the top of the confined space and hydrogen sulfide (H2S) is detected, the sample may not be entirely reliable. H2S has a molar mass of 34 g/mol, which is significantly heavier than that of air (29 g/mol). As a result, H2S sinks to the bottom of a space, where its concentration would be greatest. Identifying a presence at the top of the confined space says immediate danger and appropriate actions should be taken.

Light gases quickly mix with air and rise to the top. As a result, any measurements in open atmospheres should be performed close to the leak, and increases in concentration should appear in the highest points of the confined space. Heavy gases, on the other hand, should sink and flow like liquids, pass obstacles or stick to them. They barely mix with air like light gases do, so their samples should always be taken at the lowest points of the confined space.

Determine the type/shape of the confined space: In an ideal scenario, each confined space area would be in an “even” or level position. This isn’t always the case, and a container may be placed on an inclined surface, making the highest point in the corner positioned toward the top of the inclined surface. Thus, entry may be nearer to where the heavy gases have accumulated.

Take tabs on temperatures. All matter is made up of atoms and molecules that are constantly moving. When heat is added to a substance, such as a gas, the molecules and atoms vibrate faster. As the gas molecules begin to move faster, the speed of diffusion increases. If the sun has been shining on a tank for hours, there’s a good chance the clearance measurement taken at dawn no longer reflects the current readings due to the increase in diffusion.

Vet the ventilation. Air currents change the position and concentration of air clouds, and often times, the way a confined space is ventilated can affect readings. Containers cannot always be separated from pipelines, or there may be leaks in the tanks that must be accounted.

Roco Comment: Not only is it required by certain OSHA provisions like alternate entry procedures, but Roco highly recommends monitoring the atmosphere prior to initiating ventilation. This is intended to provide a reasonable assessment of the potential atmosphere change should the ventilation equipment fail. The rate for a potential hazard to re-develop will be based on factors such as the effectiveness of isolation, any residual product within the space, temperature, humidity and passive ventilation which are among just some of the factors.

How do I safely conduct the measurement for an accurate reading?

People often question why they can’t just use the carrying strap of their device to lower the device into the confined space for a reading. Although this seems like a simple fix, it’s not a safe or recommended way to conduct the measurement. Lowering the device into the container this way not only obscures the way the display is read, but it may not audibly alarm. If the measured value is slightly below the threshold value and the alarm does not sound, a worker would not be notified of the dangerous concentrations lurking below. Not only this, but measurements may be inaccurate since the measured gases, due to their molar masses, may be concentrated at a higher or lower point within the container. Clearance measurements should be conducted on-site and on-the-ground of the confined space for accurate, safe readings.

Roco Comment: The points made in the preceding paragraph are certainly valid. The best solution that we can offer is to use remote sampling probes or tubes to actively draw (pump) samples from the stratified levels of the space while the direct reading instrument is in a position outside the space to observe the real time readings. To expound upon the point the author makes, if the pre-set threshold for the alarms are not enough to trigger the alarm indicating the presence of a hazardous atmosphere, and the individual performing the assessment relies instead on rapidly pulling the monitor from the space in the hope that they are able to read the display before the values change, is a very dangerous way of approaching this procedure. Depending on the sampling rate of the monitor, the hazardous gas(s) may have cleared from the monitor in the time it takes to withdraw it from the space, and it is very likely that the instrument will display a normal atmosphere by the time it is back within view. Additionally, for areas within the space that cannot be remotely assessed by remote sampling prior to entry, the only safe recourse is to limit entry to the areas that have been assessed and to take a monitor into the space to continuously assess the unreachable regions before venturing further.

What do I need to document during clearance measurement protocols?

Just as it’s important to remain thorough in clearance measurements procedures, it’s equally as important to remain thorough in the general housekeeping protocols surrounding samples. This includes documenting:

• • The container number
• • The measuring point of the container, and whether there was more than one measuring point
• • At which time was the clearance performed
• • Under what condition was the measurement performed
• • Measured hazardous substances
• • Name of person performing measurement
• • Equipment used for clearance

Safety, regardless of job title or responsibility, should be everyone’s top priority. When working in the midst of poisonous and explosive hazards, performing clearance measurements correctly and carefully means not only keeping one’s self safe, but keeping the working environment safe, as well.

About the Author:
Russell Warn is the product support manager for gas detection products at Dräger. He has been in the safety industry for more than 29 years, with most of this time dedicated to gas detection product and application support.

As shown in this photo, an engulfment scenario was featured at last year's Rescue Challenge. Be aware...it only takes 5 seconds for flowing grain (or other product) to engulf and trap a worker.

In 60 seconds, the worker is submerged and is in serious danger of death by suffocation. More than half of all workers engulfed die this way. Many others suffer permanent disability.

OSHA has recently issued further warnings on the dangers of working in grain or bulk storage facilities.

An "engulfment" often happens when "bridged" grain and vertical piles of stored grain collapse unexpectedly. Engulfments may occur when employees work on or near the pile or when bin augers whirl causing the grain to buckle and fall onto the worker. The density, weight and unpredictable behavior of flowing grains make it nearly impossible for workers to rescue themselves without help.

"Far too many preventable incidents continue to occur in the grain-handling industry," said Kim Stille, OSHA's regional administrator in Kansas City. "Every employee working in the grain industry must be trained on grain-handling hazards and given the tools to ensure they do not enter a bin or silo without required safety equipment. They must also take all necessary precautions - this includes using lifelines, testing the atmosphere inside a bin and turning off and locking out all powered equipment to prevent restarting before entering grain storage structures."

In 2016, OSHA has opened investigations of the following grain industry fatalities and incidents:

• March 16, 2016: A 42-year-old superintendent at Cooperative Producers Inc.'s Hayland grain-handling site in Prosser, Nebraska, suffered fatal injuries caused by an operating auger as he drew grain from a bin. OSHA cited the company on Sept. 9, 2016, for three egregious willful and three serious violations and placed the company in its Severe Violator Enforcement Program. The company has contested those citations. See news release here.
• March 22, 2016: A 21-year-old worker found himself trapped in a soybean bin, but escaped serious injury at The Farmer's Cooperative Association in Conway Springs, Kansas. Rescue crews were able to remove the worker and he was treated and released at a local hospital. On June 2, 2016, OSHA cited the company for 13 serious violations.
• March 25, 2016: A 51-year-old employee was trapped in a grain bin at McPherson County Feeders in Marquette, Kansas. Emergency crews were able to rescue him. OSHA cited the company for four serious violations on April 14, 2016.
• May 19, 2016: A 53-year-old male employee at Prinz Grain and Feed suffered severe injuries on May 18, 2016, as he worked in a grain bin in West Point, Nebraska. The maintenance worker was in a grain bin when a wall of corn product collapsed and engulfed him. He died of his injuries two days later.
• Sept. 1, 2016: A 59-year-old employee suffered severe injuries to his leg when the sweep auger inside a bin at Trotter Grain in Litchfield, Nebraska, caught his coveralls.
• Sept. 19, 2016: A 28-year-old employee of the Ellsworth Co-Op in Ellsworth, Kansas, had his left leg amputated when he stepped into an open auger well inside a grain bin while the auger was running.

"It is vital that we work with leaders, farmers and those employed in the grain and feed industry to increase awareness of hazards in the grain industry and discuss ways to protect workers on the job," stated an Omaha OSHA official.

We add that it’s critically important for emergency responders to be aware of the dangers they may face in bulk storage facilities. In addition to engulfment, there’s also the risk of dust explosions as well as entrapment from moving mechanical equipment.

Does a competent person inspect your rescue equipment each year?

If not, you may want to consider having an independent third party perform the inspection for you. This service is offered by Roco as a stand-alone service, or it can be added to your next private training session. 

Functional Ops Check

The service includes a “sight and touch” functional inspection of hardware, nylon products (including rope, webbing, and anchoring components), harnesses, and accessory equipment (including litters and stretchers) utilized in confined space/high angle applications. The inspection will be conducted in accordance with manufacturer’s specifications and will satisfy the requirement for an annual² inspection by a competent person.
Note: Equipment recommendations will NOT be provided by inspection personnel unless requested to do so.

Service Inspection Benefits include:

• Certified personnel to inspect equipment to manufacturer's standards.
• Inspection documentation from an independent third party.
• Frees your personnel from the responsibility of equipment inspections.

A full report of findings will be provided to include accessibility of equipment to responders and any other recommendations to improve overall team performance. It will include other pertinent information such as the manufacturer, product number, and serial/lot number (where applicable), date of manufacture, and in-service date (when available). It will also include the results of pass/fail testing for both visual and functional inspection. All equipment deemed unsuitable for use will be tagged for removal from service.

Regardless of the stated service life, the condition of equipment – as determined through inspection by a qualified party – is a key factor in determining whether or not a piece of equipment is fit for service.

Although the definition of “equipment lifespan” is very broad depending on the manufacturer, each provides specific instructions on proper inspection of equipment and detailed explanations on when to retire the service item. Several general identifiers that pertain to all equipment are shown below.

Reasons for Equipment Retirement include:

• Item fails to pass any pre/post use or competent person inspection.
• Item has been subjected to a major fall or load.
• Item is constructed of plastic or textile material and is older than 10 years.
• You cannot determine the complete full-use history of item.
• You are not certain or have lost confidence in the equipment.

As a reminder, it is very important to keep the manufacturer’s instructions when purchasing new equipment. This is vital to identifying and keeping track of the manufacture date as well as other important information. For example, if the manufacture date of equipment, such as life safety rope and harnesses, cannot be identified; it can pose extreme liability for agencies or facilities whose teams may potentially be operating with equipment that has passed its service life. It could also create a compromise in the safe operation of the equipment.

A 10-year service life for nylon/polyester products is set according to ASTM F1740-96 (American Society for Testing and Materials).

Inspect Rescue Equipment Every Time It’s Used

All team members should be qualified and knowledgeable enough to perform pre- and post-use inspections of equipment. It is crucial that all members document each use of equipment, denote any deficiencies, and report to the proper person. One person should be designated to perform the competent person annual inspection. This person should have complete knowledge of the equipment and inspection procedures as well as the authority to keep or remove equipment from service as they see fit. If team members are unable to fill this role, a qualified third party with applicable manufacturer certifications in competent person inspection should be utilized to assist in determining the condition and estimated service life of rescue equipment.

Download Roco's Quick Checklist for your convenience. →

Rescue team members are encouraged to attend this inspection where they will receive information on proper pre- and post-use inspections for their equipment. Guidance can be also offered in areas of equipment care, inspection, record-keeping, and proper storage. Again, equipment recommendations will not be addressed unless specifically asked to do so – this is only an inspection of the equipment you currently have on site.

Remember, with rescue gear, lives are literally “on the line,” – if in doubt, throw it out!

To schedule your Roco Competent Person Inspection, or add it to your current training dates, call us at 800-647-7626 or email info@rocorescue.com. Roco offers this service at no charge for current customers or for a very nominal fee for non-customers.¹

¹ Current customers receive a one-day equipment inspection at no charge. Travel expenses apply for out-of-town customers.

² References include: 1926.502 Appendix C; ANSI Z359.2 Section 5.5.2 Inspections; ASTM Rope Inspection Guide; NFPA 1983 Section 5.2; ANSI Z359.11 Annex A (harnesses); and ANSI Z359.4 Section 6.1.

NOTICE: The client remains responsible for ensuring that all guidelines and requirements for maintaining and, where indicated, removal of equipment from service, are followed. This includes removing equipment from service anytime there is a situation or incident that occurs during handling, training, or rescue, that might have caused damage or otherwise compromised the integrity of the equipment, particularly where internal damage that is not visible might be present (e.g. equipment dropped from height, exposure of nylon products to chemicals or other potentially degrading substances, etc.). Client will be required to complete a certification that between Roco inspections, the equipment was properly stored, was available only to personnel trained to use the equipment properly, and that any equipment that was exposed to any condition or occurrence that could have resulted in hidden damage has been removed from service. A company representative, preferably someone from the rescue team, must be present during the inspection process.

Roco is excited to be conducting several Rescue & Fall Protection Workshops at the 44th Annual Safety Conference next month in Bismarck, ND. This will kick off our working relationship with the ND Safety Council to provide safe, effective confined space rescue training for their membership. 

What's more, the North Dakota Safety Council (NDSC) is currently constructing a new safety campus in Bismarck that will house a 5,000 square foot hands-on training lab. Roco, as a training partner, will provide high-level technical rescue courses at this new facility on a year-round basis.

For the conference on February 20-23, we will be conducting a number of hands-on rescue workshops and presentations to be presented by Roco Lead Instructors Dennis O’Connell, Pat Furr, Brad Warr, Eddie Chapa and Josh Hill. Sessions include:

• Intro to Competent Person Requirements for Fall Protection
  2/20 9am-6pm (classroom w/demo)
• Confined Space Entrant, Attendant, and Supervisor Requirements
  2/20 9am-6pm (classroom w/demos) 
• Tripod Operations
  2/21 11am-5pm (hands-on training) 
• So You’ve Fallen, Now What?
  2/22 10am-11:30am (classroom)
• Dial 911 for Confined Space Rescue
  2/22 1:30pm-2:30pm (classroom w/demos)
• Confined Space and Rope Rescue...
  2/22 1:30pm-5pm (hands-on training) 
• Trench Collapse Rescue Considerations
  2/22 2:45pm-3:45pm (classroom) 
• Fallen/Suspended Worker Rescue
  2/23 8am-11:15am (classroom w/demos) 
• We look forward to meeting you at Roco booths (#202 & #203) or in these training sessions. For more info, click to NDSC’s 44^th Annual Safety & Health Conference. Don't forget to register online at www.ndsc.org for these training sessions.