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.

Whenever I go out into the field for a rescue stand-by job, I always take note of the attendant. I will always talk to them in order to try and gauge this person’s level of knowledge about confined spaces in general as well as the particular entry that is being made. Unfortunately, more often than not, I discover that this worker has very little experience or very little training in confined spaces. Most of these workers tend to be the “low-man” on the work crew and seem to just be “thrown” in to that position. A lot of the facilities and contractors seem to have the attitude that anyone can be the “hole-watch.” This can be the major ingredient in a recipe for disaster.

When OSHA created the Confined Space Regulation (29 CFR 1910.146) they included a list of the “roles and responsibilities” of the Entrant, Attendant and Entry Supervisor. A cursory glance at the responsibilities of the attendant paints a picture of someone who is acutely tied to the overall safety of the operation.

These are some of the highlights of the attendant’s duties:

• Know the hazards that may be faced during the entry, as well as the effects of those hazards
• Monitor conditions inside and outside of the space
• Call for the evacuation of the space in the event of an emergency or the detection of a prohibited condition

When you look closely at these duties, you’ll see that this is a lot more than just some “body” standing outside of the space. For example, in order to monitor the conditions inside a space, most attendants are handed a two- or four-gas air monitor and sent out to the space to “sniff” the air inside. The untrained or inexperienced “hole-watch” will likely not be aware of the numerous things that can affect the atmospheric testing results. Things such as the techniques used to calibrate the monitor, or the oxygen content of the air, or the concentration of certain gases can all skew the readings of a monitor. I have also seen, on at least two occasions, a ventilation fan being placed within a few feet of a bank of gas-powered welding machines. In one case, the carbon monoxide readings inside the space reached a high enough level to actually set off the alarms on the atmospheric monitor. These are things that unqualified workers are simply not going to know about.

Not only do the attendants out in the workforce need to be better trained, they also should be brought into the planning phase of the entry operation. The attendant should attend pre-job meetings as well as assist in the process of making the space safe for entry. In one entry that I witnessed about 10 years ago, a very well qualified attendant was present. The entry was into an underground vault that housed a large water main. The entrants were installing a new valve into the system. Because the attendant had helped shut down and isolate the space, he was familiar with the system in general. Once the repairs to the valve were completed, a call was made to re-pressurize the line in order to make sure there were no leaks present. The attendant ordered the entrants to exit the space while the pipe was brought up to pressure. The entrants argued that they needed to be there to tighten up any leaks that might develop, but the attendant was adamant that they leave the space. As the pressure in the line climbed higher, it ruptured and the entire vault filled with water in about 30 seconds. It happened so fast that no amount of pre-rigging for rescue would have saved the two entrants.

A well-qualified attendant can have a definite impact on the entire project. It is unfortunate that many times they are looked at as just some person standing outside the space – instead of a key component in the overall safety of the entry operation.

Additional Resources

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

 

 

As with all rescue equipment, it’s extremely important to inspect your equipment before and after each use according to the manufacturer’s recommendations. Here are some tips from Skedco for inspecting your Sked Stretcher.

For the Sked Body: Do a visual inspection of the plastic. If there are cuts that go completely through the plastic (especially at the edges or the grommets), it should be   taken out of service and replaced. This is a very rare occurrence. If the plastic is wearing thin and preventing the Sked from retaining its shape, take it out of service.

Check all brass grommets. If they are badly bent or coming apart, they should be changed. This may also require sewing a new strap into it. Grommets can be replaced inexpensively by parachute riggers or any awning shop. When it is done, be sure the grommeting tools do not cut the inside of the grommet. Grommets that are sharp inside can cut webbing or rope.

Check all straps for broken stitching, discoloring (usually white), and fraying. If straps are badly frayed, discolored or if ten (10) or more stitches are broken, replace the straps.

Horizontal lift slings: Check for excessive wear, broken stitches or severe discoloration. If these conditions are found, replace the slings.

Vertical lift slings (3/8 static kernmantle rope): Check for severe discoloration and soft or thin spots. Thin spots that are soft indicate damaged core. If found, cut the rope at that point and take it out of service.

All other webbing products should be inspected in the same way as the slings and Sked straps.

The carabiner should work smoothly when the gate is opened and closed. Check for alignment. Check the hinge pin for looseness. The lock nut should work smoothly without hanging up at any point. Failure at any of these points requires replacement. A poorly functioning carabiner should be broken or destroyed to prevent others from using it by mistake.

If you have any doubts, call Skedco for assistance.

How often have you heard the statement “I will just call 911 if we have a confined space emergency”?  Let’s dispel some common myths and misunderstandings regarding confined space rescue compliance.

In accordance with OSHA 1910.146 (d)(9) an employer that will have personnel entering Permit Required Confined Spaces at their workplace must “develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue.

Meeting this requirement can be accomplished in several ways…

    - Develop an in-house rescue team made up of host employees.
    - Contract with an outside third party rescue team.
    - Coordinate with local emergency services (“911”).

Whatever way an employer chooses, there are specific evaluation criteria that must be met according to 1910.146 (k)…

1. The rescue team must be capable of responding in a timely manner and reaching the victim(s) within an appropriate amount of time based on the hazards of the confined space.  On-site teams (in-house or third party contracted teams) are generally better able to meet this requirement.
2. The team must be equipped and proficient in performing the type(s) of rescue that may be encountered.  Can they walk the walk, or just talk the talk?
3. The employer shall ensure at least one member of the rescue team is currently certified in CPR/First Aid.
4. The employer shall also ensure that the designated rescue team practices making permit space rescues at least once every 12 months from the actual spaces or representative spaces in regards to opening size, configuration, and accessibility. Representative spaces shall simulate the types of permit spaces from which rescue is to be performed.

Non-Mandatory Appendix F – Rescue Team/Rescue Service Evaluation Criteria

These are some but not all of the requirements of an initial and periodic performance evaluation of the rescue team:

1. At a minimum, if an offsite rescue team is being considered, the employer must contact the service to plan and coordinate the evaluation of the team based on 1910.146 (k).  Merely posting the service’s phone number or planning to rely on “911” to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.
2. Can the rescue team respond in an appropriate amount of time based on the hazards of the space?  For known IDLH hazards or hazards that can quickly develop into IDLH conditions, on scene rescue standby is required.  For non- IDLH hazards, a response time of 10-15 minutes may be adequate.
3. Will the offsite rescue team be available to respond to a confined space incident or is there a potential they will be out of service on a separate incident and unable to respond?
4. If necessary, can the rescue service properly package and retrieve victims from a permit space that has a limited size opening (less than 24 inches in diameter) or from a space that has internal obstacles or hazards? Does the service have the capability to provide rescue from an elevated location using high angle rescue techniques?

Yes, with a couple of extra precautions.

•    The rope should run over an edge for extra control.
•     A line tender should be added to assist the primary belayer.