The concept of Lock-Out/Tag-Out is a great one and it works. As rescuers, however, we have to take the common industrial application and expand it to ensure that the rescue scene is safe and that we are controlling hazards at the point of contact with the victim or in a space where something has gone very wrong.

What Does OSHA Say?

Although commonly referred to as the “Lock-out/Tag-out” (LOTO) standard, the actual title of 1910.147 is “The Control of Hazardous Energy.” This title probably better describes its true purpose – and there's no doubt that the understanding of this concept has saved many lives and prevented countless injuries. Prior to work, potential sources of hazardous energy must be identified and controlled. As responders, we do not have the luxury of studying blueprints and schematics to identify how to isolate the hazard. In fact, we’re most often responding to incidents where LOTO turned out to be ineffective or was improperly used.

Standard LOTO is usually defined in a work planning and control process or a job safety analysis. Days, weeks, and even months are spent planning and assessing cause and effect to ensure a safe work environment. During an actual emergency, rescuers have only minutes to assess and determine how to “make the scene safe.” This safety mindset serves to protect both the rescuer(s) and the victim(s) from additional harm following an incident.

NOTE: While LOTO tags are permissible by OSHA, they are not commonly used as you must prove that a tag is at least as effective as a physical lock – something that would be hard to ensure.

 We’ve found that if you ask different people to define LOTO and who is responsible for performing it, you will get a variety of answers. OSHA 29 CFR 1910.147(b) has a very narrow and specific definition of who can perform lock-out or tag-out operations. That definition does not include rescuers; and there is good reason for that. OSHA defines two types of persons in regard to LOTO; “authorized employees” and “affected employees.”

An authorized employee is a person who locks out or tags out machines or equipment in order to perform service or maintenance on that machine or equipment. An affected employee becomes an authorized employee when that employee's duties include performing service or maintenance covered under this section.

Translation: A person that the employer says has the systems or mechanical knowledge and authority to safely lockout/tagout a machine or space.

An affected employee is an employee whose job requires him or her to operate or use a machine or equipment on which service or maintenance is being performed under lock-out or tag-out, or whose job requires work in an area in which such service or maintenance is being performed.

Translation: A person who has to work in an area where LOTO is in place. (Sounds like a rescuer to me.)

LOTO for rescuers

According to an OSHA clarification letter¹, an affected employee is one who does not perform service or maintenance work on the machine or a piece of equipment and does not implement the LOTO system procedural elements. Rather, the affected employee's job responsibilities include operating the machine or equipment or performing other work in an area where the service or maintenance work is being performed.

There is good reason for these prohibitions on applying Lock-out/Tag-out. Improperly performed LOTO can be just as dangerous, if not more so, than no LOTO at all. Allowing LOTO to be performed by personnel who are not familiar with the processes and equipment increases the chances of improper lock-out. As rescuers, we rarely (if ever) have the kind of institutional knowledge to perform true LOTO of a process or environment.

If the reason for the rescue is something other than an exposure to a hazardous energy source, and LOTO has already been performed, the rescuers should walk through and verify the "authorized employees'" LOTO and ensure no changes are made to the system.

If LOTO was performed improperly or has failed and is causing the emergency, then rescuers can lock-out the equipment as they see fit or as the rescue needs dictate. The control of hazardous energy is part of making the area safe for rescue operations, but doing so without understanding the bigger picture can be dangerous.  Whatever actions are taken should be completed with the coordination of a facility representative who understands where or what you are working with. 

From a rescuer’s viewpoint, our definition and options for effective LOTO needs to include other equipment and techniques that provide a safe area for rescue operations and prevent further harm to the victim. This includes equipment that is used every day in the municipal rescue world that may not typically be found in an industrial facility. This includes equipment such as hydraulic spreaders and high-pressure air bags. Even simple tools, such as metal wedges, can be used to isolate and protect the hand or arm of a victim trapped in a piece of machinery. The key is to review your current capabilities and identify what may be needed prior to an incident occurring.

Machine entrapment rescues are another all too common situation in which responders need to isolate the area at the point of contact with the patient to prevent further movement. RESCUERS BEWARE – Another huge consideration for rescuers is stored energy! Sometimes what sounds like a simple solution (such as turning off a machine) can do more harm IF the machine normally recycles before coming to a resting position. OSHA identifies these hazards and provides a pretty good list of examples to be aware of when responding. It includes stored or residual energy in capacitors, springs, elevated machine members, rotating flywheels, hydraulic systems, and air, gas, steam, or water pressure, etc. Rescuers need equipment and techniques to control, restrain, dissipate, and immobilize these hazards.

Municipal and industrial rescuers get called to a wide variety of rescues – each with its own unique problems. As we know, the number of ways people can get themselves in harm’s way is unlimited! In all entrapment incidents, however, it is essential that we protect both the victim and ourselves from further injury and limit our exposure to the hazards that are present. In every incident, rescuers must first identify the hazards and try to eliminate or control them in every way possible.

Sixth most cited standard

Every year, OSHA issues its “Top 10 Most Frequently Cited Standards” list. While the order of the list is different from year to year, it is generally still comprised of the same 10 standards year after year. LOTO, the control of Hazardous Energy (29 CFR 1910.147), consistently makes the list; and, for 2021, it was no different. For 2021, the LOTO standard landed as the 6^th most frequently cited standard in the industry.

Incident: An Ohio aluminum parts manufacturer with a history of safety violations now faces penalties for 38 safety and health violations and a proposed $1 million fine following an investigation into the death of a 43-year-old worker struck by a machine's barrier door on March 30, 2021.

OSHA alleges that the company allowed employees to bypass guarding mechanisms designed to protect employees from the barrier door closing on them and that a malfunction in the door's optic control existed prior to the deadly incident. The worker was loading a part into the machine when the barrier door closed on his head.

OSHA's investigation identified problems with machine guarding and a lack of protective procedures – commonly known as lockout/tagout – throughout the facility. OSHA claims that the company was aware of these problems and failed to address them adequately.

Incident: Another case of LOTO “gone bad” occurred during a Roco CSRT stand-by job at a local industrial plant. After LOTO had supposedly been performed, one of our team members decided to test it by pushing the “Start” button on a hyper bar in a tank – it turned “ON!” Further investigation revealed that electrical work had been done in the area and the fuse lock-out was moved to another box adjacent to its original location. No one had notified the workers or changed the written protocol. Workers were locking out the wrong circuit! Had this been a rescue, how would rescuers control the hazard without knowing where the problem was with the LOTO?

Conclusion

It is clear that rescuers need to look deeper into their technique toolbox for creative options to isolate energy sources in order to protect themselves as well as the victim. And, this doesn’t only apply to municipal rescuers. Industrial rescue teams are very likely to be called when an emergency like this occurs. In order to be proactive and prepared, take the time in advance to evaluate your response capabilities as well as that of local responders in your immediate area. Every minute is critical for that person trapped or injured.

¹ Standard Interpretation: Clarification of "authorized" and "affected" employees and proper energy control procedures, Feb 10, 2004, question #3

Additional Resources

• Improper LOTO Costs Company $283,390
• OSHA Lock-out/Tag-out Fact Sheet 
• Evaluating Your Rescue Service

Whether you’re a comedian telling jokes or a quarterback throwing a fade route to your favorite receiver, timing is key. And when you’re rescuing a worker who’s fallen into a fast-moving river, timing becomes an incredibly critical issue. In an instant, a Roco marine standby boat and rescue team can mean the difference in life or death for a fallen worker. What’s more, OSHA requires prompt retrieval during construction projects over or near water, and that’s just what Roco teams can provide.  

As part of Roco Rescue’s CSRT Services Division, Roco marine standby crews spend hundreds of hours each year on the waterways of the Baton Rouge-New Orleans industrial corridor, ensuring the safety of those working on structures above the water. According to Brad Duplessis, CSRT Director for Roco, “By far, the majority of our marine standby work is on the Mississippi River near a dock or facility under construction, but our teams are mobile and can work most anywhere in the U.S. In fact, we recently quoted a project on the Ohio River.”

Many companies performing construction work over or near waterways may not realize that a boat or skiff in the water for rescue is actually an OSHA requirement. OSHA 1926.106(d) states, “At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.” In fact, according to one OSHA letter of interpretation (LOI 6/13/90), the retrieval of an employee from the water is required no more than three to four minutes from the time they entered the water. Depending upon hazards present, rescue could be required even sooner. Another OSHA LOI (12/5/03) states, “As a skiff supplies a backup to potential failures of fall protection devices, the use of fall protection systems is not a substitute for the skiff.”

Simple Premise. Complicated Process. 

The concept is simple. Roco Rescue places a boat on-site to monitor projects where work is being performed over water. The Roco team, consisting of a boat operator and a lead rescuer, is there to closely monitor the site and immediately retrieve anyone that falls in the water. If the worker falls and is hanging from scaffolding or dangling from the side of a structure, it is the duty of the site rescue team to assist. But the minute a worker falls into the water, Roco Rescue’s marine standby team springs into action – and that’s when the process becomes both dangerous and complicated.

“Our eyes are constantly on the water,” explained Devin Payne, Roco CSRT Logistics Manager, who also works marine rescue standby.

“The minute a worker falls in, our two-person team goes to work striving to get that person out of the water as quickly as possible. One team member maneuvers the boat and the other uses equipment like life rings, ropes, grab poles or a davit arm, which is a specialized winch.”

“There are a number of factors at play, plus the fact that the person needing rescue may be injured or unconscious,” said Denver Payne, Roco CSRT Regional Manager (and twin brother of Devin).

“Most people don’t realize the dangers of river water, the intricacies that go into rescue or the potential hazards that stand in our way.”

Current: River water on the Mississippi generally moves at a rate of approximately 30 knots, which is just under 30 miles per hour. Rivers at flood stage can move even faster. At this rate, an individual that falls in can be swept away ending up hundreds of feet from the water entry point in a matter of seconds. For this reason, Roco Rescue boats observe closely from just downstream, ready to pull workers from the water as quickly as possible.

Temperature: Many would assume that river water, especially during southern summers, hovers around the 80-degree mark. However, in actuality, the average temperature of river water is 64-70 degrees, which can lead to the rapid onset of hypothermia. The Mississippi River averages 58 degrees during the spring and early summer due to the snowmelt coming down from the north. At this temperature, hypothermia can set in at an even faster rate.

Debris: Rivers have an unbelievable amount of debris such as tree limbs, logs, trash and more, much of which may not be visible from the surface. A worker may fall on a piece of debris or have debris strike him moving 30 mph, which can render him unresponsive during a rescue.

Visibility: Underwater visibility in a river is zero. If someone falls in without a personal floatation device, he could go under immediately making the rescue even more challenging.  

Boat Traffic: The river is shared by a number of additional boats and barges of varying sizes. Maneuvering the Roco boat between traffic can also be challenging. In addition, a person being swept away at 30 mph who is slammed into the side of a parked barge or a moving boat can experience great bodily harm.

Special Equipment. Specially Trained Personnel.

Although the OSHA standard does not identify specific training for the rescue boat personnel, all Roco marine standby personnel are First Responder/CPR/First Aid trained, certified EMR or higher, and most are EMTs. Each member has passed a Boater’s Education Course along with specialized Roco Rescue training developed in conjunction with the U.S. Coast Guard and EBR Sheriff’s Department. Roco boats are fully equipped with first aid kits, AEDs and oxygen for prompt emergency care. These twin-engine crafts are safer and float lower in the water, making rescue access easier. Each boat is equipped with everything needed for rescue including a davit arm strong enough to lift 400 pounds. Our specialized navigation system allows for work during periods of low visibility as well.

We remind all companies who have personnel performing construction activities over or near the water, please make sure you are OSHA compliant and have a boat onsite to provide timely rescue. For additional safety and to ensure the highest level of service, rely on Roco Rescue. For more information on our marine rescue standby services, please contact us via phone at 800-647-7626 or email us at info@RocoRescue.com.

 Evaluating your rescue service helps ensure that the team you have selected has the knowledge, technical skills, and capabilities required to meet your company’s specific needs. In addition, a team evaluation helps fulfill the performance requirements outlined in OSHA 1910.146 and 1926.1211. If you doubt the importance of selecting a competent and properly trained rescue team, consider this disturbing statistic: more than 60% of confined space fatalities occur among would-be rescuers.

OSHA 1910.146 Appendix F (non-mandatory) provides a great roadmap for employers when choosing and evaluating a confined space rescue team. It contains criteria that may be used to evaluate the capabilities of both prospective and current rescue teams. (Note: Although Appendix F is “non-mandatory”, the standards of 1910.146 are not. Appendix F is OSHA’s recommended method for compliance. Learn why you should pay close attention to Appendix F, even though it is “non-mandatory.”) 

The Two Components Of A Rescue Service Evaluation:

1. An initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform permit space rescues of the kind needed at the facility and whether such rescuers can respond in a timely manner; and
2. A performance evaluation, in which employers assess the skills of a prospective rescue team or rescue service during an actual or practice rescue.

Step 1: Initial Evaluation

The initial evaluation considers:

• A team’s technical skills as evidenced by documented training
• Number of personnel
• Availability
• Timeliness based on the hazards inherent in the space
• Whether they meet the requirements of 1910.146 (k)(2) with regards to access to personal protective equipment (PPE), training in both technical rescue and first aid/CPR, and practice in representative permit-required confined spaces at least once per year
• The ability to notify the employer when they are unable to respond – which is of particular importance for employers using 911 as their rescue service
• and more (see Section A, Initial Evaluation in OSHA 1910.146 Appendix F)

Step 2: Performance Evaluation

Once employers have selected one or more rescue services that meet their criteria on paper, employers should provide the rescue service access to their worksite and ask them to perform in various scenarios of the employer’s choice. Performance evaluations should be administered to a prospective rescue service, as well as to periodically evaluate your current rescue service.

Consider Using A Third Party To Evaluate Your Rescue Service

Employers may opt to use a third party to evaluate their prospective rescue service. Third-party evaluations provide a number of added benefits:

• They are useful when employers may not have the in-house expertise necessary to administer an accurate evaluation, or for employers who prefer having a third-party evaluation as a documented, independent, and unbiased record of the rescue service/team’s capabilities.
• They provide an opportunity for the evaluator to recommend minor changes in equipment or techniques that would enhance the capability of the team.
• In cases where contractors will be providing their own rescue capability, third-party evaluations help ensure that all parties are doing their due diligence where permit space entry is required. Some host employers mistakenly believe that they are relieved of all responsibility when a contractor’s employees are performing the entries. But 1910.146(c)(8) and (9) place reciprocal responsibilities on host and contractor. This includes the host employer informing the contractor that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146, and the contractor informing the host employer of the permit program it will be following.

Taking the time to ensure that the rescue service you choose has the proficiencies and equipment to perform the specific types of rescue required at your facility could not only prevent injuries, it could even save lives.

If you would like additional information on utilizing Roco Rescue’s documented Team Performance Evaluation for your rescue service, please call 800-647-7626.

We're looking for experienced, Baton Rouge area rescue professionals who have availability during off-shifts to work standby rescue services jobs at industrial facilities. If you're EMR certified and have at least 1 year of emergency response experience, you've cleared the first hurdle. If you have great rescue skills, are calm under pressure and are passionate about rescue, then you just might have what it takes. 

We offer flexible, part-time scheduling so that you can fit this work in alongside firefighting or EMT shifts. We pay competitive wages with opportunities for advancement. And we will augment your rescue skills by slotting you in one of our Fast Track courses to get you NFPA 1006 certified in confined space rescue. 

Register here: https://hubs.ly/H0jnJYW0

We'll make arrangements to connect with qualified applicants. If we schedule you for an in-person conversation, be prepared for a basic skills assessment, a physical readiness test and a brief interview.

READER QUESTION:
Our company procedures require an on-site rescue capability for permit- required confined space entry operations during normal Monday-Friday “day shift” operations, but for entries other than during that shift, we rely on an off-site rescue service. Shouldn’t the rescue capability, specifically the rescue response time, be the same no matter when the permit required confined space entries are being made?

ROCO TECH PANEL ANSWER:
Yes; and no, not necessarily.

Yes, if the nature of any known or potential hazards that may affect the entrants in the permit space, and the configuration of the confined space are the same during regular M-F day shift as they would be during off-shift entries, then the answer is yes. The rescue capability regarding response time, manning, equipment, and overall performance capability should be the same.

No, not necessarily. For example, if the nature of the known or potential hazards of a permit space entered during the day shift requires a shorter response time, or if the configuration of the space requires a higher level of rescue expertise, rescuer PPE, number of rescue personnel, or if there is any other factor that may require a different performance capability than the requirements of the day shift entries, then no, the same rescue capability would not necessarily be required.

This is because OSHA 1910.146 is a performance-based standard. For confined space rescue, specifically regarding what would be considered “prompt rescue,” the performance standard will be most influenced by the nature of the potential and known hazards and how quickly the hazards will affect the authorized entrants, as well as the complexity of providing effective rescue from the particular permit-required confined space.

To demonstrate this point, here are some extracts from OSHA 1910.146 Permit Required Confined Space Regulation Section K, the Summary and Explanation of the Final Rule, and also from OSHA 1910.146 Appendix F.

From 1910.146 (k)(1)(i)“Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

Note to paragraph (k)(1)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §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.”

From the Summary and Explanation of the Final Rule (1910.146) “OSHA has therefore decided to promulgate the requirement it proposed for "timely" rescue, a requirement that was not opposed by any rulemaking participant, rather than to define precisely what is timely. That determination will be based on the particular circumstances and hazards of each confined space, circumstances and hazards which the employer must take into account in developing a rescue plan. OSHA has added a note to paragraph (k)(1)(i) to clarify this point.”

From 1910.146 Appendix F, A. Initial Evaluation, II, 1. “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 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.”

The response time of the rescue service is also different than the time needed to provide rescue. Response time generally means the time it takes for the rescue service to arrive on scene. From that time forward, the rescue service must perform a size-up, identify and don PPE, set up rescue systems, and perform many other tasks before initiating entry rescue. Any need to provide victim packaging or to deliver breathing air to the victim will add to the total time it takes to complete the rescue.

Therefore, it is imperative that the employer ensures that the measure of “Prompt Rescue” is driven by the nature of the known or potential hazards of the permitted confined space as well as the complexities of the configuration of the space and how those will effect the time required to the setup the rescue system.

Roco provides confined space rescue services for a variety of industries and is confronted with a very wide range of hazards associated with the entry operations and a vast range of space configurations. The determination on the rescue team’s posture is based primarily on the answer to the following questions.

• 1.  How quickly will the entrants be overcome by the known or potential hazard(s) of the space, and /or how quickly will the entrants suffer permanent injury if exposed to those hazards?
• 
  
• 2.  If non-entry retrieval systems are not employed due to the system not contributing to an effective rescue, or the retrieval system creates a greater hazard, how much time would be needed to arrive on scene, set up an entry rescue system to support the entrant rescuer(s) and the victim(s)?

These are just two of the primary questions that we consider for our CSRT operations. If the nature of the known or potential hazards would require a near immediate rescue of the entrant(s), we would assume a “Rescue Standby” posture where the rescue systems are pre-rigged, the entrant rescuers are already in appropriate PPE or have it available to be quickly donned, and the rescue effort can be initiated in a very short time in an effort to meet that “Prompt Rescue” performance benchmark.

It is vitally important that the employer honestly evaluates the nature of the hazards or potential hazards of the permitted confined spaces that they plan on entering. This can be accomplished by reviewing product SDS (Safety Data Sheets), understanding the nature of the hazards that are not included in the SDS, and always considering worst case scenarios. Additionally, the employer must include an evaluation of the time it would take the rescue service to arrive on scene as well as the additional time to safely assess the situation and setup the required rescue systems prior to initiating rescue.

The answer to the question of a different rescue capabilities based on the “day shift” or “night shift/week-ends” can only be answered by performing a thorough assessment of the permitted spaces. And, on a case by case basis, determine if the rescue capability for that particular entry operation does indeed meet the spirit of “Prompt Rescue.”