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Confined Space Rescue: Non-Entry or Entry Rescue?

Tuesday, November 1, 2022

It’s December 21st on a Saturday night, and the plant is running on a skeleton crew. Operations wants to get a head start on annual preventive maintenance and decides to knock out several permit required confined space entries before the majority of the work is to be done after the New Year.

night plantRandy has just finished the third of five vessels that are identical in configuration. He and his authorized attendant and good friend, Hector, have been working together for over 15 years and they both know the drill. They have changed out the stainless-steel bolt sets on the agitator blades of these vessels every year at about this same time. The entry supervisor has just closed out the permit for the third vessel. After reviewing the permit for the fourth vessel and helping with the pre-entry atmospheric monitoring, he signs the permit authorizing entry.

Hector checks Randy’s harness and the attachment of the non-entry rescue retrieval cable to his dorsal D-ring, and double checks the davit arm and the mounting point of the self-retracting lifeline with the built-in retrieval winch. As Randy climbs 25 feet down the rope ladder to access the bottom of the vessel, all is going according to plan. As he steps off the ladder and begins to loosen the first bolt set, he slips on the concave floor of the stainless-steel vessel. Before he can react, he strikes his head on the agitator blade which causes a 5-inch gash to his left temple and knocks him unconscious. He falls between two of the agitator blades and then slides to the bottom of the vessel with his retrieval line wrapped over one of the blades and under another. Hector tries to winch his friend out of the space only to find that Randy’s limp body gets wedged under the agitator blade. You can probably guess what happened next.

Keep additional personnel (even rescuers) out of the space
unless absolutely necessary.

Realizing there is no entry rescue capability on this shift, Hector’s gut reaction is to enter the space to help his friend. In his rush, he slips from the rope ladder and falls 20 feet to his death. When the entry supervisor arrives 30 minutes later to close the permit and initiate the last entry, he sees two bodies at the bottom of the space.

Understand OSHA Rescue Requirements  

confined space entry permit

Are there permit required confined spaces at your worksite? Are employees allowed to enter these spaces? If you answered yes to these two questions, it is critically important to understand the OSHA requirements for rescue. As part of a written permit space program, the employer 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.”

When considering what methods should be used for rescuing authorized entrants, the safety of the rescuer(s) should be considered as important as the effectiveness of the rescue technique. If it is possible to perform non-entry rescue of the entrant(s), that should always be the first choice. It’s always a given – keep additional personnel (even rescuers) out of the space unless absolutely necessary. It is important to consider potential scenarios that could arise when determining if non-entry (or retrieval) rescue is sufficient.

Non-Entry Rescue

What are the requirements for non-entry rescue? OSHA states, “To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.”

An assessment should carefully consider both capabilities and limitations of the retrieval system for any planned or unplanned condition that may arise during entry.

Let’s examine this further. What conditions would preclude the use of non-entry retrieval systems? Here are some guidelines that OSHA will use to make this determination:

  • A permit space with obstructions or turns that prevent pull on the retrieval line from being transmitted to the entrant does not require the use of a retrieval system.
  • A permit space from which an employee being rescued with the retrieval system would be injured because of forceful contact with projections in the space does not require the use of a retrieval system.
  • A permit space that was entered by an entrant using an air supplied respirator does not require the use of a retrieval system if the retrieval line could not be controlled so as to prevent entanglement hazards with the air line.

Assess The Space

confined space permit only

The ONLY way to determine if a non-entry retrieval system will provide adequate safety for entrants and satisfy OSHA’s requirement is to perform an honest and thorough assessment. This assessment should provide careful consideration for the capabilities and limitations of the retrieval system for any planned or unplanned condition that may arise during entry. We have all heard of “Murphy’s Law” and most of us have experienced the effects of that particular law. I encourage you to remember that Murphy is always lurking close by.

So, when evaluating these spaces to determine if non-entry or entry rescue is the appropriate choice, always ask yourself “what if?” For the fictitious accident that opened this article, the plan was to do all the work on the near side of the agitator blade directly below the top portal. In that case, it would have been safe to assume non-entry retrieval was the only plan needed for rescue. Enter Murphy… Was the rescue plan developed with the assumption that the planned work activities would always ensure the successful use of the retrieval system, but failed to consider the “what ifs”? Some might say that we can “what if” things to death. Let’s turn that around; we SHOULD “what if” these questions in an effort to PREVENT death.

If there is any reasonable potential for an unplanned change
in the conditions, then an entry rescue capability
must be in place as a backup.

When evaluating permit spaces to determine the appropriate rescue capability, please explore those “what ifs.” This is not to say that in the case cited above that the only option would have been entry rescue. That may not be necessary and if the non-entry retrieval system would have worked, then there is no need to expose rescuers to the hazards of entering the permit space. But there was a potential for the condition to change, and it sure did. So, recognizing that potential, an entry rescue capability should have been planned in the event that the change in conditions rendered the non-entry rescue system ineffective.

Backup Plan

The point of this article is to consider non-entry rescue as the default for assisted permit space rescue unless the conditions cited by OSHA are present. At that point, entry rescue must be planned. But this isn’t necessarily a one or the other choice. As we can see from this story, it is sometimes best to plan for non-entry rescue as the primary technique, but if there is any reasonable potential for an unplanned change in conditions, then an entry rescue capability must be in place as a backup.

This article was originally featured on the cover of the March 2014 issue of ISHN, and authored by retired Roco Chief Instructor Pat Furr.

Additional ResourcesConfined Space Rescue Chart

 

Rescue Compliance…Is Your Team Ready?

Saturday, October 1, 2022

We’re often asked by plant managers or rescue team supervisors about how they can make sure their rescue team is ready and in compliance should a confined space emergency occur at their site. Our answer usually revolves around practice, practice, practice; but here are a few other recommendations that you may want to consider.

Consistency

training class

First of all, make sure you and your team are speaking the same language when it comes to rescue techniques and equipment. Consistency is key in having an organized response to a confined space emergency. We always recommend that customers evaluate and choose a single provider for their confined space and high angle rescue training. Using multiple training providers (even if they are similar) can result in confusion for team members as to what techniques and equipment are supposed to be used – especially during a rescue!

Compliance

If you have permit spaces at your site, then we assume OSHA compliance is a priority. OSHA’s Permit-Required Confined Space standard (1910.146) is a performance standard and is based on operational capabilities – as is OSHA’s Confined Spaces in Construction (1926 Subpart AA). While minimum practice requirements are once annually for each team member in the applicable representative spaces, the standard goes far beyond this in terms of proving that your team can function in a safe, timely and effective manner. Have you documented your annual rescue practice requirements in the relevant confined space types? Have you conducted an evaluation of your team’s performance in realistic confined space scenarios? Has your team prepared recommended preplans for the permit spaces on site?

Make sure you and your team are speaking the same language when it comes to rescue techniques and equipment.

There are other national consensus standards to take into consideration as well. This includes the National Fire Protection Association (NFPA) rescue skills requirements of NFPA 1006. This standard provides an excellent means of documenting individual proficiency of your team members. If there is an incident and OSHA were to investigate, would you be able to document the individual skills proficiency of your team members? Remember, if it’s not documented – with OSHA, it doesn’t exist!

Credentials

Team members should be trained to an appropriate level based on the potential scenarios they may be called to respond. Do your personnel routinely work at height? Is there a potential for IDLH atmospheres? Know the hazards that your team may face and make sure they are adequately prepared. For overall team proficiency, it’s important to determine what credentials or level of skills you expect of your individual rescue personnel.

Ideally, all team members would be certified minimally to the Confined Space Rescue Technician level (NFPA 1006) along with the third-party certification to back it up. Of course, all should be CPR certified at a minimum. Additional medical training may be required depending on what level of patient care you intend to provide. And, with these certifications, come recertifications and continuing education, which must be completed as appropriate.

“Can you document your team’s competency and prove that your team members are capable of functioning in a safe, timely and effective manner?”

It's also important to check your team’s training records and make sure everyone is “up to par” with their training currency and skill level. Do you have a particular goal or level that you want your team to strive for, achieve, and maintain? Determining an overall goal for your team is significant in planning for and achieving long-term results. If you’re counting on your team to be ready and prepared, we strongly suggest that all team members be trained to the same proficiency level.

Capabilities

Here’s where the rubber meets the road – how capable is your team of performing a confined space rescue? In the worst of circumstances, can your team safely rescue a patient in a confined space filled with obstacles and unforeseen hazards? Do they possess the technical skills and equipment to perform a rescue safely and timely?

One of the best ways to determine the capability of your team is via simulated, realistic rescue practice drills in the representative confined spaces they may be called to respond. Adding a time limit – without compromising safety – can increase the perceived pressure and further simulate a real rescue. It’s an excellent way to see how your team would respond in an actual emergency situation and correct any deficiencies discovered.

Roco offers two great methods for evaluating rescue team competency. One is a Roco Team Performance Evaluation and the other is our annual Rescue Challenge event. Both offer realistic scenarios conducted under the guidance of experienced instructors along with a critique or debrief of each evolution. Each scenario is graded for various rescue and medical components. With each, comes a Team Performance Report to provide documentation of rescue capabilities.

Certification

If you plan to take your rescue personnel to the level of Rescue Technician, Roco has several options. The quickest way of reaching this certification to NPFA 1006 is by attending our Fast-Track™ Confined Space Rescue Technician course, which is a 70-hour program. This course meets the needs of municipal and industrial emergency responders with a mix of confined space and rope rescue. The class is geared for confined space rescue with additional rope technician skills needed for elevated or high angle rescue. The certification process includes a written exam and performance skills testing and is valid for a period of two years.

“Establish training goals for the team as well as individual team members, so that every training session stays on track and is productive.”

An alternative path to certification includes attending Roco’s Urban/Industrial Rescue Essentials™ 50-hour course and then completing the certification process in a Confined Space Rescue Technician 40-hour program. In either method, your personnel will receive consistent training and be certified to the same level of competency.

Training Cycle for Compliance

Once all team members have reached the appropriate training level, skills maintenance and ongoing proficiency become the norm for continuing compliance. Again, OSHA 1910.146 is a performance and capabilities-based standard that includes minimum annual rescue practice requirements for each team member.

Because our certification is valid for two years, we recommend a rotating cycle. Once Rescue Technician certification is achieved, the following year would include a Roco Team Performance Evaluation – or the attendance of Roco’s Rescue Challenge event. Both events provide graded rescue scenarios, which are debriefed by evaluators to correct any deficiencies found. Each of these options includes a Team Performance Evaluation report, which provides excellent documentation for compliance. The alternative year would include attendance of a Roco Recertification program.

This cycle of training works well in documenting that you have met the minimum requirements of OSHA while also meeting the skills requirements of NFPA. The supporting documentation provided offers a realistic “snapshot” of where your team stands in terms of competency and proficiency. 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.

 

Training CycleConclusion

Rescue skills are extremely perishable, and if not used or practiced routinely, they can be quickly lost. For an effective rescue, team members must be confident in their skills, their equipment and their other team members. This requires regular practice that is realistic and practical. Make sure your rescue team is ready for an actual emergency – as you know, lives are on the line.

 

Confined Space Rescue Chart

 

Additional Resources

 

 

 

Using a Crane in Rescue Operations

Tuesday, May 31, 2022

We’re often asked, “Can I use a crane as part of my rescue plan?” 

If you’re referring to using a crane as part of moving personnel or victims, the answer is “No, except in very rare and unique circumstances.” The justification for using a crane to move personnel, even for the purposes of rescue, is extremely limited. Therefore, it is very important to understand the “do’s and don’ts” for using a heavy piece of equipment in a rescue operation.

crane3_5.22rev

On the practical side, the use of a crane as a “stationary, temporary high-point anchor” can be a tremendous asset to rescuers. It may also be part of a rescue plan for a confined space –  a top entry fan plenum, for example. The use of a stationary high-point pulley can allow rescue systems to be operated from the ground. It can also provide the headroom to clear rescuers and packaged patients from the space or an elevated edge.

Because of the dangers involved in moving personnel with heavy equipment, OSHA strictly limits its use.

The security of the system's attachment to the crane and the ability to “lock-out” any potential movement are a critical part of the planning process. If powered industrial equipment is to be used as a high-point, it must be treated like any other energized equipment with regard to safety. Personnel would need to follow proper Lock-out/Tag-out procedures [Control of Hazardous Energy 1910.147]. Any equipment used in the rescue operation would need to be properly locked out – (i.e., keys removed, power switch disabled, etc.). You would also need to check the manufacturer’s limitations for use to ensure you are not going beyond the approved use of the equipment.

Because of the dangers involved in moving personnel with heavy equipment, OSHA strictly limits its use. In order to utilize a crane, properly rated “personnel platforms or baskets” must be used. Personnel platforms that are suspended from the load line and used in construction are covered by 1926.1431.
There is no specific provision in the General Industry standards, so the applicable standard is 1910.180(h)(3)(v). This provision specifically prohibits hoisting, lowering, swinging, or traveling while anyone is on the load or hook.

OSHA prohibits the hoisting of personnel by crane or derrick except when no safe alternative is possible. The use of a crane for rescue does not provide an exception to these requirements unless very specific criteria are met.

An OSHA Letter of Interpretation (LOI 1993-02-17) states, “OSHA has determined, however, that when the use ofa conventional means of access to an elevated worksite would be impossible or more hazardous, a violation of 1910.180(h)(3)(v) will be treated as de minimis if the employer has complied with the provisions set forth in 1926.550(g)(3) through (g)(8).”

Note: De minimis violations are violations of standards which have no direct or immediate relationship to safety or health. Whenever de minimis conditions are found during an inspection, they are documented in the same way as any other violation, but are not included on the citation.

Therefore, the hoisting of personnel is not permitted unless conventional means of transporting employees  is not feasible. Or, unless conventional means present even greater hazards (regardless if the operation is for planned work activities or for rescue). Where conventional means would not be considered safe, personnel hoisting operations meeting the terms of this standard would be authorized. OSHA stresses that employee safety, not practicality or convenience, must be the basis for the employer's choice of this method.

However, it is also important to note that OSHA specifically requires rescue capabilities in certain instances, such as when entering permit-required confined spaces [PRCS 1910.146]; or when an employer authorizes personnel to use personal fall arrest systems [PFAS 1910.140(c)(21) and 1926.502(d)(20)]. In other cases, the general duty to protect an employee from workplace hazards would require rescue capabilities. 

Consequently, being “unprepared for rescue” would not be considered a legitimate basis to claim that moving a victim by crane was the only feasible or safe means of rescue.

This is where the employer must complete written rescue plans for permit spaces and for workers-at-height using personal fall arrest systems – or they must ensure that the designated rescue service has done so. When developing rescue plans, it may be determined that there are no other feasible means to provide rescue without increasing the risk to the rescuer(s) and victim(s) other than using a crane to move the human load. These situations would be very rare and would require very thorough documentation. Such documentation may include written descriptions and photos of the area as part of the justification for using a crane in rescue operations.

Bottom line… simply relying on using a crane to move rescuers and victims without completing a rescue plan and very clear justification would not be in compliance with OSHA regulations. It must be demonstrated that the use of a crane was the only feasible means to complete the rescue while not increasing the risk as compared to other means. Even then, there is the potential for an OSHA compliance officer to determine that there were indeed other feasible and safer means.

crane6_5.22WARNING: Taking it a step further, if some movement of the crane  is required, extreme caution must be taken! Advanced rigging techniques may be required to prevent movement of the crane from putting undue stress on the rescue system and its components. Rescuers must also evaluate if the movement would unintentionally “take-in” or “add” slack to the rescue system, which could place the patient in harm’s way. The movement of a crane can take place on multiple planes – left-right, boom up-down, boom in-out and cable up-down. If movement of the equipment must take place, rescuers must evaluate how it might affect the operation of the rescue system.

Of course, one of the most important considerations in using any type of mechanical device is its strength and ability (or inability) to “feel the load.” If the load becomes  entangled while movement is underway, serious injury to the victim or an overpowering of system components can happen almost instantly. No matter how much experience a crane operator has, there is no way he can “feel” if the load becomes entangled. And, most likely, he will not be able to stop before injury or damage occurs. Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is completely lost when energized devices are used to do the work.

For rescuers, a crane is just another tool in the toolbox – one that can serve as a temporary, stationary high-point making the rescue operation an easier task. However, using a crane that will require some movement while the rescue load is suspended should be a last resort! There are simply too many potential downfalls in using cranes. This also applies to fire department aerial ladders. Rescuers must consider the manufacturer’s recommendations for use. What does the manufacturer say about hoisting human loads? And, what about the attachment of human loads to different parts of the crane or aerial?

However, there may be cases in which a crane is the only option. For example, if outside municipal responders have not had the opportunity to complete a rescue plan ahead of time, they will have to do a “real-time” size-up once on scene. Due to difficult access, victim condition, and/or available equipment and personnel resources, it may be determined that using a crane to move rescuers and victims is the best course of action. 

Think of it this way, just as rescuers limit the number of haul team members so they can feel the load, that ability is completely lost when energized devices are used to do the work.

Using a crane as part of a rescue plan must have rock-solid, written justification as a demonstration that it is the safest and most feasible means to provide rescue capability. Planning before the emergency will go a long way in providing options that may provide fewer risks to all involved.

So, to answer the question“Can I include the use of a crane as part of my written rescue plan?” 

Well, yes and no. Yes, as a high-point anchor. And, no, the use of any powered load movement will most likely be an OSHA violation without rock-solid justification. The question is, will it be considered a de minimis violation if used during a rescue? Most likely it will depend on the specifics of the incident. However, you can be sure that OSHA will be looking for justification as to why using a crane in motion was considered to be the least hazardous choice.

NOTE: Revised 5/2022. Originally published 10/2014.

 

Additional ResourcesRescue PrePlans

 

 

Confined Space Rescue Planning: Key Considerations

Monday, March 2, 2020

Do you have a rescue plan for your permit-required confined space entry work? One that has been practiced regularly and revised if necessary? If you can't emphatically say "yes" to these questions, consider this sobering statistic: Over 60% of confined-space fatalities in multifatality confined-space incidents involve the would-be rescuer. This is often due to poor and/or quick decision-making when things go wrong... in other words, not sticking to the plan (if one exists). Having a plan in place that accounts for all the "what-ifs" can prevent these fatalities from happening.

What elements should a permit-required confined space rescue plan include? Roco Rescue Safety Officer Pat Furr outlines these in an article in Safety + Health (the official magazine of the National Safety Council).

Read the article in its entirety and download our Confined Space Entry Quick Reference Checklist.

CS Preplan Checklist

When Learning the Ropes, There’s Always More to Learn

Monday, February 24, 2020

By Brad Warr, Roco Rescue Chief Instructor

I took my first rope rescue class in 1995. I spent a lot of my youth in the outdoors and did some knot-tying and rappelling at scout camp. I have fond memories of flying down the (super-sketchy) zip line at summer camp. Climbing over the edge at my first rope rescue class wasn’t terrifying, it was exhilarating. It was also confusing - really confusing.

Scaling a vertical surface

Urban and industrial rope rescue had collided with wilderness rescue techniques. NFPA regulations relating to technical rescue were being adopted by fire departments across the country. Industrial rescue teams were adopting those same standards and the race to heavy rigging was well underway. 

Questions Abound

Confusion reigned, in part because it was a time of great change, but also because I was so green. I remember having so many questions. Did my rope need to be brand new for every rescue? Why did a figure 8 have ears? So, I wrap three but only pull two? Why should I avoid descenders with too many moving parts and why do my double pulleys weigh 6 pounds? Mechanical cams will strip my rope but if I wrap a couple of those little cords around my big rescue rope then I am safe? It was a lot to digest.

Now, 25 years later, I have learned so much. Mostly I have learned that there’s always more to learn. I have learned that money spent on quality training is money well spent. I have been privileged to train with some of the best instructors in the world. It has taught me that if I am to be successful as a rescuer and as an instructor that I must evolve… much like the equipment has evolved and will continue to evolve over time.

Equipment Advances & New Techniques

Brad Warr teaching at the Roco Training Center

Today our descenders have pulleys, our pulleys have swivels and the equipment we use is incredibly reliable and, well, mechanical. The equipment is sleek. It’s smooth. Best of all, it’s not complicated.

We’ll be doing a demo of some of that equipment and the techniques that drive the hardware (teachings adapted from our rope rescue training courses) at the North Dakota Safety Council's 2020 Safety Conference. We’re proud to be partnering with the North Dakota Safety Council to make industrial safety training and services more accessible in a region experiencing rapid industrial growth. Roco Rescue Director of Training Chris Carlsen and I will be offering a different hands-on session on each day of the conference. Sessions and topics include:

  • Advanced Rope Rescue. Learn the most efficient rescue techniques, using modern rescue equipment and systems. Recent advances make it possible to perform the same task with a higher degree of safety while also being more efficient in terms of manpower, equipment and time.
  • Mechanical Advantage Systems. We’ll teach you the principles of mechanical advantage in an easy-to-understand way. Covered topics include calculating input and output forces, determining appropriate equipment requirements for a given situation, as well as often-overlooked considerations such as frictional loss and sheave diameter. This is a hands-on class, taught on a 2-story training prop.
  • Vertical Mobility in Place of Traditional Means of Access. Rope access is significantly safer and in most cases more cost effective than traditional means of access (scaffolds, man-lifts, etc), which explains why it is gaining acceptance in a wide variety of industrial settings. We’ll teach and demonstrate several different rope access techniques and talk about scenarios in which they might be applied.
  • Intro to Rescue Advancements. A great opportunity to see the latest advancements in rescue equipment, systems and techniques, attendees will get hands-on experience as we demonstrate the latest techniques and equipment - and show how many tasks can now be done with a higher degree of safety and efficiency. Today’s lightweight precision manufactured equipment as well as modern synthetics have increased safety and give rescuers greater flexibility and multi-functionality than ever before.

A Safer Way

Even if you’re not attending NDSC’s conference this week, these are the types of topics you can expect when you come to Roco Rescue for training. We stay on top of the very latest developments in rescue and distill what’s most useful and most effective into our courses, in an easy-to-remember fashion. Our instructors are skilled rescuers and teachers who adapt their methods to a variety of learning styles.

We hope to see you at the NDSC Safety Conference or in one of our rope rescue certification courses. Check out your training options below, or call us to arrange for us to come to your site for training.

View All Training Options

 

bradwarr

Brad Warr is a Chief Instructor for Roco Rescue and a Captain at the Nampa (ID) Fire Department. Brad joined Roco Rescue in 2003 and teaches a wide variety of technical rescue classes including rope rescue, confined space rescue, trench rescue, and structural collapse. He is also a member of Roco’s Contracted Safety & Rescue Team, providing standby rescue services for plants, refineries and other industrial facilities. Brad became a firefighter for the Nampa Fire Department in 1998 and was promoted to Captain in 2006. His responsibilities include training for the department’s Heavy & Technical Rescue Team. Before joining the fire department, Brad worked for three years as an Emergency Response Technician for a large manufacturer in Boise, Idaho, where he was responsible for OSHA compliance, emergency medical response, confined space/rope rescue response and hazardous materials response.

 

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