In this article, we want to provide some background on our experiences with users of rescue equipment, and why we feel proper training is so important.  In the past 30 years, we’ve had the honor of having thousands of students attend our rescue training classes.  Attitudes toward the statement “Do not use this equipment without proper training!” runs the gamut. It goes from “I never read the instructions,” to “I read, understand, and follow them to the T.” As our students come in all shapes, sizes, experience levels, attitudes, and needs, this is understandable.  However, there’s one common denominator, they have come to us for training – and that’s our critical role.

In many cases, an entire rescue team will show up for training with all their rescue gear in tow. They will then tell us that they have never received training on, nor really understand the proper use of their equipment.

Because it is important to keep our readers and students updated, we wanted to share the following information with you. Please note that this issue is not resolved as of this time, and we have a letter submitted to OSHA for clarification. However, we wanted to keep you in the loop so that you can make better decisions when it comes to your rescue preplanning and operations.

It has recently come to our attention that there is a pending OSHA Letter of Interpretation (LOI) regarding the requirement for an “individual retrieval line” for each entrant. This pending interpretation is different from our understanding of what’s required by the regulation (1910.146). While this particular technique is one option of providing external retrieval, there are other alternatives currently being used by rescuers.

As mentioned above, Roco has submitted a detailed letter to OSHA for a clarification, stating our position that the use of individual lines for entrants in all cases is problematic for a number of reasons. Although OSHA’s response in its letter of interpretation is ambiguous as to its applicability to entry rescue operations, in our commitment to follow the intent of all OSHA standards, Roco is assuming that OSHA’s response was intended to apply to all entries, including rescue entries. Therefore, we will teach and use “individual lines” for the time being until we get further clarification from OSHA.

Question to OSHA:
In a request for clarification, a gentleman from Maryland had asked this question, “Does OSHA 1910-146 (k)(3) require that each individual entrant, including workers and/or rescuers, entering into a confined space be provided with an independent retrieval line or can more than one entrant be connected to a single retrieval line?”

OSHA’s Response:
OSHA’s response in the LOI states, “OSHA 1910.146(k)(3)(i) requires that each authorized entrant into a permit-required confined space must have a chest or full-body harness attached to their ‘individual’ retrieval line or life line to ensure immediate rescue of the entrant.”

Roco Note: It is important to note that “individual” retrieval line is not used in (k)(3)(i); it simply refers to “a” retrieval line. The standard states, “Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant’s back near shoulder level, above the entrant’s head, or at another point….”

Additional Roco Comments:
First of all, OSHA’s Permit-Required Confined Spaces Standard is, for the most part, a “performance-based” standard, meaning that it generally provides a result that is to be met, but leaves the manner by which that result is to be obtained to the judgment of the employer. This is particularly true of the rescue and retrieval requirements, as the specific circumstances and conditions of each entry or rescue will dictate what equipment and techniques may be required. However, this pending Letter of Interpretation (LOI) regarding the use of retrieval lines in Confined Spaces crosses over into the area of specific equipment and techniques that must be used.

Consistent with the performance-based nature of the standard, Roco has taught for years a technique that uses a single retrieval line for multiple entrants as an option to reduce line entanglement hazards during a rescue. The use of this technique was based on testimony given to OSHA prior to the Permit Required Confined Spaces Standard (29CFR 1910.146) being published, and indeed our interpretation of the intent of the standard. The particular technique in question is a common practice for rescuers in which one retrieval line is used and multiple entrant/rescuers are attached at different intervals with butterfly knots to reduce entanglement hazards during a rescue (see example below.)

This pending interpretation would put restraints on techniques used by rescuers when entanglement issues could be a problem. It would result in the management of multiple retrieval lines in the space which could affect the effectiveness of the rescue or result in an increased danger to the entrants and/or rescuers. In effect, this OSHA interpretation could cause an “all or nothing” response regarding the use of retrieval lines for rescuers and entrants. This LOI would eliminate the opportunity of using an external rescue technique for certain situations.

Paragraph (k)(3)  allows entrants to forgo using a retrieval line in certain situations –
“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.”

The technique in question is an option that falls between each individual having an “individual” retrieval line, and having to opt out of using a retrieval line at all, and it allows for external retrieval to still be an option in many cases. And, as most of you know from personal experience, for most confined space portals only one individual can pass through at a time anyway. Even with multiple retrieval lines, it is still a “one at a time” event.  A shared retrieval line allows the same to take place.

It is Roco’s position that the rescue and retrieval techniques used in rescue should be performance based to allow for the ever-changing conditions and problems that are unique to rescue. We also feel this pending LOI could affect the safety and ability of rescuers to adjust to these situations. However, until this issue is clarified, Roco will not teach or use the technique of having multiple rescuers/entrants attached to the same retrieval line in consecutive order using midline knots as their attachment points.

Well, maybe not half the time, but certainly some fraction of the time.

In How to Haul a Victim in Half the Time: Part 1, we covered ways to reduce the time needed to haul a rescue package by taking advantage of changes of direction.

Here, we want to address OSHA and ANSI guidance regarding retrieval systems – specifically mechanical devices used for rescue.

OSHA 1910.146(k)(3) 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.

Additionally, OSHA follows the ANSI Z117-1-1989 approach that was in effect at the time of OSHA 1910.146 promulgation, which states, “A mechanical device shall be available to retrieve personnel from vertical type PRCS’s greater than 5 feet in depth.” It also adds, “In general, mechanical lifting devices should have a mechanical advantage adequate to safely rescue personnel.”

Subsequent revisions to ANSI Z117 included the recommendation that “The mechanical device used should be appropriate for rescue service.” The revised standard adds,“Mechanical lifting devices should have a mechanical advantage of at least four to one and the capacity to lift entrants including any attached tools and equipment.”

Two key points that must be considered: (1) OSHA follows the ANSI approach that was in effect at the time 1910.146 was promulgated which did not recommend a minimum mechanical advantage ratio; and, (2) The rule makers intended to leave a degree of latitude for the rescue service to select a lifting device that is most appropriate for the particular situation encountered.

Roco’s rule of thumb is… the mechanical device used should be appropriate for rescue service – and the employer should not use any mechanical device that could injure the entrant during rescue, which would include a mechanical device with too great a mechanical advantage (MA) for the number of people operating the system. Here’s a guideline we use for determining the proper number of rescuers for a particular system – it should take some effort to haul the victim, but not so much effort that it wears the rescuers completely out. And, it should not be too easy, or you won’t as readily feel if the victim gets hung-up.

Because 1910.146 is a performance-based regulation, it does not specify the rescue procedures that are most appropriate for any given PRCS. It leaves this to the responding rescue service based on their assessment of the PRCS in terms of configuration, depth, and anticipated rescue load. Current ANSI Z117 recommends that the MA “should” be at least four to one. Notice that it does not state “shall” and thus the discretion of the rescue service is taken into account. A generic recommendation of a 4:1 is a good start but should not be considered as a catch-all answer to the problem of lifting the load. Even a 4:1 may not be enough if the person doing the hauling is not strong enough and may require a greater M/A in order to remove the load from the space.

Must we always use a minimum MA of 4:1, or could there be justification in using an MA below the 4:1 ratio when there is a need to provide a faster means of hauling the rescue package? Consider the possibility of reducing the mechanical advantage ratio when there is plenty of haul team members. If you have 4 haul team members for a 250 pound rescue package, do you really need that 4:1 MA? Consider going with a 3:1 or even a 2:1, especially if the throw is short and the haul is long. However, keep in mind that the package will be traveling much faster by reducing the MA – so it is imperative that a “hole
watch” be assigned to monitor the rescue package and be ready to call an immediate “STOP” should the package become hung up.

Caution: If you’re using a piggyback system, make sure the haul team does not outpace the individual taking in the mainline slack through a ratchet device. Should a lot of slack build up in the mainline and the haul team lose control of the haul line, the resulting free-fall of the load could spell disaster. Of course we always encourage the use of a safety (belay) line, but on rare occasions the urgency of the rescue may warrant not using a safety line on the victim.

Ultimately it is the employer’s responsibility to evaluate the selected rescue service’s ability to provide prompt and effective rescue. If the rescue service is able to demonstrate their capability using an MA that is less than the current ANSI recommendation, then that would meet the performance-based nature of the standard. In reality, by using a reduced MA, the time required to extricate the rescue package can be cut by 1/3 to 1/2 depending on the situation. In certain emergencies, that saved time could very easily mean the difference between a successful rescue and a body recovery.

As anyone who has ever been summoned to an industrial site for a confined space rescue, or has taken the opportunity to practice rescue drills in these facilities knows, sometimes the working area for the rescue team can be a tad cozy.  By “cozy” we mean cramped.  If there is the need for a haul of the rescuers or victim after a lower, these cramped conditions can cause multiple problems.  Consider it a challenge to overcome, and use your rope rescue know-how to come up with an efficient solution that will not only reduce congestion at the working area, but will most likely provide for a much faster haul of the rescue package.

First of all, if the space lends itself to a vertically mounted block and tackle, the problem is greatly reduced.  However, if there is no overhead anchor available and the use of a portable overhead anchor such as a tripod is not feasible then a “lane” for the haul team may be necessary.  At times, even the use of a vertically mounted block and tackle may require a solution to a congested working area.

Sometimes we are confronted with a very short throw between the mechanical advantage anchor point and the edge of the portal.  This may cause multiple resets of the haul system, be it a piggyback system or a Z-Rig.  These short throws with multiple resets will really slow down the progress of hauling the rescue package and can become a significant hazard when the need for rapid retrieval is needed.

If the opportunity presents itself, take advantage of a simple change of direction on the haul system.  At times, a single 90-degree change of direction can convert a short 3-4 foot throw into a throw many times longer.  We see this all the time on catwalks, yet it is often overlooked by our rescue teams when we throw scenario-based training evolutions at them.  Yes, it does require some extra equipment which typically amounts to a single sheave pulley, a carabiner, and a utility strap.  It also adds some frictional losses at that directional pulley, but the advantage gained by extending the throw from 3-4 feet to 20 or more feet, far outweighs the disadvantages of extra equipment, added friction, and time needed to make the change.

If a single change of direction doesn’t quite solve the short throw problem, consider two, or even more changes of direction in order to position the haul team in an area thatthey can “walk the haul” using their leg strength instead of being bunched up and using their arm strength only.  Of course, it gets to a point where too many changes of direction exhausts the equipment cache or creates so much friction that any advantage is lost.

As in any rescue situation, a good cohesive team is a great benefit.  If the situation causes the team to be bunched up on top of each other, remember to scan the area for an opportunity to open things up a bit.  Sometimes that change of direction does wonders for the ability of the team to take full advantage of their strength in numbers, and creates a situation where if needed, speed can be a lifesaver.

The author, Pat Furr, reporting for duty...

We received an interesting question about pre-rigged systems from one of our subscribers. The TechPanel had some helpful comments to share, so we have re-posted the info here. It’s a great topic.

Things to consider about leaving systems pre-rigged

First of all, whether to pre-rig systems or not depends a lot on the types of rescues you will be doing. Pre-rigged systems make sense for most industrial and municipal teams who have rope equipment designated specifically for rescues. However, it makes less sense for climbers and wilderness personnel who will be using the same equipment for multiple uses and putting systems together based on a specific need. This also reduces the amount and weight of equipment they must carry, which is a big concern. However, it also requires a high level of proficiency in a variety of systems in order to build systems safely and in a timely manner.

What is a “pre-rigged system”?

• “Plug-n-Play” – These are systems that come pre-built and seem to require little training to operate. These “Plug-n-Play” systems may work for a specific location or type of rescue but may not work in every situation. Training for these systems should address what to do if the device/system malfunctions, or if it will not work for the type of scenario you may be faced with. These are things like the Petzl Jag or CMC Aztek.
• “Customized Pre-rigged Systems” – These are customized pre-rigged systems that rescuers build for site-specific needs and their team’s needs using existing equipment and training.

Confined space and rope rescue can be broken down into three core tasks: (1) Lowering, (2) Safety line Belay, and (3) Mechanical Advantage/Retrieval systems. You can build pre-rigged systems that make sense for your specific needs. Many of the teams we work with have adopted a three-bag system.

For example, one rope bag is designated for “Lowering” along with the typical equipment needed for a lowering system (i.e. descent control device, carabiners, anchor straps, padding). This will provide a pre-rigged system that will handle most of your lowering needs. You may decide to supplement that with another anchor strap and a pulley for a high-point directional, etc.

Your “Safety line/Belay” bag can be set up the same way with enough carabiners and shock absorbers attached to the rope bag to allow for at least two rescuers and a victim.

The third bag of rope (“Mechanical Advantage/Retrieval”) with a simple, pre-built Block-n-Tackle hauling system and its own anchor straps will give your team an “immediate means of retrieval” for either the main line or a safety line retrieval. With a few additional pieces of hardware, you will be able to handle the vast majority of urban rope/confined space rescue scenarios.

We find that for industrial rescue teams or municipal fire and police rescue squads, these pre-rigged systems make sense. They save set-up time and get a rescuer to the victim as quickly as possible, which is especially critical for an IDLH emergency.

Many times teams will arrange their equipment so that it’s easier to inventory rather than what’s the fastest way to deploy it. For example, if you have twenty carabiners, why not have them attached to a rapid deployment bag type system rather than in a hardware bag that a team member will have to go through and pick out what is needed?

Our best advice would be to look at your team’s response area and consider the types of rescues that may be needed. You can then customize and build pre-rigged systems that make sense for your team. “Plug-n-Play” systems may handle most of your rescue situations or they may be part of a larger pre-rigged rescue system like the one described above. Using a “pre-rigged systems” approach saves time, cuts down on confusion, and uses equipment more efficiently – especially when the pressure is on.

Still have your doubts? Try out some of our Quick Drills in your next team training session and compare your times between your current kit configuration and a pre-rigged setup.