confined space rescue training compliance issues

Confined Space Rescue Training Compliance Issues

Most confined space fatalities are poorly trained rescuers…

Many of these heroes died because Many of these heroes died because their employer unintentionally broke their employer unintentionally broke the law-the law-

OSHA regulations!OSHA regulations!

How many people die or get hurt How many people die or get hurt seriously in confined space accidents?seriously in confined space accidents?

Prior to the OSHA Confined Space Standard:

63 Fatalities

5,931 Lost workday cases

6,951 Non-lost workday cases

How many people die or get hurt seriously How many people die or get hurt seriously in confined space accidents? (Cont.)in confined space accidents? (Cont.)

The numbers of deaths and injuries if the OSHA standard is followed:

9 Fatalities

890 Lost workday cases


How many people die or get hurt seriously How many people die or get hurt seriously in confined space accidens? (Cont.)in confined space accidens? (Cont.)

The numbers prevented by following the OSHA standard:

54 Fatalities

5,041 Lost workday cases


OSHA requirements

OSHA’s 3 levels of protection for confined space entrants: 1) Permitting procedure identifies hazards 1) Permitting procedure identifies hazards

and addresses protective measuresand addresses protective measures

2) Retrieval equipment required for quick 2) Retrieval equipment required for quick

external rescueexternal rescue

3) Rescue services required to be available 3) Rescue services required to be available

to perform internal rescueto perform internal rescue

Criteria of a Confined Space

1) Large enough to bodily enter and work1) Large enough to bodily enter and work 2) Limited entry and exit2) Limited entry and exit 3) Not designed for continuous human 3) Not designed for continuous human

occupancyoccupancy

Permit Required Con. Space

1) 1) Hazardous AtmosphereHazardous Atmosphere

-Exists or has the potential to exist-Exists or has the potential to exist 2) 2) Engulfment HazardEngulfment Hazard

-Water, sludge, grain, etc....… -Water, sludge, grain, etc....… (3) (3) Entrapment HazardEntrapment Hazard

-Hoppers, converging pipe, etc.......-Hoppers, converging pipe, etc....... 4) 4) Any other Health or Safety HazardAny other Health or Safety Hazard

-Fall, heat, trip, varmints, etc........-Fall, heat, trip, varmints, etc........

What emergency rescue options What emergency rescue options does the site have?does the site have?

1. Employers have three options under 29CFR 1910.146(k):

a. Utilize their own employees to enter confined spaces to perform

rescue services.

b. Arrange to have an outside service perform confined space rescues.

c. Combination response.

Emergency response options

Because there is a need for quick response, Because there is a need for quick response, on-site rescue teams are usually preferred.on-site rescue teams are usually preferred.

Definitions: Emergency -Emergency -

any occurrence that could endanger entrantsany occurrence that could endanger entrants Entry - Entry -

any part of the body breaks the plane of the any part of the body breaks the plane of the openingopening

Self-rescue - Self-rescue -

entrant evacuates the space without assistanceentrant evacuates the space without assistance

Definitions Continued:

Hazardous atmosphere -Hazardous atmosphere -

any atmosphere that could hinder an any atmosphere that could hinder an entrant’s ability to self-rescueentrant’s ability to self-rescue

Rescue service -Rescue service -

personnel designated to perform rescuepersonnel designated to perform rescue Retrieval system -Retrieval system -

equipment used for non-entry rescueequipment used for non-entry rescue

OSHA Special Emphasis

For 1996, OSHA continues to emphasize For 1996, OSHA continues to emphasize

those hazards it considers the greatest those hazards it considers the greatest

problems for workers…problems for workers… Confined SpacesConfined Spaces Lock-out / Tag-outLock-out / Tag-out Fires & ExplosionsFires & Explosions Exposure to Lead, Silica & Asbestos.Exposure to Lead, Silica & Asbestos.

Proposed Revisions...

• Revisions due to Steelworkers’ Union Revisions due to Steelworkers’ Union

Lawsuit:Lawsuit:

No method for employees to view monitoringNo method for employees to view monitoring

Concern over an off-site rescue team’s Concern over an off-site rescue team’s

ability to rescue endangered workers.ability to rescue endangered workers.

Lawsuit Result - Changes in the rule regarding rescue...

OSHA proposed to amend and OSHA proposed to amend and

STRENGTHENSTRENGTHEN its final confined space its final confined space

regulation, which was published in January regulation, which was published in January

1993.1993.

OSHA clarification factors...

Response Time;Response Time; Equipment; and,Equipment; and, State of Training.State of Training.

OSHA believes that an employer who does OSHA believes that an employer who does not consider these factors is NOT complying not consider these factors is NOT complying with (d) (9) and (k).with (d) (9) and (k).

Effective Rescue Capability...

OSHA believes that, even under the current OSHA believes that, even under the current

rule, an employer must take rule, an employer must take timelinesstimeliness, and , and

accountabilityaccountability into account if that employer into account if that employer

is to have a truly effective rescue capability.is to have a truly effective rescue capability.

Evaluation & Verification...

Proposed provision clearly indicates Proposed provision clearly indicates

employers must employers must evaluateevaluate and and verifyverify that the that the

rescue service’s needed capabilities are rescue service’s needed capabilities are

present.present. Documented average response timesDocumented average response times Training recordsTraining records Graded performance evaluationsGraded performance evaluations

OSHA’S Measurement...

Based on employer’s effort Based on employer’s effort prior to prior to

arrangingarranging for a rescue service. for a rescue service.

Must ensure the service is indeed Must ensure the service is indeed capablecapable in in

terms of timeliness, training & equipment terms of timeliness, training & equipment

of performing an effective rescue.of performing an effective rescue.

Point of Attachment...

Entrants shall use chest or full-body harness Entrants shall use chest or full-body harness

with retrieval line, unless…with retrieval line, unless… Amend law to allow employers to choose Amend law to allow employers to choose

where they attach retrieval lines to workers.where they attach retrieval lines to workers. Becomes performance-based.Becomes performance-based. Attachment point that provides the smallest Attachment point that provides the smallest

possible entrant profile.possible entrant profile.

Employer shall ensure...

(i) The outside rescuer can effectively (i) The outside rescuer can effectively respond in a respond in a timely mannertimely manner to rescue to rescue summons.summons.

(ii) The outside rescuer is (ii) The outside rescuer is equippedequipped, , trainedtrained, , and and capablecapable of functioning appropriately to of functioning appropriately to perform permit space rescues…perform permit space rescues…

(iii) …rescuer is aware of the hazards…(iii) …rescuer is aware of the hazards… (iv) …provide access...(iv) …provide access...

What is timely response?

“…“…permit space hazards vary in their permit space hazards vary in their capacity to kill or permanently injure capacity to kill or permanently injure employees and that what constitutes employees and that what constitutes ‘timely’ will vary accordingly.”‘timely’ will vary accordingly.”

Response Vs Rescue Time...

(1) React Time(1) React Time: :

Attendant recognizes that the Entrant has a Attendant recognizes that the Entrant has a problem.problem.

(2) Contact Time(2) Contact Time: :

Attendant contacts the Rescue Service.Attendant contacts the Rescue Service. (3) Response Time(3) Response Time::

Rescue Service arrives at the scene.Rescue Service arrives at the scene.

Rescue Vs Response Time...

(4) Assessment Time(4) Assessment Time::

Size-up and strategy determination.Size-up and strategy determination. (5) Preparation Time(5) Preparation Time::

Rescue equipment set-up.Rescue equipment set-up. (6) Rescue Time(6) Rescue Time::

Reaching, treating, packaging, and Reaching, treating, packaging, and evacuation of the victim.evacuation of the victim.

Timely Response, Training, and Equipment

Establish a competency bench-mark (goal) to Establish a competency bench-mark (goal) to evaluate training and response:evaluate training and response:

OSHA suggests 4 minutes in a CPR OSHA suggests 4 minutes in a CPR emergencyemergency

The “Golden Hour” is an accepted principle The “Golden Hour” is an accepted principle in all injury-related and medical emergenciesin all injury-related and medical emergencies

Rescue Stand-by

Goal: Goal: 4-Minute Rescue Response4-Minute Rescue Response

Possible only if rescuers are rigged and Possible only if rescuers are rigged and ready while the entry is taking place. This ready while the entry is taking place. This is defined asis defined as Rescue Stand-by Rescue Stand-by. .

Rescue Available

Appropriate (and Appropriate (and ApproximateApproximate!) Goals:!) Goals: Respond To CS Scene / 10 MinutesRespond To CS Scene / 10 Minutes

Reach The Victim(s) / 5-10 Minutes LaterReach The Victim(s) / 5-10 Minutes Later

Case law update….10 minute response held to Case law update….10 minute response held to be be notnot timely in a Nov. 1997 case! timely in a Nov. 1997 case!

Rescue Available - Supervisor’s Role

Verifies the rescue service is available and Verifies the rescue service is available and the means to summon them is operable….the means to summon them is operable….

Recent Administrative RulingRecent Administrative Ruling::

Regardless of whether the employer thinks Regardless of whether the employer thinks it is unreasonable to call the service for it is unreasonable to call the service for every entry - the employer must comply!every entry - the employer must comply!

Evaluation Milestones

Rescue Stand-by establishes a Rescue Stand-by establishes a GOALGOAL of of reaching the victim in 2-4 minutes.reaching the victim in 2-4 minutes.

Rescue Available establishes a Rescue Available establishes a GOALGOAL of of responding to the scene within 10 minutes responding to the scene within 10 minutes and reaching the victim within 15 minutes.and reaching the victim within 15 minutes.

Goals are to be strived for - not required…. Goals are to be strived for - not required…. they should serve as comparative milestones they should serve as comparative milestones for judging team competency.for judging team competency.

Choosing the Appropriate Response

Decision: Decision: Stand-byStand-by Vs. Vs. AvailableAvailable Each Each entryentry must be evaluated to determine must be evaluated to determine

the appropriate response mode.the appropriate response mode. The evaluation must be done by a qualified The evaluation must be done by a qualified

person (rescuer and/or entry supervisor).person (rescuer and/or entry supervisor). Factors to be considered include the severity Factors to be considered include the severity

of the hazard, required PPE, and the ability of the hazard, required PPE, and the ability of the entrant to self-rescue.of the entrant to self-rescue.

Categorizing PRCS

Cat I - RACat I - RA

-Hazard (Potential) is not -Hazard (Potential) is not IDLHIDLH

-Supplied breathing air is -Supplied breathing air is not requirednot required

-No anticipated difficulty -No anticipated difficulty for entrant to self-for entrant to self-rescuerescue

Cat II - RSCat II - RS

-Hazard (Potential) is -Hazard (Potential) is IDLHIDLH

--Supplied breathing air is Supplied breathing air is requiredrequired

-Anticipated difficulty for -Anticipated difficulty for entrant to self-rescueentrant to self-rescue

Categorizing Spaces Cat must be reviewed prior to entryCat must be reviewed prior to entry Entrant Supervisor must have authority to Entrant Supervisor must have authority to

make the call….make the call….

Common sense approach to compliance:Common sense approach to compliance:

- Documents intent to make a “timely rescue”- Documents intent to make a “timely rescue”

- Establishes training goal & evaluation criteria- Establishes training goal & evaluation criteria

Timely Response, Training, and

Equipment Rescue Rescue Retrieval Retrieval Ventilation & Atmospheric Monitoring Ventilation & Atmospheric Monitoring BarriersBarriers Access/Egress (ladders, etc...)Access/Egress (ladders, etc...) LightingLighting CommunicationCommunication

Timely Response, Training, and Equipment

Documented training by each team member Documented training by each team member via simulated rescues in every type of via simulated rescues in every type of confined space (Rescue training)confined space (Rescue training)

Authorized Entrant/Attendant Authorized Entrant/Attendant First Aid & CPR (Blood-borne pathogens)First Aid & CPR (Blood-borne pathogens) Haz Com, PPE, Respiratory, Lockout, PSMHaz Com, PPE, Respiratory, Lockout, PSM Equipment training (Fall Protection)Equipment training (Fall Protection)

CSR Training:

Each rescue team member must be trained Each rescue team member must be trained to safely perform all assigned rescue duties.to safely perform all assigned rescue duties.

- Rigging - Rigging

- Entry (claustrophobia)- Entry (claustrophobia)

- PPE utilized outside the space- PPE utilized outside the space

- Equipment maintenance- Equipment maintenance

- Individual skills (IPE)- Individual skills (IPE)

Hands-on Rescue Training:

EachEach member must practice member must practice simulated simulated rescue operationsrescue operations at least once every 12 at least once every 12 months in the actual PRCS or representative months in the actual PRCS or representative spaces that simulate the spaces that simulate the typestypes of spaces of spaces based on based on opening size, configuration, and opening size, configuration, and accessibility….accessibility….

What are the requirements for What are the requirements for practice rescue exercises?practice rescue exercises?

1. Practice exercise must involve the actual removal of dummies or persons from the actual permit spaces or from representative spaces.

2. Representative spaces need to simulate the types of permit spaces from which rescues may be performed with respect to:

· Opening size

· Configuration

· Accessibility

PRCS Typing Criteria - Opening Size

-24” or larger-24” or larger

-Less than 24”-Less than 24”

(ID measured at smallest width) (ID measured at smallest width)

PRCS Typing Criteria -Accessibility

Access - Access - PassagePassage into space into space

-Vertical entry into a horizontal portal-Vertical entry into a horizontal portal

-Horizontal entry into a vertical portal-Horizontal entry into a vertical portal

PRCS Typing Criteria - Accessibility

Access - Access - ApproachApproach to the space to the space

Elevated (4’ or more from ground Elevated (4’ or more from ground level) or non-elevatedlevel) or non-elevated

PRCS Typing Criteria - Configuration

External Configuration External Configuration

Shape of portal - Round/RectangularShape of portal - Round/RectangularInternal ConfigurationInternal Configuration

Congested or non-congestedCongested or non-congested

Confined Space Types

CS TYPE 1 / 1E - elevated

Portal Size: Less than 24-inches

Configuration: Round / Oval

Accessibility: Horizontal Entry (vertical portal)



Portal Size: 24-inches or larger






Configuration: Square / Rectangle






Accessibility: Vertical Bottom Entry (horizontal portal)

Internal Configuration

Hands-on Rescue Training:

EachEach member must practice member must practice simulated simulated rescue operationsrescue operations at least once every 12 at least once every 12 months in the actual PRCS or representative months in the actual PRCS or representative spaces that simulate the spaces that simulate the typestypes of spaces…. of spaces….

- Identify the number of types- Identify the number of types

- Design a training matrix for the year- Design a training matrix for the year

- Practice worst case scenarios- Practice worst case scenarios

confined space rescue training compliance issues

Documents

confined space n

n osha

n emergency

internal rescue slide

work n

nonentry rescue slide

confined space fatalities

quick external rescue