Occupational Health & Safety

A Report on Confined Space Retrieval. . .

. . . to Program Managers and Workers.

THIS report has been produced by a confined space "expert" Consultant. Expert because he knows how to spell "compliance," has been in a bunch of spaces, sometimes carries a briefcase, and is not from your hometown! The client is you: the person responsible for entries into permit required confined spaces at your site.

Let's get started with a quick look at the basics so we can progress to some of the "pointy" issues that you either already have, or surely will, run into.

OSHA Definitions
According to definitions in OSHA's 29 CFR 1910.146:
"Confined space" means a space that:
(1) Is large enough and so configured that an employee can bodily enter and perform assigned work; and
(2) Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces that may have limited means of entry.); and
(3) Is not designed for continuous employee occupancy.

Please note that normally (there are always exceptions to a rule, like the ones listed below under the heading Space Identification and Classification), permanent stairways are not considered limiting or restricting access and egress, while ladders and temporary stairs are considered limiting.

And that:
"Permit-required confined space (permit space)" means a confined space that has one or more of the following characteristics:
(1) Contains or has a potential to contain a hazardous atmosphere;
(2) Contains a material that has the potential for engulfing an entrant;
(3) Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
(4) Contains any other recognized serious safety or health hazard.

A space must meet all three of OSHA's criteria in order to be deemed a confined space (CS). Once determined to be a CS, the space must meet only any one of the four criteria to be determined a Permit Required Confined Space (PRCS).

All confined spaces that are closed up and not exposed to the outside atmosphere should be considered regulated PRCSs when they are first opened. For many PRCSs, it may then be possible to reclassify them based on eliminating all hazards (i.e., by effective isolation methods) and potential atmospheric hazards. The only exception to this re-classification rule is OSHA's Alternate Entry procedure regarding spaces that only have a hazardous atmosphere that is controlled by continuous forced air (i.e., positive-pressure) ventilation. The Consultant does not recommend employing this section of the OSHA standard (section (c)(5)) unless sufficient time is available for an entrant to safely exit the space if the ventilation fails or stops.

Space Identification and Classification
Spaces that do not meet the criteria of a confined space commonly should not be classified as a CS, much less a PRCS, because of the dilution effect on the permit program. These spaces should more accurately be labeled as "Restricted Work Area--Authorized Personnel Only." The client should train employees and contractors about the definition of "authorized" and who falls within this classification.

The Consultant often observes some spaces that are identified as PRCSs although the entry into and egress from these spaces were standard-sized doors that allowed entrants to access and leave the space by simply walking through an open doorway. Note the following from the OSHA Preamble:
As indicated in the preamble to the proposal. . . , OSHA notes that doorways and other portals through which a person can walk are not to be considered limited means for entry or exit.

As long as the doorways remain unobstructed so they do not hinder the entrant's ability to escape the space, these spaces should not be considered and labeled as a CS or extrapolated to a PRCS. However, if they contain or potentially can contain a hazard that would inhibit an entrant's ability to escape the area unaided, then they could be classified as a CS/PRCS. OSHA's Enforcement Directive for compliance officers notes that:
The determination whether a space has "limited or restricted means for entry or exit" within the meaning of the standard's definition of "confined space" should include consideration of whether, in light of the hazards posed by the particular space at issue, the configuration or other characteristics of the space would interfere with an entrant's ability to escape or be rescued in an emergency situation.

For example, a basement that is entered by an unobstructed doorway and permanent stairwell, but contains pipes or other physical impediments, may be classified as a CS because the impediments could hinder the entrant's ability to escape the space. The space could then be classified as a PRCS if it contains any one of the hazards (even if only potentially) listed above.

Signage
Based on the Consultant's experience, it is suggested that all signs in the confined space program be uniform in size, shape, colors, and wording. This would better facilitate recognition and educational intent.

Emergency Response Hierarchy
OSHA regulations are based on a hierarchy of protection for CS entrants. The first level of protection is a properly employed permit system because it will provide a checklist for hazard detection and then elimination or mitigation prior to entry.

OSHA has pointed out, however, that even within a perfectly administered program, the unforeseen can happen requiring the urgent removal of entrants from a space. The proper emergency response sequence is for the entrant to self-rescue if possible; failing that, to be extracted from outside the space (retrieval); and finally to use an entry rescue team as the last alternative. It is important to recognize that these emergency response strategies should be attempted in the proper order for EVERY confined space.

Also, prior to entering a confined space, the facility emergency and rescue services should be notified (and confirm the service is available) that an entry is about to be made in that particular space. Entry cannot be made unless the service (or alternate service) is available to respond.

Full-body Harness and Lifeline
All
CS rescues require reasonable attempted retrieval if self-rescue is not feasible and before entry rescue is attempted. Retrieval is feasible upon any initial entry into a confined space.

Additionally, initial entry into vertical confined spaces that are 6 feet deep or greater should incorporate fall protection measures that would be fulfilled by the use of a full-body harness and attached lifeline that could be used for both fall arrest/fall prevention and retrieval. Please note the following quote from the Preamble of CFR 1910.146:

. . . OSHA believes that, considering the suddenness with which permit space hazards often manifest themselves, entrants who have disengaged from their retrieval lines are not adequately protected from permit space hazards. Therefore, the Agency expects that employers who have a reasonable basis for determining that the use of retrieval systems will pose excessive risk of entanglement will implement other rescue equipment and procedures.

The Consultant suggests that entry work practices should include documentation of any action that is an exception to normal OSHA requirements. An example of this would be to document an entry team's reasons for removing or not wearing a harness and lifeline. And if, for some reason, it is determined necessary to remove the lifeline or harness during an entry, the entrant should notify the attendant of such action.

Retrieval
Again, retrieval should be contemplated in every confined space emergency response before entry rescue. Exceptions include the internal configuration leading to a victim entanglement hazard and patient condition that warrants technical patient packaging.

Retrieval should be based on visual or verbal confirmation that the patient can be moved safely. If the patient cannot be seen or communicated with, entry rescue should be initiated. It should be stressed to attendants to attempt untangling lines that are wrapped around obstacles in the space, but that it is unsafe to continue to pull an entrant who is hung up on that same obstacle. The client should note the accompanying Consultant-suggested retrieval checklist.

Communications
OSHA requires that employers . . .

1910.146(d)(4). Provide the following equipment (specified in paragraphs (d)(4)(i) through (d)(4)(ix) of this section) at no cost to employees, maintain that equipment properly, and ensure that employees use that equipment properly;

1910.146(d)(4)(iii). Communications equipment necessary for compliance with paragraphs (h)(3) and (i)(5) of this section;

1910.146(h)(3). <Entrants must> Communicate with the attendant as necessary to enable the attendant to monitor entrant status and to enable the attendant to alert entrants of the need to evacuate the space as required by paragraph (i)(6) of this section;

1910.146(i)(5) <Attendants must> Communicate with authorized entrants as necessary to monitor entrant status and to alert entrants of the need to evacuate the space under paragraph (i)(6) of this section;

Obviously, entrant-attendant communication is vital to OSHA because of the added protection afforded the entry team. The language of these provisions is performance-oriented, allowing any effective means of accomplishing the goal set by the two paragraphs. Successful permit space programs currently in effect use such systems as two-way radios, television, or other continuous electronic monitoring equipment in combination with alarms and voice contact as effective methods of communication between attendants and authorized entrants.

While these types of systems (because they were selected by the employer involved on the basis of experience) are acceptable, the exact type and extent of communication needed to meet paragraph (h)(3) of the final rule are dependent on the hazards that might arise and the operations being performed within the permit space. For example, work that must be performed in IDLH atmospheres (because engineering controls are infeasible) might necessitate the use of continuous monitoring equipment. In contrast, authorized entrants performing work in spaces that pose only mechanical hazards would need a communication system that provides only periodic monitoring.

An attendant sitting in a chair outside a CS must be alert to the entrant's actions and needs. Radio use in a CS often is not adequate because of garbled messages caused by the blocking effect of the metal walls of the space and by the naturally poor acoustics inside the space. The Consultant recommends the client consider obtaining hard-wired communications equipment as a more reliable means of effective communications. Otherwise, it is important to establish a communications protocol within the PRCS entry procedures that calls for entrant checks on a regular basis.

Anchorage
It is suggested the client assess all spaces to determine whether permanently installed anchor points are feasible to enhance rescue response time and efficiency. It is also recommended that entry teams intending to utilize a tripod anchor without a mechanical winch attached to the tripod be taught to install a bottom directional pulley to counter side-pull that could topple the tripod (see the photo below).

Entry teams also must be reminded that all entries requiring tripods or other retrieval equipment must have that equipment stationed at the entry site before and during the entry operation.


Note the bottom directional pulley rigged to offset side-pull.

Training & Retraining
OSHA requires that training be provided for all workers who are required to work in permit required confined spaces. Training should be performed before initial work assignment begins; additional training is required when 1) job duties changes, 2) there is a change in the permit space program or the permit space operation presents new hazards, and 3) when there are deviations from the permit space procedures or inadequacies in the employee's knowledge or use of these procedures.

The training shall introduce new or revised procedures, as necessary, and shall establish employee proficiency. Furthermore, the employer must certify that training has been accomplished.

Confined Space Emergency Retrieval Checklist

Retrieval (external rescue) shall be contemplated in every confined space emergency before entry rescue (internal rescue) is attempted and only after self-evacuation (entrant self-rescue) is determined to be not feasible.

Exceptions:
1) Rescue subject's (incapacitated entrant) medical condition would warrant technical patient packaging such as spinal immobilization.
2) No visual or verbal communication exists with the rescue subject.
3) There are physical hazards in the retrieval path that could injure the rescue subject or inhibit the retrieval process.
4) Retrieval line entanglement hazards cannot be successfully negotiated.

Note: Immediately life-threatening hazards may be cause to pre-empt the above exceptions. For example, it would be appropriate to attempt retrieval of a rescue subject that cannot be seen or verbally contacted (# 2 above) but is believed to be in a hazardous (IDLH) environment without appropriate life-saving PPE.

Note: This checklist is a recommended tool only. It is not an OSHA requirement, but rather a simple guide.

If the client plans to implement the suggestions included in this report, then it may be necessary to conduct retraining of the CS entry personnel. Additionally, entry team members should be trained on the proper set-up and use of the retrieval equipment, as necessary. Remember, a pre-entry safety briefing on the hazards, controls, and emergency response should be an ongoing procedure--regardless of how effective or experienced you think your program is.

It is further suggested that when the facility performs initial or refresher training, emphasis should be placed on procedures such as thorough atmospheric monitoring techniques before and during entry. Personnel should be cautioned against just monitoring at the entry portal only, rather than striving to monitor the entire space. Also, it is important to relay to entry teams the critical importance of keeping fully hydrated while working in confined spaces, because heat-related illnesses are common in entry work. Engineering controls such as ventilation and air conditioning are recommended to combat the heat in confined spaces.

Summary
The client should be proactive with the CS program strategy. By continually re-evaluating its program and its spaces, the client can refine its program with the dual goals of preparedness and compliance that keep worker safety in mind.

It is the Consultant's experience that when a compliance officer assesses an employer's program, the efforts made by the employer prior to any potential or actual incident are deemed crucial to the success of the program. The Consultant finds it a pleasure to work with an organization that strives for the highest standards of safety rather than the minimum standards of compliance.

This article originally appeared in the February 2003 issue of Occupational Health & Safety.

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