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Confined Space: Preparing for Rescue
With a focus on decreasing or minimizing injuries and fatalities, Permit Required Confined Space 1910.146 was established by OSHA as a safety standard to protect employees from injury or fatality when working in a confined space. The standard stipulates that when employees enter permit required confined spaces, the employer’s confined space program must include necessary measures and resources for rescue:
- Shall have all confined spaces identified and those considered hazardous marked with "Permit Required"
- Shall have a rescue team that is available
- Shall have training focused on the skills necessary to rescue in confined spaces
- Shall have proper rescue equipment for the entry/exit of a confined space
Experience shows that preparedness, rescue-focused skills training, knowledge and proper utilization of rescue equipment, and real scenario hands-on practice make rescue teams more proficient and reduce human error when rescuing in confined spaces.
Identifying Confined Spaces
Employers must have all confined spaces identified and those considered hazardous marked with "Permit Required."
OSHA defines a confined space as "large enough that a person can bodily enter, has limited or restricted means for entry or exit, and is not designed for continuous occupancy." And if the space has one or more of the following—potential for hazardous atmosphere, potential for engulfment, entrapping internal configuration, or any other serious hazard—OSHA requires these spaces be classified and marked as "Permit Required."
OSHA requires employers to have a written confined space program that includes specific procedures for rescue in all permit required confined spaces identified at their facilities.
Employers must have a rescue team available while employees are working in a permit required confined space. The OSHA standard, however, has a caveat: Your rescue team must be able to respond in a "timely manner." So what is a "timely manner," knowing seconds count when an incident occurs?
OSHA defines "timely manner" based on the hazards associated with the space. An exception does exist and must be noted: "If entering an Immediately Dangerous to Life or Health (IDLH) Permit Required Confined Space, the rescue team is required to be at the space, onsite, and ready to rescue prior to entry (refer to 1910.134)."
Some employers misunderstand the permit required space requirements and think that only bad atmospheres cause injury or fatality. Too often I hear, "Our permit spaces are not that bad, so we don't have a rescue team at the site, we just write 'Call 911'on our permits." But it is not only the atmosphere in a space that causes injury or, worse, a fatality; it can be a medical condition such as a heart attack, stroke, or heat exhaustion in a space. And sadly, a high percentage of confined space fatalities are unauthorized personnel, co-workers trying to save the worker in trouble.
Having had the misfortune of conducting confined space entry and rescue training after a confined space fatality—a worker had a heart attack and neither the employees nor the fire department could extract the worker or get to the worker to administer first aid in a space deemed "not that bad"—I can attest that this is not a pleasant experience. It's after the fact. Grief-stricken employees are now learning what they should have been taught before the incident, causing another set of emotions; they're distraught that their employer did not comply with the requirements of 1910.146.
I consider myself knowledgeable in Permit Required Confined Space 1910.146, being immersed daily as a training instructor of confined space entry and rescue, a certified standby rescuer, and an industrial safety consultant. Never have I read or found these words written by OSHA: "If your permit required spaces are 'not that bad,' you do not have to have a rescue team available or on standby."
Trained and equipped rescue teams need to be on site prior to entry and should consist of employees or a third-party rescue service, or a combination thereof. Your local fire department typically cannot be considered an option because there is no guarantee of being able to respond in a timely manner and it may not have the technical training or equipment to perform rescue.
For permit required confined spaces, OSHA requires employers to develop and implement procedures and have a rescue team proficiently trained and equipped on site for rescuing entrants and preventing unauthorized personnel from attempting a rescue. A rescue team on site at your facility prior to entry is not just critical, but is required in 1910.146.
Confined Space Rescue Training
Employers must have training focused on the skills necessary to rescue in the facility's confined spaces. Developing a rescue team that is proficient and able to perform a rescue is accomplished through rescue-focused skills training with simulated exercises, real-life scenarios specific to your facility. Rescue training should encompass those skills necessary for your facility's confined spaces. Incorporate the skills needed to meet Curriculum Standards (NFPA, OSHA, etc.) into scenarios as soon as possible to help the students start to tie it all together. Students should have the skills (able to tie knots, rig, etc.) but need to apply those skills to rescue scenarios where they have to think through how to rescue and make team assignments. Skills proficiency is only half of the training; the other half is how to apply the proficiency into a rescue scenario, how to think through the scenario keeping rescuers safe, and how to identify hazards and challenges associated with rescue.
Training instructors also need to be familiar with your facility and confined spaces so they can design and deliver an effective rescue training program that meets your needs. They should train using the rescue equipment utilized at your facility since your rescuers must have knowledge on how to use their equipment properly and effectively.
Confined Space Rescue Equipment
Employers must have proper rescue equipment for the entry/exit of a confined space. In addition to rescue equipment being available, rescue teams must have training on the equipment and be knowledgeable on how to use the equipment appropriately. This requires employers to assess their existing equipment, evaluate the latest available, and provide their rescue team with equipment that reduces error and increases proficiency.
In the fire service, there is a saying: "One hundred years of tradition unimpeded by progress." In an industry such as the fire service, we are proud of our rich history and traditions; however, many times this gets in the way of progress. The same is true with confined space and rescue equipment. The technological and design advance in the rope rescue equipment has moved significantly ahead in recent years. It is important to keep up with what is available and determine which items of equipment are most beneficial for your team.
Some of the benefits of employing newer equipment: It's easier for rescue personnel to stay proficient on; can reduce the chance for human error of rigging incorrectly; can reduce the number of rescuers needed (extremely beneficial for facilities with minimal rescue staff); can reduce the amount of hardware needed; and can reduce overall time to rig so rescuers can get to the worker at risk safely and quickly.
Here are a few of the newer style rescue devices available today. I am not recommending any of these brands, just providing examples of advanced equipment.
- Petzl ID’l and CMC MPD. A lowering system, raising system. Eliminates some old-school equipment and can easily be operated by one person. Old-school systems required two to three people to operate.
- Petzl ASAP Lock. Belay device hooked to the rescuer and the rope. Eliminates a person to manage the belay line.
- Anchor Straps. Adjustable or fixed-length straps that replace webbing. Eliminates the need to remember how to tie a water knot or how to loop the webbing around an anchor.
- Rock Exotica Aztek Kit and Petzl Jag. Assists with rescuing a person who has fallen and is hanging from their harness, as well as pick offs.
- Petzl Rescuecender. A rope grab much easier to use than tying prusiks or using the older-style rope grabs.
- CMI Uplifter. 4 to 1 system with a built-in, easy-to-use brake that can be used for lowering and raising.
- Yates Spec Pak. Short board that immobilizes the head and neck and can be hoisted vertically or horizontally, a great device for confined space rescue.
There are other devices and brands in the marketplace, and it is recommended that employers assess their equipment needs and evaluate multiple brands to determine what equipment is best for their rescue teams.
To help you assess existing equipment and evaluate new equipment, look for a company that conducts rescue training, performs standby rescue services, and sells rescue equipment. These full-service companies are staffed with real-life rescue experts who are knowledgeable in all areas of rescue and use rescue equipment. They can help you determine what works best for your facility. For your rescue team to be proficient in rescue and in the use of rescue equipment, the most effective training is hands-on and simulated real-life scenario exercises preferably led by a confined space rescue professional training service.
Updating rescue procedures, equipment, and training specific to your facility is an integral part of the portion of the 1910.146 standard that often gets forgotten: Rescue Team. Follow the standard and continuously prepare your rescue team for higher performance with a focus on decreasing or minimizing injuries and fatalities.
Not being able to rescue a worker from a confined space has a devastating impact on the company and, more importantly, the employees.
This article originally appeared in the November 2017 issue of Occupational Health & Safety.