To Whom Do You Turn?

Evaluate your site's needs, then look at all of the options for a confined space rescue team.

MANY articles in safety magazines address the subject of confined space rescue, so everyone should be familiar with 1910.146 (d)(9). It states that a company entering permit-required confined spaces must: "Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces . . . ."

The problem for many comes when they try to decide how to fulfill the requirements. Who will be the rescue team? The confined space regulation, 29 CFR 1910.146, is performance-based and is not specific about how a company should comply. All of the options must be considered to see what will work best for your situation. This article will explore the available options, including local emergency services, an employee-based team, and private stand-by rescue teams.

Prior to 1999, many companies blindly relied on the fire department to provide confined space rescue. OSHA's confined space regulation at that time was vague on the subject, and it was often interpreted that using the fire department was allowed even though their capabilities were not known. Frequently, the only "Emergency Procedures" found on a confined space permit were "Dial 911." But at the beginning of 1999 came an updated regulation with more detail about the requirements for rescue.

In 1910.146(k)(i) and (ii), there is new language addressing the requirements for a rescue team. Now, companies working in permit-required confined spaces are required to meet with the prospective rescue service and evaluate their capabilities. The regulation also includes the new "Appendix F (Rescue Team or Service Evaluation Criteria)," a non-mandatory guide to the evaluation of the potential rescue team. It includes guidelines to help determine whether the rescue team has the equipment and training needed to perform rescues from the specific types of confined spaces found at the site. It also addresses whether they can provide a timely response to the spaces, given the degree of hazards found. The appendix suggests a performance evaluation of the team by holding a practice rescue that can be critiqued by a company representative or another qualified party.

Option One: The Local Fire Department
The first choice for a confined space rescue team is often the local fire department. An evaluation of its capabilities using Appendix F will show whether the fire department can provide the rescue service needed. Many fire departments have technical rescue teams that perform not only confined space rescue, but also high angle, trench, and/or water rescues. As a rule, they will be more than qualified to provide the service needed.

Other departments do not have rescue trained firefighters or proper equipment to perform confined space rescues. This may be due to budgetary limitations, departmental priorities, or staffing issues. The local fire department may be a volunteer department and not able to respond quickly enough to meet the requirements of the regulation. Even large metropolitan fire departments may not be able to respond in a timely manner, because generally they will have only one or two rescue trucks to cover the entire city and those trucks may not be close to the company requesting the service.

Initially, a fire department may not even consider being a "designated" rescue team. This can be from a fear of being contractually accountable for their rescue response or being held liable by OSHA under the confined space regulations. This does not mean the department will not respond if you call 911 for a confined space rescue--it means they may not provide the response that a company is required by regulation to have. Normally, a fire department is under no specific directive or regulation requiring them to provide confined space rescue to the public. It may take a bit of education and convincing to get them to open up to the idea.

If the evaluation finds a fire department to be deficient in training or equipment, some companies have provided funding for training fire department members in confined space rescue or have purchased rescue equipment to bring them up to the needed response level. This may be less expensive and more practical than other options. Some fire departments have developed a partnership with other agencies to provide a joint response team. This partnership may be with another public agency such as a water district, with a private organization, or with both. An example of this is in San Diego County where the Santee Fire Department has joined forces with Padre Dam Municipal Water District and the Santee Public Works. Together they funded a response trailer filled with confined space and trench rescue equipment, then cross-trained members of each agency. The firefighters were trained in confined spaces, and the water district and public works employees were trained in rescue. They jointly respond to any emergencies occurring within Padre Dam Municipal Water District or Santee Public Works confined spaces, thereby fulfilling their responsibility for rescue from permit-required spaces. The team also responds to the local region for any public emergency responses. They recently responded to a trench collapse rescue 30 miles from their city.

Option Two: Employee-Based Rescue Team
If the evaluation of your local fire department shows it is not willing or able to provide the rescue response needed, you have to look at other options. One is to set up an employee-based rescue team. Many companies find that having employees trained and equipped for confined space rescue is the only way to provide a timely response. One advantage is that these employees will already be very familiar with their confined spaces and the hazards within. In addition, their response should be quicker since they work at, or near, the location of the entries.

A company must be prepared to dedicate the time and funding necessary to set up a properly established employee-based rescue team. Once the decision is made to set up this type of team, the company will have to provide rescue training to the employees chosen to be rescuers. This course should be 24 to 40 hours and taught by a reputable rescue training company. The length of the class depends on the number and types of spaces on site and degree of hazards found. The curriculum should follow NFPA 1670, "Standards on Operations and Training for Technical Rescue Incidents." The National Fire Protection Association created this standard in 1999 to provide criteria for a public or private rescue team. Although the use of this standard is not required by the confined space regulation it is cited in ANSI Z117.1-2003 (E15.2).

The rescue team should have a comprehensive cache of equipment. Primarily, the team can use normal confined space entry equipment such as a tripod, winch, blower, and atmospheric monitor, but this limited equipment will need to be supplemented with equipment such as rope, a stretcher, and SCBAs. Exactly what equipment a company will need depends on the site. A pre-plan of each space assists in determining what equipment will be needed. The team also will need a rescue plan to operate under, including procedures on how the team is contacted, how it responds to the scene, and the structure of the team.

Option Three: Stand-by Rescue Team
A company's evaluation of rescue needs may find the limited number of permit-required confined space entries do not warrant the time and financial commitment needed for an employee-based team. If permit entries are few, a private stand-by rescue team may be the answer.

A stand-by rescue team generally consists of professional rescuers with their own equipment cache who work under contract or on an as-needed basis. They can be called in when a permit-required entry is to occur and be on hand, on the ready, in case of an emergency. They are usually required to be on site before the entry in order to pre-plan the space, prepare their equipment, and be involved in the permitting of the space. Stand-by rescue teams are often reserved for more hazardous or complicated confined space entries, where the rescue needs may be beyond the capabilities of the local rescue team.

An example of a stand-by rescue team being used is with the Central Arizona Project (CAP) in the Southwest. Annually, the CAP enters river siphons for inspection and cleaning. These siphons are about 20 to 25 feet in diameter and can range from one-half mile to 2 miles long. There are fall, atmospheric, and water engulfment hazards within the spaces, which usually are very remote. When these annual entries occur, a stand-by rescue team of five or more people is brought in. They may be on site for four to eight days, depending on the project.

Conclusion
Finding the right rescue team for a company can be an involved process but it is required if permit-required confined space entries are made. It takes more than just considering the use of the fire department: It takes an evaluation of the rescue needs.

Once the needs are determined, a decision must be made as to which option suits the needs. Then comes an evaluation of the rescue team chosen, to determine who is capable and available. The local fire department, an employee-based rescue team, a stand-by rescue team, or a combination team are potential options to consider. Remember that the goal is life safety for your employees.

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

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