Rescue Requirements

Make sure your communications plan is identified during the pre-entry briefing.

R-E-S-C-U-E. The Merriam-Webster Dictionary defines rescue as "to free from danger, harm or confinement." Confined space rescue can be a very dangerous act. Statistics show that more than 60 percent of those who die in confined spaces are people attempting to perform a rescue.

Confined space rescues are technically challenging because of the environment in which they occur. The spaces, such as underground vaults, silos, storage tanks, and sewers, are often narrow and constricting, preventing easy access by rescuers.

"Confined space rescues are very risky based on the hazards involved," said Kent Freeman, president of California Health and Rescue Training. "Many people do not recognize the hazards and miscalculate their abilities and resources." Freeman, a confined space expert, teaches a course on working within confined spaces at the Sacramento, Calif.-based Safety Center, a nonprofit organization whose mission is to reduce injuries and save lives by providing safety education and training.

To prevent rescuer fatalities, the Occupational Safety and Health Administration requires rescuers to assess the hazards prior to entry and complete a permit or checklist during the entry process. By completing a permit or checklist, the entrant allows for a systematic entry to ensure his or her safety while performing the rescue.
There are several steps that rescuers must follow before, during, and after a confined space rescue. These include:
1. Size-up of the incident
2. Atmospheric monitoring
3. Ventilation
4. Communications
5. Respiratory protection
6. Retrieval lines
7. Mechanical device
8. Lighting
9. Mandatory positions

Monitoring the Atmosphere
Initially, the rescue team will need to size up the incident. To protect the rescue team, entrants need to determine which hazards exist. This can be determined by viewing the initial entry permit. This document will reveal the initial atmospheric monitoring results, equipment in the space, number of entrants in the space, initial entrants’ entry time, and reason for the entry. "We are all human. Mistakes happen, and the permit should be used as a guide, not taken as gospel," said Freeman.

In a recent report, 65 percent of confined space deaths were listed as having resulted from an atmospheric hazard. It should not be a surprise that atmospheric monitoring is a mandatory component in a confined space rescue. According to OSHA, atmospheric monitoring is initiated before the rescue attempt is begun and done continually while you are in the confined space. The readings should be done in 4-foot increments, starting at the top of the space and working your way down. Be sure to record your results on the permit or checklist.

OSHA does not require ventilation when you are entering a confined space, but it does require that a safe atmosphere be maintained when entering a space without respiratory protection. In order to maintain a safe atmosphere, ventilation plans are recommended. To ventilate the area, a natural, forced supply, forced exhaust, or a combination of forced supply and exhaust ventilation should be used. The intention is to keep the air clean for not just the victim, but also the rescuer because it can "buy more time" in the rescue attempt and keep everyone alive.

Documentation and Communications
"To borrow a quote from OSHA, 'If it isn't documented, it didn't happen,' " Freeman said. Permits also must be filled out correctly and thoroughly because they are legal documents. This means the permit also must be cancelled--signed and dated at the completion of the rescue--and filed for at least one year.

The next step, communications, is required, but OSHA allows latitude in how the communications plan is handled. While regulations do state that good communications must occur during a rescue, how they are done is not specified. Communication plans that have proven to be successful have involved the use of portable radios, electronic hardwire systems, voice and hand signals, rope signals, light signals, personal alarm devices, and tapping and rapping codes. Just make sure any communications plan is identified during the pre-entry briefing.

Protective Equipment
"Many items that you will need in a rescue will not be found on a list of mandatory items needed to enter a confined space on a routine basis," said Freeman. "Because the rescuer is entering a known hazard, items deemed unnecessary are vital to the survival of the rescuer and also the person you are trying to save." One such aid is a respirator. Informed rescuers know that atmospheric hazards are the primary killer of those in a confined space and that respiratory protection is not listed as a mandatory component of a confined space entry program. The difference is, on a normal entry, a rescuer would measure the levels of toxicity and not enter if levels were high. In the case of a rescue, the rescuer is entering to save a life and must be prepared to enter even with hazardous atmospheric conditions.

When making a rescue, the entrants may need to employ a harness to save a life. Typically, those entering a confined space utilize a harness that connects to the back at the shoulders or above the head with the use of a spreader bar. This is great when nothing goes wrong. If the victim becomes incapacitated, however, it may be impossible to perform a non-entry type rescue because the victim is hunched over and cannot fit through the opening. When making a horizontal entry, an anklet type of harness should be used on the victim and rescuer.

Retrieval lines are another mandatory item any time someone enters a permit-required confined space. The reason for using the retrieval line is that it allows for non-entry rescue whenever possible. However, the regulation does allow rescuers to disconnect from the retrieval line if conditions warrant. A rescuer should not assume a retrieval line is present and should use rope whenever possible because it provides greater flexibility for the rescuer.

Mechanical devices are required to assist in hoisting the victim when entries are made 5 feet or more below grade. The regulation states that the mechanical device must be readily available, but does not specify the type of device. This provides latitude for the rescuer because everything can be used, from cable winches with fall restraint to rope and pulley mechanical advantage systems in a z-rig fashion.

The final device is lighting. Although it is not considered to be mandatory, employers are directed to provide all equipment needed to complete work safely, and that would include lighting. It is essential to have several lighting sources, including LED-type flashlights that are less likely to ignite a flammable atmosphere.

Personnel
Finally, at all times, four positions at minimum must be filled. These positions include:
• Entry supervisor
• Attendant
• Entrant
• Back-up entrant

"A lot of training needs to be completed for those who perform confined space rescues," Freeman explained. "We need people to understand what a confined space rescue is and what the hazards are. This way, they can adapt to the situation safely."

Remember, confined spaces are hazardous, but with proper training injuries can be reduced. The ultimate goal in performing confined space rescues is to successfully rescue the victim and bring the rescuer back to the surface safely. Every life counts.

Raymond Wagner II is a freelance writer based in Sacramento, Calf. Kent Freeman serves as a Captain and the Coordinator of technical rescue services for the Roseville Fire Department in the greater Sacramento, Calif. area. He is author and developer of the California State Fire Training Division Confined Space "Awareness" program and is the instructor for the Confined Space Awareness individual safety training at the Safety Center in Sacramento.

Entry into Manholes and Vaults: OSHA Interpretation Letter, Nov. 21, 2006

This letter of interpretation, signed by Richard E. Fairfax of OSHA's Directorate of Enforcement Programs, answered a letter sent to a regional director earlier in the year by Edgar R. Mings, business manager of Local 196 of the International Brotherhood of Electrical Workers in Elgin, Ill. Mings asked several questions about qualifications for workers who enter manholes and vaults and the OSHA standards governing such entries. The interpretation letter explained how 29 CFR 1910.269, the general industry standard for electric power generation, transmission, and distribution, relates to 29 CFR 1910.146, the confined spaces standard.
The full letter is posted at www.osha.gov. In it, Fairfax answered seven questions, three of which are printed here.

Question #1: Who is qualified to enter a manhole or vault?

Response: For the purposes of your inquiry, we will assume the entry into the space is to perform work covered by 29 CFR 1910.269. First, employees performing work covered by this standard must, at a minimum, have received the training required by 1910.269(a)(2). Second, if the vault or manhole meets the definition of an "enclosed space," as found in 1910.269(x)1, then any entry into the space would be governed by the requirements found in 1910.269(e) and 1910.269(t). Any person entering an enclosed space or acting as an attendant to an enclosed space entry must, in accordance with 1910.269(e)(2), have been "trained in the hazards of enclosed space entry, in enclosed space entry procedures, and in enclosed space rescue procedures." If the hazards associated with the space cannot be eliminated through the precautions in paragraphs (e) and (t) of 1910.269, then entry into the space must meet the requirements of paragraphs (d) through (k) of 29 CFR 1910.146, OSHA's Permit-required confined spaces standard. The requirements of 1910.146 also apply when an employee enters an enclosed space to perform tasks not covered by 1910.269, OSHA's Electric power generation, transmission, and distribution standard. Paragraph (g) of 1910.146 contains training requirements for permit required confined space entry.

Question #2: Who is qualified to enter and perform work in an underground manhole or vault with energized electrical conductors (12 kV and above)?2

Response: Work with electrical conductors energized at 12 kV in a manhole or vault must be in compliance with 29 CFR §1910.269, OSHA's Electric power generation, transmission, and distribution standard. As noted earlier, training requirements for employees engaged in these operations are found at 1910.269(a)(2) and 1910.269(e)(2). Additionally, if an employee is working on exposed energized parts or is near enough to them to be exposed to the hazards they present, the employee must be a "qualified person," as required by 1910.269(l)(1), which includes having received additional training specified at 1910.269(a)(2)(ii).

Question #3: If a third party inspects the manhole or vault and the manhole or vault is deemed safe, what qualifications does it take to enter the confined space?

Response: Regardless of who performs the determination that the hazards within the space have been eliminated, the qualifications of the entrant do not change. If it is an enclosed space, as per 1910.269(x), then all of the requirements found in 1910.269(e) apply in full, including the training requirements for the entrant.

This article originally appeared in the November 2007 issue of Occupational Health & Safety.

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