Getting Rescue Right
Fatal incidents where rescue capability is not standing by and available are all too frequent.
- By Jerry Laws
- Nov 01, 2010
In May 2010, OSHA announced it had cited and fined a shipbuilder $1.3 million for a fatal incident in which the company allegedly did not test the atmosphere of a confined space prior to entry, did not use explosion-proof lighting, and failed to have rescue standing by and available during an entry. On Aug. 25, 2010, the U.S Chemical Safety Board (CSB) issued a final report finding Xcel Energy and its contractor, RPI Coating Inc., at fault for the Oct. 2, 2007, deaths of five RPI workers when a fire erupted inside a water tunnel at the energy company's Cabin Creek plant west of Denver. The workers were recoating the tunnel using epoxy and a solvent, methyl ethyl ketone, when the solvent ignited.
CSB said the two companies did not effectively plan for the dangers of bringing flammable liquids into the tunnel and also failed to have technically qualified rescuers immediately available and standing by in case of an emergency. The closest technical rescue unit that was equipped and trained to respond was about one hour and 15 minutes' travel time away, according to the board.
Such incidents, unfortunately, happen all too frequently, said Bryan Rogers, contracted stand-by rescue team coordinator for Baton Rouge, La.-based Roco Rescue. Roco which is primarily known for its rescue training programs, also provides stand-by rescue capabilities on site for employers who do not have their own rescue teams or when additional support is needed during turnarounds or special projects. It's a service utilized across the country, most heavily among petrochemical facilities in the Gulf Coast region.
Roco also has a permanent presence for stand-by rescue services in Albuquerque, N.M., at a semiconductor facility. Pat Furr, chief instructor with the Roco group there, said the plant has more than 1,200 documented confined spaces that include boilers and cooling towers. Roco's personnel administer the confined space program, writing from 500 to 1,200 permits and making more than 300 stand-bys per year, he said. In addition, they teach classes, consult on fall protection, and perform some rope access work there, Furr said.
Analyzing All of the Hazards
"Whenever I teach a class or go to a facility for a stand-by, I always stress the importance of considering all the hazards and potential hazards when doing a confined space hazard analysis to determine whether a space is permit required or not," he said. "Typically, the focus is only about what's in the space when it's operating normally. They will go through the steps to prepare the space for entry, such as locking out energy sources and cleaning it out by running water or steam through the system. But they don't always think about the kinds of hazards that they may be bringing into the space. Often, they're thinking, 'This space normally contains benzene, what do we need do to make it safe from benzene?' Then they enter the space to do the work and never really assess the potential hazards of the work they will be doing in the space -- or the hazards they're introducing into the space, for that matter.
"Every single stand-by I go on -- which is dozens of times a year -- my first question is, 'What's inside this space normally when it's operating?' My next question is, 'What are they going to do in the space once they get in there?' You can then use this information to help them determine what hazards they'll likely face. A lot of times, we see where they've made the space perfectly safe for entry, but then go in to weld or use solvents. They may be using a special solvent without any real ability to monitor the air for that specific chemical. They're monitoring for oxygen, LEL, maybe carbon monoxide, maybe H2S gas, but they're not monitoring for that specific chemical that they're introducing into the space.
"I don't want to paint a negative picture here," he added, "it's not always easy to monitor for these potential hazards."
It's rescue that often gives employers trouble. While it's possible to have agreements with local emergency response agencies -- the responders who answer 911 calls -- this method should be used only when the outside agency has been consulted and its capabilities evaluated. "When it comes to rescue services, [customers] often ask us about how they can evaluate their own in- house rescue team or, if they're using an outside service, how can they evaluate those folks," Rogers said. "What I'm getting at here is in the confined space standard [1910.146 Appendix F -- Rescue Team or Rescue Service Evaluation Criteria], it talks about the confined space rescue team needing to be trained, equipped, willing, and able to respond. They've put these restrictions in there to keep people from just listing '911' on the permit as the rescue team without documenting capabilities or establishing a formal response agreement. These local 911 services are not always available to respond, and they're certainly not always trained for confined space rescue.
"So we get lots of calls about, 'How do you ensure that a rescue team is all of those things?' It boils down to testing a team's ability to respond and effect a confined space rescue in a safe, timely, and effective manner. At some of our stand-by jobs, the client will actually go out and setup a mock rescue for us to complete. By doing this, they confirm that the team is actually able to perform. This is really what Appendix F is getting at."
Training On Site
Most of the companies that seek assistance from Roco are at least aware of the OSHA standard's requirements and make a valiant effort to satisfy those requirements, said Rogers, who has worked for Roco for about 16 years and teaches confined space entrant classes for clients.
Before a course begins, he asks to see the client's entry permits, asks about the entrants' experience and knowledge, examines their gas monitors, and studies the confined spaces on site. He'll cover entrant and attendant duties and requirements, equipment, safe entry conditions, air monitoring, rescue -- the works.
"At the end of the day, I like for them to get out of the classroom and do a mock entry," he said. "We actually fill a permit out, sample the air in an actual or representative confined space, handle a monitor, set up a tripod. Whatever equipment they're planning to use, I like to discuss its advantages and disadvantages. I try to leave them with a good understanding of their own program and equipment, rather than a generic course on complying with things in the regulation. I like to get it as specific to their facility as possible."
Once clients get to the stage where they're training their team members and buying gas monitors and rescue equipment, "they've committed themselves to some degree to follow the 1910.146 standard," he said. "They've made some effort to understand it and how it applies to their industry."
Gas monitors, fall harnesses, and rescue equipment have improved significantly in recent years. One device, the Petzl ID, changed how Roco pre-rigs for rescue on about 70 percent of its stand-by work, Rogers said. "We used to use a common, simple 4:1 or 3:1 mechanical advantage system, sort of like a block-and-tackle pulley system. [The Petzl device] allows us to lower the rescuer into a hole and quickly convert it into a hauling system. Once you retrieve the entrant and rescuer, it quickly converts to a lowering system to lower the patient down to the ground."
Today's gas monitors are more capable and much easier for minimally trained entrants to use, but those personnel still must know how to interpret a monitor's readings. Entrants also may be using a variety of gas monitors made by more than one manufacturer, he noted. "For example, there's a turnaround [where] the plant's management has hired a contractor to come in and do the entry, and the contractor rents the atmospheric monitors from a local safety supplier. . . . It's hard for your temporary labor force to get attuned to all of these different devices."
A Construction CS Standard is Needed
OSHA continues to work on a confined spaces standard for the construction industry after issuing a proposed rule in November 2007. Rogers agrees that a standard applying to the construction industry is needed, and he favors applying the 1910.146 general industry standard to the construction industry, as top OSHA officials suggested during an advisory committee meeting in April 2010.
Even new, chemical-free construction confined spaces can be hazardous, Rogers observed. "Just because a new tank is sitting there and has never been used doesn't mean that when we go into the space to weld or apply a special coating, we're not going to create some problems. It's possible that you're going to create some of the exact same problems that an operating plant creates."
Noting the general industry standard is already "field tested" and well understood, he said, "There's no need to reinvent the wheel. They already have a functioning program out there." In addition, many construction contractors already have experience with 1910.146 because they've worked on turnarounds in manufacturing facilities where it applied, he said, adding, "It certainly wouldn't be a shock to the system like when 1910.146 was first introduced."
This article originally appeared in the November 2010 issue of Occupational Health & Safety.