PRCS: Who, Why & How
Going back to §(d)(9), we have to prevent unauthorized persons from attempting a rescue.
PRCS: Post-Release Community Supervision; Parks, Recreation and Community Services; or is it Project Revision Control System? As we know, it is none of these. PRCS in the safety world stands for Permit-Required Confined Spaces, and faithful readers of this magazine have read more than 1,000 articles on the subject of confined spaces, with a very good article by Pat Furr of Roco Rescue having just been published in the November 2012 issue1. So it begs the question, "What can Barry add?" Let's see....
From a fictional emergency service call:
Operator: "9-1-1, what's your emergency?"
You (emotionally): "We have an employee who is hurt and needs help. He's inside a 20-foot-deep mixing tank."
Operator (in a calm voice): "What you are describing sounds like a confined space. Is that correct?"
You (in a panicky voice): "Yes, and he can't get out! Can you hurry?"
Operator (calmly): "I'm sorry. Neither our police department nor fire department is qualified in confined space rescue. Thank you for calling. Goodbye."
You (in a panicky voice and talking to the air): "What the $#%@? Did she just hang up on me? I need help!"
I hope this never happens at your company. The time to consider confined space rescue is not when the employee is in the space, but many months prior to your first activities in or near the space. When we review the regulations in paragraph §1910.146(k)-- Rescue & Emergency Services, we are referred to §(d)(9), which says:
"Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue." (emphasis added)
Does that mean that if the space is not a permit space, we don't have to worry about rescue? No, we need to be concerned about all confined spaces. Looking at the text in the "Definitions in 29 CFR 1910.146(b)" sidebar, we see the definitions for both confined space and permit-required confined space. Any space must be a confined space first (and meet that definition), and then it must have an additional hazard (or two) to make it a permit-required confined space.
The Lockout/Tagout Example
Why do we need to worry about definitions and rescue services?
Depending upon your information source, approximately 66 percent of all confined space fatalities occur to the would-be rescuers2. How do we ensure that we can keep these numbers down? Effective training is one answer. Because many of these incidents occur to the those standing by, it would seem industry might be doing fair to okay in training those employees who are supposed to go into the space but may not be sufficiently training the rest of the workforce.
When we talk about lockout/tagout, for example, we have authorized employees and affected employees. Authorized employees are those allowed to work on the equipment once it is locked out, but affected employees have to know not to try to run the machine or remove locks and tags that are on the machine.
For PRCS, OSHA requires something similar. Authorized entrants are trained and have the hazards in the space explained to them. OSHA also says that affected employees are to be trained but does not define who an affected employee is. It is my understanding after reading paragraph §1910.146(g)(2) that affected employees mean employees who are authorized to enter the spaces, rather than employees who are working in the area. Those employees, the attendant, and the entry supervisor have their own set of duties with which they must comply.
Passers-by who are not involved with the entry also need training. They need to be told three things:
1. No one enters a confined space without specific confined space training.
2. They cannot do any of the other jobs unless they have been trained to understand the duties of those positions.
3. They are not to enter a confined space to attempt a rescue.
What's the Solution?
The solution has two parts.
First, the most desirable method is self-rescue. When the employee in the confined space gets into trouble (of any sort), he or she is able to climb back up the ladder and get out of the space, or the attendant begins to retrieve him using the hoist and tripod above the space.
If only it were that simple. More realistically, the employee gets into trouble in the space and either the attendant or a passer-by sees the incident, doesn't stop to think about the consequences, and enters the space, thus putting himself into danger and not being any help to the employee already in the space.
Going back to §(d)(9), we have to prevent those unauthorized persons from attempting a rescue. We'll come back to this later.
Second is to use either an in-house or outside service for rescue. Volunteer employees could make up the in-house team, while the outside service team could be the police, fire departments, or the local hazardous materials team. Regardless which group it is, all of them need training, and both the in-house team and the outside team need to train in your confined spaces
(§(k)(1)(v)) and must make practice rescues at least once every 12 months (§(k)(2)(iv).
If you are using an outside service, you will need to make arrangements with them so they will be on site next to the space when you need to do an entry.
Why Is This Necessary?
Let's say an employee is in trouble in the space, in this case he is overcome with vapors and stops breathing. How long can he live without air? Estimates are that being without air for four minutes gives that person about a 50 percent chance of being revived with CPR and/or mouth-to-mouth resuscitation. The percentages drop by 10 percent for each additional minute without air.
How long does it take to get a rescue team to your site once you call 9-1-1? That presupposes you have previously contacted them and they will perform a rescue one they get there. Once they arrive on site, how long does it take them to prepare to enter the space? If you did not anticipate a vapor problem and your employee is overcome by a toxic environment, it means that the rescue team's members will need SCBAs and some level of PPE before they can enter. Generally, if the rescue team is not on site at the beginning of the entry, they are there only for recovery.
Keeping Unauthorized People Out of Confined Spaces
There are many real and apocryphal stores about George going into a space to rescue Jim and both end up in trouble; then Bob sees them and goes in and gets into trouble; and it continues until a properly trained and properly equipped team does not perform rescue -– they perform recovery of the bodies.
I do'’t have the answers. I would ask that readers of this article log on to the www.oshonline.com website, locate this article in the archives, and leave comments on how they would ensure that, in the heat of the moment, an untrained friend doesn't enter the space and provide an extra body to be recovered.
The How (the Program)
The regulations (§1910.146(d)) specify the details that are required in a confined space program. I would urge all who have confined spaces, be they just confined spaces or permit-required spaces, to have such a written program. As a famous safety manager once told me, ensure that your program is developed, written, and numbered in the same order as the regulation is. If you are audited, your program will match the audit elements, and the compliance officer will not have to hunt for each element.
Don't forget to document, document, and document what is done and what training was performed. Retain those documents for the time period as required in the regulation or according to your company’s records retention policy.
Definitions in 29 CFR 1910.146(b)
"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.
"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.
1. Furr, Pat. Confined Space Rescue: The Good, the Bad, and the Ugly. November 2012. Online at: http://ohsonline.com/articles/2012/11/01/confined-space-rescue-the-good-the-bad-and-the-ugly.aspx?sc_lang=en
2. WorkSafeBC – (OSHA in British Columbia, Canada) http://www2.worksafebc.com/Topics/ConfinedSpaces/ConfinedSpaceRescue.asp
This article originally appeared in the February 2013 issue of Occupational Health & Safety.