Confined Space Rescue Training Compliance Issues Most confined

Confined Space Rescue Training Compliance Issues

Most confined space fatalities are poorly trained rescuers… Many of these heroes died because their employer unintentionally broke the law. OSHA regulations!

How many people die or get hurt seriously in confined space accidents? Prior to the OSHA Confined Space Standard: 63 Fatalities 5, 931 Lost workday cases 6, 951 Non-lost workday cases

How many people die or get hurt seriously in confined space accidents? (Cont. ) The numbers of deaths and injuries if the OSHA standard is followed: 9 Fatalities 890 Lost workday cases 1, 043 Non-lost workday cases

How many people die or get hurt seriously in confined space accidens? (Cont. ) The numbers prevented by following the OSHA standard: 54 Fatalities 5, 041 Lost workday cases 5, 908 Non-lost workday cases

OSHA requirements

OSHA’s 3 levels of protection for confined space entrants: n 1) Permitting procedure identifies hazards and addresses protective measures n 2) Retrieval equipment required for quick external rescue n 3) Rescue services required to be available to perform internal rescue

Criteria of a Confined Space 1) Large enough to bodily enter and work n 2) Limited entry and exit n 3) Not designed for continuous human occupancy n

Permit Required Con. Space 1) Hazardous Atmosphere -Exists or has the potential to exist n 2) Engulfment Hazard -Water, sludge, grain, etc. . … n (3) Entrapment Hazard -Hoppers, converging pipe, etc. . . . n 4) Any other Health or Safety Hazard -Fall, heat, trip, varmints, etc. . . . n

What emergency rescue options does the site have? 1. Employers have three options under 29 CFR 1910. 146(k): a. Utilize their own employees to enter confined spaces to perform rescue services. b. Arrange to have an outside service perform confined space rescues. c. Combination response.

Emergency response options n Because there is a need for quick response, on-site rescue teams are usually preferred.

Definitions: Emergency any occurrence that could endanger entrants n Entry any part of the body breaks the plane of the opening n Self-rescue entrant evacuates the space without assistance n

Definitions Continued: Hazardous atmosphere any atmosphere that could hinder an entrant’s ability to self-rescue n Rescue service personnel designated to perform rescue n Retrieval system equipment used for non-entry rescue n

OSHA Special Emphasis n For 1996, OSHA continues to emphasize those hazards it considers the greatest problems for workers… F F Confined Spaces Lock-out / Tag-out Fires & Explosions Exposure to Lead, Silica & Asbestos.

Proposed Revisions. . . • Revisions due to Steelworkers’ Union Lawsuit: u No method for employees to view monitoring u Concern over an off-site rescue team’s ability to rescue endangered workers.

Lawsuit Result - Changes in the rule regarding rescue. . . n OSHA proposed to amend and STRENGTHEN its final confined space regulation, which was published in January 1993.

OSHA clarification factors. . . Response Time; n Equipment; and, n State of Training. n u OSHA believes that an employer who does not consider these factors is NOT complying with (d) (9) and (k).

Effective Rescue Capability. . . n OSHA believes that, even under the current rule, an employer must take timeliness, and accountability into account if that employer is to have a truly effective rescue capability.

Evaluation & Verification. . . n Proposed provision clearly indicates employers must evaluate and verify that the rescue service’s needed capabilities are present. Documented average response times u Training records u Graded performance evaluations u

OSHA’S Measurement. . . n Based on employer’s effort prior to arranging for a rescue service. n Must ensure the service is indeed capable in terms of timeliness, training & equipment of performing an effective rescue.

Point of Attachment. . . n Entrants shall use chest or full-body harness with retrieval line, unless… n Amend law to allow employers to choose where they attach retrieval lines to workers. Becomes performance-based. u Attachment point that provides the smallest possible entrant profile. u

Employer shall ensure. . . (i) The outside rescuer can effectively respond in a timely manner to rescue summons. n (ii) The outside rescuer is equipped, trained, and capable of functioning appropriately to perform permit space rescues… n (iii) …rescuer is aware of the hazards… n (iv) …provide access. . . n

What is timely response? n “…permit space hazards vary in their capacity to kill or permanently injure employees and that what constitutes ‘timely’ will vary accordingly. ”

Response Vs Rescue Time. . . (1) React Time: Attendant recognizes that the Entrant has a problem. n (2) Contact Time: Attendant contacts the Rescue Service. n (3) Response Time: Rescue Service arrives at the scene. n

Rescue Vs Response Time. . . (4) Assessment Time: Size-up and strategy determination. n (5) Preparation Time: Rescue equipment set-up. n (6) Rescue Time: Reaching, treating, packaging, and evacuation of the victim. n

Timely Response, Training, and Equipment n Establish a competency bench-mark (goal) to evaluate training and response: OSHA suggests 4 minutes in a CPR emergency n The “Golden Hour” is an accepted principle in all injury-related and medical emergencies n

Rescue Stand-by n Goal: 4 -Minute Rescue Response Possible only if rescuers are rigged and ready while the entry is taking place. This is defined as Rescue Stand-by.

Rescue Available Appropriate (and Approximate!) Goals: Respond To CS Scene / 10 Minutes Reach The Victim(s) / 5 -10 Minutes Later Case law update…. 10 minute response held to be not timely in a Nov. 1997 case!

Rescue Available - Supervisor’s Role n Verifies the rescue service is available and the means to summon them is operable…. n Recent Administrative Ruling: Regardless of whether the employer thinks it is unreasonable to call the service for every entry - the employer must comply!

Evaluation Milestones Rescue Stand-by establishes a GOAL of reaching the victim in 2 -4 minutes. n Rescue Available establishes a GOAL of responding to the scene within 10 minutes and reaching the victim within 15 minutes. n Goals are to be strived for - not required…. they should serve as comparative milestones for judging team competency. n

Choosing the Appropriate Response Decision: Stand-by Vs. Available n Each entry must be evaluated to determine the appropriate response mode. n The evaluation must be done by a qualified person (rescuer and/or entry supervisor). n Factors to be considered include the severity of the hazard, required PPE, and the ability of the entrant to self-rescue.

Categorizing PRCS n Cat I - RA n Cat II - RS -Hazard (Potential) is not IDLH -Supplied breathing air is not required -No anticipated difficulty for entrant to selfrescue -Hazard (Potential) is IDLH -Supplied breathing air is required -Anticipated difficulty for entrant to selfrescue

Categorizing Spaces Cat must be reviewed prior to entry n Entrant Supervisor must have authority to make the call…. n Common sense approach to compliance: - Documents intent to make a “timely rescue” - Establishes training goal & evaluation criteria n

Timely Response, Training, and Equipment Rescue n Retrieval n Ventilation & Atmospheric Monitoring n Barriers n Access/Egress (ladders, etc. . . ) n Lighting n Communication n

Timely Response, Equipment Training, and Documented training by each team member via simulated rescues in every type of confined space (Rescue training) n Authorized Entrant/Attendant n First Aid & CPR (Blood-borne pathogens) n Haz Com, PPE, Respiratory, Lockout, PSM n Equipment training (Fall Protection) n

CSR Training: Each rescue team member must be trained to safely perform all assigned rescue duties. - Rigging - Entry (claustrophobia) - PPE utilized outside the space - Equipment maintenance - Individual skills (IPE) n

Hands-on Rescue Training: n Each member must practice simulated rescue operations at least once every 12 months in the actual PRCS or representative spaces that simulate the types of spaces based on opening size, configuration, and accessibility….

What are the requirements for practice rescue exercises? 1. Practice exercise must involve the actual removal of dummies or persons from the actual permit spaces or from representative spaces. 2. Representative spaces need to simulate the types of permit spaces from which rescues may be performed with respect to: · Opening size · Configuration · Accessibility

PRCS Typing Criteria Opening Size -24” or larger -Less than 24” (ID measured at smallest width)

PRCS Typing Criteria Accessibility u. Access - Passage into space -Vertical entry into a horizontal portal -Horizontal entry into a vertical portal

PRCS Typing Criteria Accessibility u. Access - Approach to the space Elevated (4’ or more from ground level) or non-elevated

PRCS Typing Criteria Configuration u. External Configuration Shape of portal - Round/Rectangular u. Internal Configuration Congested or non-congested

Confined Space Types CS TYPE 1 / 1 E - elevated Portal Size: Less than 24 -inches Configuration: Round / Oval Accessibility: Horizontal Entry (vertical portal)

Confined Space Types CS TYPE 2 / 2 E - elevated Portal Size: 24 -inches or larger Configuration: Round / Oval Accessibility: Horizontal Entry (vertical portal)

Confined Space Types CS TYPE 3 / 3 E - elevated Portal Size: Less than 24 -inches Configuration: Square / Rectangle Accessibility: Horizontal Entry (vertical portal)

Confined Space Types CS TYPE 4 / 4 E - elevated Portal Size: 24 -inches or larger Configuration: Square / Rectangle Accessibility: Horizontal Entry (vertical portal)

Confined Space Types CS TYPE 10 / 10 E - elevated Portal Size: 24 -inches or larger Configuration: Round / Oval Accessibility: Vertical Bottom Entry (horizontal portal)

Confined Space Types CS TYPE 11 / 11 E - elevated Portal Size: Less than 24 -inches Configuration: Square / Rectangle Accessibility: Vertical Bottom Entry (horizontal portal)

Internal Configuration

Hands-on Rescue Training: Each member must practice simulated rescue operations at least once every 12 months in the actual PRCS or representative spaces that simulate the types of spaces…. - Identify the number of types - Design a training matrix for the year - Practice worst case scenarios n