2Most confined space fatalities are poorly trained rescuers… Many of these heroes died because their employer unintentionally broke the law-OSHA regulations!
363 Fatalities 5,931 Lost workday cases 6,951 Non-lost workday cases How many people die or get hurt seriously in confined space accidents?Prior to the OSHA Confined Space Standard:63 Fatalities5,931 Lost workday cases6,951 Non-lost workday cases
41,043 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 Fatalities890 Lost workday cases1,043 Non-lost workday cases
55,908 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 Fatalities5,041 Lost workday cases5,908 Non-lost workday cases
7OSHA’s 3 levels of protection for confined space entrants: 1) Permitting procedure identifies hazards and addresses protective measures2) Retrieval equipment required for quick external rescue3) Rescue services required to be available to perform internal rescue
8Criteria of a Confined Space 1) Large enough to bodily enter and work2) Limited entry and exit3) Not designed for continuous human occupancy
9Permit Required Con. Space 1) Hazardous Atmosphere-Exists or has the potential to exist2) Engulfment Hazard-Water, sludge, grain, etc....…(3) Entrapment Hazard-Hoppers, converging pipe, etc4) Any other Health or Safety Hazard-Fall, heat, trip, varmints, etc
10What emergency rescue options does the site have? 1. Employers have three options under 29CFR (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.
11Emergency response options Because there is a need for quick response, on-site rescue teams are usually preferred.
12Definitions: Emergency - any occurrence that could endanger entrants Entry -any part of the body breaks the plane of the openingSelf-rescue -entrant evacuates the space without assistance
13Definitions Continued: Hazardous atmosphere -any atmosphere that could hinder an entrant’s ability to self-rescueRescue service -personnel designated to perform rescueRetrieval system -equipment used for non-entry rescue
14OSHA Special EmphasisFor 1996, OSHA continues to emphasize those hazards it considers the greatest problems for workers…Confined SpacesLock-out / Tag-outFires & ExplosionsExposure to Lead, Silica & Asbestos.
15Proposed Revisions... Revisions due to Steelworkers’ Union Lawsuit: No method for employees to view monitoringConcern over an off-site rescue team’s ability to rescue endangered workers.
16Lawsuit Result - Changes in the rule regarding rescue... OSHA proposed to amend and STRENGTHEN its final confined space regulation, which was published in January 1993.
17OSHA clarification factors... Response Time;Equipment; and,State of Training.OSHA believes that an employer who does not consider these factors is NOT complying with (d) (9) and (k).
18Effective Rescue Capability... 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.
19Evaluation & Verification... Proposed provision clearly indicates employers must evaluate and verify that the rescue service’s needed capabilities are present.Documented average response timesTraining recordsGraded performance evaluations
20OSHA’S Measurement...Based on employer’s effort prior to arranging for a rescue service.Must ensure the service is indeed capable in terms of timeliness, training & equipment of performing an effective rescue.
21Point of Attachment...Entrants shall use chest or full-body harness with retrieval line, unless…Amend law to allow employers to choose where they attach retrieval lines to workers.Becomes performance-based.Attachment point that provides the smallest possible entrant profile.
22Employer shall ensure...(i) The outside rescuer can effectively respond in a timely manner to rescue summons.(ii) The outside rescuer is equipped, trained, and capable of functioning appropriately to perform permit space rescues…(iii) …rescuer is aware of the hazards…(iv) …provide access...
23What is timely response? “…permit space hazards vary in their capacity to kill or permanently injure employees and that what constitutes ‘timely’ will vary accordingly.”
24Response Vs Rescue Time... (1) React Time:Attendant recognizes that the Entrant has a problem.(2) Contact Time:Attendant contacts the Rescue Service.(3) Response Time:Rescue Service arrives at the scene.An OSHA confined space citation was upheld in a November, 1997 case where the investigating OSHA Ind. Hyg. found that communications between the attendant and entrant in a possible IDLH atmosphere needed to be at least every minutes as opposed to every 3-4 minutes…..the administrative judge upheld the OSHA citation…..
25Rescue Vs Response Time... (4) Assessment Time:Size-up and strategy determination.(5) Preparation Time:Rescue equipment set-up.(6) Rescue Time:Reaching, treating, packaging, and evacuation of the victim.
26Timely Response, Training, and Equipment Establish a competency bench-mark (goal) to evaluate training and response:OSHA suggests 4 minutes in a CPR emergencyThe “Golden Hour” is an accepted principle in all injury-related and medical emergencies
27Rescue Stand-by 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.
28Rescue AvailableAppropriate (and Approximate!) Goals: Respond To CS Scene / 10 MinutesReach The Victim(s) / 5-10 Minutes LaterCase law update….10 minute response held to be not timely in a Nov case!This particular OSHA case used the example of if the space was IDLH that 6 minutes was too long and therefore held a 10 response time is too long. It should be noted that OSHA is referring to arrival at the site of the emergency - not at the actual CS scene…..which may take several additional minutes. The only response mode capable of reaching and viably treating the patient/victim who is not breathing in an IDLH atmosphere is Rescue Standby.
29Rescue Available - Supervisor’s Role Verifies the rescue service is available and the means to summon them is operable….Recent Administrative Ruling:Regardless of whether the employer thinks it is unreasonable to call the service for every entry - the employer must comply!The employer must contact the service at the beginning of the day and if the service could not guarantee its availability for the entire day the employer was obligated to call it before every entry….it was also pointed out that verification required the employer to ensure not only that the service was available, but that the needed equipment, manpower, and expertise was available as well…..OSHA requires the service to be properly trained and equipped…..
30Evaluation Milestones Rescue Stand-by establishes a GOAL of reaching the victim in 2-4 minutes.Rescue Available establishes a GOAL of responding to the scene within 10 minutes and reaching the victim within 15 minutes.Goals are to be strived for - not required…. they should serve as comparative milestones for judging team competency.
31Choosing the Appropriate Response Decision: Stand-by Vs. AvailableEach entry must be evaluated to determine the appropriate response mode.The evaluation must be done by a qualified person (rescuer and/or entry supervisor).Factors to be considered include the severity of the hazard, required PPE, and the ability of the entrant to self-rescue.
32Categorizing PRCS Cat I - RA Cat II - RS -Hazard (Potential) is not IDLH-Supplied breathing air is not required-No anticipated difficulty for entrant to self-rescueCat II - RS-Hazard (Potential) is IDLH-Supplied breathing air is required-Anticipated difficulty for entrant to self-rescue
33Categorizing Spaces Cat must be reviewed prior to entry Entrant Supervisor must have authority to make the call….Common sense approach to compliance:- Documents intent to make a “timely rescue”- Establishes training goal & evaluation criteria
35Timely Response, Training, and Equipment Documented training by each team member via simulated rescues in every type of confined space (Rescue training)Authorized Entrant/AttendantFirst Aid & CPR (Blood-borne pathogens)Haz Com, PPE, Respiratory, Lockout, PSMEquipment training (Fall Protection)
36CSR 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)
37Hands-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 based on opening size, configuration, and accessibility….
38What 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
39PRCS Typing Criteria - Opening Size -24” or larger-Less than 24”(ID measured at smallest width)
40PRCS Typing Criteria - Accessibility Access - Passage into space-Vertical entry into a horizontal portal-Horizontal entry into a vertical portal
41PRCS Typing Criteria - Accessibility Access - Approach to the spaceElevated (4’ or more from ground level) or non-elevated
42PRCS Typing Criteria - Configuration External ConfigurationShape of portal - Round/RectangularInternal ConfigurationCongested or non-congested
43Confined Space Types CS TYPE 1 / 1E - elevated Portal Size: Less than 24-inchesConfiguration: Round / OvalAccessibility: Horizontal Entry (vertical portal)
44Confined Space Types CS TYPE 2 / 2E - elevated Portal Size: inches or largerConfiguration: Round / OvalAccessibility: Horizontal Entry (vertical portal)
45Confined Space Types CS TYPE 3 / 3E - elevated Portal Size: Less than 24-inchesConfiguration: Square / RectangleAccessibility: Horizontal Entry (vertical portal)
46Confined Space Types CS TYPE 4 / 4E - elevated Portal Size: inches or largerConfiguration: Square / RectangleAccessibility: Horizontal Entry (vertical portal)
52Hands-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