1. Confined Space Rescue Training Compliance Issues

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

3. 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?
Prior to the OSHA Confined Space Standard:
63 Fatalities
5,931 Lost workday cases
6,951 Non-lost workday cases

4. 1,043 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 Fatalities
890 Lost workday cases
1,043 Non-lost workday cases

5. 5,908 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 Fatalities
5,041 Lost workday cases
5,908 Non-lost workday cases

6. OSHA requirements

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

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

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

10. What 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.

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

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

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

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

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

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

17. OSHA 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).

18. Effective 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.

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

20. OSHA’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.

21. Point 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.

22. Employer 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...

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

24. Response 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…..

25. Rescue 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.

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

27. Rescue 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.

28. 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 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.

29. Rescue 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…..

30. Evaluation 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.

31. Choosing the Appropriate Response
Decision: Stand-by Vs. Available
Each 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.

32. Categorizing 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-rescue
Cat II - RS
-Hazard (Potential) is IDLH
-Supplied breathing air is required
-Anticipated difficulty for entrant to self-rescue

33. Categorizing 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

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

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

36. 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)

37. 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 based on opening size, configuration, and accessibility….

38. 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

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

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

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

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

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

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

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

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

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

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

51. Internal Configuration

52. 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