Session No. 633 Dial 911 For Permit Required Confined Space Rescue Patrick Furr, COSS Chief Instructor/Technical Consultant Roco Rescue Incorporated Baton Rouge, Louisiana Introduction It is still happening out there, folks. We are killing our employees during permit required confined space entry operations. Entrants are dying because the permit space was not properly prepared prior to entry; and, tragically, some of these fatalities are the would-be rescuers. As disturbing as the entrant fatalities are, it is the would-be rescuer fatalities that are even more disheartening. Would-be rescuers may have been authorized attendants or passersby that reacted improperly and took heroic, but inappropriate action. Or they may have been professional rescuers, who were not trained or equipped for this type of rescue In nearly every case, these fatalities are completely preventable by properly preparing the permit space prior to entry by isolating or if needed, controlling all hazards. However, should an emergency arise, the rescue service must be prepared to respond to these types of emergencies. This includes proper training and equipment to ensure a successful rescue and that everyone involved goes home safe and sound. Options for Rescue There are three primary ways that an employer can ensure there is a capable confined space rescue service in place as part of their written permit required confined space program. These options include (a) an in-house rescue team made up of host employees; (b) a third party contracted rescue service, or (c) relying on 911 emergency responders. All three options have their benefits and their shortcomings. However, it is critically important that the employer focus on the entrant s safety more than any other consideration, be it monetary, personnel, equipment, or any other resource when deciding what type of rescue service to employ. I get around no, not the Beach Boys song. I travel extensively visiting a variety of private and public sector worksites, and I also do the tradeshow/lecture circuit. In my travels, I hear all sorts of variations to the confined space rescue service theme. Many employers use inhouse rescue teams and accept the funding and time commitments required to keep this capability proficient in the needed skills. Some employers rely on a third party professional rescue service to meet this requirement. Sometimes these third party agreements are for the short term such as
during turnarounds, or even for sustaining operations as imbedded contractors. And, still other employers rely on 911 public safety responders for their confined space rescue needs. All three options can, and do work, but the one option that I hear having only a cursory vetting process in many cases is the 911 option. At times I have asked an employer to describe the extent of the agreements between their facility and the 911 responders, and when I hear an answer such as Well, all our employees know the phone number to dial. that s when I offer to buy a cup of coffee so that the employer and I can have a little chat. Assumptions Merely posting the (Rescue) service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard. This presentation focuses on using 911 as your permit required confined space program rescue service. Before I go any further, I want to say that in my view our 911 emergency responders are true heroes. And at times I feel they are under-appreciated. Until a major national disaster hits us, I think a lot of us are guilty of overlooking just what risks these women and men take on a very regular basis. I also think it is important to help employers understand that our Firefighters in particular, have a very extensive set of skills and education they are required to master in order to perform their primary job as Firefighters and Emergency Medical Responders. So here is a news flash. In addition to maintaining proficiency in skills such as pumping operations, ventilating fires, PPE, emergency vehicle driving, medical skills such as advanced airway management, pharmacology, advanced cardiac life support and - are you getting the picture? - the skills and knowledge required to perform technical rescue is a specialty not typically included in a Firefighters job description unless they are assigned to a heavy technical rescue (HTR) squad. NFPA 1006 Standard for Technical Rescuer Professional Qualifications lists all the specialty areas that an HTR squad member may be called on to master. The first set of requirements is established by the department s authority having jurisdiction and may include such things as a minimum level of physical fitness, HAZMAT training, emergency medical care training, and several other requirements. And then there is what used to be referred to as core skills now known as Job Performance Requirements. These knowledge and skill requirements are extensive just on their own before even addressing any of the 19 different technical rescue specialty areas. Some of these 19 different specialty areas include; swift water rescue, trench rescue, machinery rescue, structural collapse rescue, wilderness rescue, and the list goes on. Included in that list of specialty areas is confined space rescue. In Albuquerque, New Mexico, where I live, we are fortunate to have a dedicated HTR squad within our fire department that is trained, equipped, and staffed 24/7. This team is called upon to respond to flashflood rescues in our many arroyos, mountain rescue in the peaks east of the city, vehicle entrapments on two interstate highways as well as our surface streets, and may also be called to an employer s worksite to perform a variety of rescues there. This could be anything from trench rescue to you guessed it confined space rescue.
I hope I have made it clear that our women and men that make up our 911 emergency responders, particularly our Firefighters, are asked to master an awful lot of skills just to prepare to perform their primary tasks of firefighting and providing emergency medical services. It is fairly rare that municipal responders are provided the resources (including specialized training and equipment) to safely and effectively respond to confined space rescue emergencies. Rarer still, for these responders to have been afforded the opportunity to practice in the types of confined space rescues that may be required in their local industrial corridors. Any rescue service would need to be trained and equipped in advance to handle the many hazards and obstacles of permit required confined spaces. It is because of this that it is the employer s responsibility, both from a legal as well as a moral position to engage with the 911 fire department that is being considered as their confined space program rescue service. Evaluating 911 Emergency Response to a Confined Space Emergency Appendix F of 1910.146 (Rescue Team or Rescue Service Evaluation Criteria) is a very valuable means to ensure that both the rescuers and the employer know what the requirements are and that proper agreements are in place prior to confined space entry operations. Any shortfalls must be addressed. This may include lack of training, equipment, staffing, or many other requirements necessary to ensure a response appropriate for the types and hazards of the spaces onsite. The employer's evaluation should consist of two components: An initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform rescues of the kind needed at the facility and whether such rescuers can respond in a timely manner Can the service Talk the Talk Response time required based on level of hazards (IDLH vs. Non-IDLH) Availability and reciprocal notification when unavailable First Aid/CPR Communications Vertical entry greater than 5 feet in depth Proper rescue equipment And a performance evaluation, in which employers measure the performance of the team or service during an actual or practice rescue. Can the service Walk the Walk Rescue services are required to practice rescues at least once every 12 months As part of each practice session, the service should perform a critique of the practice rescue, or have another qualified party perform the critique, so that deficiencies in procedures, equipment, training, or number of personnel can be identified and corrected Have all members of the service been trained as permit space entrants? Can team members recognize the signs, symptoms, and consequences of exposure to any hazardous atmospheres that may be present in those permit spaces? Is every team member provided with, and properly trained in, the use and need for required PPE which may be required to perform permit space rescues in the facility? Is every team member properly trained to perform his or her functions and make rescues, and to use any rescue equipment, such as ropes and backboards, that may be needed in a rescue attempt?
Are team members trained in the first aid and medical skills needed to treat victims overcome or injured by the types of hazards that may be encountered in the permit spaces at the facility? Do all team members perform their functions safely and efficiently? Do rescue service personnel focus on their own safety before considering the safety of the victim? If necessary, can the rescue service properly test the atmosphere to determine if it is IDLH? If necessary, can the rescue service safely perform an elevated (high angle) rescue? Does the rescue service have a plan for each of the kinds of permit space rescue operations at the facility? Teams may practice in representative spaces, or in spaces that are "worst-case" or most restrictive with respect to internal configuration, elevation, and portal size Addressing 911 Responders Shortfalls What if there are shortfalls in the 911 responder s capabilities regarding confined space rescue response? These shortfalls may be due to lack of training, equipment, staffing, or many other requirements necessary to ensure a response appropriate for the types of spaces and the hazards of the spaces. This is where an employer and a 911 public safety agency may enter a cooperative arrangement beyond what may already be expected of 991 responder s normal duties. OSHA states in section (d) (4) of 1910.146 that the Employer shall provide rescue and emergency equipment needed to comply with paragraph (d)(9) of this section, except to the extent that the equipment is provided by rescue services; Anyone who is involved with their local fire department understands that funding through grants and other resources has become very lean in the last several years. As public safety budgets are trimmed down, both career and volunteer fire departments must make budgetary decisions that in many cases result in sacrificing any emergency service capability beyond firefighting and emergency medical services. This would mean that many of the technical rescue capabilities outlined in NFPA 1006 are not within the means of many fire departments. The impact on an employer may be that they lose a previously established ability to rely on a 911 responder for their confined space rescue needs, or they may not be able to rely on that rescue service option during the development of their permit required confined space program. Not all is lost.. It is becoming more and more common for employers to provide rescue equipment and/or funding for rescue training specific to the needs of the employer s confined space program. Various state and local requirements may differ, but generally this can be accomplished by having the employer set up a grant with those monies being donated for specific training or equipment purchases. Depending on the local ordinances, equipment can be directly transferred from the employer to the 911 agency through a simple agreement that outlines its intended purpose and ownership. This type of arrangement may benefit the employer in terms of not only helping to establish a confined space rescue service to meet OSHA compliance, but the same rescue capability may ultimately save lives at other employer s facilities in the area or even save the lives of the 911 emergency responders by allowing them to be trained and equipped to safely respond to this type of emergency. Whether or not there would be any tax advantages to the employer would have to be determined on a case-by-case basis, but generally there would be.
Consider Response Time The response time is generally extended when relying on an offsite rescue service such as 911 emergency responders. This response time must be appropriate for the types of known or potential hazards affecting the confined spaces at the employer s facility. Relevant factors to consider would include: the location of the rescue team or service relative to the employer's workplace, the quality of roads and highways to be traveled, potential bottlenecks or traffic congestion that might be encountered in transit, the reliability of the rescuer's vehicles, and the training and skill of its drivers. One of the biggest factors often overlooked by an employer relying on 911 is the availability of the rescue service. Is it unavailable at certain times of the day or in certain situations? What is the likelihood that key personnel of the rescue service might be unavailable at times? If the rescue service becomes unavailable while an entry is underway, does it have the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately? These considerations apply to any of the three means of providing a confined space rescue service, be it an in-house service, third party contracted service, or a 911 emergency response. But it is typically one of the limitations of relying on 911 more so than the other two means available. It is for this reason that if you are an employer that has 911 identified as the confined space rescue service written into the confined space program, it is of critical importance that you take all the necessary steps to vet them as being a good fit to protect your employees. In addition to all the requirements of appendix F for an initial and performance evaluation of the rescue service, it is of utmost importance that if relying on 911, to pay particular attention to the service s ability to respond in a time appropriate for your needs, and to ensure that reliable two way communications are in place to inform the 911 dispatch of when entry operations are to commence and as importantly, that the 911 dispatch will notify the employer when the service is not able to respond to an emergency so entry operations can be immediately aborted. In Summary Many employers have relied on 911 as their confined space rescue service in both urban and rural settings. It can and it does work as evidenced by many successful confined space rescues performed by 911 emergency rescue services. Unfortunately in some instances, the outcome is tragic with loss of life not only to the Authorized Entrant(s), but also to the unprepared 911 responders who had little clue as to what they were about to encounter. With thorough proper planning and with a cooperative association between an employer and their local 911 responders, 911 may very well be the very best answer to that facilities confined space rescue needs. Bibliography U. S. Department of Labor. Regulations (Standards 29 CFR) 1910.146: Permit-required confined spaces. U. S. Department of Labor. Regulations (Standards 29 CFR) 1910.146: Permit-required confined spaces. Appendix F
National Fire Protection Association (NFPA). 2013. Standard 1006: Standard for Technical Rescuer Professional Qualifications.