Replies to This Discussion

Permalink Reply by lutan1 on September 21, 2009 at 3:01am

What this discussion clearly highlights to me is that there is almost a conflict in interpretations and requirements for the emergency services as oppossed to industry.

In industry, there would appear to be very different legislative requirements to that imposed on the emergency services.

Very confusing system, from an outsiders perspective.

Over here in Oz, we have the Legislation in place and whilst the emergency services are exempt in an emergency siutation, they still clearly have a duty of care to protect their members from harm. There is not however a different set of requirements on how they respond, what they do once there and the equipment they use. They may have internal requirements, but that's it....

Permalink Reply by TrainingTECH1 on September 21, 2009 at 4:44pm

I have to agree. Some states exempt rescue departments from some standards...I met with a rep and their response was "you gotta do what ya gotta do". Anothe rep could tell you something completely different.

Permalink Reply by Doesn't play well with others. on October 2, 2009 at 11:18am

The TEEX (Texas A&M) Confined Space Rescue Technician (NFPA 1006) curriculum is;

Mod 1; Knots
Mod 2; Patient Packaging
Mod 3; Hauling Systems
Mod 4; Lowering Systems
Mod 5; Federal Regulations
Mod 6; Confined Space Hazards
Mod 7; Atmospheric Monitoring
Mod 8; Hazard Control and PPE
Mod 9; Confined Space Rescue
Mod 10; Operations Level Scenarios
Mod 11; Technician Level Scenarios

36 hour course

Prerequisites; Rope Rescue Awareness or Operations (NFPA 1006 Ch5 JPRs)

If I remember right, the Proboard certification had a lot of medical and atmospheric monitoring questions, without a background in EMS (basic level) or HAZMAT (at least awareness) I doubt the test would have been easy.

Let me know if you need some more info, I have the student manuel and our textbook on a shelf here at home and the station.

Permalink Reply by Daniel Bacigalupo on December 30, 2009 at 11:32am

Hi Jeff, sorry by the delay of my answer.
The name of the book is "Rescate en espacios confinados" the author is Delfin Delgado and the editorial is "Desnivel". I think that you can find it on the web.

I'll appreciate if you can send me a SOP for improve mine.
Keep safe.
Daniel

Permalink Reply by Jason Brooks on January 3, 2010 at 2:46pm

I am a little late to the party on this one, but I have to disagree on this completely. The standard you are using refers to the tagline/belay/retrieval system for the entrants. It does not refer to using a single or double rope system. While we use a lowering system to get out people into a space, typically a 4:1, we use a tagline attached to them unless it is an impediment. The lowering system can then be detached once in the space and sent back up for the next rescuer or to remove a victim. The rescuer/entrant is still on a system at all times, unless it is a problem. There is no reason to have every entrant/rescuer attached to two systems at all times.

Add into the equation, communications and air and you will have one hell of a mess. We are fortunate enough to use ResCom for comms, thus elimintating a line. But we still have air and comms/tagline on each person.

Permalink Reply by Ben Waller on January 9, 2010 at 10:02pm

Sorry for the very late reply - I've been busy.

The OSHA confined space regulations require both a mechanical advantage system and a fall arrest/belay system. The M:A system cannot be used as the fall arrest system, ergo two lines are required.

That's true even if ladders are used. The rope system must be able to retrieve entrants (or rescuers) who become too injured, incapacitated, or ill to climb the ladder or to assist in their own rescue.

Permalink Reply by TrainingTECH1 on January 16, 2010 at 7:08pm

Daniel,

Email me off line - jmatthews@technicalrc.com Let me see what I can come up with.

Permalink Reply by Ben Waller on January 20, 2010 at 8:28pm

From OSHA 1910.146 the Non-Entry retrieval system part of the standard:

"1910.146(k)(3)
To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements.

1910.146(k)(3)(i)
Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant's back near shoulder level, above the entrant's head, or at another point which the employer can establish presents a profile small enough for the successful removal of the entrant. Wristlets may be used in lieu of the chest or full body harness if the employer can demonstrate that the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative.

1910.146(k)(3)(ii)
The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical device shall be available to retrieve personnel from vertical type permit spaces more than 5 feet (1.52 m) deep"

For entry rescue,

Mandatory Appendix D-1 has the following as seperate items on the permit checklist:

Safety harnesses and lifelines
for entry and standby persons ( ) ( ) ( )

Hoisting equipment ( ) ( ) ( )

OSHA makes a clear distinction here between the hoisting equipment (winch or MA rope system) and the lifelines/retrieval lines.

OSHA 1926.502 (the fall arrest standard that also applies to confined spaces) states;

(d)(16)(iii)

be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level;

(d)(16)(iv)

bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet (1.07 m); and,

(d)(16)(v)

have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet (1.8 m), or the free fall distance permitted by the system, whichever is less.

A mechanical advantage system doesn't have the shock-absorption capability required for a vertical fall arrest system. (RipStitch lanyard or something similar)

The confined space standard does allow for disconnecting from the retrieval/tag line if it is an entanglement hazard or otherwise causes a more severe hazard than operating without the retrieval line...but that isn't during the lowering phase in a vertical space.

Don't limit perceptions to just the confined space standard - OSHA has standards that overlap, and it doesn't have to be in the confined space standard to apply to confined spaces.

Permalink Reply by Ben Waller on January 20, 2010 at 8:32pm

JB, that's still a two-line system during the lowering phase when a fall is possible. A fall is always possible, due to the potential failure of the MA system.

Note that my comment didn't say that the entrant rescue had to be attached to both lines all of the time, just that two had to be used.

No MA system that I've ever seen can function as a fall arrest system that's compliant with OSHA 1926.502.

Add that the NFPA 1670 standard requires a redundent belay for high angle rope work (which includes confined spaces) and if you use a single-line lowering system and have an accident, it's going to be difficult to defend the single line according to either the combination of OSHA 1910.146 and 1926.502 or NFPA 1670.

OSHA doesn't enforce NFPA standards, but the courts definately do.

Permalink Reply by Ben Waller on January 20, 2010 at 8:35pm

Francis,

The "mechanical device" must be a mechanical advantage system.
OSHA generally enforces this as either a rated winch (the drum provides the MA) or a block-and-tackle MA system like the ones commonly used in high angle and vertical confined space rescues.

You don't have to stay on the MA system once you reach a solid bottom in the space and you don't have to stay on the retrieval line if it creates a greater hazard (entanglement, etc) as you state.

However, the practicalities of the lowering/raising phase of confined space rescue dictate seperate MA and fall arrest/belay lines to meet the intent of the two applicable OSHA standards.

Permalink Reply by Ben Waller on January 30, 2010 at 7:00pm

Francis,

OSHA has applied the fall arrest standard to confined spaces in my state, particularly with the overlap between trench rescue and confined space rescue and the fact that many confined spaces involve construction work such as installing new product mixing equipment, new mechanical devices such as pumps, and/or new electrical equipment.

If your personal experience with OSHA is different, wait until you get a new OSHA inspector with a different interpretation.

The OSHA regs don't mention the general duty clause, either, but the general duty clause still overlaps every other OSHA standard.

You can attach more than one person to a vertical MA system in a confined space entry or rescue, just as you can attach more than one person to a shaft safety line for construction.

I did not say that OSHA requires a tag line at all times - it clearly doesn't. However, close interpretation will show that they require a redundent belay seperate from the MA system for vertical rope work within a confined space. Further, the OSHA standard I cited requires a mechanical advantage method to perform non-entry retrievals for entrants. A fixed point anchor will not do that. What that means is that you don't have to attach the tag line to the MA system - it can be secured to a fixed point when no lifting or lowering is in use. However, good luck performing a non-entry retrieval without a MA system (either rope/pulley system or a winch) if you just attach a tag line to the rescuer and secure it to a fixed point outside the space.

More importantly, in the U.S., the "reasonable man" legal standard is going to be the NFPA 1006 and 1670 standards. Both of those standards clearly require redundent belwys for vertical rope work, including vertical rope work in confined spaces.

Regardless, I'm not going to intentionally under-engineer a confined space rope system due to an assumed good relationship with a specific OSHA employee.

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