September Focus of the Month: Confined Spaces
Permit required confined spaces are high hazard locations that your employees work near and in. Their safety depends on your ability to identify the confined spaces and properly assess the hazards. The risk that permit required confined spaces pose to worker is so great that OSHA regulations specifically address them in General Industry and in Construction.
The regulations require employers to identify and assess the hazards of each confined space, and to document them all in a confined spaces inventory. They also establish training requirements, procedures, employee roles, and responsibilities for entering permit required confined spaces. A significant component of the responsibilities and procedures for entering permit required confined spaces is the requirement to make appropriate rescue services available during every entry.
Permit required confined spaces can be extremely dangerous. If something goes wrong during an entry, any workers in the space could be seriously, even fatally injured. Therefore, a well-conceived rescue plan is imperative. A few seconds, or even a few minutes, can be the difference between life and death for the entrant.
We hope your employees are never involved in an incident in a permit required confined space. Hope is not enough to ensure your employees’ safety, though; planning and preparing properly for the worst-case scenario – the unthinkable – can.
Rescue Service Requirements
Whether your employees are entering a space under a machine in a steel mill, performing maintenance in a tank in a processing plant, or entering a manhole for utility work, the requirements for rescue and emergency services are very similar.
Rescue services can consist of an internal team of trained employees or an external service. Many companies prefer to use the services of a highly trained external service that has extensive experience dealing with emergencies, like the fire department. Before deciding to use an external rescue service, though, you must evaluate it to ensure it will be an effective option.
Regulations require that a rescue service be evaluated to ensure it:
- Responds to rescue summons in a timely manner based on the hazards
- Has the necessary equipment to perform rescues and protect the rescuers
- Demonstrates proficiency with rescue-related tasks and equipment
What constitutes a “timely manner” can vary significantly depending on the hazards of the space. When hazards are immediately dangerous to life and health (IDLH), the rescue service must be able to initiate a rescue immediately. This is only possible if the rescue service is on-site during the entry, which may not be feasible for external services. Non-IDLH hazards require a prompt response, but may allow time for an off-site crew to be called in to perform the rescue.
Evaluating an External Rescue Service
First, you must verify that the external service can perform rescues. This usually includes reviewing documentation to ensure that they are trained to enter and perform rescues in confined spaces, that they have first-aid and CPR training and certifications, that they have the necessary PPE to protect them from the specific hazards in your permit-required confined spaces, and that they are trained to deal with those hazards. The employer is always responsible for the safety of its employees, so you must verify that any external rescue services are trained, capable, and equipped to respond to the hazards of your permit required confined spaces and rescue employees from them.
A performance evaluation should be conducted after the initial evaluation to ensure the service is able to function appropriately while rescuing entrants from a permit space, or from a representative permit space. While not specifically stated in the regulation, it does require the employer to “Evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified” (1910.146(k)(1)(ii); 1926.1211(a)(2)). The only way to evaluate a service’s ability to function appropriately and demonstrate proficiency with rescue-related tasks and equipment is to see them in action.
Non-mandatory Appendix F agrees by stating the evaluation should consist of two components: an initial evaluation and a performance evaluation.
In some areas, 911 and/or the local fire department meet these requirements. Not every fire department or emergency service is trained, equipped, and capable of performing permit required confined space rescues, though, making it imperative that you properly evaluate the local service before relying on it. For utility and construction work where employees enter permit-required confined spaces in many locations, you would need to verify and evaluate each local service before relying on them during an entry.
Once the external service is chosen, you need to work with them so that they have access to all permit spaces from which a rescue may become necessary so they can develop rescue plans and practice rescue operations.
Additional Considerations for External Rescue Services
Most emergency services that do perform confined space rescues do so in addition to their normal duties. There may be times when their normal duties are higher priority, like a fire department that needs to respond to a fire, making them suddenly unavailable to perform a confined space rescue.
Whenever a permit-required confined space entry is made, entry supervisors must communicate with the external rescue services to ensure they are available during the entry. They must also ensure that the external service notifies them immediately if the service becomes unavailable at any time during the entry, so that the supervisor can abort the entry. In a standard interpretation letter dated May 23, 2008, OSHA responded to a question about utilizing a fire department as a rescue service that may become unavailable if they get called to a fire. In the letter, OSHA provides this response:
The employer must evaluate and select an off-site rescue service that has the capability to respond in a timely manner to the particular hazards at issue and to the types of emergencies that may arise in the employer’s confined spaces. The criteria employers can use in evaluating and selecting a service include determining whether the service is unavailable at certain times of the day or in certain situations, the likelihood that key personnel of the rescue service might be unavailable at times, and, if the rescue service becomes unavailable while an entry is underway, whether the service has the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately.
Compliance may require the employer to be in close communication with the off-site rescue service immediately prior to each permit space entry. In the scenario you describe, the employer must ensure close communication with the rescue service during entry operations so that if the rescue service becomes unavailable while an entry is underway, the employer can instruct the attendant to abort the entry immediately. Entry operations cannot resume until the entry supervisor verifies that rescue services are able to respond in a timely manner.
In short, if you rely on external emergency services for confined space rescues, you need to ensure that they are available during the entry, and must be prepared to abort the entry immediately if they become unavailable.
The Dangerous Assumption
A mistake that some employers make that has significant repercussions for their employees is to rely on emergency services for permit-required confined space rescues without evaluating them first. They are a great option if they are capable and willing to do so. As an employer, it is your duty to ensure that they are the right option. No employee’s life should end because an employer failed to ensure that a rescue service could perform a rescue when it is needed.
When the day ends, will your employees go home to their family and loved ones?