Rescue Plan? You must have lost your mind…there is no such requirement in 1910.146 for each entry to have a “rescue plan.”
This is the typical response we get during our audits and 3rd party investigations, and let’s say folks are not happy with the idea that each entry must have a rescue plan. I want to share with you the EXACT QUESTIONS that an OSHA CSHO will be asking should your facility have the privilege of going through an OSHA inspection where Permit Required Confined Spaces is a topic of inspection. You can use these questions to see if your rescue plans would pass OSHA’s test:
Everything in italics is OSHA wording, everything in bold non-italic are my comments…
Review the employer’s policy to determine which rescue procedures are being employed. If non-entry rescue has been ruled out, ascertain which of the entry rescue options has been implemented.
A. Non-entry rescue:
1. If non-entry rescue is being practiced, what equipment is used?
Remember, a tripod and wench are often USLESS in so many confined space configurations. They get in the way of horizontal entries, yet we still see them set up in front of the entry portal!!!
2. If non-entry rescue is not being practiced, what are the employer’s reasons for not using it?
This can NOT be stressed enough! Non-Entry rescue is a REQUIREMENT for EVERY ENTRY INTO A PRCS; OSHA allows for two “EXCEPTIONS” to this requirement: 1) the retrieval equipment would increase the overall risk of entry or 2) the retrieval equipment would not contribute to the rescue of the entrant. I have seen a lot of arguments as to why non-entry rescue is not in place, and unfortunately, the vast majority of them did not meet either of these exemptions!
3. Does the employer review each space to be entered to determine whether to employ or not to employ non-entry rescue?
I have seen OSHA take two different paths on this question. Some area offices feel this review should be done in the CS evaluation each business is required to do, and some offices accept a review if it is documented on the entry permit. I feel this is a review that must be done during the permitting process, as there are a lot of factors that could dictate non-entry vs. entry style rescue that has more to do with the type of work being done and the number of entrants more so than the space itself.
B. On-site rescue services: (A host employer’s own employees)
1. Determine the number of employees assigned to perform rescue, verify training for each member of the rescue service, and find out which of them have a current first-aid and cardiopulmonary resuscitation (CPR) certification.
How many rescuers does your site require to be on site for an entry to take place? Keep in mind one of the permit requirements and responsibilities of the entry supervisor is to verify that rescue services are available and that the means for summoning them are operable. This means the site has to have some means of knowing which company rescue personnel are on-site AND available. The site also needs to have a means in place to track their availability and a means to communicate with them (e.g., if they leave the site for lunch or to run an errand the entry may need to be stopped!). The easiest way to ensure we have a trained first-air person on hand is to have your entire rescue team trained in 1st Aid/CPR; however, many facilities will have separate teams for rescue and 1st aid. This is perfectly compliant, BUT the site MUST NOW ENSURE the availability of TWO team members, and this is often not done. In other words, the entry supervisor is checking to ensure that he/she has enough rescuers on site, but they are not checking on the availability of 1st Aid team members. We have found permits listing rescue team members who were NOT 1st aid trained, and no 1st Aid personnel were on-site during the entry.
2. Review the rescue procedures as they compare with the written PRCS program, and with the requirements of paragraph (k)(1).
This requirement implies that there be “written rescue procedures” in place. Some would argue that if the overall written CS program contained a “Rescue” section, this would meet OSHA requirements. I again go back to the complexities and stark differences in entries from one space to the next and even the same space but with different work and different numbers of entrants. Writing a generic rescue plan that could cover each entry into each PRCS on-site is impossible. I would also point out that the wording of this task for the CSHO implies that the “rescue procedures” are a SEPARATE document, as the CSHO is required to compare the rescue procedures with the “written PRCS program,” which to me makes it clear that we are talking about two separate documents.
3. Note the work shifts of the rescuers and compare them to the permit entry times.
This one is almost a given finding during our audits! Most facilities have plenty of rescue personnel on-site during the day shift on regular Monday-Friday work times, so I like to look through the permits issued in months that have holidays that usually are associated with a long weekend (e.g., Memorial Day, 4th of July, Labor Day) and start with any permits issued during this time frame to see if the permit was issued with an ample number of rescuers on site (e.g., comparing this to the site’s written program requirements). I then look to permits issued after 6 pm and before 6 am. In one of our fatality investigations, we even pulled time sheets of rescuers to determine who was on the clock during the past 12 months of permits. BOTTOM LINE…OSHA knows that things are DIFFERENT on 2nd, 3rd, and 4th (Swing) shifts, so they gravitate to these times as their first pass for checking rescuer availability.
C. Non-host employer rescue employees (off-site):
1. Who provides the off-site rescue service and where is the service located?
There is SO MUCH TO THIS REQUIREMENT than most facilities recognize. Too many facilities will tell OSHA the rescue service is the nearest fire station, not realizing that the rescue team is NOT the first arriving engine company. Over the years, OSHA has learned this is a red flag and means that the facility has MOST LIKELY not actually EVALUATED their rescue service but like so many, just figured that the local fire department would arrive and take care of the situation. PLEASE read my other articles on CS Rescue and Emergency Response for a more detailed analysis of using your local FD as your CS rescuer. For most of us, it is NOT AS SIMPLE as dialing 911!
2. How is the arrangement between the employer and the off-site rescue service documented (contract, letter of agreement, verbal agreement)?
NOTICE that OSHA will ask how the rescue agreement with your off-site rescuers is “documented.” They will accept “verbal agreements,” but they will ask the off-site responders for details of your rescue plan to ensure EVERYONE is on the same page. Having something in writing is the WAY TO GO for safety and compliance. Most local fire departments (FD) have hundreds of businesses to cover, and thinking that they can keep track of them mentally is just crazy.
3. How does the employer decide, given the identified permit-space hazards, that the off-site rescue service’s response time, experience, and training are adequate?
This is getting to the heart and soul of how a rescue service evaluation is to be done. I will never forget the first time we arrived to do a mock rescue for a local business that we had said we would provide their rescue services for years. We quickly learned that we were NOT PROPERLY equipped for this mock rescue, and the space chosen for the drill was one of their easier spaces!!! Right then, I learned the importance of doing the initial PRCS evaluation and the Rescue Team Evaluation with a fine tooth comb! Let’s say a PROPERLY EQUIPPED rescue team will have more than a tripod, wench, and harnesses! We were much more sophisticated and came up way short in our experience. I will always thank Vanderbilt Chemical in Murray, KY, for teaching me such a valuable lesson in “pre-planning”. They told us in the drill critique that they were always a bit uneasy with our quick acceptance of such a serious task and wanted us to demonstrate our abilities. It took less than 15 minutes for reality to set in! This was in 1992, a couple of years BEFORE 1910.146 came into play!
4. Have the rescue service training requirements in paragraph (k)(1) been met?
5. What method is used to summon rescuers?
This, too, is often taken for granted. Please read my article “Who Calls 911” for more on this simple but often confusing task.
6. Are rescue services on-call or on-site when permit space entry is underway?
7. What is the response time for rescue service?
PLEASE be VERY CONSERVATIVE in your estimations. ALWAYS consider rush hour traffic, road construction, inclement weather, bridge closings, etc. We did an audit last winter and came across a business that could not operate because of some serious snow, which shut down the roads and prevented the 1st shift from making it to work. Due to a business slowdown, this facility used the 3rd shift as their maintenance shift. This meant that maintenance people were already at the plant. So management did not want to let them try and drive home, so they decided to keep them on the clock and let them work some overtime while they were stuck at the plant. Some of the tasks they decided to do were the CS entries they had been waiting for several months. Now I don’t know how busy your FD is when snow covers the roads where you live, but where I have lived, it is NON-STOP runs to wrecks. To think that your FD can arrive at your plant in less than 15 minutes in inclement weather is just not realistic!
8. How does the employer verify that the rescue service will be available during the time of employee entry? PLEASE read my Article “Using my local FD as my PRCS Rescue Team“
D. Combinations:
1. If combination of on-site and off-site rescue services is employed:
a. Obtain a copy of the rescue plan which describes the roles of each party.
As I have often done, this could be part of your Emergency Response Plan. The ERP, required under 1910.120(q), can easily be modified to cover all types of emergencies, including PRCS Rescue. The plan is required to have a “Planning Section,” and in this section, each response agency is to be listed and what their role in each type of emergency will be. For example, some businesses rely solely on the FD for rescue, and their employees play no role. Some facilities have an in-house rescue team but will rely on the FD to extract the worker from the high elevations to the ground. Some facilities only need the FD for advanced medical care and transportation. Our rescue plan needs to spell out who will be doing what and that each party KNOWS their roles and responsibilities in a rescue.
b. Verify that the on-site and off-site rescue services employees have trained together as a team.
Suppose your facility’s rescue will work with the off-site rescue team in ANY CAPACITY. In that case, they need to have trained together, understand what a UNIFIED COMMAND structure looks like, and have completed a GAP ASSESSMENT to ensure neither party expects the other to do something they can NOT do. If your facility has 100% of the rescue from the space, high angle getting them down to the ground, and transportation to a medical facility, then this requirement would not apply to your facility.
c. Determine if, the combined rescue services enable the employer to comply with the requirements for rescue services.
GAP ASSESSMENT/PRE-PLANNING. Sit down with your rescue service (even if they are your employees) and take the MOST COMPLICATED rescue they can think of and do your MOCK RESCUE in it with any off-site service that may be called to support the rescue. At the very least, do a walk-through with both teams (preferably together) to ensure there are no gaps in personnel numbers, equipment, and training.
