We have all seen it… the person assigned to be the PRCS Attendant (and Fire Watches suffer this infliction as well) are the youngest, weakest, least trained, least experienced, lowest paid, and most incapable person on the job/team. As I have written about before, one of my former employers actually but an age restriction on the role as we just grew tired of our field audits always finding some 18-20-year-old son or nephew/niece working the summer and not having a clue how to perform his/her duties. They were actually hired to perform FW and Attendant duties because they were the cheapest labor and “anyone can do these jobs“. Makes your blood boil right?
But recently we came across an incident where the PRCS Attendant was assigned the job due to his “restricted duty injury”, which just happened to be to his dominant shoulder and it was incapacitated in a brace/sling. Yes, you heard that right, workers on “restricted duty” were assigned Attendant Duties. We even found a few cases the worker’s injury would have been a Lost-Time injury, but the business could and would bring them back for these “attendant duties” so as to not incur the LT and instead have a “Restricted Duty Case”. Now is your blood boiling? And I will bet you a steak dinner this practice of using PRCS Attendant and FW duties in this manner is being done at many other sites – we see it in our work at least annual – especially with the embedded contractors at these large facilities.
But one day it came to bite them in the a_s!!! There was a need to perform a non-entry rescue and the attendant was unable to perform their duties. Luckily, it turned out not to be an atmospheric condition that caused the entrant to lose consciousness, it was a personal medical episode, but it was a learning event for this global chemical company. We were asked to assist in the investigation and corrective countermeasures and this is what we came up with…
Both OSHA PRCS standards REQUIRE the attendant to be able to:
1910.146(i)(9) Performs non-entry rescues as specified by the employer’s rescue procedure
1926.1209(i) Performs non-entry rescues as specified by the employer’s rescue procedure
Keeping in mind that there are two (2) conditions in which the Entry Supervisor can waive the non-entry rescue requirements:
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.
1926.1211(c) Non-entry rescue is required unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant.
These non-entry rescue exemptions are RARE. But they can apply in real-world entries, such as entering a horizontal space which has its man-way on the top – end of the tank and the tank has baffle walls. When the entrant has to climb over these baffles to reach to the opposite end of the tank, there is NO WAY non-entry rescue is possible! Sadly we see these types of spaces claiming non-entry rescue as the primary means of rescue!!!! But I digress…
The entry where the incident occurred was what I would call the “traditional vertical entry” – a vertical entry, about 15′ down – very simple and easy non-entry rescue for a CAPABLE attendant. These simple vertical entries are exactly what the tri-pod/winch combo was designed for – we just need a CAPABLE attendant to operate the winch.
BOTTOM LINE – the job of a PRCS attendant is NOT one to be filled by a worker who is on RESTRICTED DUTIES because of an injury or illness that would hinder his/her ability to perform the non-entry rescue needs for the entry. This person(s) MUST have the FULL CAPABILITIES, both in physical STRENGTH and CONDITIONING to perform his/her duties. Too many attendants have NEVER ONCE actually used their non-entry rescue equipment and when they do for the first time they are shocked at how easy the winch turns but then are shocked again at how much work it takes to winch someone 10′. We took some managers to the training grounds on a nice summer day, donned them in the PPE (which included the FRC and the FRC Hi-Vis Vest) and had them crank out “rescue randy” (200-pound dummy) to let them experience FIRST HAND what an attendant would need to be able to PHYSICALLY do should a non-entry rescue be needed. Five took us up on the demo offer and we only had to do two to make them all believers that the attendant job is SAFETY CRITICAL and the person filling the role needed to be a FULLY functioning adult with good conditioning.
I pushed them to their limits, knowing that HR was going to take issue with my “requirements” from an ADA or “equality” perspective – but I am a firm believer that these roles MUST be filled by people who have the physical STRENGTH and CONDITIONING to crank out an entrant who is wearing all their PPE. This could be a 6’2, 250-pound worker who has to be winched out in a TIMELY MANNER and they are 20′ down. I am sorry but STRENGTH and CONDITIONING matter in this role. This is NOT about what sex the attendant is, it matters about their physical STRENGTH and CONDITIONING. In other words, NOT everyone will be capable of being a PRCS Attendant!
