Permit-Required Confined Space rescuer training; 8, 12, 24, or 40 hours?

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I have been working with a client on developing their PRCS Rescue team and of course, we get to the final phase, training the team, and the questions begin with how long is the training.  Now, the topic of training and its time commitment was discussed a long time ago; even before they decided they wanted their own team, as I always make sure my clients understand fully what it literally means and takes to have a functioning PRCS Rescue team.  And of course, their purchasing manager can find outfits that are claiming their 8-hr, 12-hr rescue classes are all that “OSHA requires” and that I am somehow ripping them off with my 24-hr course.  So I ask the client’s purchasing manager to get the information from these outfits so we can all learn where OSHA has specified 8 or 12 hours of training – heck the other two bidders can not even agree on what OSHA has supposedly stated!  So if the 8-hr and 12-hr is not the right amount of time, where do I get off quoting a 24-hr course?  It’s simple, I turn to the most trusted source for emergency responder training qualifications and there we find the exact same terminology and training framework as we find in OSHA’s HAZWOPER standard (1910.120(q)).

  • NFPA 1670, Standard on Operations and Training for Technical Search and Rescue Incidents, and
  • NFPA 1006, Standard for Technical Rescue Personnel Professional Qualifications

And would you believe that in these standards, the time period to properly train a rescuer (who already has some HAZMAT and PPE training) is 24-hours!  I promise I do not make this stuff up (unlike some of the ya-hoo’s in this business)!!!

When we look at these two (2) NFPA standards, which are in fact consensus standards and have NOT been incorporated by reference, we see their structure is very much like OSHA’s HAZWOPER standard training requirements.  In fact, the same titles and times are used in the NFPA standards as in 1910.120(q).

NFPA 1670 states:

  1. Awareness Level. This level represents the minimum capability of organizations that provide response to technical search and rescue incidents.
  2. Operations Level. This level represents the capability of organizations to respond to technical search and rescue incidents and to identify hazards, use the equipment, and apply limited techniques specified in this standard to support and participate in technical search and rescue incidents.
  3. Technician Level. This level represents the capability of organizations to respond to technical search and rescue incidents and to identify hazards, use the equipment, and apply advanced techniques specified in this standard necessary to coordinate, perform, and supervise technical search and rescue incidents.

Now it is my professional opinion (of 30+ years being trained in PRCS Rescue) that the vast number of rescue teams will be the PRIMARY response (i.e. FD will back them up) will need to be at a Technician Level.  If the local FD will be the primary response and the facility personnel will back up the FD, then the Operations Level may very well meet the needs of the team.  But to be clear, all of the clients I have trained put a team in place so that they could fulfill 100% of their rescue needs with no necessary involvement from the community responders, other than transporting any patients.  If you’re considering doing an OPs Level Rescue team, PLESSE be fully aware of the limitations this level of training has:

Operations-level organizations shall be RESTRICTED TO RESCUE INSIDE CONFINED SPACES WITH THE FOLLOWING CHARACTERISTICS:

  1. Where the internal configuration of the space is clear and unobstructed so retrieval systems can be used for rescuer entrants without the possibility of entanglement

  2. Where the victim can be easily seen from the outside of the space’s primary access opening

  3. Where rescue entrants can pass easily through the access/egress opening(s) with room to spare when PPE is worn in the manner recommended by the manufacturer

  4. Where the space can accommodate two (2) or more rescue entrants in addition to the victim

  5. Where all hazards in and around the confined space have been identified, isolated, and controlled

In my time as a rescuer, I have never had such luxuries!  I do not know of any facility that could lay claim that 100% of their PRCS would fall under these restrictions, but that is not to say there is a site that could fully meet the needs of their entrants by being an OPs level rescue team.

 

The next BIG ITEM is “rope rescue” or as I call it, “High Angle Rescue”.  This is an ABSOLUTE need of any PRCS rescue team!  Without the ability to perform rope rescues, simply removing the entrant(s) from the space may be more of a challenge than the team is capable of and certainly, once we have the entrant(s) out of the space, getting them to the ground for full medical eval and treatment AND transportation will be impossible without “rope rescue”.  Don’t be fooled into thinking that a tripod and winch is PRCS rescue –  most of my teams use their tripods and winches as boat anchors!!!  PLEASE read my 2011 article:

CS Rescue… Tripods and Winches and a false sense of security

The Rope Rescue training requirements are set up the same way as the basic rescue training with Awareness, Operations, and Technician; keeping in mind that Rope Rescue is an entirely different course than the general rescue course! 

 

Let’s see what a Rope Rescue Technician is expected to be competent in:

Organizations operating at the technician level for rope rescue incidents shall develop and implement procedures, commensurate with the identified needs of the organization, for the following:

  1. Accessing a patient using techniques that require rescuers to climb up or down natural or man-made structures, which can expose the climber to a significant fall hazard

  2. Using rope rescue systems to move a rescuer and a patient along a horizontal path above an obstacle or projection

  3. Performing a high-angle rope rescue of a person suspended from, or stranded on, a structure or landscape feature

  4. Applying the principles of the physics involved in constructing rope rescue systems, including system safety factors, critical angles, and the causes and effects of force multipliers

  5. Performing a high-angle rope rescue with a litter using tender(s) to negotiate obstacles, manipulate or position the patient, or provide medical care while being raised and lowered

 

When we look at the actual PRCS Rescuer Technician we see:

Organizations operating at the technician level for confined space search and rescue emergencies shall meet the requirements of this chapter and Section 12.2 (awareness level for machinery search and rescue).

Organizations operating at the awareness level for machinery emergencies shall implement procedures for the following:

  1. Recognizing the need for a machinery search and rescue
  2. Identifying the resources necessary to conduct operations
  3. Initiating the emergency response system for machinery search and rescue incidents
  4. Initiating site control and scene management
  5. Recognizing general hazards associated with machinery search and rescue incidents 

 

The organization operating at this level shall be responsible for the development of a confined space rescue service that is trained, equipped, and available to respond to emergencies within confined spaces of a type and complexity that requires a technician-level organization.

A technician-level rescue service shall be required for confined spaces with one or more of the following characteristics:

  1. Where the internal configuration of the space might create entanglement hazards and retrieval might not be effective
  2. Where the victim cannot be seen from the outside of the space’s primary access opening
  3. Where the portal size and configuration will not allow a rescuer to pass through the access/egress opening(s) using SCBA when worn in the manner recommended by the manufacturer
  4. Where all hazards in and around the confined space have been identified and can be mitigated by using respiratory protection

Organizations operating at the technician level for confined space search and rescue emergencies shall develop and implement procedures for the following:

  1. Developing hazard isolation and control requirements
  2. Planning response for entry-type rescues in hazardous environments
  3. Implementing the planned response
  4. Using victim packaging devices suitable for confined spaces with small entry portals and/or that are internally congested

 

If we want to be ONLY an OPERATIONS LEVEL rescue team, this is what is required:

Organizations operating at the operations level for confined space search and rescue incidents shall meet the requirements specified in Sections 7.2 [Awareness], 7.3, and 5.3 (operations level for rope rescue).

5.3 Rope Rescue Operations Level

  1. Sizing up existing and potential conditions at incidents where rope rescue operations will be performed

  2. Assuring safety in rope rescue operations

  3. Establishing the need for, selecting, and placing edge protection

  4. Selecting, using, and maintaining rope rescue equipment and rope rescue systems

  5. Configuring all knots, bends, and hitches used by the organization

  6. Selecting anchor points and equipment to construct anchor systems

  7. Constructing and using single-point anchor systems

  8. Constructing and using multiple-point anchor systems with regard to the potential increase in force that can be associated with their use

  9. Selecting, constructing, and using a belay system

  10. Selecting and using methods necessary to negotiate an edge or other obstacle that includes protecting all personnel working nearby from accidental fall

  11. Ascending and descending a fixed line

  12. Self-rescue

  13. Selecting, constructing, and using a lowering system in both the low- and high-angle environments

  14. Securing a patient in a litter

  15. Attaching a litter to a rope rescue system and managing its movement

  16. Selecting, constructing, and using rope-based mechanical advantage haul systems in both the low- and high-angle environments

  17. Negotiating a loaded litter over an edge during a raising and lowering operation

 

The organization operating at this level shall be responsible for the development and training of a confined space rescue service that is trained, equipped, and available to respond to confined space emergencies of a type and complexity that require an operations-level organization.

The role of a confined space rescue service is intended to include entry into the space to perform a rescue and, as a minimum, shall be staffed to provide sufficient members with the following exclusive functions:

  1. Rescue entrant/entry team of sufficient size and capability to perform the rescue

  2. Backup rescue entrants of a sufficient number to provide immediate assistance to, or rescue of, rescue entrants who become ill or injured and are unable to perform self-rescue

  3. Rescue attendant whose function is to deny unauthorized persons access and to monitor the conditions in the space and the status of all entrants

  4. Rescue team leader (supervisor) whose function is to maintain control of the entire operation and be knowledgeable in all rescue service functions

Operations-level organizations shall be RESTRICTED TO RESCUE INSIDE CONFINED SPACES WITH THE FOLLOWING CHARACTERISTICS:

  1. Where the internal configuration of the space is clear and unobstructed so retrieval systems can be used for rescuer entrants without the possibility of entanglement

  2. Where the victim can be easily seen from the outside of the space’s primary access opening

  3. Where rescue entrants can pass easily through the access/egress opening(s) with room to spare when PPE is worn in the manner recommended by the manufacturer

  4. Where the space can accommodate two (2) or more rescue entrants in addition to the victim

  5. Where all hazards in and around the confined space have been identified, isolated, and controlled

The operations-level organization shall ensure that each member of the rescue service meets the minimum requirements of operations-level confined space rescue in NFPA 1006.

If required to provide confined space rescue within regulated industrial facilities, the organization shall ensure the rescue service has access to all confined spaces from which rescue could be necessary so that they can develop rescue plans and practice rescue operations according to their designated level of competency.

The organization shall ensure that each member of the rescue service practices making confined space rescues once every 12 months, in accordance with the requirements of 4.1.10 of this document, by means of simulated rescue operations in which he or she removes dummies, mannequins, or persons from actual confined spaces or from representative confined spaces resembling all those to which the rescue service could be required to respond in an emergency within their jurisdiction. Representative confined spaces shall — with respect to opening size, configuration, and accessibility — simulate the types of confined spaces from which rescue is to be performed.

Organizations operating at the operations level shall develop and implement procedures for the following:

  1. Sizing up existing and potential conditions at confined space emergencies

  2. Protecting rescue personnel from hazards within and adjacent to the confined space

  3. Ensuring that rescue personnel are capable of managing the physical and psychological challenges that affect rescuers entering confined spaces

  4. Identifying the duties of the rescue entrant(s) and backup rescue entrant(s), rescue attendant, and rescue team leader as defined herein

  5. Monitoring continuously, or at frequent intervals, the atmosphere in all parts of the space to be entered for oxygen content, flammability [lower explosive limit/lower flammable limit (LEL/LFL)], and toxicity, in that order

  6. Performing entry-type rescues into confined spaces

  7. Using victim packaging devices that could be employed in large, unobstructed confined spaces

  8. Selecting, constructing, and using a rope-based lowering and -raising system in the high-angle environment

 

So as we can see, 24-hours of training for someone already trained in HAZMAT response may be adequate – but in NO WAY would it be ample time to take someone who has never been trained in ER and make them competent in rope rescue and confined space rescue.  This is a 40-hr course, and much like SAFTENG, I will NOT take on a client who wants ONLY a rescue team and will only allow a 24-hr course.  Far too much at stake to cut corners in PRCS!

So now let’s turn our attention to NFPA 1006: Standard for Technical Rescue Personnel Professional Qualifications (as referenced in NFPA 1640 above)…

The operations-level organization shall ensure that each member of the rescue service meets the minimum requirements of operations-level confined space rescue in NFPA 1006.

This is where NFPA gets very specific on the skills and knowledge a person trained to a PRCS Rescue Tech level should possess.

Technician Level

The job performance requirements defined in Sections 7.1 [Awareness] and 7.1 [Operations] shall be met prior to or during technician-level qualification in confined space rescue.


7.3.1 Initiate a search inside a confined space in those areas not immediately visible from the confined space entry portal, given hazard-specific PPE, confined space rescue entrant(s) to perform the search, equipment pertinent to search mission, a confined space, and victim investigative information, so that search parameters are established; the victim profile is established; search result information is acquired and relayed to command; the personnel assignments match their expertise; all victims inside the space are located and identified quickly; applicable technical rescue concerns are managed; risks to searchers are minimized; and all searchers are accounted for.

(A) Requisite Knowledge. Local policies and procedures and how to operate inside the confined space.
 
(B) Requisite Skills.  The ability to work inside the confined space; communicate with rescuers outside the confined space portal; and, when possible, perform self-rescue if conditions become untenable.
 
7.3.2  Preplan a confined space incident, given applicable guidelines and regulations and a preplan form, so that a standard approach is used during a confined space rescue emergency, hazards are recognized and documented, isolation methods are identified and documented, all accesses to the location of the confined space entry opening are identified and documented, all types of confined space entry openings are identified and documented, and internal configurations and special resource needs are documented for future rescuer use.
 
(A) Requisite Knowledge. Operational protocols, specific preplan forms, types of hazards common to jurisdictional boundaries, hazards that should and must be identified on preplans, isolation methods and issues related to preplanning, issues and constraints relating to the types of confined space openings, internal configuration special resource needs of a confined space, and applicable legal issues.
 
(B) Requisite Skills.  The ability to select a specific preplan form; draft or draw a sketch of confined spaces; complete supplied forms; identify and evaluate various configurations of confined spaces, access points, confined space entry openings, isolation procedures, and energy control locations; recognize general and site-specific hazards; document all data; and apply all regulatory compliance references.
 
7.3.3  Apply and use supplied-air respirators (SARs) as a rescue entrant, given a confined space incident requiring respiratory protection, a rescue assignment, a means of entry into and exit from the space, a rescue attendant outside the space, personnel to manage air lines outside of the space, a SAR, a breathing air supply system with air lines to supply the SAR, breathing apparatus cylinders, personnel to monitor and maintain the air supply system, and a confined space, so that the internal configuration of the space will not create entanglement hazards when using air lines, the victim cannot be seen from the outside of the space’s primary access opening, the portal size and configuration will not allow a rescuer to pass through the access/egress opening(s) using SCBA when worn in the manner recommended by the manufacturer, all hazards in and around the confined space have been identified and might be mitigated by using respiratory protection so that the rescue entrant passes through the portal without removal of the SAR and the assigned rescue duty is performed.
 
(A)  Requisite Knowledge.  Capabilities and limitations of SAR in confined space rescue, breathing air conservation, air-line management and communication methods appropriate to breathing apparatus use in confined spaces.
 
(B)  Requisite Skills.  The ability to use SAR in a confined space entry for rescue, use of breathing techniques that will conserve the air supply, manage airlines while working within the space and use of communication methods that effectively convey information between rescuers inside and outside of the space.
 
7.3.4  Perform short spinal immobilization of a victim inside a confined space, given a confined space incident requiring spinal precautions, a stable victim, a short spinal immobilization device, a second rescuer to assist, and a confined space, so that the portal size or internal configuration will not allow the application of a full spine immobilization device, all hazards in and around the confined space have been identified and might be mitigated by using respiratory protection so that the victim’s cervical spine is manually maintained in a neutral position immediately on contact and maintained until the short immobilization device is completely applied and secure, victim movement onto the spinal immobilization device creates minimal manipulation of the spine, void spaces between the victim and immobilization device are padded as appropriate, victim securement to the immobilization device will reduce spinal manipulation during movement, and applicable local treatment protocols are followed.
 
(A)  Requisite Knowledge.  Capabilities and limitations of short spine immobilization equipment for victims in confined space rescue, methods for movement of a victim onto a long spine immobilizer with minimum spinal manipulation, methods for securement of a victim onto a short spine immobilizer, methods for securement of a victim’s head on a short spine immobilizer, and other short spinal immobilization treatment modalities and procedures.
 
(B)  Requisite Skills.  The ability to maintain manual immobilization of a victim’s head during the immobilization process, assist in moving the victim to a short spine immobilizer with only two persons with minimal spinal manipulation, apply void space padding as needed based on the immobilization device, and apply and secure the victim’s upper body and head to a short spinal immobilization device.
 
7.3.5  Prepare for entry into the confined space with a hazardous atmosphere, given a confined space with a hazardous atmosphere, atmosphere-supplied respirators, and a confined space tool kit, so that entry can be made into a confined space that contains one or more of the following characteristics: the internal configuration of the space could create entanglement hazards and retrieval might not be effective, the victim cannot be seen from the outside of the space’s primary access opening, the portal size and configuration will not allow a rescuer to pass through the access/egress opening(s) using SCBA when worn in the manner recommended by the manufacturer, all hazards in and around the confined space have been identified and can be mitigated by using respiratory protection so that continuous atmospheric monitoring is initiated, the atmosphere is assessed to be manageable with atmosphere-supplying respirators, victim communication is established when possible, atmosphere-supplying respirators are used by rescue entrants while within the space, atmosphere-supplying respirators are rapidly applied to the victim, rescuer readiness is verified, rescuers’ limitations are identified and evaluated, rescuers unsuitable to entry operations are reassigned and replaced, route and methods of confined space entry are determined, and rescuer evacuation is planned.
 
(A) Requisite Knowledge.  Effects of hazardous atmospheres on victims and rescuers, types and operation of required hazard-specific monitoring equipment, types and operation of required atmosphere supplying respirators, organization protocol for medical and psychological evaluation related to confined space entry, methods of entry into confined spaces with hazardous atmospheres in accordance with operational protocols, and rescuer evaluation methods.
 
(B)  Requisite Skills.  The ability to operate monitoring equipment, perform rescuer pre-entry medical exam, evaluate rescuer capabilities and limitations, identify victim communication needs, evaluate for point and route of confined space entry, and select evacuation methods.
 
7.3.6  Enter a confined space with atmospheric hazards, given hazard-specific PPE; safety, communication, and operational protocols; a confined space with a hazardous atmosphere; a confined space rescue tool kit so that the victim is contacted; and a confined space, so that the internal configuration of the space could create entanglement hazards and retrieval might not be effective, the victim cannot be seen from the outside of the space’s primary access opening, the portal size and configuration will not allow a rescuer to pass through the access/egress opening(s) using SCBA when worn in the manner recommended by the manufacturer, all hazards in and around the confined space have been identified and can be mitigated by using respiratory protection so that a controlled confined space entry is established and maintained, the atmosphere is continuously monitored, the rescuers and patient(s) are protected from the hazards, the victim’s mental and physical conditions are further assessed, patient care is initiated, the patient is packaged to restrictions of the space, and patient removal can be initiated.
 
(A)  Requisite Knowledge.  Principles of operation for atmospheric monitoring equipment; methods for patient care in confined spaces; application of hazard-specific PPE; safety, communication, medical, and operational protocols; and controlled confined space entry and egress procedures for confined spaces.
 
(B) Requisite Skills.  The ability to use and apply hazard-specific PPE and rescue-related systems and equipment; implement safety, communication, and operational protocols; use medical protocols to determine treatment priorities; use medical equipment specific to confined space victim needs; and reassess and confirm mode of operation.

 

Even when your team has extensive experience with traditional respiratory protection such as SCBAa, these rescue teams will need to be equipped with Supplied Air Respirators with Auxiliary bottles for use in IDLH/Potential IDLH atmospheres.  These respirators are NOTHING like using an SCBA and just covering the RP will be 2-3 hour session!

There is just NO WAY any trainer can take an employee who has never been trained in “entry-style” PRCS rescue and make them competent in all that is stated above in 8 hours; not even in 12 hours.  My 24-hour course is based on the fact that I have been training this client’s HAZMAT team for 15 years, of which the HAZMAT team has been using SARs for decon for several years now, they are well trained on hazardous atmosphere and chemical behaviors and proper use of direct-reading instruments.  Therefore we can spend our hours on rope rescue and entry-rescue; otherwise, I would be pushing for, and not accepting anything less, than a 40-hour course.

 

 

 

 

 

 

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