In our PSM/RMP and OSH audits, we always spend more time on the Life Safety Standards, such as PRCS, LOTO, LEO, Respiratory Protection, etc. One of the most common errors we find in these audits is the lack of training for the attendants. It’s not that they are not meeting 1910.146(i)(1) – 1910.146(i)(10) training obligations; it’s that they are missing the KEY ROLE most businesses put on their “Attendants”. NON-Entry Rescue!
We get a lot of pushback on our bids to do CS/PRCS training, as our model is an 8-hour session that is broken down like this:
In the first 40 minutes, everyone who works around a CS/PRCS gets basic awareness. After this awareness session, those who will be an Entrant, Attendant, and Entry Supervisor will stay for the next session, which is for those who will be an Entrant into a PRCS. This session is 2-hours. After this entrant session, those who will be Attendants and Entry Supervisors will stay for the next session, which is for those who will be an Attendant for a permitted entry into a PRCS. This session is 2 hours long and is mostly hands-on work with the non-entry rescue setups the business uses. After this Attendant session, those who will be Entry Supervisors will stay for the next session, which is for those who will be an Entry Supervisor for a permitted entry into a PRCS or reclassifying a PRCS to NON-PRCS. This session is 3-4 hours long, with a lot of time spent on the Direct-Reading Instruments and Ventilation that the business uses.
What we typically find is that attendants have never set up or operated the non-entry rescue systems they will be expected to operate in an emergency situation. Not an optimal time to become familiar with the gear/equipment. Although OSHA does not specifically require this hands-on approach in 1910.146(i)(9); we believe it to be a CRITICAL PATH in the training of Attendants. The looks on their faces when they start cranking on a winch with a 200-pound dummy on the other end is something a trainer never forgets. Even more of a surprise is when they discover, for the first time, the amount of force it takes, and even more shock at how SLOW the winch is pulling them up. Most attendants, even a lot of EHS pros, do not understand the limitations of the outdated Tripod/Winch system, such as weight limits of the system (harness, cable, winch, tripod, etc) or the surface the three (3) tripod feet are exerting on the surface the tripod is set up on.
We believe this hands-on training is ESSENTIAL to building great attendants. We treat the attendant role as our front-line rescue service should something go wrong; therefore, we believe these 4.5 hours of training are mandatory for this role. And please keep in mind that if the Attendant will be setting up the non-rescue system(s) at the space, this is ADDITIONAL HANDS-ON training needed and usually takes another 45 minutes to 2 hours, depending on the complexity of the non-entry rescue systems in use at the facility.