As the debate rages on regarding rescue services, there is ONE SMALL and SIMPLE requirement that would STOP ALL entries…
1910.146(j) Duties of entry supervisors. The employer shall ensure that each entry supervisor:
…
1910.146(j)(4) Verifies that rescue services are available and that the means for summoning them are operable;
This Entry Supervisor REQUIREMENT could not be any more clear… it is their RESPONSIBILITY (and SOLELY their RESPONSIBILITY) as Entry Supervisor to VERIFY that whatever rescue service they plan to use (on-site or off-site) the service/team is AVAILBLE to respond in a TIMELY MANNER and the means the attendant will use to summon them to the space is “operable.”
What does this actually mean?
As I have written about MANY times, this means that if the “rescue service” is your local fire department, the entry supervisor MUST contact them and verify they are “available.” Now imagine how this will happen… do NOT call 911 to reach the Fire Department in our effort to verify they are available! The entry supervisor will need some means to contact the local FD in a non-emergency fashion and know who they are to communicate with regarding the availability of the rescue team. So, let’s say you have a great working relationship with your local FD and have worked out this means to communicate your rescue needs. Now comes the tricky part… knowing when the FD is no longer “available” to provide this service!
The entry into the PRCS MUST STOP, and everyone exits the space when the rescue service is no longer available for whatever reason. We are now at the mercy of the FD and can NOT resume our entry into the PRCS until they have confirmed they are again available to provide rescue services.
But know this: it is the Entry Supervisors’ RESPONSIBILITY to verify that “rescue services are available and that the means for summoning them are operable.” This may seem minor, but it is in the CRITICAL PATH for a safe entry and an essential requirement of ALL entries into a PRCS, yet sadly, it is often NEVER done.
The next time you audit an entry into a PRCS, interview the entry supervisor and have them explain how they met their responsibility for this requirement, especially if the rescue plan is to dial 911! Having an in-house team makes this responsibility easier to manage; using an off-site team almost always goes unmanaged, placing entrants at an unrecognized risk.
Here is what OSHA said about (j)(4) in their pre-amble to the PRCS Standard…
emphasis added by me – NOT OSHA
Paragraph (j)(4) of the final rule requires the entry supervisor to verify that rescue services are available and that the means for summoning them are operable. The proposed rule did not contain a corresponding provision explicitly imposing this duty on the entry supervisor. Proposed paragraph (h), however, would have required the employer to have an in-plant rescue team or an arrangement under which an outside rescue team would respond in an emergency. Additionally, OSHA proposed (in paragraph (c)(8)) that employers implement and provide the procedures and equipment necessary to rescue entrants from permit spaces and (in paragraph (g)(1)(ii)) that the entry supervisor determine that the necessary procedures, practices, and equipment for safe entry are in effect. OSHA believes that the inclusion of paragraph (j)(4) in the final rule will emphasize the need for the entry supervisor to assure that rescue and emergency services are indeed readily available BEFORE entry. Since the employer delegates responsibility for safe permit entry to the entry supervisor, it is reasonable and consistent with the rescue provisions in the permit program to specify that the entry supervisor verify the availability of rescue services and the operability of the means for summoning them.
PLEASE read my other posts regarding flaws with using your Local Fire Department as your rescue service.
