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EMERGENCY AND RESCUE PROCEDURES

Chapter 4

EMERGENCY AND RESCUE PROCEDURES

Responsibilities. The MEP will include emergency and rescue procedures consistent with the nature of each known operation that requires entry into a permit-required confined space. The entry supervisor will coordinate with the CST when required to enter permit-required confined spaces and ensure emergency rescue is available prior to entry.

Note: In the industry standard 1910.146 there was suggested the possibility of using the fire department for rescue services. All that changed, on December 1, 1998 OSHA published revisions to 1910.146 that virtually eliminated the use of fire department for rescue services. Most fire departments can't meet the OSHA/ANSI requirements for the timeliness requirement of 3-4 minutes (too far away, stuck in traffic, responding to another emergency). Most are unwilling to submit themselves to the required employer evaluation. Won't perform the pre-planning rescue requirements. Most do not have the specialized equipment needed not only for confined space rescues, but other required rescues as well. Most won't perform confined space rescues at all, but will conduct body recovery.

WARNING: The construction industry has never been allowed to use civil rescue. The civil rescue can be called in after the rescue for treatment and transportation, but can't be the primary rescue service.

1926.21(b) clearly states the employer is responsible: (1) to provide rescue equipment (d)(4)(viii), and (2) actually rescue victims from confined spaces. OSHA 1926.21(b)(6)(i) mandates employee training in the use of emergency equipment. OSHA 1926.35(b)(4) requires the employer to appoint employees for rescue and medical duties. Both ANSI Z117.1 (mandatory for construction) and NIOSH 80-106 mandates on-site rescue.

As mentioned above, the employer must appoint employees for rescue duties. These rescue duties are not only limited to confined spaces, but include: trenches (1926.651), falls (1926.502), underground construction (1926.800), ventilation and hotwork (1926.353), hazardous chemicals (1926.65), respirator failure (1910.134), and electrical emergency (shock) (1926.950(e)). No civil rescue service on earth has the equipment or response time to effectively rescue victims. Effective is defined as rescue that will actually save an accident victims life. A best practice is to train the rescue team not only in confined space rescue, but to also perform all the construction required rescues.

There are three means of confined space rescue: self-rescue, non-entry rescue, and an organizational rescue team.

Self-Rescue. Employees are trained to exit from the confined space according to requirements Chapter 5.

Non-entry rescue: the use of retrieval devices outside of the space to rescue the entrant. Mandatory for vertical spaces 5' more in depth.

Organizational Rescue Team. When confined space work is performed, the responsible contractor will establish an organizational rescue team. The entry supervisor in charge of the entry will ensure the organizational rescue team is available or the confined space work is rescheduled. Organizational rescue teams shall consist of trained personnel equipped with appropriate PPE, including respiratory protection equipment necessary for entry into confined spaces, and with rescue and retrieval equipment suitable for the type of confined spaces involved.

"All oxygen-deficient atmospheres shall be considered IDLH" (1910.134 (d)(2) (B)(iii)). Humans themselves create oxygen-deficient atmospheres by breathing and 87% of all confined space emergencies are a result of oxygen deficiency. Entry into IDLH confined space is usually a pre-planned event. However, if an IDLH (oxygen-deficient or other chemicals) develops by accident; then rescue from the confined space must comply with 1910.134 (g)(3).

The organizational rescue team shall be available at the scene for permit-required confined space entry under pre-planed IDLH conditions.

WARNING: If a victim is within the space and the atmosphere is unknown or tests reveal no hazard; treat it as IDLH. If there is a victim - there must be a reason!

For other rescues that have chemicals, dusts, fumes, mists, or products that might exceed the exposure limits (having a victim tells me something is wrong!) or have chemicals that could harm the skin or eyes, must be provided all the needed PPE and respirators designed for the air hazard (ref: 1910.134(a)). In fact, the employer must have such respirators on hand just in case there is an accident (ref: 1910.134(d)(3)). The rescue procedures for each chemical, dust, fume, mist, or product is included in its MSDS.

For rescues where there is no hazard, such PPE is not required to conduct a rescue.

Organizational rescue team training shall as a minimum include: CPR, confined space entrant, the use of retrieval/rescue equipment (1926.21(b)(6)(i)), the proper wearing of PPE (1926.95(a)), and the 1910.134 requirements including respirators/SCBA that is required during actual rescues. For training on the use of retrieval/rescue equipment, consult the manufacturer's instruction; it tells you how to use it.

The CST will assist as needed in the selection of equipment and training for organizational rescue teams.

Inspection of Safety Equipment: Entry supervisors/CST will ensure the inspection, testing, maintenance, and documentation of safety/rescue equipment is accomplished according to manufacturer's instructions and 1910.134.