It is around the year 110 A.D.; the Roman Emperor Trajan sentences three criminals to clean sewers, an occupation considered to be one of the worst. How Many Of These Confined Spaces Are In YOUR Jurisdiction? Auto repair lift pits Below-grade basements...
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It is around the year 110 A.D.; the Roman Emperor Trajan sentences three criminals to clean sewers, an occupation considered to be one of the worst.
From Roman times, fast forward 18 centuries. In an article in the Philadelphia Inquirer describing the duties of firefighters assigned to one of the city’s four heavy rescue companies, the following account is given of a confined space rescue operation during the summer of 1947:
Two workmen had been emptying a tank car of transformer oil — tricky stuff that can give off dangerous fumes. A few inches remained, and one of the pair dropped inside to clean the car. The railroad siding was only slightly cooler than Death Valley at high noon; inside the car, the heat and fumes were literally unbearable. One workman looked blank and fell on his face in the oil. His companion yelled for help and went to his aid. In proof of a point Captain Joseph F. Meskill of Rescue 1 was trying to make —- that rescue is for professionals — the man passed out beside his mate. Somebody ran for firemen from a fireboat moored nearby. The first fireman went in without a gas mask. Now there were three in the oil, which was deep enough to drown a fallen man. A second fireman donned a mask but it was the wrong kind or got knocked askew. He added himself to the stack.
Rescue 1 got there with the proper masks but, as usual, there were complications. The breathing bag and canister on the chest made a man too bulky to go through the hatch. Time was everything; four men were in imminent peril of drowning or suffocating. One rescuer made a lasso. Another used a ceiling hook to fish for victims; as he raised one of their arms or legs, his mate dropped the loop over it. Head first or feet first, the four were hauled out. Put under resuscitators and drained of oil, all four came around fairly quickly.
For the years 1971 through 1981, the U.S. Occupational Safety and Health Administration (OSHA) estimated that 174 fatalities per year occurred in confined spaces.
How do these three pieces of information, which span nearly 2,000 years, apply to us in the fire service today? The reality of the issue is that the dangers of work in confined spaces have been known (and documented) for centuries, yet many of us do not recognize the life-threatening hazards that exist within them. Nearly 50 years after that article in the Philadelphia Inquirer appeared, citizens across the country still rely on fire departments to respond to and successfully resolve confined space emergency incidents.
As emergency service providers, fire departments are called to respond when things go wrong in a confined space. When added to the fact that approximately 60 percent of deaths in confined space rescue incidents are those of rescuers, we have great reason to be concerned. It is because of the high fatality rate of the untrained and unprepared rescuer that each fire department must develop standard operating procedures for confined space incidents.
It is easy to underestimate the serious risk potential of a confined space incident. They are particularly difficult to manage for us in the fire service, due to our limited exposure to and experience with actual rescue incidents. They simply do not occur with the frequency of fire duty; hence, our “learning curve” for confined space incidents, as in other technical rescue operations, is much greater.
In 1993, after about 18 years of information gathering, study and public hearings, OSHA issued a comprehensive Federal Regulation that addresses worker safety in confined spaces (29 CFR 1910.146). Although primarily targeted toward industry (excluding the agriculture, construction and maritime industries, which have their own standards regarding confined space operations), fire departments, to varying degrees, are affected by this regulation. OSHA does not have jurisdiction over state and local public employees but if a state adopts its own OSHA plan, it must extend coverage to its public employees. Twenty-five states are regulated by state OSHA plans but must adhere to the federal confined space standard until their state plans adopt a comparable updated version for confined space operations. Six states recently had their own confined space standards in effect.
In many states, government agencies such as fire departments, emergency services and police departments are exempted from this federal regulation. However, the U.S. Department of Labor defines the federal OSHA standards as minimum standards and has furnished research and tabulated data to support the regulations.
Regardless of whether your state is bound to implement the OSHA regulations for public employees, it is recommended that these minimum requirements be used as a baseline guide to develop your own standard operating procedures. The liability could be tremendous and financially devastating to be ignorant of or neglect the minimum safety parameters established by these standards. A civil liability case would be a strong possibility and certainly hard to defend against if recognized minimum safety standards were not utilized. For this reason it would serve in the best interest to use the standard in confined space activities as a template to ensure the safety of fire department members.
Many other agencies have a potential impact on fire department confined space operations:
- National Institute for Occupational Safety and Health (NIOSH).
- American National Standards Institute (ANSI).
- National Safety Council.
- National Fire Protection Associa-tion (NFPA).
- State and local level agencies.
Some agencies contributed much data and counsel to the OSHA Federal Regulation Final Rule; others have direct impact regarding equipment and operating methods when it comes to confined space incidents. (For example, NFPA Standard 1983 recommends specific requirements and tensile strengths for ropes and associated hardware and software used extensively in retrieval systems for confined space entry.)
Much reference material and many guidelines are available regarding confined space operations; it is up to each fire department to utilize whatever information it deems relevant in establishing a standard operating procedure for confined space rescue operations.
Recognition Of Confined Spaces
According to OSHA, a confined space is defined as a space:
- Large enough and so configured that an employee can bodily enter and perform assigned work.
- With limited or restricted means for entry or exit (for example, tanks, vessels and pits are spaces that may have limited means of entry).
- Not designed for continuous em-ployee or human occupancy.
OSHA further defines specific confined spaces in a class that has, or has the potential for, one or more of the following characteristics as “permit-required confined spaces” (OSHA requires that these be inspected and all potential hazards reduced before a permit is issued prior to entry):
- A hazardous atmosphere.
- An engulfment hazard.
- An internal configuration that could trap or asphyxiate an entrant (such as inwardly converging walls or a downward sloping floor that tapers to a smaller cross-section).
- Any other recognized serious safety or health hazard.
Confined spaces can be hazardous in varied ways. Often, a confined space will not appear hazardous; it may have been entered on prior occasions without incident and may give no apparent sign of danger. At other times, there may be indications of danger: a distinct odor of irritating or toxic atmospheres, continued mild shocks, arcing electrical equipment, or flowing grain or sand. By their nature, confined spaces concentrate hazards: atmospheric (some gases will displace breathable air or a confined space will allow the accumulation of toxic hazards or flammable or explosive atmospheres); and phy-sical (limited ability to avoid contact with electricity, moving mech-anical components or machinery, or unstable substances).
Recognizing the capacity of these spaces to harbor hazardous agents is a significant element in any workplace hazard assessment. When confined spaces are recognized to be hazardous, provisions for minimizing the need for entry and for use of appropriate work practices and equipment can be made. (Worker Deaths in Confined Spaces, page 10. U.S. Department of Health and Human Services; Public Health Service; Centers for Disease Control and Prevention; NIOSH; 4676 Columbia Parkway, Cincinnati, OH 45226-1998.)
Confined Space Programs
Under the General Requirements section of the OSHA Final Rule, employers are directed to establish a permit-required confined space program which would be defined as the employer’s overall program for controlling and, where appropriate, for protecting employees from permit space hazards and for regulating entry into permit spaces.
This standard directs employers who determine that employees will enter permit spaces for any reason to finalize responsibilities for workplace evaluation, hazard determination, employee information access and the development of a written permit space entry program.
OSHA has documented that “many of the employees who died in permit space incidents were would-be rescuers who were not properly trained or equipped,” and notes that untrained or poorly trained rescuers comprise a significant “group at risk.”
The OSHA Regulation requires the employer to provide the equipment necessary for safe entry into and rescue from permit spaces at no cost to employees, to maintain that equipment properly and to ensure its proper use by employees.
All employees who work in and around confined spaces (particularly rescuers) should have the understanding, knowledge and skills necessary for the safe performance of their duties. Rescuers should become proficient in the duties required for responding to these types of emergencies and use appropriate procedures.
OSHA identifies four specific categories of personnel involved in confined space operations:
- Confined space supervisor. The person (such as the employer, foreman or crew chief) responsible for determining if acceptable entry conditions are present at a permit space where entry is planned, for authorizing entry and overseeing entry operations, and for terminating entry as required by this section.
- Confined space attendant. A person stationed outside one or more permit spaces who monitors the authorized entrants and performs all attendant’s duties assigned in the employee’s permit space program.
- Confined space entrant. An employee who is authorized by the employer to enter a permit space.
- Confined space rescuer. Personnel designated to rescue employees from permit spaces. (Rescuers must be qualified entrants.)
It is easy to transpose OSHA’s definitions for each of the four personnel categories into our own positions within the fire service. A confined space supervisor could be the incident commander, whether that person is the first-arriving company officer or a subsequently arriving chief officer. In industry, the role of the confined space attendant is commonly referred to as the “hole-watch”; in fire service terms, this position would be the company officer or firefighter assigned the duties of monitoring the authorized rescuers and performing all specified attendant’s duties. The third and fourth personnel categories (confined space entrant and/or confined space rescuer) would be the firefighter(s) assigned the task of actively making entry into the confined space and performing the rescue.
OSHA Training Requirements
A major portion of the overall program mandated by this law involves training requirements. The OSHA standard requires training in four specific personnel categories:
- A supervisor must be trained in atmospheric monitoring, hazard recognition and hazard abatement.
- An attendant must be trained in rescue management, rescue safety and rescue response. (The attendant cannot leave his or her position until relieved by another attendant.)
- An entrant must be trained in hazard recognition, communications, personal protective equipment (PPE) and self-rescue.
- A rescuer must be trained in the same categories as an entrant. Additionally, a rescuer must be an authorized entrant in order to enter a confined space to perform a rescue.
The OSHA Regulation establishes a proficiency level for training that must be attained:
- The employer must ensure that each rescue service member is provided with, and trained to use properly, the PPE and rescue equipment necessary for making rescues from permit spaces.
Each rescue service member must be trained to perform all assigned rescue duties and also receive the training required of authorized entrants under paragraph (g) of the final rule.
- Each member of the rescue service must practice permit space rescues at least once every 12 months, by means of simulated rescue operations in which they remove dummies, mannequins or people from the actual or representative permit spaces.
- Each member of the rescue service must be trained in basic first-aid and cardiopulmonary resuscitation (CPR). At least one of the members on site during rescue operations must hold current certification in both areas.
Although the OSHA regulation requires training, it does not specify the amount of hours, and it does not certify training agencies or curriculums and lesson plans. There is a wide variety of training available — from local and state level fire academies to private training consultants and organizations. Many fire departments provide three levels of training for confined space rescue operations.
The first level is a basic awareness course that informs all members of a department of the hazards associated with confined space operations and gives them a base-level familiarization of specialized equipment and practices utilized for rescue operations. Here, members are taught what actions not to take in order to protect themselves when they arrive first-in at a confined space incident.
The second level of training is commonly referred to as a support level. This is a more comprehensive program that is more hands-on in nature and will enable first responders to competently assist the more highly trained firefighters upon their arrival.
The third level of training is classified by many departments as the technician level. This is the highest level of training given, and involves many hours of classroom and practical training exercises. It is usually concentrated on a small percentage of members; for example, in many urban departments, rescue company members receive this training. In departments without dedicated rescue companies, specially formed technical rescue teams would be given this training.
Regardless of how your department structures its confined space training program, it is critical that every person who responds on an apparatus fully understands the deadly potential of confined spaces and is properly trained to his or her level of expected performance.
Fred Endrikat, a Firehouse® contributing editor, is a lieutenant and 22-year veteran of the Philadelphia Fire Department, assigned to Rescue Company 1. He also is a Task Force Leader for Pennsylvania Urban Search and Rescue (USAR) Task Force 1.