HAZMAT/Confined space entry

[7Stones]

So I have a dilemma. I work in a place that contains permit required confined space and entries are being made somewhat routinely. The confined space rescue team fell apart a couple of years ago. I am new kid on the block so they have asked me to revive the rescue team. However, my boss wants to do it as inexpensively as possible. The question has come about HAZMAT atmospheres. I am a HAZMAT tech. I argue that if the rescue effort is into a toxic atmosphere that requires A level entry, that our rescue personnel must be trained to HAZMAT Tech. My boss disagrees because he says that the entry is not being made to contain or mitigate a HAZMAT incident, only to remove victims. He thinks we can do that with Operations level training. I have always been taught (although I cannot remember the reference) that level A requires Technician level training and Operations level is limited to B and defensive procedures. Where are the suit level restrictions spelled out (NIOSH, OSHA, NFPA?).

Can someone help me straighten this mess out? My fear is that if my boss thinks we can get by with Operations Level training then we will have guys dressing in A suits without the proper training and performing rescues (offensive operations).

Has anyone else dealt with the HAZMAT/Confined Space question before. I am new to this forum so I apologize if this question has been answered before.

Thank you VERY much for your help.

Jon
jcstone@mtu.edu

[jbrescue]

I have to say that I totally agree with you. However, take a look at NFPA 472, it allows for operations personnel to be trained for mission specific tasks. If you are always using chemical xyz in your plant, they can be trained to work in a suit for that mission. Now, NFPA does not apply to industry. So look at OSHA for more guidance. Your are right, you need a rescue team before someone needs to be rescued. Good Luck.

[WCENG23]

OSHA 1910.146 Appendix F covers emergency response criteria for confined space.

Joe

[Halligan84]

What type of toxic materials do you expect?

What do the entrants use for PPE?

Are you trained to the level of the entrant?

I have long felt that con space rescue should be done by haz mat techs as a general rule (particularly in the public sector) due to the amount unknowns.

[DFD271]

What level of PPE did the oringinal entrants have on (the victims). I hate to say if you are going to need level A in a confine space "rescue" you are probally doing a body recovery. Remember Level A is only usally required if you have a compound with a skin/vapor toxicity hazard. I am not familar with any confined space training program that suits up rescuers in Level A to do an entry. Before you worry about the HAZMAT tech level your boss needs to review the entire OSHA confined space standard. External rescue would be your primary tool if you had a situation requiring Level A.

[7Stones]

What type of toxic materials do you expect?

What do the entrants use for PPE?

Are you trained to the level of the entrant?

I have long felt that con space rescue should be done by haz mat techs as a general rule (particularly in the public sector) due to the amount unknowns.

We expect H2S, Methane, Propane, Natural Gas, CO, etc. However, we are a research university so there could always be some nasty stuff floating around somewhere. Monitoring is the key!

I am a HAZMAT Specialist, one course away from Hazardous Materials Emergency Response Professional. Training isn't the issue. I can train our team to Tech level.

I am working to put together a team. A supervisor, however, thinks we can short-change the HAZMAT training because we are only talking about rescue, not full mitigation. We have a mitigation contractor. I told him that any level A entry requires Technician level training. He told me to prove it.

I am not sure what we are trying to do ... save a little money? But at what expense.

Ultimately I think both the HAZMAT and Confined Space Rescue teams are going to fall in my lap. I have only gone through confined space awareness training so far so it looks like I will need some more training. I am comfortable with my HAZMAT knowledge and competency. One nice thing about working for a university is I have seen just about everything -- in smaller quantities of course.

I appreciate all the input.

I am considering organizing a confined space rescue training that we can open up to a local FD which already does high rope rescue. We have to train specifically in our spaces but it would be nice to have them trained and ready to back us up if we need help.

Now I am looking for training options. The search continues...

Jon

[gdsqdcr]

You should be able to find this information at OSHA. FRO is only defensive operations. For Fed OSHA, you need to be a Hazmat Tech at minimum. For CalOSHA, we have something called Hazmat Industry Technician. This is a 24 hour class taught onsite at your facility that allows you to respond offensively to a hazmat incident.

You should check to see if your state has something along those lines.

As for a Level A entry into a Confined Space. I don't think I would ever do that, even for a rescue. If i need to take that much time to suit up into a Level A, I would give serious thought to the situation being a recovery effort instead of a rescue. In addition, for me entering a confined space in any type of chemical PPE, would be a serious concern to me as a safety officer. Confined Spaces are tough enough to work in, crawl in. I was always taught and I teach you are never to let your suit touch the ground as they may break the integrity of the suit.

There are ways to mitigate the hazard before you enter.

My thoughts as a Hazmat Specialist and Confined Space Rescue Operations certified.

Anthony

[rescue542]

Jon,

In the state of Michigan both private and public employees are covered by MIOSHA, with the only exception being federal employees. MIOSHA regulations are for the most part the same as OSHA regulations with some additions.

In reviewing the MIOSHA regulations for confined space (Part 90) they are exactly the same as OSHA (29 CFR 1910.126) with the exception of one rule that applies a different standard to agriculture, construction, and shipyards. Additionally in reviewing MIOSHA regulations for HAZCOM (Part 154) and Emergency Response (Part 432) they are essentially the same as OSHA (29 CFR 1910.1200 and 29 CFR 1910.120) with only additions regarding the history of the standard in Michigan and adoption by reference of DOT markings.

As an initial entry into the confined space, the HAZCOM regulation (Part 154)would cover the entrants unless they are responding to an unintended release in which case the Emergency Response regulation would apply (Part 432).

So based upon the relevent regulations for your state I don't see anything that denies the use of level A PPE for an entry into a confined space. It also does not specify that Operations level personnel may not wear Level A PPE provided they were trained in its use and limitations. The exception would be if they were expected to stop the leak, in which case they would need to be trained to the Technician level.

In the non-mandatory Appendix E of Part 432 it states "hands-on training including level A, B, and C ensembles and appropriate decontamination lines; field activities including the donning and doffing of protective equipment to a level commensurate with the employee’s anticipated job function and responsibility and to the degree required by potential hazards." In the non-mandatory appendix C of Part 432 it does specify that the individual performing the required tests on the level A suits should be trained at the specialist level.

I would be happy to provide you with additional information if you like. You can contact me at scottvanb628@aol.com

Hope this helps.

Scott Van Boerum
Alps Rescue Services

[alexrangel7]

I have never heard of any one doing a confined space rescue in level A. It would be very difficult especially if the rescuer is being lowered on a system or has to crawl in cramped conditions. If it is a toxic atmosphere, then one needs to change that atmosphere to meet OSHA entry requirements.

Any one out there ever had to do confined space rescue in level-A? and if so, what were the conditions?

AL

[rsqman]

It seems like everyone is assuming that the entrant into an IDLH confined space is requiring rescue because of either a breach in his chemical protective clothing or a loss of air supply or both. While entries are often made into permit-required confined spaces under IDLH conditions, a rescue is seldom caused by a suit breach or an air loss. Slips, trips and falls, strains and sprains, heat illness problems, medical problems such as insulin dependent diabetics, allergic reactions, etc., are much more likely problems.

The majority of workers making IDLH entries do not wear SCBA. They use airline respirators (often with a two-part face piece that bolts in place and cannot be removed by the entrant) and multiple redundant air sources. Many of these confined spaces have open holes in slick floors and slips, trips and falls are a real concern. Standard rope rescue gear may be quickly compromised because of the corrosive effects of some of the atmospheres.

Any effective rescue must be pre-planned before allowing any workers to make entry. I have been involved in many of these types of entries as part of a contracted stand by rescue team and while no IDLH rescues have had to be made on any of our jobs in the last 13 years, we have been geared up and ready to make entry for rescue safely due to pre-planning.

Mike Dunn

[RangerJake72]

While I don't claim any sort of expertise, nor much recent familiarity in confined space ops or HAZMAT, I thought I might through in the definition for a Confined Space, as it seems we are all thinking along the lines of a pipeline or tunnel.

From Wikipedia (and this is the same definition I remembered from my confined space rescue classes long ago):

A confined space is any space: 1) that has limited or restricted means of entry or exit; 2) is large enough for a person to enter to perform tasks, and 3) is not designed or configured for continuous occupancy. [1] A utility tunnel, the inside of a boiler (only accessible when the boiler is off), the inside of a fluid storage tank, and a small underground electrical vault are all examples of confined spaces. The exact definition of a confined space varies depending on the type of industry. That is, confined spaces on a construction site are defined differently than confined spaces in a paper mill. Confined spaces that present special hazards to workers, including risks of toxic or asphyxiant gas accumulation, fires, falls, flooding, and entrapment may be classified as permit-required confined spaces depending on the nature and severity of the hazard.

so maybe a Level A suit entry would not be that unlikely if you are in an area that may contain an IDLH atmosphere, but is not a cramped vault, but perhaps the inside of a tank or chamber for some sort of process, that would normally be sealed to the outside, and personnel only enter for maintenance, repairs, etc.

Be Safe

[rdw930]

I work for an Industrial Emergency Services Department and we respond to Fires, EMS, Hazmat, and all types of Technical Rescues on our campus. The company deals with manufacturing and uses a large number of chemicals and gases. We are lucky enough to have both a Hazmat Truck and a Hazmat Support Trailer in addition to a Confined Space Rescue Unit. I have been on a few hazmat incidents that involved confined spaces. The most recent being a large spill of 98% Sulfuric Acid (minimal vapor). Unlike your facility our Hazmat Team does clean up the bulk contaminates and we have the decon done by contractors. On the incidents I have been on the entry team and the back up team were both in Tychem SL Suits and SCBA. Obviously the suits were taped using Kaplar ChemTape. I have never heard of or trained in entering a confined space in a Level A suit. All of the members of both the Hazmat and Confined Space Rescue Team are required to be certified in Basic and Advanced Rope Rescue and Advanced Confined Space Rescue and also all are required to be certified Hazmat Technicians with some being certified Hazmat Incident Commanders. Our certifications are all through State Fire Programs and are ProBoard.

[rwd3rd]

I am a Safety Professional with a background in Hazardous Materials from the fire service. I took the Haz Mat Tech Course in Pueblo, CO at the National Transportation Test Center. Working in the Petro-Chemical Industry I can say the best resource is OSHA CFR 1910.146 Permit Required Confined Space Entry. Appendix F outlines the rescue aspect of confined space. It says you are required to be certified in Basic and Advanced Rope Rescue and Advanced Confined Space Rescue and also all are required to be certified Hazmat Technicians with some being certified Hazmat Incident Commander. I will say that we use Level B Personnel Protective Equipment. The respiratory protection if fresh air is required is airline w/egress bottle. Especially when your talking about tanks, vessels, etc.... OSHA does say that you must provide a rescue team during confined space operations. I have never heard of being trained at Level A for confined space rescue in industry. Most plants utilize the plant fire brigade for Confined Space Rescue if they are trained. The level of PPE is determined by the concentration in air. This means a good multi-gas monitor needs to be used inside the confined space. We utilize mechanical ventilation devices for air flow watching the LEL of course.