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  1. #1
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    Default confined space question

    What training and other requirements do your agencies (jurisdictions) have regarding rescue in confined spaces that are certified (via documentation) as non-permit or are clearly non-permit? Are they the same as for permit-required confined spaces? Do you just assume that all confined spaces are permit-required?

    I don't know anything about confined space rescue. Thanks for answering my question.


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    What a great question; it's one that gets asked A LOT. Whether you're new to confined space rescue or you've been involved for many years, this is an important topic to address.
    A couple years ago there was a "discussion" between some professional rescuers/trainers and an organization that wanted to allow their rescue team to perform rescues without breathing apparatus. This is the (edited) response that was put together.

    The history of confined space incidents tells us that the real killer in confined spaces is the atmosphere. With that in mind a good idea would be to always wear respiratory protection; let's call that Rule #1. But you might ask, is there ever a time when you would consider not using respiratory protection? Our answer was NO, NEVER and here's why.

    1. ATMOSPHERIC MONITORS
    a) They should be counted on to only tell you when the air is bad. If they alarm BELIEVE that something is bad. If they don't alarm DO NOT ASSUME THAT THE AIR IS GOOD; they typically only test for a very limited number (usually four) of the world's known bad atmospheres. They won't tell you when something bad is in there if they are not set up to test for that product. Refer back to Rule #1 "the real killer in confined spaces is the atmosphere... always wear respiratory protection".

    b) The accuracy of these monitors is highly dependent on people who use and take care of it. Who last calibrated it and how competent are they? How long ago was that? What is the skill level of those that are performing the test at the scene? Was the monitor properly bump tested prior to this test? Was it properly fresh air tested? Has it been recently dropped or otherwise physically abused? Is the pump working properly? Was it given the correct amount of time at each level of testing?
    If you are feeling 100% confident with the answers to all of these questions and would still like to send your rescuers into a confined space without breathing apparatus, refer to rule #1 "the real killer in confined spaces is the atmosphere... always wear respiratory protection".

    2. CONFINED SPACE ENVIRONMENTS
    a) Confined spaces typically have air flow restrictions which minimizes the replacement of oxygen. Having 2 or 3 rescuers and a patient breathing the existing oxygen without properly replacing it will cause an oxygen deficient atmosphere. If you are counting on your portable confined space ventilation system to remedy this you must again be 100% confident with the answers to a number of question.
    * is the blower supplying rather than exhausting air?
    * is sufficient air (oxygen) reaching the rescue area?
    * what is the size of the space and the capacity of your blower?
    * is the duct tubing kinked?
    * is it short circuiting or recirculating?
    Are you sure that there will be enough oxygen in the space for the rescuers and the victim(s) for as long as they need to breath? If not, refer to Rule #1.

    b) Changes in the atmosphere can occur while the rescuers are in the space. The rescuers (both inside and outside) can change the flow of air currents in the space by moving and opening things thus bringing hazardous atmosperes into the rescue area that were not there during the testing procedure. If the entry team is not wearing respiratory protection when this occurs they will be exposed and possibly injured or killed. Something as simple as the rescuers stepping on a crusted-over liquid and breaking the seal of the crust can release toxic fumes. If you are not 100% sure that no changes can possibly occur, refer to Rule #1.

    c) If the confined space has a recorded history of never having an atmospheric hazard, you will want to see said "recorded history" and determine how many safe entries have beeen conducted during the recorded time frame. Who conducted the tests and recorded the history? How competent is that person(s)? If that seems like it will take too much time during a rescue, refer to Rule #1.

    In the last few years there have been at least three (3) incidents where firefighters have been killed or seriously injured as a result of exposure to hazardous atmospheres in/around confined spaces. Wearing respiratory protection at every confined space incident might be overkill and it's certainly inconvenient but it would have prevented ALL of the injuries to these firefighters.

    I suppose that if your (teams) confined space training was of the highest caliber, that your (teams) training is up to date and that you regularly practice in a variety of spaces, if you're intimately familiar with your equipment and that your assessment of this particular confined space on this particular day is accurate, then maybe you can get away without breathing apparatus, But if you only train on confined spaces once or maybe twice a year, haven't used a four-gas air monitor since you don't know when, aren't 110% certain that there isn't anything "bad" in the space you ought to refer to Rule #1, "the real killer in confined spaces is the atmosphere... always wear respiratory protection".

    Stay safe.
    Dave

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    OK, what if we're talking about a 10 ft diameter 2 mile long irrigation siphon with obvious huge fresh air exchange at the surface. The siphon is not running with water, it's dry. How would you feel about sending a non-confined space certified team into the siphon to rescue a worker with a traumatic injury?

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    Quote Originally Posted by servantleader View Post
    OK, what if we're talking about a 10 ft diameter 2 mile long irrigation siphon with obvious huge fresh air exchange at the surface. The siphon is not running with water, it's dry. How would you feel about sending a non-confined space certified team into the siphon to rescue a worker with a traumatic injury?
    Since the siphon has the potential to run water and presents a potential hazard, I would consider this a permit required space. Some form of lock-out tag-out would have to be put into place. Also, the air exchanger/s has the potential to fail, or inadvertently shut off.

    To me this sounds like a permit require space.
    Last edited by MichaelXYZ; 03-07-2013 at 01:36 AM.

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    Quote Originally Posted by MichaelXYZ View Post
    Since the siphon has the potential to run water and presents a potential hazard, I would consider this a permit required space. Some form of lock-out tag-out would have to be put into place. Also, the air exchanger/s has the potential to fail, or inadvertently shut off.

    To me this sounds like a permit require space.
    Fair enough. Thanks.

    Lock out/tag out of the water source would need to be verified. Does this automatically make it a permitted space.

    There are no air exchangers. The air exchange is due to natural air flow. The wind blows like crazy around here.

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    Quote Originally Posted by servantleader View Post
    Fair enough. Thanks.

    Lock out/tag out of the water source would need to be verified. Does this automatically make it a permitted space.

    There are no air exchangers. The air exchange is due to natural air flow. The wind blows like crazy around here.
    As I understand the OSHA regs.

    A permit required confined space has one or more of the following characteristics:

    A potential to contain a hazardous atmosphere;
    Material that can cause the engulfment of an employee;
    An internal configuration that might cause an employee to be trapped or asphyxiated by inwardly converging walls or by a floor that slopes downward and tapers to a smaller cross section; or
    Contains any other recognized serious health or safety hazard.
    According to OSHA, if you have to lock-out, tag-out, then this implies a potential hazard exist, so I would say this is a permit required space. If it were my guys to go in, I would treat as a permit space.

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    Quote Originally Posted by MichaelXYZ View Post
    As I understand the OSHA regs. According to OSHA, if you have to lock-out, tag-out, then this implies a potential hazard exist, so I would say this is a permit required space. If it were my guys to go in, I would treat as a permit space.
    Hi Michael,

    LO/TO removes the potential hazard. If you go back in the 1910.146 standard to paragraph C it describes how to reclassify a permit-required confined space to a non-permit-required space. They say that if all hazards are controlled/eliminated to where the only potential hazard is atmospheric and you can control that effectively with ventilation then you can reclassify the space. I'm not sure I totally agree with that but I see it done a lot. If it is a non-permit space then the owner of the confined space is not required to have an attendant (hole watch) for the entry, not required to have a rescue team available, don't have to go out and spend lots of money buying rescue gear and training a team or having a contract rescue team come in. You can see how attractive that becomes in tight budget times for an industrial facility.

    I frequently see industrial facilities take obvious permit-required confined spaces, with some pretty serious hazards, reclassify them just for that particular entry and then immediately call them permit-required when the job is finished. It's a paperwork game for the plant and they are crossing their collective fingers hoping nothing goes wrong.

    If you are called to a non-permitted or permit-required confined space rescue then something has obviously gone wrong and they are expecting you to "fix" it because they can't. If you refer back to Dave's answer, protection of your rescuers is the #1 rule. Stay safe and don't be too trusting when the plant people tell you there are no hazards in the space and you are just wasting time putting all that "junk" on.

    Mike Dunn

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    Quote Originally Posted by rsqman View Post
    Hi Michael,

    If you are called to a non-permitted or permit-required confined space rescue then something has obviously gone wrong and they are expecting you to "fix" it because they can't. If you refer back to Dave's answer, protection of your rescuers is the #1 rule. Stay safe and don't be too trusting when the plant people tell you there are no hazards in the space and you are just wasting time putting all that "junk" on.
    This.
    It seems that permit/non-permit spaces is largely the responsibility of the owner of the confined space and impacts how/when the initial (non emergency) entry was performed. When something goes wrong and we are called to make an emergency entry our activities don't change depending on if the space is permitted or not.. we are still going to have monitors, safety lines, air supplies..etc.
    So you call this your free country
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  9. #9
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    Quote Originally Posted by voyager9 View Post
    This.
    It seems that permit/non-permit spaces is largely the responsibility of the owner of the confined space and impacts how/when the initial (non emergency) entry was performed. When something goes wrong and we are called to make an emergency entry our activities don't change depending on if the space is permitted or not.. we are still going to have monitors, safety lines, air supplies..etc.
    All very true. If the facility is depending on the local FD to make any high angle or confined space rescues then OSHA says they are supposed to contact that FD to first, see if they are willing and able to perform the rescue safely. That frequently doesn't happen. I know of one fertilizer plant in Kansas who had a 180-foot-tall column with internal trays. Entry would be made horizontally through a 20" manway at the top of the column and then proceed down through the trays. The trays were 18" apart with a square 16" by 16" opening in the trays. The column was only 6 feet in diameter. The plant reclassified this as a non-permit required confined space and simply planned to call 911 if they had a problem. They never contacted the local FD to see if they could or would provide rescue services. Luckily, no one required rescue during the job. The main thing is.....you may be the plant's rescue team and not even know it. This facility was in a rural area protected by a small volunteer FD who did not have any training or equipment for a rescue such as this one.

    If it occurred in a city protected by a well equipped and trained FD rescue team it still would not be a timely rescue. How long will it take for rescuers to climb a 180 foot tall vertical scaffolding ladder (oh yeah, did I forget to mention that there is no permanent access up the tower and they build scaffolding to reach the top), with all the equipment needed to safely perform a rescue? You had better have a bunch of very physically fit, skinny rescuers for this one.

    Mike

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