1. #1
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    Default Confined Space Program

    We currently are the rescue service for the majority of industry in our jurisdiction. A company will call and report that they are entering a confined space, and the watch desk will enter it into a log book. We are looking to restructure our confined space service and any help will do. My question is; is this there a better way to track entrys?, (i.e the use of a form listing hazards, type of work, atmoshperic conditions, attendant name ect..) Also do any of your deparments require stand-bys at CS entry, dependent on conditions? Do private buisness' contribute to the funding of CS equipment, refresher training? Thank you in advance for any help

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    I'll preface my response by stating that I am trained in confined space rescue and I perform this service at a large chemical plant where on an average day we may have a dozen or more confined space entries going on simultaneously. As such, we are regulated by OSHA and there are some very specific guidelines that we must follow regarding confined space entries and rescue. Most of our policies and procedures are dictated by OSHA, but some of our practices are above and beyond the requirements.

    The reason I state this is to point out that there are some requirements out there that many fire departments are not aware of or do not fully understand. I'm sure there are some departments out there who do provide this service to facilities in their area and do it well. In fact, I'd say your department is already a couple of steps ahead of the curve in that you at least have a communication established with local industry and they notify you when they are performing an entry. That's a start. I'll bet the majority of FD's out there have confined space entries going on in their areas daily that are never reported or planned for. I'd be further willing to bet that many smaller industries do entries daily that meet the definition of a confined space and don't even know that there are regulations involved.

    However, there are some points here that I would be concerned with. First is the fact that although you guys are being notified, there doesn't seem to be any real planning involved. Just noting it in the log book doesn't constitute planning. Planning should address several issues; Is the entry point at ground level or 200 feet up the side of a vessel? What hazards exist in the space? Physical hazards and obstacles (internal agitators, trays, etc.). Atmospheric hazards? Is breathing air required for entry or will the space be cleared prior to entry? Is the atmosphere considered IDLH? How big is the manway? Are there high anchor points available for your hauling system and are they accessible? How many workers will be in the space at any given time? Lots of items need to be addressed to adequately plan a rescue, and it's almost impossible to address them without going out to the site and inspecting the job (in our plant, we do site visits and plan confined space rescues almost on a daily basis).

    Another issue I would want to look at would be availability. How large is your fire department? By which I mean, do you have multiple stations and a large amount of resources such that a large working fire doesn't suck up all your available personnel? In short, is your rescue team guaranteed to be available 100% of the time when these entries are taking place? For that matter, if your only rescue team gets tied up doing a rescue in Facility "A", are they still available for the entries still going on at Facility "B"? The industries may feel that they are meeting the letter of the law by contacting your rescue team, but are they ensuring that a team is actually going to be available when needed?

    Industry is always going to be concerned with the bottom line. If they can check a box stating that the local fire department has been notified, rather than paying for a standby team that probably won't be needed, then they'd rather do that. That's not always the smartest or safest way to do business, but it is the cheapest. OSHA states that it is the employer's responsibility to ensure that rescuers are available, have been notified, and have had the opportunity to not only inspect and plan the rescue but also to train in a similar, representative space.

    Response time is another concern. How long does it take to get to their facility, get INTO the facility, reach the vessel, rig up and get to the patient? OSHA says that for IDLH entries, it had better be less than 6 minutes. That means a standby team.

    I think it would be a wise idea to schedule a meeting with some of these industry reps and discuss the situation. Review the applicable OSHA standards and see if everyone thinks you are REALLY in compliance, or are they just giving everyone a false sense of security.

    I'll see if I can find a link to the applicable OSHA standards...I think they're available online.
    Chief Dwayne LeBlanc
    Paincourtville Volunteer Fire Department
    Paincourtville, LA

    "I have a dream. It's not a big dream, it's just a little dream. My dream and I hope you don't find this too crazy is that I would like the people of this community to feel that if, God forbid, there were a fire, calling the fire department would actually be a wise thing to do. You can't have people, if their houses are burning down, saying, 'Whatever you do, don't call the fire department!' That would be bad."
    C.D. Bales, "Roxanne"

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    Here is an excerpt from OSHA 1910.146, Confined Space entries.....This is specifically the part regarding the employer's responsibilies in selecting an external rescue team.....this is only part of the standard, you may want to go to

    http://www.osha.gov/pls/oshaweb/owad...ARDS&p_id=9797

    and review the entire standard.



    Rescue and emergency services.
    1910.146(k)(1)
    An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of this section, shall:
    1910.146(k)(1)(i)
    Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

    Note to paragraph (k)(l)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, 1910.134, Respiratory Protection, requires that employers provide a standby person or persons capable of immediate action to rescue employee(s) wearing respiratory protection while in work areas defined as IDLH atmospheres.
    1910.146(k)(1)(ii)
    Evaluate a prospective rescue service's ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified;
    1910.146(k)(1)(iii)
    Select a rescue team or service from those evaluated that:
    1910.146(k)(1)(iii)(A)
    Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;
    1910.146(k)(1)(iii)(B)
    Is equipped for and proficient in performing the needed rescue services;
    1910.146(k)(1)(iv)
    Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and
    1910.146(k)(1)(v)
    Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations
    Chief Dwayne LeBlanc
    Paincourtville Volunteer Fire Department
    Paincourtville, LA

    "I have a dream. It's not a big dream, it's just a little dream. My dream and I hope you don't find this too crazy is that I would like the people of this community to feel that if, God forbid, there were a fire, calling the fire department would actually be a wise thing to do. You can't have people, if their houses are burning down, saying, 'Whatever you do, don't call the fire department!' That would be bad."
    C.D. Bales, "Roxanne"

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    I agree with everything the DMLE stated.

    One thing I would add is, I believe that if someone is making entry into a confined space per OSHA, they should have a safety line tied into them. Are you sure that the industry in your area is actually doing this?

    Excerpt:
    1910.146(k)(3)
    To facilitate non-entry rescue, retrieval systems or methods shall be used whenever an authorized entrant enters a permit space, unless the retrieval equipment would increase the overall risk of entry or would not contribute to the rescue of the entrant. Retrieval systems shall meet the following requirements.
    1910.146(k)(3)(i)
    Each authorized entrant shall use a chest or full body harness, with a retrieval line attached at the center of the entrant's back near shoulder level, above the entrant's head, or at another point which the employer can establish presents a profile small enough for the successful removal of the entrant. Wristlets may be used in lieu of the chest or full body harness if the employer can demonstrate that the use of a chest or full body harness is infeasible or creates a greater hazard and that the use of wristlets is the safest and most effective alternative.
    1910.146(k)(3)(ii)
    The other end of the retrieval line shall be attached to a mechanical device or fixed point outside the permit space in such a manner that rescue can begin as soon as the rescuer becomes aware that rescue is necessary. A mechanical device shall be available to retrieve personnel from vertical type permit spaces more than 5 feet (1.52 m) deep


    FYI
    Where I work, we have a stand by rescue team in place at every confined space entry taking place. We have paid these teams alot of money and currently they are training some of our volunteer response team in actual entry rescue.

    Anthony

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    Great info thanks, I have read standard and have a fairly good idea what is expected. Bottom line is that we are a department of 40 line personnel, operating out of two stations split 6 and 3 for a total of 9, with 6 staff on weekdays. We have very light industry an only 3 CS incidents in the last ten years, however I believe in prepardness. We are also located in NH which is not an OSHA state(unless accident or death occur) so standards are taken lightly. There are 5 of use trained to a technician level in our department, the unfortunate thing is due to an old school mentality the rescue will be affected by untrained personnel depending on who is on duty. I understand the need for preplanning sites, which we are in the process of doing. I was curious if developing a OSHA based permit to use as a log would benefit us. This permit would list: physical hazards, atmoshperic readings(done by company), type of work, and number of entrants, ect.. I also could not find in the standard if a team is required on site, other than if supplied air is being used.

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    Default

    Rather than telephone the station would the industry be able to fax the confined space permit paperwork to the station? That should list everything that you are looking for.

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    That would be a great idea, however due to the fact that we are a Non-OSHA state, the majority of business(including PWD)in our juristiction do not use a permiting program. I hope that developing our own detailed logging program may spur a joint FD/industry initiative to address these issues. What do you guys think if; We asked for air-monitoring results, hazards, work being preformed, attendant name ect... after a while of asking these questions would the company take it upon themselves to accomplish this prior to calling? Do any of you have the same issues?

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    irons308
    You need to look at appendix F under the OSHA standards. Even though this is a non-mandatory appendix it is just like driving a car with a warning sign for a speed limit going around in curve, you don't follow it, have an accident, get a ticket. Here some of the things I think might help you.

    I. The employer should meet with the prospective rescue service to facilitate the evaluations required by 1910.146(k)(1)(i) and 1910.146(k)(1)(ii). At a minimum, if an off-site rescue service is being considered, the employer must contact the service to plan and coordinate the evaluations required by the standard. Merely posting the service's number or planning to rely on the 911 emergency phone number to obtain these services at the time of a permit space emergency would not comply with paragraph (k)(1) of the standard.

    1. Have all members of the service been trained as permit space entrants, at a minimum, including training in the potential hazards of all permit spaces, or of representative permit spaces, from which rescue may be needed? Can team members recognize the signs, symptoms, and consequences of exposure to any hazardous atmospheres that may be present in those permit spaces?

    4. Do all team members perform their functions safely and efficiently? Do rescue service personnel focus on their own safety before considering the safety of the victim?

    If you have personnel that are entering a confined space or would enter a confined space for a rescued without training, your department would be held responsible like any other industry. Just because we are the rescue team does not mean we do not have to follow the regulations. Your department must have a written program just like industry.

    By federal law there has to be some type of regulatory agency that covers your state. The OSHA standard states that if a state is a non-OSHA state the regulatory agency must have standards equal to or higher than the OSHA standards. No state can have standards lower or less than the OSHA standards.

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    I have just read appendix F and this is what should be done(correct me if wrong):

    1. All permit confined spaces should be preplanned for; Entrance/egress layout, potential Physical hazards, IDLH potential, Anchor points, ect...

    2. A minimum of 4 rescuers should be available at all times, for rescue. Only one entry at a time should happen in the city, due to lack of resources

    3. We should meet with industry represenatives, to discuss these issues

    4. Annual refresher training should mimic possible situations we may encounter

    5. Contact our Department of Labor for specific regulations on CS as it pertains to rescue(I belive the administration will want to follow 1910.146)

    We have drafted and operational guideline for Confined Space however is there anybody who has anything on Logging/permiting procedures pertaining to FD

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    irons

    I think you have it.

    One thing more about the permit ... IF you can get industry to intiate the permit, it helps you when you respond to rescue people. Our local FD depends on our permit so when they get there, they do a quick verify on our paperwork and go in. Very helpful to the victim.

    Anthony

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    The industry that you respond to should have the permit started before you arrive. Regardless of who enters the space everyone should operate off of the same permit. If you arrive at an incident where the plant employees are not using a permit system, you should have a generic permit system in place that you can start.

    Our interp of the "notify the rescue team" standard is to have all of the industries in town call the FD dispatch center and tell them when they are getting ready to enter a space. The dispatch center keeps a log of entries, in the event that the team is dispatched the FD dispatcher calls all of the other businesses that have employees in spaces and tells them we are not available and that they should stop their entries until the team is available.

    We don't collect information other than the contact information because we have 50 to 60 con-space entries in our community every day. We also send out our training calendar one year in advance so industries know when we will be out-of-service. Usually three days per month.

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    Default Misconceptions

    There are many misconceptions in confined space rescue standby operations and many of them have been repeated in this message thread. I have been actively involved in the fire service at a local, state and federal level for 40 years and run a private training company that teaches emergency responders worldwide. We also provide confined space and swift water rescue standby teams to industry on a contract basis.

    1. A non-OSHA state means the state does not have a state OSHA plan. All industry in every non-OSHA state falls under federal OSHA regulations instead of state OSHA regulations. There are 26 non-OSHA states/territories in the U.S., Louisiana (where I am from) being one of them. Being in a non-OSHA state means that local fire and police departments, city employees, county/parish workers, colleges and university and state workers do not fall under OSHA regulations and cannot be cited by OSHA. If a fire dept in a non-OSHA state responds to a confined space rescue inside an industrial facility and kills 6 firefighters in the attempt OSHA cannot cite the FD. They will, however, cite the facility. OSHA will consider the firefighters to be facility employees as soon as they cross the property line and if 6 of them die then the plant was negligent in training and equipping the firefighters to work safely.

    2. Response times, as stated in Appendix F, are pretty straight forward for the most part. If entry is being made into a space that is IDLH or has the potential to rapidly become IDLH then the rescue team has to be ready to make immediate entry. That means fully geared up with harnesses, appropriate respiratory protection and rescue equipment, and standing by at the entry point.

    If the potential injuries are likely to be mechanical in nature instead of atmospheric related (falls, cuts, breaks, etc.) then OSHA says a 10-15 minute response MIGHT be adequate. OSHA defines response time as time for notification of the rescue team, response of the team to the location of the rescue, size up of the incident, rescuers getting geared up and being ready to make entry into the vessel for rescue in 10-15 minutes.

    If you are ready to make entry in 10-15 minutes from the time of the alarm then you are probably not ready to make a safe entry. OSHA says in 1910.146(d)9 that every permit-required confined space has to be pre-planned for rescue prior to entry being allowed by the workers. If the FD hasn't pre-planned the space for rescue then they don't know what they are getting into.

    Are you going to take the facility's word that the atmosphere is safe? Atmospheric monitoring is the one area of confined space entry that we see the most problems with nationwide. Employees don't know how to calibrate the monitors, interpret the results, perform a test properly and are just plain complacent/lazy about doing the tests. The FD must be able to conduct its own atmospheric testing. Done properly, depending on the size, shape and internal configuration of the space, atmospheric testing may take 30+ minutes. We teach an atmospheric monitoring class for the maritime industry that is 16 hours in length and 8 hours of that involves being in the field testing spaces. Are your firefighters proficient in using the monitor?

    3. A confined space entry permit is not required to make entry into a vessel for a rescue. You are required to make sure that your firefighters are properly protected prior to entry. Filling out an entry permit will do most fire departments little good because they have zero knowledge of the lockout/tagout, energy isolation requirements and chemical/physical/mechanical hazards for that particular vessel.

    4. While the FD in a non-OSHA state cannot be cited by OSHA for any mistakes they make they can be sued by the victim's, by the facility and everybody else you can imagine. Be very sure that you understand exactly what you are opening yourself up for if you agree to be the standby rescue team for an industrial facility.

    Feel free to contact me if you have any questions.

    Mike Dunn
    Emergency Response Training, Inc.
    Port Allen, LA
    888-639-4600
    ert@ertrescue.com

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    Hi, Mike....I hope most of my post was correct, 'cuz you taught me a bunch of it

    Dwayne with Dow ES&S here......
    Chief Dwayne LeBlanc
    Paincourtville Volunteer Fire Department
    Paincourtville, LA

    "I have a dream. It's not a big dream, it's just a little dream. My dream and I hope you don't find this too crazy is that I would like the people of this community to feel that if, God forbid, there were a fire, calling the fire department would actually be a wise thing to do. You can't have people, if their houses are burning down, saying, 'Whatever you do, don't call the fire department!' That would be bad."
    C.D. Bales, "Roxanne"

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    Default On target

    Hi Dwayne,

    You were absolutely on target on what you said. I'm just afraid too many fire departnments are going to be lead into agreeing to be a confined space rescue standby team by upper management who don't have a clue as to what happens in industry or what they are getting themselves in to.

    Mike

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    Default C Space

    I know I am coming into the conversation late, but the information I see is correct. However NH might be a non OSHA state for the fire departments and DPW but private industry still has to follow OSHA laws for Confined Space Entry. They have to by law use the permit system and have to give the fire department access to the facility if the fire department is listed as the rescue team. I have not seen any time frames listed by OSHA they usually state "in a timely manner" or something similiar. We teach C Space at the state level here in Mass and I have taught a few classes in NH for private industry clients. They know they must use the permit system and follow OSHA for all their work including hot work, LOTO, etc.. If you need any further information feel free to contact me. We also operate a technical rescue team that trains monthly and we use private industry facilities for training and they know it works to their advantage to have us on site. The normal interpretation regarding respirator usage is if it requires their use then the rescue team must be on site for immediate deployment
    Last edited by FIRELT03; 06-23-2007 at 10:06 AM.

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    Default Time frames

    Read 1910.146 Appendix F for OSHA suggested time frames for what constitutes a timely response. They are pretty clear about what they expect the "rescue team", whoever that is, (in-house or outside contracted team) to be able to do. If you are an outside contracted team and you receive money from the plant for that service you might fall under OSHA regulations and be subject to citations for substandard performance in techniques, preplanning, response times, etc. You might want to consult with an attorney first.

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