If you’re working in a confined space and the unthinkable happens, your team can just call 911, right? According to Gary Toothe, F.S. Solutions customer training manager, dead wrong.
“Calling 911 is not going to work, because most fire departments, especially volunteer fire departments, are not trained in confined-space rescue.”
Take Atlanta, Toothe’s closest city center. He says the metropolis has three departments that are trained for confined-space rescue — out of 34 total stations.
“If they happen to be out at a fire, they’re not going to let the building burn down,” Toothe says. “You may not have (a large) number of confined-space rescue teams, so put somebody on deck. Make sure you let them know enough in advance that somebody will need to be available if necessary.”
That may seem obvious, but again, it’s often something taken for granted. The OSHA regulation itself is somewhat lacking in specifics, and many contractors tend to overlook this aspect of confined-space entry.
Training expectations
There are different types of confined-space training — and being trained to perform confined-space entry does not qualify you to perform rescue.
“Generally, the operation training will say something like, ‘You need to ensure that confined-space rescue services are available.’ And that’s it. That’s pretty much the throwaway tag line for the whole basic training,” Toothe says.
It’s also important to note that you can’t just call the first phone book ad claiming confined-space rescue services. OSHA clearly lists the criteria for a confined-space rescue team, and it is incumbent on the employer to evaluate any chosen team for proper training and capability.
Part of the difficulty of confined-space rescue training is that OSHA quantifies 16 different scenarios or manhole configurations, and a properly trained rescue team has to be prepared to act on any of those scenarios that could reasonably be expected in their service area.
For example, elevated or nonelevated manways are different scenarios, as are restricted and nonrestricted, as well as obstructed and nonobstructed. So if rescuing in a manway with obstructions, oxygen tanks and breathing apparatus could become a challenge, and rescue teams need to be prepared for that.
“Here’s the big problem with confined-space rescue: Ask most people how many different kinds of confined-spaces there are, and they will say two: nonpermit required and permit required. Ask them how often they practice, and they’ll say, ‘Once a year, just like OSHA says,’” Toothe says. “But there are 16 different configurations for permit-required confined spaces, which means if you’re going to be certified as a confined-space rescue person, you have to be able to extract people from 16 different styles of confined spaces. And you should practice those, or at least those you are expected to provide rescue from, at least annually — all of them.”
This means that instead of the one day that many contractors believe to be the expectation, in order to be ready for all of the different scenarios, you would need about five full practice days throughout the year.
“That doesn’t happen a lot,” Toothe says. “The regulation states that you must practice for each configuration you’re reasonably expected to provide rescue from. Most contractors don’t get that. It’s a big mistake as far as confined-space rescue is concerned — it’s something that lays in the weeds, if you will.”
Developing a rescue team
Toothe says before becoming a safety manager, he did a fair amount of work for nuclear power plants, where safety is paramount. They had two confined-space rescue teams available, but even so, he had to make sure that one of the teams would be available before he could proceed — it wasn’t simply a matter of assuming there would be rescue available.
“I generally tell people you need to put the rescue team on deck. Tell them they need to be prepared to do rescue if such an eventuality occurs so they can have the cart loaded with the proper materials. ... You need to make sure you let them know enough in advance that somebody will be available to perform it if necessary.”
Larger contractors or facilities like the power plant can have its own rescue teams on hand, but even then, their availability can’t be taken for granted, and they must qualify by OSHA’s standards.
If developing your own rescue team is feasible, Toothe recommends an analytical approach.
“The first thing you should do is identify what types of confined spaces you need to provide rescue for or from. So do a general sort and say we don’t have any elevated, so we can eliminate that. Do an inventory of what style of confined spaces you need to provide rescue for.”
An added lifeline
Another big misunderstanding of confined-space rescue stems from an oversimplified interpretation of OSHA’s lifeline rule.
“There’s one other thing that most people don’t get, and that’s if you’re not going to wear a lifeline — if nonentry rescue is unavailable because you have chosen not to wear a lifeline — then the rescue team must be present at the portal, ready to perform rescue,” Toothe says. “They have to physically be there, sitting in a chair with their backpacks on, ready to go at a moment’s notice.
“OSHA says if wearing a lifeline would produce a greater danger to your life or health, it is not required. Now, people will bleed that off into, ‘OSHA says if it’s going to be a pain in my butt, I don’t have to wear one’ — that’s not exactly what OSHA says. If I have on a lifeline, the confined-space attendant can perform nonentry rescue. He can crank on the tripod or pull on the lifeline, and pull the entrant to the manway.”
Otherwise, a rescue team is required on site.
It’s important to note that even when you’re wearing a lifeline, for permit-required confined-space work, a rescue team must still be notified and ready to respond — even if they’re not required to be at the manhole.
“For most companies, confined-space rescue training is the minimum required by law: A 20-minute video and a 10-question true/false test afterward — it’s ‘What can we get away with?’” Toothe says. “I teach confined-space competent person (certification), and that’s an eight-hour class. But most people when you say, ‘Hey, if you’re going to do confined-space, get serious about it; I’m going to train you as a competent person and it’s eight hours,’ they’re like ‘Holy crap, I don’t think we’re ready for that.’ But it’s something you need to know.”
