Confined spaces and rescue operations
A look at some common assumptions
‘I’ve done this a thousand times and I’ve never gotten hurt. I’ll be all right.’
Worker assumptions can be dangerous – particularly when confined spaces are involved. That’s because of the potential severity of the hazards associated with them and the need to quickly extract incapacitated workers.
Unless confined space hazards are respected and rescues are planned for and practiced, incidents can prove deadly for workers and rescuers alike.
From 2012 to 2017, the number of annual confined space fatalities in the United States nearly doubled – to 166 from 88, according to the most recent data available from the Bureau of Labor Statistics. (See “Confined space fatalities in recent years.”)
“Few workplace areas present as many potentially serious hazards as confined spaces,” said David Consider, senior workplace safety consultant and trainer at the National Safety Council, “and without dedicated procedures for safe entry and monitoring employees within the confined space, catastrophic events can occur.”
‘I know what a confined space is.’
For workers who are experienced or savvy, this may be true. However, the sheer variety of confined spaces, along with regulations – often purposefully vague – can cause confusion and difficulties.
For example, trenches and ditches can be considered confined spaces “when access or egress is limited,” the Canadian Center for Occupational Health and Safety says. Other confined spaces include silos, vessels, storage bins, hoppers, vaults and pits, according to OSHA’s general industry regulations. In OSHA’s definition, a confined space must have each of the following characteristics:
- Is large enough and configured so employees can enter and perform assigned work
- Has limited or restricted means of entry or exit
- Is not designed for continuous occupancy
That type of confined space differs from a “permit-required confined space,” which has at least one of the following characteristics:
- Contains or has the potential to contain a hazardous atmosphere
- Has a material that could engulf someone who enters
- Is configured in such a way that an entrant could become trapped or asphyxiated as a result of “inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section”
- Has any other recognized serious safety or health hazard
“Many employers simply fail to consider or understand that certain work areas constitute a confined space, hence the need for a competent job hazard analysis,” Consider said. He recommends organizations partner with a third-party consultant or industry peer group and conduct routine audits/assessments. This can help identify the hazards that are often unique to the confined spaces at their locations.
“They should ask their safety professional colleagues how they manage (confined spaces) – other people that are seemingly doing it well, especially if they are in that particular business,” said Jody Rood, president of American Emergency Response Training, based near Knoxville, TN.
‘We don’t need a rescue plan for non-permit confined spaces.’
Much of OSHA’s regulation on confined space rescue focuses on spaces that require a permit – and for good reason: They typically contain more significant and potentially fatal hazards. However, non-permit required spaces obviously have their hazards as well, including slips and trips. Another concern: potential medical issues among individuals working in confined spaces.
During a presentation at the National Safety Council 2019 Congress & Expo in San Diego, James Lange, department chair and safety instructor at Fox Valley Technical College in Appleton, WI, noted that an employee at one of his former workplaces had a heart attack while in a non-permit confined space.
“Even on the non-permit areas, where OSHA doesn’t tell us we have to do this, you still need a plan because things go wrong,” Lange said.
Consider said organizations should plan rescue procedures in advance and include the plan in a written confined space entry program. The plan should be specific for every type of confined space and take into account the size and configuration of the space, along with potential hazards. This could be a deadly mistake, experts warn, because the worker may not know what hazards are in a confined space, especially one that requires a permit. For example, colorless and odorless gases such as methane or carbon dioxide may be present.
‘I’m only going in there for a minute.’
|Confined space fatalities in recent years|
|Source: Bureau of Labor Statistics|
According to OSHA, post-incident atmospheric testing in the manhole revealed lethal levels of hydrogen sulfide and carbon monoxide.
A noxious atmosphere is one of the many hazards rescuers might face if they don’t have a plan or proper training before attempting to save anyone in danger.
A NIOSH study published in 1986 found that more than 60% of confined space deaths involved “would-be rescuers,” a statistic that’s often cited today. In January 1994, NIOSH published another study that found that of the 70 confined space incidents the agency investigated, 25 had multiple fatalities that included rescuers. The Key Largo tragedy shows that this still remains an issue.
During his presentation, Lange asked how many times people have heard: “I’m a strong guy. I can go down there. I can hold my breath long enough to climb down that 10 feet of ladder, take two people up and climb 10 more feet. I can do that.”
‘We can call 911 or rely on emergency responders to be our rescue team.’
OSHA regulations require covered establishments to have the ability to “reach the victim(s) within a time frame that is appropriate” for the pertinent hazard in the confined space.
In the non-mandatory Appendix F of 1910.146, OSHA offers two examples. In situations where a permit-required confined space has an atmosphere that is an immediate threat to life or health, the agency recommends having a rescue team or service at the space.
“On the other hand, if the danger to entrants is restricted to mechanical hazards that would cause injuries (e.g., broken bones, abrasions), a response time of 10 to 15 minutes might be adequate,” the agency says.
The National Fire Protection Association’s “Guide for Safe Confined Space Entry and Work (350)” divides emergency responses into three tiers:
Tier 1: The space contains no potential for hazards but “its configuration would prohibit entrants from being easily removed” if they became incapacitated by a medical issue. Setup and rescue entry should be within 15 minutes of arrival onsite.
Tier 2: The space contains no immediate danger to life or health or other life-threatening hazards, but contains other actual or potential hazards that could prevent entrants from exiting unless assisted. A rescue team should be “equipped and mobile and capable of setup and rescue entry” within 12 to 15 minutes of the incident occurring.
Tier 3: The space contains a hazard(s) that is a threat to life and health. A rescue team should be set up and ready for entry within two minutes of the incident occurring.
During his presentation, Lange shared the results of an informal survey he conducted among Wisconsin fire chiefs. He said 36% reported they weren’t capable of responding to a confined space emergency. Of those who said they could respond, 31% could be ready for entry within 10 to 20 minutes, 20% said 20 to 30 minutes and 7% said they would need more than 30 minutes. That doesn’t include response time, Lange added.
“This is Wisconsin, but my guess is you could kind of filter this out to most of your areas as well,” he said. “Most states are probably pretty similar to this.”
Also, if you’re relying on a fire department or other emergency responders to act as your onsite rescue team, what happens if they get a call that takes them away?
“If they are your rescue team, you’re done,” Lange said. “You’re shut down until they come back.”
Lange and Consider recommend that if you’re going to rely on emergency responders as your rescue team, get it in writing.
“OSHA recognizes that not all rescue services or emergency responders are trained and equipped to conduct confined space rescues,” the agency states in a 2016 fact sheet titled, “Is 911 Your Confined Space Rescue Plan?” “When employers identify an offsite rescue service, it is critical that the rescuers can protect their employees. The emergency services should be familiar with the exact site location, types of permit-required confined spaces and the necessary rescue equipment.”
‘We only need rescue training once a year.’
It’s true that OSHA regulations require affected employees to practice permit-space rescues at least once a year. Ideally, Rood said, rescue practice would take place about once every three months. He added that the best rescue teams his organization works with typically practice multiple times a year.
“What that does is keep people fresh,” he said. “It keeps them engaged. It keeps them focused.”
Whatever equipment is needed, ensure a rescue team or employees know how to use it. “If you don’t use these items on a regular basis, it’s not going to work when you need it,” Lange added.
Affected employees should also be properly trained on assigned rescue duties, as well as basic first aid and CPR. At least one available member of the rescue team must have a current certification in both areas.
“Bottom line, it is truly a team sport,” Rood said. “It’s like the fire (department) analogy: Someone has to drive the truck. Someone has to pull the hose. Someone has to spray the water. And someone has to be in charge of looking at the big picture.”