Page 42 - OHS, April 2020

CONFINED SPACES
When we extract a conscious person in the event of a prohibited condition in or around the space, it is retrieval, not a rescue.
trant up as planned. However, the entrant who is passed out and slumped over gets to the confined space entrance/exit but will not fit through the opening. The attendant calls for help and other co- workers arrive and try to help, but cannot get the worker out of the space. The fire department is contacted and responds; however, they have not had any confined space rescue training. To make matters even worse, the only equipment they have at the scene is their medical bag and AED.
The worker dies in the space from a heart attack since no one could get him out of the space in a timely manner and provide him with the advanced medical care he needed. While I wish this was a made-up scenario, it unfortunately is not.
Some employers rely on Non-Entry Rescue as their only res- cue plan, as in this fatal incident. While OSHA 1910.146 standard allows for Non-Entry Rescue, I have been performing Confined Space training and rescue for over 20 years, and non-entry rescue requires additional planning and consideration. Nothing is as sim- ple as it seems. The unexpected happens every day.
Per OSHA 1910.146(i)(9), the employer must ensure the atten- dant can perform non-entry rescues as specified by the employer’s rescue procedures. Before you define any rescue procedures, the first step is to evaluate each of your spaces to ensure that non-en- try rescue will even work. Here are a few things to consider when evaluating your spaces:
■ Will an unconscious entrant fit through the entrance/exit?
■ Will they be able to be raised out and above the entrance? For example, if you have low head space above the opening, can they be raised high enough to clear the space or will it require more manipulation?
■ When operating your winch system, will the set-up tolerate the additional forces of transitioning a victim from the horizon- tal position on the bottom of the tank to the vertical position to lift them out of the tank? What kind of additional considerations should be given for the forces that are going to be applied to the victim’s body, neck, and head without any entry rescue assistance?
■ Will the lone attendant be able to manage the multiple lines running into the space without twisting or wrapping them together and rendering the haul system useless? Cables, hoses, and electri- cal cords could all come into play in most systems. Training must be done so that the attendant recognizes and manages the types of problems that could be encountered, especially if the patient is ro- tating around or spinning due to the weight transferred onto their harness in unusual positions.
■ If the entrant is only on a winch line because they climbed down a fixed ladder, can the attendant winch an unconscious per- son up without them getting entangled on the ladder? Typically, it is the victim’s feet or shoulders that get caught on the ladder.
■ For horizontal spaces, can an unconscious person be drug out with a tag line without causing more injury to the victim than whatever has caused them to be unconscious in the space?
the victim to be pulled out without getting hung up or entangled on anything?
In addition to these, the employer will have additional planning and considerations specific to each of their confined spaces. And, it is imperative that the person evaluating your spaces has experi- ence, knowledge and understands the ins and outs of horizontal confined space rescue or the ups and downs of vertical confined space rescue.
Do you have a Plan B for your Non-Entry Rescue?
Following the OSHA Non-Entry Rescue standard and using it as your Plan A is good, but experience from the real-world proves every employer needs a Plan B.
In the scenario I shared at the beginning of this article, the em- ployer thought they were doing the right thing using Non-Entry Rescue. They ventilated the space, they monitored the air, and they had the equipment set up to raise and lower the entrant up and down, in and out of the space. But you don’t know what you don’t know, and unfortunately, they didn’t know, or understand, the limitations of non-entry rescue in the event the entrant becomes unconscious either from a problem in the space or a sudden health issue with the entrant.
When evaluating permit required confined spaces, you must think about and identify the worst-case scenarios to determine which rescue method will work. If it’s determined that Non-Entry Rescue will work for an unconscious person by practicing res- cues—and sometimes it does work even with unconscious entrants but these are few and far between—then you need to have in place a Plan B if something goes wrong. Calling the fire department should never be a backup plan.
If you do not have the expertise on staff to make these criti- cal evaluations, engage a reputable company with actual rescue experience to help you evaluate your spaces and determine what level of training and equipment you need for your permit re- quired spaces. They can also help you in identifying worst case scenarios and write workable rescue procedures specific to each of your spaces.
Many employers rely on Non-Entry Rescue as their only means of rescue due to the cost of the additional equipment and training required to have a competent Entry Rescue Team or the cost of hiring a competent third-party rescue team. While it may work in some confined spaces, the safety of your workers should never be an afterthought and there should always be a plan B in place.
Once you are confident that you have made the right assess- ments of your spaces and developed you rescue procedures (Plan A and Plan B), PRACTICE, PRACTICE, PRACTICE. Was your rescue procedure successful 100 percent of the time? Ninety per- cent of the time? Eighty percent of the time? Is that risk acceptable for the safety of your employees?
Assessing and defining the right rescue method combined with a successful rescue plan is an absolute must for the safety of all your employees.
Is it Rescue or Retrieval?
Here’s a closing thought I’d like to share on terminology that may
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