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Mar 6, 2018


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Confined Space Entry Safety

In the last couple of episodes, I dance around the rescue team parts of the standard. I want to get into that section here. Let’s start with an outside rescue option since a lot of folks go this route. If you recall, whenever you use outside resources you must evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified.

So you have to have done a hazard assessment first so that you can have a meaningful conversation with the outside agency. Also, don’t forget, bring them in to do a walk-thru, look at the spaces involved, the internal configurations, chemicals used onsite, etc.

You also have to develop and implement procedures for summoning rescue and emergency services to your location. Ask about whether the local authorities use a regional dispatcher, this may delay response time a little, does your site use a different number to dial out to emergency services, instead of 911? All of this goes into your program and training.

Once you determine the rescue team that will be used, you have to develop a procedure for rescuing entrants from permit spaces and be able to provide necessary emergency services to those workers. The primary requirement in the first aid standards is that an employer must ensure prompt first aid treatment for injured employees, either by providing for the availability of a trained first aid provider at the worksite or by ensuring that emergency treatment services are within reasonable proximity of the worksite.

You have to take appropriate steps prior to any accident (like making arrangements with the service provider) to determine if emergency medical assistance will be promptly available when an injury occurs. While the standards do not prescribe a number of minutes, OSHA has long interpreted the term "near proximity" to mean that emergency care must be available within no more than 3-4 minutes from the workplace, an interpretation that has been upheld by the Occupational Safety and Health Review Commission and by federal courts.

One option these standards provide employers is to ensure that a member of the workforce has been trained in first aid. This option is, for most employers, a feasible and low-cost way to protect employees, as well as putting the employer clearly in compliance with the standards. OSHA recommends but does not require, that every workplace include one or more employees who are trained and certified in first aid, including CPR.

The first aid training standards at 29 CFR 1910.151 and 1926.50(c) generally apply throughout the industries that they cover. Other standards which apply to certain specific hazards or industries make employee first aid training mandatory, and reliance on outside emergency responders is not an allowable alternative. For example, see 29 CFR 1910. 266(i)(7) (mandatory first aid training for logging employees), and 29 CFR 1910.269(b) (requiring persons trained in first aid at work locations in the electric power industry).

So seriously look at getting a team of volunteers to be trained, on all shifts. More support for this is that medical literature establishes that, for serious injuries such as those involving stopped breathing, cardiac arrest, or uncontrolled bleeding, first aid treatment must be provided within the first few minutes to avoid permanent medical impairment or death.

Also, in workplaces where serious accidents such as those involving falls, suffocation, electrocution, or amputation are possible, emergency medical services must be available within 3-4 minutes, if there is NO EMPLOYEE on the site who is trained to render first aid. So this can buy a victim more time if folks are trained and equipped onsite already.

OSHA exercises discretion in enforcing the first aid requirements in particular cases. OSHA recognizes that a somewhat longer response time of up to 15 minutes may be reasonable in workplaces, such as offices, where the possibility of such serious work-related injuries is more remote.

Now, I will restate what the standard says: In the absence of an infirmary, clinic, or hospital in near proximity to the workplace which is used for the treatment of all injured employees, a person or persons shall be adequately trained to render first aid. Adequate first aid supplies shall be readily available. This is a way to meet that standard!

And, for an in-house rescue team, at least one member of the rescue team or service holding a current certification in first aid and CPR is available. Trust me, ALL of them should have it. What if the only member trained in 1st aid goes down? So spread the love folks!

So what does this tell us? Well, it tells us we need to carefully examine and consider the actual hazards likely to be present as well as the injuries and illnesses likely to occur. This has to be included in the training in order for us to claim our in-house first aid team is “adequate”.

Let, me illustrate this for you; A lot of the first aid training programs I have reviewed are really good at preparing you (as best as possible) for an emergency. They cover what to do, how to react, things like that. A lot of effort goes into keeping the responder safe; bloodborne pathogens, PPE, checking the scene; which is great. Then there are sections that get into how to perform a patient survey, for both an unconscious and conscience patient. And then there are sections of training covering how to stop bleeding and immobilize a limb maybe.

Here is where you need to be sure to include covering injuries likely to occur at your facility. Work with the instructor ahead of time to include how to treat a chemical burn, and be specific - like hydrochloric acid, or chlorine gas for example. This site-specific or even chemical or hazard-specific training is what will deem your personnel “QUALIFIED” to render first aid at your facility. The basic community first aid training, just won’t be enough.

Okay, let’s move on to an in-house rescue team. First, they have to be equipped for and proficient in performing the needed rescue services. Do you have underground tanks? Do they have rectangular, square or round entry points, or a combination? This tells me what types of hoists I will need to have available for rescue. What about horizontal spaces? Are some of them above grade, requiring staging from an elevated platform? This tells me aerial lifts, personnel hoists, stair chairs, stokes baskets, etc may be needed as well. What about SCBA, airline respirators, things like that for rescue teams?

So equipped means just that; equipment needed to facilitate a rescue from any and all possible spaces to be entered. Standardization really helps but some older facilities that have been upgraded and modified over the years do not have this luxury. But think about this moving forward; standardize openings (their shape and size) whenever possible, and their location (at grade vs. elevated openings, things like that.). This ALL has to be set up and gone over each time you have training for this team. Every piece, all the PPE that may be needed, all of the monitoring instruments, everything!

Ensure that rescue and other affected employees (like potential victims) practice making permit space rescues at least once every 12 months. This has to be by way of a simulated rescue in which you remove dummies, manikins, or actual persons from the actual permit spaces or from representative permit spaces. Representative permit spaces shall, with respect to opening size, configuration, and accessibility, simulate the types of permit spaces from which rescue is to be performed. I have seen a few facilities that have old tanks that have been cleaned and the sides cut open but they keep them onsite as a training aid for this purpose. Of course, you may not have the room for this, but that was a representative space from them.

Of course, non-entry rescue is where it’s at whenever possible. If your rescue personnel never have to enter this is best. To facilitate non-entry rescue, retrieval systems or methods have to 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.

So practicing at LEAST every 12-months is the OSHA standard. I recommend quarterly just so that you can reinforce these procedures and familiarize rescue teams with this equipment better. Also, hold a monthly first responder meeting instead of just the annual refresher for first aid and every two years for CPR recertification. This is a “use it or lose it” skill, it's perishable, so keeping it fresh is going to help save lives. Give your responders a chance to talk about scenarios, practice first aid techniques in the meetings, dry runs, even debrief past responses since the last meeting to see what went right, what could be better, things like that. It will really add value and enhance the bare minimum OSHA sets for this stuff.

Look at your training program; what is it missing? What don’t you cover that we just ran through? How can you enhance your existing training? Make it stick? This is the challenge I have for you: do a full review of your written confined space entry program, the written permit, the rescue plan, your chosen method of rescue (non-entry, in-house or outside rescue team) and try to poke holes in the plans. That way you can improve it.

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