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OSHA & Timely Manner For Emergency Responses | Hux Safety Solutions

Emergencies happen quickly and can have severe effects on workers in confined spaces. It's therefore imperative to conduct a rescue operation that will ensure everyone is safe and the worker needing rescue has the best possible outcome. According to the Occupational Safety and Health Administration (OSHA) regulations for confined spaces, employers who appoint rescuers should make sure that the rescue team can act promptly depending on the potential risks involved.

Federal OSHA standards cover many aspects of confined spaces, including emergency situations, emergency procedures, personal protective equipment (PPE), what are considered health hazards, hazard communication, first aid, and hazardous materials. Please refer to OSHA's website here for more information. OSHA also has training requirements to consider for your team.

Emergency Timely Response

In most permit-required confined spaces, the potential hazard can limit access to the area, thus affecting the rescue operation. In some cases, surrounding workers have panicked and tried to save the day, resulting in additional injuries including death.

Therefore a timely response and rescue plan could be the difference between life and death. The employer must ensure that the prospective rescuer or confined space rescue team has the necessary equipment and experience and is available to act in an emergency.

It's important to understand that the response time begins when the incident occurs. Therefore you should consider how long it will take for the rescue team to be notified and prepare for the rescue. For instance, it might take significantly longer for an outsourced rescue response team to assemble and prepare for the rescue than it would take an in-house team.

Outsourced emergency response teams may not be on standby at the worksite while the task is ongoing, but they must be informed that the facility relies on their emergency rescue services. Therefore they must be prepared to respond on time depending on the type and severity of the anticipated hazards. It's also important to alert them when workers are entering or exiting the confined spaces.

When utilizing a local Rescue or Fire department consideration should be given to the ability to cover the needs throughout the day. In most cases these departments are part of the local emergency response. In cases of being dispatched to fires, first responder calls or vehicle crashes the ability to respond may be taken away for the duration of the call. A provision should be made to notify the entry supervisor in such cases as the OSHA required “Timely response” is not available.

The excerpt below from OSHA [1910.146(k)(1)(i)] requires a rescuer be at the space ready for immediate action in spaces with IDLH conditions.

Note to paragraph (k)(1)(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.

OSHA Requirements for Permit-required Confined Space

The Occupational Health and Safety Act (OSHA) 1910.146 contains the standard requirements, procedures, and practices to safeguard employees from the risks involved in entering confined spaces. Employers must evaluate their workplaces and determine whether they are permit-required confined spaces.

Employers also have to inform their employees of any risks they are exposed to while working in these spaces. It's important to indicate who should enter the confined space. If most employees enter these spaces, the employer should draft a confined space program and issue it to the employees. Any time OSHA states “shall” it's required. Sometimes companies miss this and look past the fact that it's the law.

From OSHA 1910.146: (c) General requirements. [1910.146(c)] (4) If the employer decides that its employees will enter permit spaces, the employer shall develop and implement a written permit space program that complies with this section. The written program shall be available for inspection by employees and their authorized representatives. [1910.146(c)(4)]

(d) Permit-required confined space program (permit space program). [1910.146(d)] Under the permit space program required by paragraph (c)(4) of this section, the employer shall: [1910.146(d)] (9) Develop and implement procedures for summoning rescue and emergency services, for rescuing entrants from permit spaces, for providing necessary emergency services to rescued employees, and for preventing unauthorized personnel from attempting a rescue; [1910.146(d)(9)]

(k) 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; [1910.146(k)(1)(i)]

In short, it is the employers responsibility to be sure the rescue provision required will work and be available while entries are being made.

NFPA 350 Guide for Safe Confined Space Entry and Work

Where OSHA is vague in regards to a response time only stating a “timely manner” NFPA350 gives us a picture of what should be considered “best practices”. Broken down into 3 Tiers we can now understand what should be required.

Section Rescue Response Modes States: The degree and rapidity of response should be driven principally by the anticipated hazards. Those spaces that contain known hazards should receive greater scrutiny and perhaps more rapid or complex response based on the hazards...Consideration should be given to three basic modes of response:

1. Tier 1: Those that have no recognized hazards but could require technical rescue for extraction should a worker become incapacitated. Tier 1 Response Mode: A Tier 1 response mode may be indicated if a hazard evaluation has been performed (in accordance with Chapter 6) and the space contains no potential for hazards, but its configuration would prohibit entrants from being easily removed if they were to become incapacitated due to either medical illness or injury. At minimum, this should be applicable to any vertically oriented space greater than 4 ft. (1.2 m) in height, whether or not retrieval equipment is in place. A Tier 1 capability suggests that a fully trained rescue team meeting the requirements of the technician level confined space rescue chapter in NFPA 1670 is available to respond within 5 minutes to the site and is capable of setup and rescue entry within 15 minutes of arrival on site.

2. Tier 2: Those with non-life-threatening conditions requiring rapid intervention. Tier 2 Response Mode: A Tier 2 response mode is indicated if a space contains no IDLH or other potentially immediate life-threatening hazards but does contain other actual or potential hazards that could incapacitate entrants or prevent them from exiting the space without assistance (self-rescue). A Tier 2 capability suggests that a fully trained rescue team meeting the requirements of the technician level confined space rescue chapter in NFPA 1670 is on site with appropriate capability to make safe entry for rescue. The team should be equipped and mobile and capable of setup and rescue entry within 12 to 15 minutes of incident occurrence.

3. Tier 3: Those with life-threatening hazards requiring immediate intervention. Tier 3 Response Mode:

A Tier 3 response mode is indicated if work occurs inside a space that contains an IDLH or other immediately life-threatening hazard, either actual or potential. A Tier 3 capability suggests that a fully-trained rescue team meeting the requirements of the technician level confined space rescue chapter in NFPA 1670 is standing by in the immediate area with appropriate capability to make safe entry for rescue. This team should be completely set up and capable of rescue entry within 2 minutes of incident occurrence. The rescue team should be dedicated to this singular entry with no other responsibilities.

Final Thoughts

There is no one-size-fits-all duration to how long a timely response should take. NFPA350 does provide a guideline for what is believed to be best practices. However, stakeholders must assess every space, identify the potential hazards and design an appropriate emergency action plan for preparedness. The facility should have the requisite resources to ensure that the response is swift enough to help the affected employees.

At Hux Safety Solutions, we believe that worker safety is the top concern in all work operations. Contact us for your confined space rescue team needs.