Needs and Requirements - rockymountain.asspwp.org fileRP 2217A-2017 •Safe Work in Inert Confined...

transcript

CONFINED SPACE RESCUE

Needs and RequirementsRocky Mountain Chapter ASSP – 11 April 2019

▪ Health, Safety and Environmental Health

• Consultation

• OSHA Inspection and Abatement Support

• Training and Education

• OSHA-Based Medical Surveillance

Industries▪ Agriculture

▪ Alternative Energy

▪ Analytical Labs (stable and radiochemistry)

▪ Breweries

▪ Chemical Blending & Delivery

▪ Construction Trades (Industrial/Commercial and Residential)

▪ Distilleries

▪ Electrical & Controls

▪ Food and Beverages

▪ Government Agencies

▪ High Tech

▪ Hydroelectric Power Plants

▪ Manufacturing/Production

▪ Microelectronics Manufacturing

▪ Pipeline and Structure Coating

▪ Transportation & Storage

▪ Unexploded Ordinance Disposal (UXO)/ Explosive Ordinance Disposal (EOD)

▪ Upstream Oil & Gas

Training Certificates

▪ Need a certificate?

• Remember to sign-in

• Make sure your name and email is legible

▪ 1.5-hours / 0.15-CEU

Assumptions

▪ You are familiar with construction and general industry confined space regulations

▪ You are comfortable classifying confined spaces as non-permit spaces and permit-spaces

▪ You understand basic confined space entry procedures

Problem Statement

How do I rescue victims from a permit-space in a timely fashion, and provide

or obtain timely medical care……and comply with regulations?

Topics

▪ Review relevant regulations and consensus codes

▪ Discuss regulatory requirements for rescue

▪ Use consensus codes to help fill in the gaps with specific guidance

OSHA Regulations

▪ 29 CFR 1910.146 – General Industry

▪ 29 CFR 1926 Subpart AA – Construction

▪ Industry Specific

• 29 CFR 1910.269(e): Electric Power Generation, Transmission & Distribution

• 29 CFR 1910.272(e)(2), (g) and H: Grain Handling

General Industry vs. Construction

▪ These two regulations are very similar

▪ Additional elements unique to construction

• Extra focus on multiemployer work sites

• Competent person required in construction

• Simplified structure

• OSHA discussed clarifications applicable to general industry

Oil and Gas Task-Specific Codes

▪ RP 2026-2017• Safe Access/Egress Involving Floating Roofs

of Storage Tanks in Petroleum Service

▪ RP 2217A-2017• Safe Work in Inert Confined Spaces in

the Petroleum and Petrochemical Industries

▪ STD 2015-2018• Requirements for Safe Entry and Cleaning of

Petroleum Storage Tanks

▪ RP 2207-2017• Preparing Tank Bottoms for Hot Work

Generic Consensus Codes

▪ ANSI/ASSP Z117.1-2016• Requirements for Entering Confined

Spaces

▪ NFPA 350-2019• Guide for Confined Space Entry and Work

▪ NFPA 1006-2017• Standard for Technical Rescue Personnel

Professional Qualifications

▪ NFPA 1670-2017• Standard on Operations and Training for

Technical Search and Rescue Incidents

ANSI Z117.1

▪ Provides minimum safety requirements for entering, exiting and working in confined spaces at normal atmospheric pressure

▪ Complements OSHA regulations nicely

NFPA 350

▪ Designed to not conflict with existing OSHA standards

▪ Provides guidance on how to comply with OSHA

▪ Direction for those looking to improve program

▪ Simplifies confined space terminology and addresses gaps in existing regulations

NFPA 1006 and 1670

▪ Each has an entire chapter on confined space rescue

▪ Picks up where NFPA 350 leaves off

• 1006 discusses training requirements for Awareness, Operations and Technician levels

• 1670 discusses planning, hazard assessments, functional capabilities

▪ Authoritative, comprehensive

▪ Adaptable to different industries and situations

Rescue Regs

Construction

29 CFR 1926.1211 – Rescue and Emergency Services

General Industry

29 CFR 1910.146(k) – Rescue and Emergency Services

Rescue Equipment

▪ 1910.146(d)(3): Develop and implement the means, procedures, and practices for:

• Necessary rescue and emergency equipment

• Other equipment necessary for safe entry into and rescue from permit spaces.

Rescue Procedures

▪ 1910.146(d)(9): Develop and implement procedures for:

• Summoning rescue and emergency services

• Rescuing entrants from permit spaces

• Providing necessary emergency services to rescued employees

• Preventing unauthorized personnel from attempting a rescue

Evaluate Rescue Needs

▪ Entry/Egress

• High-Angle (60-deg or higher) – Rescuers dependent on ropes

• Steep-Angle (35 to 60-deg) – Rescuer’s weight evenly distributed

• Low-Angle (15 to 35-deg) – Rescuer's weight suspended by ground

▪ Hazards

• Inherent, Introduced, Adjacent Hazards

▪ Timing and Logistics

• Nearest capable rescue team

Evaluate Designated Rescue Services

▪ 29 CFR 1910.146(k)(1): When designating a rescue team

• Evaluate rescuer’s ability to timely respondo Are they always available or just sometimes?

o Can they tell you when they are not available?

• Evaluate rescue service’s ability to rescueo What are rescuer knowledge, skill and ability requirements?

o Can the team rescue victims in consideration of the specific spaces and hazards?

o Are they properly equipped?

▪ Evaluate rescuers based on your spaces, location, hazards

• Provide access for preparation and training

Employees are Rescuers

▪ 29 CFR 1910.146(k)(1)• Evaluate and understand equipment and PPE needs

• Provide proper PPE

• Evaluate skills and ability

o Safe entry

o Safe patient packaging and handling

o Ability to initiate first-aid, CPR and basic medical interventions (clear airway, etc.)

Employee are Rescuers - Training

▪ Train in proper PPE use

▪ Train to perform assigned rescue duties

▪ Train at least once every 12-months

▪ Evaluate and ensure rescuer’s proficiency

▪ First-Aid/CPR/AED

• Train at least one member by reg but in practice, train the whole team

• Consider first-responder or EMT training for a small subset if in remote locations and to support team development

Substantially the Same

▪ 1926.1211

• Evaluate designated rescuers

• Provide access to designated rescuers

• Train in-house rescuers appropriately

• Provide appropriate equipment and PPE

1926 Subpart AA - Differences

▪ Practice at least once every 12-months unless

• Rescuers properly performed a rescue operation during the last 12 months in the same permit space the authorized entrant will enter, or in a similar permit space

• Representative spaces used for training must simulate actual spaces

▪ Rescuers must have authorized-entrant training in addition to rescuer training

1926 Subpart AA - Clarifications

▪ Are your rescuers available when you need them?

▪ Are the close enough to respond in a timely fashion?

▪ What happens when the assigned rescuers respond to another emergency?

• Does dispatch tell you?

Unanswered Questions

▪ What PPE should rescuers use?

▪ What equipment should rescuers use?• Vertical vs. horizontal rescue considerations

• OSHA-style vs. NFPA-style equipment

▪ What assigned duties must rescuers cover?

▪ What is a timely response?• What is your time gap between rescuer notification, arrival

and actual rescue?

▪ What knowledge and skills must rescuers possess?• How do you know they have the requisite skills?

▪ Is annual training sufficient?• If no, how often should rescuers train?

19101926

SOLUTIONS AND RECOMMENDATIONS

Rescue Options

▪ Self-Rescue

• Required

▪ Non-Entry Rescue

• Required

▪ Entry Rescue

• Outside resource

• On-site team

Always Rig for Non-Entry Rescue

▪ Set up equipment and follow procedures that allow self-rescue and non-entry rescue to the greatest extent

▪ Use rescue and retrieval systems for all entries unless this poses an increased risk• Prevents rescue (1910/1926)

• Entanglement (1926)

▪ Use harness with a retrieval line• Other arrangements OK if needed (wristlets, etc.)

• Rig so attached outside the space for immediate use

• If space is > 5-feet

o Also use a mechanical means of retrieval

Add Non-Entry Rescue Practice

▪ Conduct non-entry rescue practice in your authorized entrant classes or added on

▪ Evaluate skills carefully

▪ Update skills periodically

• i.e. More than once every 12-months!

• Shorter, frequent sessions better than extensive, infrequent sessions

o Quarterly or monthly

Plan with Rescue in Mind

▪ Review written plans and procedures

• Conform with ANSI Z117.1, NFPA 350, and API standards when applicable

▪ Add rescue planning to your classification forms and classification procedure

▪ Assign NFPA rescue tiers to help determine timing

How Fast Do You Need to Respond?

▪ NFPA 350 Response Tiers

• 3-Tier System

• Risk-based

• Higher risk = faster response

Tier 1

▪ What is it?

• No hazards or negligible hazards but

• Difficult entry and exit

▪ Must…

• Respond to site in 5-minutes

• Enter space for rescue in 15-minutes

Tier 2

▪ What is it?

• Incapacitation possible but no IDLH or other immediate life-threats

▪ Must…

• Be on site

• Enter space for rescue within 12 to 15 minutes

Tier 3

▪ What is it?

• IDLH or other immediate life-threats

▪ Must…

• Be on site

• Enter space for rescue within 2 minutes

Evaluate Rescue Needs

▪ Evaluate your rescue needs

• Contact FDo Do they have the capabilities you need?

o What is their timing for first-in response and full rescue response

• Figure out the gapo This is your need

o Remote locations and complex situations will have larger gap and you will need to develop a higher level of capability with your team

Bridge the Gap

1. Entry team calls 911

2. Entry team initiates non-entry rescue while waiting for professional rescuers

▪ You Must

• Enforce self-rescue and assisted self-rescue techniques in training and make folks practice

• Use equipment that facilitates non-entry rescue, train with it and enforce its use

• Ensure sufficient level of FA/CPR training consistent with gap

Gap Too Big?

▪ Need Your Own Team?

• Review NFPA 350

• Review NFPA 1006 and 1670 o To better understand professional rescuer requirements and how

they would apply in your situation

• Implement a training program consistent with NFPA codeso Require quarterly classroom and hands-on practice

o Consider advanced first-aid, first-responder or EMT training

o Skills are perishable and must be refreshed to develop a level of competency that allows for safe rescue

Equipment Needs

▪ OSHA vs. NFPA

• OSHA-type systems are simpler to set up and simpler to use

• NFPA-type systems are more complicated but increase flexibility

o Enhanced flexibility comes at a price - Training burden increased

o Skills are perishable – Frequent training required

o Increased risk to rescuers

▪ Hybrid Approach

• Use pre-rigged systems to the greatest extent

• Train heavily on non-entry rescue to bridge the identified gap

Competent Persons for Con Space

▪ Required in construction

• Get these folks properly trained and truly competent

▪ Embrace this concept in general industry as well

• Your classifications, evaluations, and planning must be done by someone knowledgeable

[29 CFR 1926.32(f)]

“One who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or

dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them."

Construction Project Planning

▪ Evaluate confined spaces and hazards in bid phase and budget as needed to address risks

▪ When hiring subs to do confined space work, validate their confined space programs• Many subs do not understand how to handle confined space issues

• Probe, ask hard questions and demand answers

• Encourage them to develop an appropriate budget

• Don’t pick low bidders!

▪ When hiring an on-site rescue service, make sure they are capable, and competent and can actually rescue someone!

Rescue vs. Body Recovery

▪ Evaluate the situation carefully

▪ Is it a body recovery or a rescue?

▪ A body recovery is NOT an emergency!

• Don’t risk lives unnecessarily

970.372.1131

Answers@Anfeald.com

www.Anfeald.com

© 2012-2018 by Anfeald, LLC – All Rights reserved by their respective owners. The ASHI and MEDIC First Aid Training Center logo are registered trademarks of the Health & Safety Institute or itsaffiliates. Andrew Troccoli member ASSE.

This presentation has been produced by Anfeald, LLC for the benefit of its clients. This contents of this presentation or any comments made by any representative of Anfeald, LLC does notimply authority over the care, custody or control of the client’s workplace and does not imply that the client is in compliance with federal, state or local laws, standards, regulations, ordinances,municipal or consensus codes. 42

Needs and Requirements - rockymountain.asspwp.org fileRP 2217A-2017 •Safe Work in Inert Confined...

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