Trying to decide if you need an on-site rescue team for your upcoming confined space work?
The best way to begin is by looking at the law, since OSHA regulations are the law within most jurisdictions. So, what does the law say? In the case of confined space safety, we are looking specifically at OSHA regulation 29 CFR 1910.146. In the standard, OSHA outlines several requirements of a rescue team that include: proficiency with skills, equipment, CPR/first-aid certification, etc. On the surface this sounds like your local fire department, and it would appear to be the perfect solution to serve as your confined space rescue team for your upcoming work. Not so fast! OSHA’s standard says that a rescue team:
“Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified.”
~OSHA 29 CFR 1910.146(k)(1)(iii)(A)
So, how does this help me decide if I need an on-site team?
As can happen when reading standard documents, you are often left with more questions than answers. What is an “appropriate time frame for the hazards identified” as referenced in the OSHA regulation? Close the book of OSHA standards, and open your copy of NFPA 350: Guide for Safe Confined Space Entry and Work. The National Fire Protection Association (NFPA) is a not for profit global organization that creates consensus based codes and standards. These standards are not laws, but they are “devoted to eliminating death, injury, property and economic loss due fire, electrical and related hazards.” NFPA 350 does not use the language “permit required confined spaces.” Instead, they define confined spaces with hazards and those without. The important thing to know is that while OSHA regulations will generally tell you what to do, NFPA standards will give you a lot more information, and tell you how to do it.
NFPA 350 defines rescue response modes for confined spaces as Tier 1, Tier 2, or Tier 3. For our purposes, Tier 2 and Tier 3 responses would apply to those spaces OSHA defines as a permit required confined space. OSHA considers a permit required space one that has one or more of the following:
- Contains or has a potential to contain a hazardous atmosphere;
- Contains a material that has the potential for engulfing an entrant;
- Has an internal configuration such that an entrant could be trapped or asphyxiated by inwardly converging walls or by a floor which slopes downward and tapers to a smaller cross-section; or
- Contains any other recognized serious safety or health hazard.
Obviously, any of those items are hazards that could incapacitate an entrant, and require rescue. So now that we have established what the response tier is for the space, what are the rescue team requirements?
Enter NFPA 350 again, which states that for a Tier 2 response:
“a full trained rescue team meeting NFPA 1670.. is on site with appropriate capability to makesafe entry for rescue. The team should be equipped and mobile and capable of setup and rescue entry within 12-15 minutes of incident occurrence.”
~NFPA 350 chapter 10.1.3.4.2
A Tier 3 response is indicated if an IDLH atmosphere or any other actual or potential life threatening hazard exist within the space. Tier 3 response teams must also be trained to the technician level, but NFPA 350 says:
“This team should be completely set up and capable of rescue entry within 2 minutes of incident occurrence.”
~NFPA 350 chapter 10.1.3.4.3
This means that if an entrant becomes incapacitated the rescue team is entering the space 2 minutes after the entrant goes down.
So, let us revisit our plan to use our local municipal fire department for rescue.
First, no fire department would meet the requirement of being onsite, but could they possibly make rescue entry within 12-15 minutes from their fire station? There are a couple of factors that impact the response.
How far is your facility from the nearest fire station?
Most fire stations are expected to arrive on the scene of an emergency within 6 minutes of receiving the call for help. Typically, this response is a fire engine or ambulance with firefighters who are trained in fire suppression and emergency medical care. Not all firefighters are trained or equipped for the complex environment of confined space rescue.
Is your closest fire station available?
As everyone knows it is impossible to predict when emergencies are going to happen. What happens if the closest fire station is already tending to another emergency call? Response time standards account for this, and allow for longer response times when multiple emergencies have occurred. This could extend the time for 911 responders to arrive at your incident from 6 to 8 – 10 minutes.
How quickly can confined space rescue technician trained firefighters arrive?
Once the firefighters arrive at your incident, these firefighters will need to size up the situation, and request units with confined space rescue training and equipment. According to NFPA 1670 annex a, which applies to the fire department’s team, “The rescue service should have a goal of responding to these emergencies within 15 minutes of the time they receive notification.” This alone could put the 911 response beyond the 12 – 15 minutes that NFPA 350 allocates for Tier 1 and Tier 2 responses
Here is an illustration on how a fire department rescue response and a standby team may play out.
The fire department is dispatched, it responds and arrives on scene. Once at the scene, they need to assess the scene, complete an entry permit, monitor the air, ensure lock out/tag out, ventilate the space, create a rescue plan, set up their rigging and retrieval system, and then make entry. Is this laundry list of tasks achievable in 12-15 minutes from incident occurrence, the answer to that is an emphatic NO.
So, to answer the original question, it is nearly impossible to meet the NFPA 350 Confined Space standard by relying on your local fire department as your rescue team. If you want to meet the industry standards, and ensure the safety of your workers a dedicated on-site rescue team is an absolute MUST, and anything else is just simply an attempt to check a box.