Work with local OSHA representatives
Kent L. Freeman
Senior Confined Space Rescue Instructor
California State Fire Division of Training
Captain
Roseville (CA) Fire Department
Stan Klopfenstein
Senior Confined Space Rescue Instructor
California State Fire Division of Training
Captain
Santa Fe Springs (CA) Fire Department
I would like to thank John T. Bentivoglio for his article “OSHA`s Confined Space Standard: What Is Really Required of Fire/Rescue Agencies?” (July 1998). Although the article provided some good information on a confusing subject, it also provided some information that could place many fire departments in serious jeopardy with regard to regulatory matters and life safety.
In Endnote 2, for example, the author explains that his article addresses the requirements in the federal OSHA document and that others [state requirements] may be more restrictive. This information should have been clearly covered in the body of the article, as nearly every state OSHA regulation is more restrictive than the federal regulation.
The author also states that there is a clear difference between the requirements placed on general industry and outside rescue service providers. Readers should be aware that most state OSHA agencies do not differentiate between general industry and outside rescue service providers. In fact, many federal OSHA enforcement officers are now following this interpretation (regardless of the writings found in the preamble). The Federal Document 1910.146 begins with the section addressing scope and applications of the confined space regulation. In the scope and application section, the document specifically lists some industries (or jobs) to which the regulation does not apply. The fire service or rescue service is not listed as an exception.
This thought process makes sense when you consider that fire or rescue providers will be responding to an accident that has most likely occurred due to a failure to adhere to appropriate safety procedures. Why would you feel it appropriate to have less restrictive regulations applied to the rescuer entering the same hazardous space as the victim? If anything, the equipment, training, and regulatory requirements should be more stringent–or at a minimum, equal to–those for the original entrant.
In Myth #2, Bentivoglio states that fire/rescue agencies need not have a written confined space program in place before performing a confined space rescue. This could not be further from the truth in almost every OSHA state. In fact, two major fire departments in California can attest to this firsthand, as they were cited by Cal-OSHA during postincident investigations for failure to have written policies for confined space rescue. Fire departments develop written guidelines on everything from how to respond to greater alarms to how to mop the dayroom floor. Sometimes we do go overboard with written rules and programs, but we personally don`t think it is going overboard to write general guidelines for an operation that is inherently hazardous–rescuers account for more than 60 percent of the deaths in these incidents.
Myth #3 states that fire/rescue personnel need not complete a written entry permit before performing a confined space rescue. We adamantly disagree with this statement regardless of whether the regulation requires a permit or not. We should think of this document as a tactical worksheet; it helps us to remember the things we must do to make a safe entry. In addition, it allows us a place on which to document our atmospheric monitoring results (a mandatory component of permit-required confined space entries). It also provides us with a means for tracking who is doing what and where, as well as many other details that should be documented. This paper is a tool to assist us. We would highly suggest developing a rescue permit and using it. This simple document may help you to remember something that could save your life. That`s the main reason most state OSHA agencies consider a written entry permit mandatory, regardless of the purpose of the entry.
Myth #5 states that full-body harnesses and retrieval lines are not required for fire/rescue service entrants. Again, if you believe that fire/rescue service personnel are exempt from the regulations and can adhere to a lower standard of safety than other workers, then you may subscribe to this myth. The fact is that federal OSHA enforcement officers are directed to check for nonentry rescue procedures during their investigation following an accident in confined spaces. Nonentry rescue is possible only when retrieval lines and appropriate harnesses are used.
Myth #6 states that there is no minimum number of hours of training required and that instructors need not be certified. This statement is true, but we must remember that entrants, attendants, and entry supervisors must be trained to adequately carry out the requisite duties, and they must be made aware of the hazards they may face while performing the duties. This requirement holds true regardless of whether it is routine work or a rescue. More important than the number of hours is the curriculum. Many states, like California, have developed awareness and specialist level programs for confined space rescue. These programs include complete lesson plans, student textbooks, instructor criteria, and so on. Instructor qualification is another area OSHA enforcement officers are directed to check following a confined space incident.
We think the best advice is, work with your local OSHA representatives before accepting the responsibility of dealing with a confined space rescue. We`ve found that developing a relationship with our OSHA representatives has been enlightening and educational; they have assisted us in developing curriculum and procedures. If you are willing to accept the responsibility of performing a confined space rescue, you had better be willing to accept the responsibility of writing operational procedures, developing tactical worksheets (entry permits), and performing realistic training.
