Beep! Beep! Beep!
It is the sound that nobody wants to hear when working in a confined space – a gas meter alarming.
A quick glance at the readings on the meter shows a sudden spike of toxic hydrogen sulfide. The attendant knows that high levels of this gas can create a potentially deadly atmosphere. A sense of panic kicks in. He calls out to the entrants and receives a troubling response:
The attendant immediately radios to his supervisor to call 911, and he waits…
This is a situation that nobody in the industry wants to experience. The thought of our fellow workers, friends or family in danger is extremely unsettling. However, regulations exist to make sure that when an incident like this occurs, proper means for rescue are in place.
Section (d)(9) of the OSHA General Industry standard for permit-required confined spaces requires that employers “Develop and implement procedures for summoning rescue and emergency services[…]” and also “[…]for rescuing entrants from permit spaces[…].” In other words- For every permit-required confined space, it is mandatory to have rescue procedures put in place. Writing “Call 911” on the permit is the easiest thing to do, but not necessarily the smartest or safest.
Here is the main reason:
There is no time limit required by OSHA for a rescue to commence. The standard for confined spaces is “performance-based.” So, what does this mean? Per Section (k)(1)(iii)(A) of the standard, an employer must select a rescue team or service that “Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified.” So not only is an evaluation of the spaces to be entered required, but also an evaluation of the rescue team or service’s response time.
Let’s look at one example:
Plans are being made to enter a confined space that has the potential for heavy gases that displace oxygen. There is a certain amount of time that the human body can withstand in an atmosphere devoid of oxygen. 4 to 6 minutes to be exact. Past this and you get tissue death, organ death and brain death. Here is a dose of reality: No fire department in the world is capable of receiving dispatch information, gearing up, heading out to your plant, navigating through your plant, setting up for a rescue and rescuing somebody in 4 to 6 minutes. Why wait agonizing minutes for help to come when a standby rescue team can have your worker to safety in a fraction of the time?
Additionally, when entrants are working under supplied air there is a requirement for an immediate response. The OSHA standard for Respiratory Protection, §1910.134, 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.
This basically means that you need at least one person standing outside of the hole, already wearing their supplied-air apparatus, to satisfy the needs for this requirement. A fire department has plenty of calls to respond to on a daily basis, they typically cannot lend you a person to stand outside of the work space at all times.
In closing, fire departments and EMS agencies are full of highly-trained and highly-skilled individuals. They face dangers and adversity on a daily basis. There is no arguing against this. However, when choosing a rescue team or service, ask yourself if calling 911 can realistically allow a victim or victims to be rescued in an adequate amount of time. The law requires it, and your workers’ lives depend on it.
Code Red Safety