PERMIT-REQUIRED CONFINED SPACE RESCUE STANDARD — AN OVERVIEW
Many volunteer fire departments are concerned about their responsibility to perform confined space rescue based on the Occupational Safety and Health Administration Regulation 29 Code of Federal Regulations 1910.146. This ruling, which took effect in April 1993, does not require that the fire service provide permit-required confined space rescue capability. However, if industrial plants, manufacturing companies, or utilities within the fire department’s response area have the need for permitrequired confined space rescue, the fire service would be the natural provider. In many cases, organizations required to have permit-required confined space rescue programs will not have the equipment and trained personnel to properly meet the requirements. They then will turn to outside rescue services, such as the fire department, to provide these resources. Confined space rescue is an excellent opportunity for the fire department to meet a new challenge and supply additional community service.
DEFINITION OF CONFINED SPACES
Confined spaces under these regulations are defined as those difficult to enter and leave; those not intended for human occupancy except during periods of maintenance or repair; and those that have possible additional dangers such as engulfment. flammable atmospheres, mechanical hazards, and oxygen-deficient or toxic atmospheres. Machinery and working spaces related to any number of industries fall into this category, including bins (grain, flour), boilers, casings at construction sites, cookers, food processors, furnaces, manholes (sewer, electrical, liquids), process vessels, production equipment, railroad tank and hopper cars, storage and other types of tanks, tumblers, underground tunnels and utilities, and ventilation and exhaust ducts. Basically, anyone entering these areas will be exposed to one or more of the following risks: engulfment, entrapment by the spatial design or moving parts, explosive atmospheres, fire and burns, suffocation, and toxic chemicals.
The key to permit-required confined space rescue for the fire department is that if it accepts the responsibility to provide this service, it must work directly with the business organizations that need assistance to ensure compliance with the OSHA regulations and the safety of all firefighters who will be involved in the rescues. These industries must have written OSHA-compliant procedures, including a permit program, for dealing with confined space emergencies. The fire department also must have a plan for confined space rescues at each site to which it will respond. This plan must cover the following areas: the hazards that will be encountered at the site and those that may develop during the rescue, equipment that will be required, on-site confined space personnel, and procedures for allowing access. The fire department must be able to get to all sites that require a permit to enter. This is necessary so that training using the correct rescue operations can be conducted.
The regulations outline specific training requirements for individuals performing the rescue, including the following:
- All rescuers must be provided with the appropriate personal protective equipment and rescue devices or tools necessary to safely make entry into the suspected atmosphere and to perform the rescue operations.
- All personnel must be thoroughly trained, which includes participation in a
- real or simulated rescue operation for each given space at least once a year. The standard is explicit on the simulation exercise, indicating that it must be performed at an actual or representative permit-requiring site. A person, dummy, or mannequin must be rescued. In addition, if other than an actual site is used for training, accessibility for rescue, configuration of the site, and the size of the opening must all be similar to the types of confined spaces in which actual rescues will be performed.
- All responders to a confined space incident must be trained in basic first aid and cardiopulmonary resuscitation. This does not present a problem within the fire service, where first responder and emergency medical technician training is common.
- All responding personnel must be trained to observe the policies and safety procedures of the facility they enter. This is more than a courtesy; when responding, the fire department becomes a contractor and must comply with all applicable safety rules. An example of this would be wearing hearing protection or safety glasses in specific areas.
Training requirements for those entering a confined space generally are well-known to the fire service: hazard recognition, communicating with the attendant, using personal protective equipment including self-contained breathing apparatus in hazardous areas, and the ability of each individual to get out of the confined space unassisted. An attendant, usually the company or safety officer, must be located near the point of entry and must perform the duties outlined in the procedure.
The regulations require the industry to inform the fire department of all hazards that may be present. It is recommended that thorough preincident planning be completed by the fire department to ensure nothing is overlooked. In fact, the regulations also require the industry’ to allow the fire department access to permit-required confined spaces for planning and training purposes.
OSHA regulations stipulate that each industry have a written permit procedure and training program for all people entering the confined space, whether to work or rescue, or attending to those entering. Also, someone must be present to authorize a permit to enter the space. The fire department needs to be familiar with all of these requirements, since it may be asked to assist in drawing up the procedures; or, more importantly, if on arrival it finds the procedures are not in place, the department must put the procedures into action before performing the rescue if it wishes to avoid an OSHA citation.
The written permit procedure ensures that unauthorized personnel—those without the proper equipment, protective clothing, and training—are not allowed to enter the confined space. It also ensures safe entry by checking for any possible hazards, identifying those present, and evaluating their risk.
OSHA outlines procedures for testing suspected unsafe atmospheres and monitoring them during rescue or other operations. The permit authorizer must be able to assess the risk and determine if entry is possible. When the facility does not have a permit authorizer, the fire department must supply one— most likely a chief officer, who should be assisted by a company representative. This system will provide technical assistance from the plant and two sets of reviewing eyes before entry is approved. Also, the permit authorizer must know how to complete the required paperwork and, most importantly, must be able to recognize conditions that will necessitate stopping the rescue attempt for the safety of the group.
Isolation. If the site requires it, the fire department must plan how to isolate the confined space from potential hazards in various forms. OSHA 29 CFR 1910.147, Control of Hazardous Energy Sources, outlines isolation techniques for these materials. To limit the escape of toxic vapors, flammable gases, corrosive liquids, or other possible hazards, it may be necessary to blank off flanges, double block and bleed sections of pipe, seal tanks, encapsulate containers, or perform any number of leak-control procedures. Never rely totally on a single valve in a confined space. These techniques will require close coordination and often direction from plant personnel.
Ventilation. Another technique that may have to be used at permit-required confined space incidents is ventilation. This can be used to dilute flammable concentrations below their flammable limits, remove toxic vapors, or introduce adequate oxygen levels into the confined area. Natural ventilation, horizontal or vertical, usually will not be sufficient. Ideally, mechanical ejectors (fans) would be placed on the top or one side with blowers on the bottom or other side. These units must be safe to operate in the atmosphere involved and must not direct the hazardous product into a safe area. Flammable vapors cannot be directed toward ignition sources, and electrical units must be bonded and grounded.
Testing and monitoring. Remember that the confined space should be tested and monitored for hazardous vapors. This may require flammable gas detectors, oxygen-monitoring devices, ionization or photoionization detectors, or calorimetric tubes for identification. In some cases, it also may be good policy to monitor the heat stmss of the rescuer.
The fire department does not have to perform permit-required confined space rescue. However, if it accepts the responsibility, it must become familiar with the regulations. Then it must plan and train for the confined space rescue operations that may be required in its community. This is a must if firefighter safety is to be maintained.
For an in-depth look at 29 CIR 1910.146, see the article by Richard .S’. Malek on page .15. ■