A blog reader, who is a member of a municipal rescue team assigned to an airport, expressed concern about fulfilling “timely response” obligations for permit-required confined space entries within his district. Here are some suggestions from our Tech Panel…
First of all, the departments and agencies involved must carefully consider the obligations in providing rescue response for permit-required confined spaces. Obviously, we cannot advise on departmental policy concerning response and notification, this must be determined by management officials. However, for you as an emergency responder, we cannot stress enough the importance of preplanning and conducting a hazard analysis for all confined spaces within your response area. The information gained by the analysis will help you determine what level of “timely response” may be required for a particular type of entry.
OSHA does not set a specific response time because there are too many variables involved – plus, they don’t want to set requirements that might cause a rescue team to “rush” into entering a space to attempt a rescue. OSHA does reference how long a person might survive an IDLH atmosphere (such as an oxygen deficient atmosphere) before becoming incapacitated (4 to 6 minutes). However, even this is up to interpretation depending on the level of oxygen present. For example, an 18% O2 level vs. a 6% O2 level, both are O2 deficient but have very different response requirements for successful rescue.
Another important consideration is when an entrant is entering an IDLH environment. In this case, having a team standing by the portal, fully equipped and ready to go may be the only way to meet a timely response for that situation. OSHA’s 1910.134, Respiratory Protection, “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.”
Most entries, however, are not IDLH. This means that other forms of “external” rescue (vs. internal rescue) may be appropriate. Many times, in the rush of the moment, rescuers forget about external retrieval. Guessing that many of the spaces around the airport are manholes or vaults, these can most often be handled by the confined space attendant with an external retrieval system. This would include a mechanical winch attached to a tripod with a cable attached to the entrant’s high-point dorsal connection. Of course, this decision would be based on a prior hazard analysis.
NOTE: It’s important to note that ALL entrants are required to have “an immediate means of retrieval.” Reference OSHA 1910.146 [note to paragraph (k)(1)(i)] concerning timely response: “What will be considered timely will vary according to the specific hazards involved in each entry…”
As a final note, if hazard analysis and rescue preplans have not been conducted on your potential sites as required by OSHA, we encourage you to do so. Taking the time to do so will better enable you to determine what would be considered an appropriate “timely response” for a particular type of entry. It will also better prepare you as an emergency responder should the need arise.