Warning Ahead: Relying on Non-Entry Rescue for PRCS
By Dave Carter and Chris Koester, OH&S April 2020
WARNING AHEAD: RELYING ON NON-ENTRY RESCUE FOR PERMIT REQUIRED CONFINED SPACE
Nothing is as simple as it seems; the unexpected happens every day.
It’s a typical work scenario. A tripod is placed over the opening of a tank and a worker (entrant) is lowered inside to clean the tank and perform an inspection. He is secured to the tripod with a winch and an SRL. There is no chance of any entanglements inside so everything should go easy. Right?
The employer had all the equipment necessary for a non-entry rescue set up. The rescue plan, in case something bad happened, was for the attendant to simply crank the handle on the winch and hoist the entrant up and out using the winch/tripod system. Unfortunately, the unexpected happens. The entrant collapses onto the floor of the tank. The attendant cranks on the winch to bring the entrant up as planned. However, the entrant who is passed out and slumped over gets to the confined space entrance/exit but will not fit through the opening. The attendant calls for help and other co-workers arrive and try to help, but cannot get the worker out of the space. The fire department is contacted and responds; however, they have not had any confined space rescue training. To make matters even worse, the only equipment they have at the scene is their medical bag and AED. The worker dies in the space from a heart attack since no one could get him out of the space in a timely manner and provide him with the advanced medical care he needed. While I wish this was a made-up scenario, it unfortunately is not.
Some employers rely on Non-Entry Rescue as their only rescue plan, as in this fatal incident. While OSHA 1910.146 standard allows for Non-Entry Rescue, I have been performing Confined Space training and rescue for over 20 years and non-entry rescue requires additional planning and consideration. Nothing is as simple as it seems. The unexpected happens every day.
Per OSHA 1910.146(i)(9),the employer must ensure the attendant can perform non-entry rescues as specified by the employer’s rescue procedures. Before you define any rescue procedures, the first step is to evaluate each of your spaces to ensure that non-entry rescue will even work.
Here are a few things to consider when evaluating your spaces:
1. Will an unconscious entrant fit through the entrance/exit?
2. Will they be able to be raised out and above the entrance? For example - if you have low head space above the opening can they be raised high enough to clear the space or will it require more manipulation?
3. When operating your winch system, will the set-up tolerate the additional forces of transitioning a victim from the horizontal position on the bottom of the tank to the vertical position to lift them out of the tank? What kind of additional considerations should be given for the forces that are going to be applied to the victim’s body, neck, and head without any entry rescue assistance?
4. Will the lone attendant be able to manage the multiple lines running into the space without twisting or wrapping them together and rendering the haul system useless? Cables, hoses, and electrical cords could all come into play in most systems. Training must be done so that the attendant recognizes and manages the types of problems that could be encountered especially if the patient is rotating around or spinning due to the weight transferred onto their harness in unusual positions.
5. If the entrant is only on a winch line because they climbed down a fixed ladder, can the attendant winch an unconscious person up without them getting entangled on the ladder? Typically, it is the victim’s feet or shoulders that get caught on the ladder.
6. For horizontal spaces, can an unconscious person be drug out with a tag line without causing more injury to the victim than whatever has caused them to be unconscious in the space?
7. In a horizontal space, is the surface smooth enough for the victim to be pulled out without getting hung up or entangled on anything?
In addition to these, the employer will have additional planning and considerations specific to each of their confined spaces. And, it is imperative that the person evaluating your spaces has experience, knowledge and understands the ins and outs of horizontal confined space rescue or the ups and downs of vertical confined space rescue.
Do you have a Plan B for your Non-Entry Rescue?
Following the OSHA Non-Entry Rescue standard and using it as your Plan A is good but experience from the real-world proves every employer needs a Plan B.
In the scenario I shared at the beginning of this article, the employer thought they were doing the right thing using Non-Entry Rescue. They ventilated the space, they monitored the air, and they had the equipment set up to raise and lower the entrant up and down, in and out of the space. But you don’t know what you don’t know, and unfortunately, they didn’t know, or understand, the limitations of non-entry rescue in the event the entrant becomes unconscious either from a problem in the space or a sudden health issue with the entrant.
When evaluating permit required confined spaces, you must think about and identify the worst-case scenarios to determine which rescue method will work. If it’s determined that Non-Entry Rescue will work for an unconscious person by practicing rescues, and sometimes it does work even with unconscious entrants but these are few and far between in our opinion, then you need to have in place a Plan B if something goes wrong. Calling the Fire Department should never be a backup plan.
If you do not have the expertise on staff to make these critical evaluations, engage a reputable company with actual rescue experience to help you evaluate your spaces and determine what level of training and equipment you need for your permit required spaces. They can also help you in identifying worst case scenarios and write workable rescue procedures specific to each of your spaces.
Many employers rely on Non-Entry Rescue as their only means of rescue due to the cost of the additional equipment and training required to have a competent Entry Rescue Team or the cost of hiring a competent third-party rescue team. While it may work in some confined spaces, the safety of your workers should never be an afterthought and there should always be a plan B in place.
Once you are confident that you have made the right assessments of your spaces and developed you rescue procedures (Plan A and Plan B), PRACTICE, PRACTICE, PRACTICE. Was your rescue procedure successful 100% of the time? 90% of the time? 80% of the time? Is that risk acceptable for the safety of your employees?
Assessing and defining the right rescue method combined with a successful rescue plan is an absolute must for the safety of all your employees.
Is it Rescue or Retrieval?
A closing thought I’d like to share on terminology that may impact your decision on confined space rescue methods. I have never been a fan of OSHA’s term “Non-Entry Rescue”. I prefer to use the term “Non-Entry Retrieval”. Why? Because in my years of experiences with confined space incidents, when we extract a conscious person in the event of a prohibited condition in or around the space, it is retrieval, not a rescue. Extracting an unconscious entrant is much more difficult, can be life threatening, and requires trained, certified and experienced personnel to “rescue”. Using the term “Non-Entry Rescue”, there is a false sense of security that you can just “pull people out” – it’s not that simple. It is our recommendation to train your workers for both non-entry rescue and entry rescue.
Without understanding the ins and outs and ups and downs of Non-Entry Rescue, employers are left unprepared to respond when “retrieval” becomes a rescue.
Dave Carter is a safety instructor and member of the Confined Space Rescue team for Priority One Safe-T, LLC. Dave has over 20 years of experience in the Public Fire Service field and is a Hazardous Materials Technician for the Homeland Security Regional Response Team for Southwest Missouri Region D which covers 19 counties and a member of the Southwest Missouri Incident Support Team. Dave is a Rescue Team leader, experienced and certified in numerous types of rescue categories, and a certified Fire Instructor. Dave holds a Bachelor of Science Degree in Criminal Justice from Drury University.
Chris Koester is a safety consultant and owner of Priority One Safe-T, LLC, an emergency response and rescue services and safety training firm for industrial and manufacturing companies. Chris has over 21 years of experience as a rescuer and is an internationally recognized expert in confined space entry and rescue. In addition to serving his industrial clients, Chris and his team of active and retired firefighters lead Confined Space Entry and Rescue classroom courses and hands-on technical training for employers from across the world at the 6-story NE Tech Rescue Training Center located in Pryor, OK.
