Appendix
F to 1910.146-Non-Mandatory Appendix F
- Rescue Team or Rescue Service Evaluation
Criteria
This
appendix provides guidance to employers
in choosing an appropriate rescue service.
It contains criteria that may be used
to evaluate the capabilities both of prospective
and current rescue teams. Before a rescue
team can be trained or chosen, however,
a satisfactory permit program, including
an analysis of all permit-required confined
spaces to identify all potential hazards
in those spaces, must be completed. OSHA
believes that compliance with all the
provisions of ¤ 1910.146 will enable employers
to conduct permit space operations without
recourse to rescue services in nearly
all cases. However, experience indicates
that circumstances will arise where entrants
will need to be rescued from permit spaces.
It is therefore important for employers
to select rescue services or teams, either
on site or off-site, that are equipped
and capable of minimizing harm to both
entrants and rescuers if the need arises.
For
all rescue teams or services, the employer's
evaluation should consist of two components:
an initial evaluation, in which employers
decide whether a potential rescue service
or team is adequately trained and equipped
to perform permit space rescues of the
kind needed at the facility and whether
such rescuers can respond in a timely
manner, and a performance evaluation,
in which employers measure the performance
of the team or service during an actual
or practice rescue. For example, based
on the initial evaluation, an employer
may determine that maintaining an on site
rescue team will bemore expensive than
obtaining the services of an off-site
team, without being significantly more
effective, and decide to hire a rescue
service. During a performance evaluation,
the employer could decide, after observing
the rescue service perform a practice
rescue, that the service's training or
preparedness was not adequate to effect
a timely or effective rescue at his or
her facility and decide to select another
rescue service, or to form an internal
rescue team.
A.
Initial Evaluation
I. The employer should meet with the prospective
rescue service to facilitate the evaluations
required by ¤ 1910.146(k)(1)(i) and ¤
1910.146(k)(1)(ii). At a minimum, if an
off-site rescue service is being considered,
the employer must contact the service
to plan and coordinate the evaluations
required by the standard. Merely posting
the service's number or planning to rely
on the 911 emergency phone number to obtain
these services at the time of a permit
space emergency would not comply with
paragraph (k)(1) of the standard.
II. The capabilities required of a rescue
service vary with the type of permit spaces
from which rescue may be necessary and
the hazards likely to be encountered in
those spaces. Answering the questions
below will assist employers in determining
whether the rescue service is capable
of performing rescues in the permit spaces
present at the employer's workplace.
1.
What are the needs of the employer with
regard to response time (time for the
rescue service to receive notification,
arrive at the scene, and set up and
be ready for entry)? For example, if
entry is to be made into an IDLH atmosphere,
or into a space that can quickly develop
an IDLH atmosphere (if ventilation fails
or for other reasons), the rescue team
or service would need to be standing
by at the permit space. On the other
hand, if the danger to entrants is restricted
to mechanical hazards that would cause
injuries (e.g., broken bones, abrasions)
a response time of 10 or 15 minutes
might be adequate.
2. How quickly can the rescue team or
service get from its location to the
permit spaces from which rescue may
be necessary? Relevant factors to consider
would include: the location of the rescue
team or service relative to the employer's
workplace, the quality of roads and
highways to be traveled, potential bottlenecks
or traffic congestion that might be
encountered in transit, the reliability
of the rescuer's vehicles, and the training
and skill of its drivers.
3. What is the availability of the rescue
service? Is it unavailable at certain
times of the day or in certain situations?
What is the likelihood that key personnel
of the rescue service might be unavailable
at times? If the rescue service becomes
unavailable while an entry is underway,
does it have the capability of notifying
the employer so that the employer can
instruct the attendant to abort the
entry immediately?
4. Does the rescue service meet all
the requirements of paragraph (k)(2)
of the standard? If not, has it developed
a plan that will enable it to meet those
requirements in the future? If so, how
soon can the plan be implemented?
5.
For off-site services, is the service
willing to perform rescues at the employer's
workplace? (An employer may not rely
on a rescuer who declines, for whatever
reason, to provide rescue services.)
6.
Is an adequate method for communications
between the attendant, employer and
prospective rescuer available so that
a rescue request can be transmitted
to the rescuer without delay? How soon
after notification can a prospective
rescuer dispatch a rescue team to the
entry site?
7.
For rescues into spaces that may pose
significant atmospheric hazards and
from which rescue entry, patient packaging
and retrieval cannot be safely accomplished
in a relatively short time (15-20 minutes),
employers should consider using airline
respirators (with escape bottles) for
the rescuers and to supply rescue air
to the patient. If the employer decides
to use SCBA, does the prospective rescue
service have an ample supply of replacement
cylinders and procedures for rescuers
to enter and exit (or be retrieved)
well within the SCBA's air supply limits?
8.
If the space has a vertical entry over
5 feet in depth, can the prospective
rescue service properly perform entry
rescues? Does the service have the technical
knowledge and equipment to perform rope
work or elevated rescue, if needed?
9. Does the rescue service have the
necessary skills in medical evaluation,
patient packaging and emergency response?
10.
Does the rescue service have the necessary
equipment to perform rescues, or must
the equipment be provided by the employer
or another source?
B.
Performance Evaluation
Rescue
services are required by paragraph (k)(2)(iv)
of the standard to practice rescues at
least once every 12 months, provided that
the team or service has not successfully
performed a permit space rescue within
that time. As part of each practice session,
the service should perform a critique
of the practice rescue, or have another
qualified party perform the critique,
so that deficiencies in procedures, equipment,
training, or number of personnel can be
identified and corrected. The results
of the critique, and the corrections made
to respond to the deficiencies identified,
should be given to the employer to enable
it to determine whether the rescue service
can quickly be upgraded to meet the employer's
rescue needs or whether another service
must be selected. The following questions
will assist employers and rescue teams
and services evaluate their performance.
1.
Have all members of the service been trained
as permit space entrants, at a minimum,
including training in the potential hazards
of all permit spaces, or of representative
permit spaces, from which rescue may be
needed? Can team members recognize the
signs, symptoms, and consequences of exposure
to any hazardous atmospheres that may
be present in those permit spaces?
2. Is every team member provided with,
and properly trained in, the use and need
for PPE, such as SCBA or fall arrest equipment,
which may be required to perform permit
space rescues in the facility? Is every
team member properly trained to perform
his or her functions and make rescues,
and to use any rescue equipment, such
as ropes and backboards, that may be needed
in a rescue attempt?
3. Are team members trained in the first
aid and medical skills needed to treat
victims overcome or injured by the types
of hazards that may be encountered in
the permit spaces at the facility?
4. Do all team members perform their functions
safely and efficiently? Do rescue service
personnel focus on their own safety before
considering the safety of the victim?
5. If necessary, can the rescue service
properly test the atmosphere to determine
if it is IDLH?
6. Can the rescue personnel identify information
pertinent to the rescue from entry permits,
hot work permits, and MSDSs?
7.
Has the rescue service been informed of
any hazards to personnel that may arise
from outside the space, such as those
that may be caused by future work near
the space?
8. If necessary, can the rescue service
properly package and retrieve victims
from a permit space that has a limited
size opening (less than 24 inches (60.9
cm) in diameter), limited internal space,
or internal obstacles or hazards?
9.
If necessary, can the rescue service safely
perform an elevated (high angle) rescue?
10. Does the rescue service have a plan
for each of the kinds of permit space
rescue operations at the facility? Is
the plan adequate for all types of rescue
operations that may be needed at the facility?
Teams may practice in representative spaces,
or in spaces that are "worst-case" or
most restrictive with respect to internal
configuration, elevation, and portal size.
The following characteristics of a practice
space should be considered when deciding
whether a space is truly representative
of an actual permit space:
(1)
Internal configuration.
(a) Open - there are no obstacles,
barriers, or obstructions within the
space. One example is a water tank.
(b) Obstructed - the permit space
contains some type of obstruction
that a rescuer would need to maneuver
around. An example would be a baffle
or mixing blade. Large equipment,
such as a ladder or scaffold, brought
into a space for work purposes would
be considered an obstruction if the
positioning or size of the equipment
would make rescue more difficult.
