PLEASE NOTE: This article may contain grammar errors, as this is my response to the more than 60 messages I received in the past seven days regarding last week's article When contractors enter a host's PRCSs (1910.146(c)(8)(iii).   I have put this together tonight so as to not keep any of those who contacted me waiting any longer. If you find an error, please be a friend and point it out to me and I will correct ASAP.  As I told many of you who contacted me, that article was not about any one particular facility; and based on the number of you who thought I was using your case as an example shows how widespread the issue/concern just is.  This article is intended to answer a lot of the questions/challenges I received regarding a contractor being responsible for the rescue aspect of their entry into a Host's PRCS.

So as to not leave anything out, I will use 1910.146(k)(1) and 1926.1211 as the guide in showing the difficulties a contractor may have complying.  This is in NO WAY stating that a contractor can not do these matters correctly and/or well; I am merely stating the difficulties most contractors would have in complying with these OSHA minimum requirements.

1910.146(k) Rescue and emergency services

1926.1211 Rescue and emergency services

1910.146(k)(1) An employer who designates rescue and emergency services, pursuant to paragraph (d)(9) of this section, shall:

1910.146(k)(1)(i) Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

Note to paragraph (k)(l)(i): What will be considered timely will vary according to the specific hazards involved in each entry. For example, §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.

1910.146(k)(1)(ii) Evaluate a prospective rescue service's ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified;

1910.146(k)(1)(iii) Select a rescue team or service from those evaluated that:

1910.146(k)(1)(iii)(A) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;

1910.146(k)(1)(iii)(B) Is equipped for and proficient in performing the needed rescue services;

1910.146(k)(1)(iv) Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and

1910.146(k)(1)(v) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

Note to paragraph (k)(1): Non-mandatory Appendix F contains examples of criteria which employers can use in evaluating prospective rescuers as required by paragraph (k)(l) of this section.

1926.1211(a) An employer who designates rescue and emergency services, pursuant to § 1926.1204(i), must:

1926.1211(a)(1) Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified;

Note to paragraph (a)(1). What will be considered timely will vary according to the specific hazards involved in each entry. For example, § 1926.103 (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.

1926.1211(a)(2) Evaluate a prospective rescue service's ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified;

1926.1211(a)(3) Select a rescue team or service from those evaluated that:

1926.1211(a)(3)(i) Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified;

1926.1211(a)(3)(ii) Is equipped for, and proficient in, performing the needed rescue services;

1926.1211(a)(3)(iii) Agrees to notify the employer immediately in the event that the rescue service becomes unavailable;

1926.1211(a)(4) Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site; and

1926.1211(a)(5) Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue team or service can develop appropriate rescue plans and practice rescue operations.

 

#1 - Both standards have the identical requirement...

Evaluate a prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified

So for a contractor to be able to do Step 1 they MUST have a good working knowledge as to how the rescuer will respond and from where they will be responding from.  If the contractor intends to have the rescue service on-site during their entry, this makes the first part of #1 easier; however, the contractor MUST still understand the specific hazards of the PRCS they will be entering in order to perform Step 1 of the evaluation.  This means that they host will have to communicate this information, in FULL detail, to the contractor, who will then communicate this information to the rescue service.

 

#2 - Both standards have the identical requirement...

Evaluate a prospective rescue service's ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified

This step makes things very difficult for the contractor who has never even seen the PRCS, it's entry portal(s), internal configuration, or even location within the plant site (including the external hazards outside of the space that may impact the entry).  The first thing the contractor will need to understand is the height of the entry portals where the rescue will take place.  For example, the entry portal is on a 120' column and is on the 2nd ladder way platform (e.g. 100' high).  This means the rescue service MUST have the ability (staffing, equipment, and training) to perform a high-angle rescue.  They will also have to work out some means to get their equipment and gear set up on the platform (if necessary for an IDLH rescue) meaning they will need to have an aerial lift or a crane to work with them.

The contractor MUST have an understanding of the entry portal size and internal configuration of the space so that they can come equipped with the proper equipment and staffing to perform the rescue.  Of course, the host can easily convey this information and in the best situation even provide photos of the entry portal and internal configuration.  In the very best of situations, the host employer will have a pre-established rescue plan with all the details necessary to effect a rescue and they can provide this to the contractor so that the contractor can then share this plan with the rescue service(s) they are evaluating.

 

#3 - Both standards have the identical requirement...

Select a rescue team or service from those evaluated that:

Has the capability to reach the victim(s) within a time frame that is appropriate for the permit space hazard(s) identified

This step is where I had the most issues when allowing a contractor to arrange their own rescue services.  I have literally had a contractor give me the name of their rescue service who I then contact to find that they are, at best, 6-7 hours away and were never actually told they would be called upon to provide the service.  And I was the "bad guy" for terminating entry of a contractor within our PRCS.  We also ran into issues with the contractor stating their rescue plan was "911", which we NEVER allowed, as we knew the issues with this "plan" long ago!  But to be more specific, Step #3 is all about "staffing levels" of the rescue team.  See I read this requirement to mean "how quickly can the rescue service perform the rescue" and not just "reach the victim".  Sure if all the victim has is a broken limb, reaching them to provide medical aid is one thing; but an unconscious entrant in an oxygen deficient atmosphere has an entirely different rescue need and merely reaching them may not be enough!  So we need to ensure the rescue service is staffed and equipped to get the entrant(s) out, and if the entry permit allows for multiple entrants this WILL IMPACT our staffing and equipment needs - will it not?

The last part of this step is to deal with the permit space hazard(s) identified.  Again, the host employer can easily communicate the hazards that made the CS a PRCS and the contractor should already be well aware of the work they have been hired to perform within the space and thus the hazards their work may create.  But for a rescue service to fully understand the rescue challenges they may be faced with, they must first understand the hazards they may face during their rescue.  PLEASE remember there are some basic staffing guidelines for working within or entering an IDLH atmosphere in emergency conditions!

 

#4 - Both standards have the identical requirement...

Is equipped for and proficient in performing the needed rescue services

I have already mentioned the staffing and equipment needs that must be communicated and considered in the selection process, but I would like to point out OSHA's use of the word "proficient" in their standard(s).  PRCS rescue is NOT a trade that can be managed by having one (1) trained rescuer and a bunch of "helpers" working along side of the trained rescuer.  Unfortunately, we see this quite often in our auditing... one or two well-trained rescuers and the other 3-4 rescuers are "trained attendants" who are not even trained in the PPE ensembles used in the rescue, nor in any of the technical aspects of the rescue operation.  This is often not identified unless someone does some digging (e.g. auditing) into the rescue service's actually ability to effect a timely rescue.

 

#5 - Applies ONLY to entry under construction activities

Agrees to notify the employer immediately in the event that the rescue service becomes unavailable

This is a new requirement found under 1926.1211(a)(3)(iii) which requires the rescue service to notify the entry supervisor when the rescue services become UNAVAILABLE.  This new addition should also be applied to General Industry entries as it means that when/if the local Fire Department is used as the rescue service, the FD must agree to notify the entry supervisor that they are no longer available should 911 be called for rescue.  This requirement, in my opinion, was to end the use of the "911 Rescue Plan" as I am not aware of any FD that will agree to this requirement.  (Members should also read Using my local FD as my PRCS Rescue Team to understand a whole host of other issues with this practice).

 

#6 - Both standards have the identical requirement...

Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site

This implies that the employer doing the evaluation knows the hazards the rescue service may confront when called on to perform a rescue at the site.  As stated above, these hazards include: 1) the PRCS hazards that made the CS a PRCS, 2) the hazards that may be created from the work taking place within the PRCS (including if other contractors will be doing simultaneous entries and the hazards they may create), and 3) hazards associated with the "area" where the PRCS is located, such as having the right equipment and PPE to work in Class I/II/III HAZLOCs.  It is rare in my experience, but I have found a rescue service doing stand-by work in a processing unit that was a Class I, Division 2 HAZLOC and none of their equipment was rated for use in this area.  To their defense, the host only informed them that the entry would involve "toxics", which was 100% true; however, the area in which they were working was a Class I, Div 2, Group D HAZLOC.

 

#7 - Both standards have the identical requirement...

Provide the rescue team or service selected with access to all permit spaces from which rescue may be necessary so that the rescue service can develop appropriate rescue plans and practice rescue operations.

OSHA saved the best for last... this requirement is darn near impossible for a contractor to meet, seeing how they do not control the host's PRCS(s) thus providing access to the PRCSs from which rescue may be necessary will be nearly impossible.  Now if the contractor is going to use a rescue service the host employer normally uses and this rescue service has been provided access to the PRCSs then all should be OK.   But if the contractor is going to use a rescue service already approved by the host site, then all the challenges stated above go away as well!  But lets, not loose site of why OSHA requires access to the PRCSs... so that the rescue service can develop appropriate rescue plans and practice rescue operations. To me, this is very clear, that OSHA is requiring a "rescue plan" be developed and in place for each entry into a PRCS.  Some of the larger rescue services may be able to arrive on site with all their gear and be able to draw up a rescue plan and then be staffed and equipped to implement their plan; however, most rescue services will need to know ALL of the items discussed above in order to arrive staffed and equipped to effect a rescue from the PRCS.  So again, do NOT forget to infom the rescue service of the NUMBER of entrants that will be permitted to enter AND any other contractors/host employees who may be in the space at the same time and creating DIFFERENT HAZARDS.

 

As I stated in the beginning, this article is not implying that a contractor hired to enter a host's PRCS can not meet all of the above requirements, but most safety professionals will admit it is a very difficult situation when the host just washes their hands of any role in the entry.  And when it comes to the rescue requirements, the bar has been raised even further for a contractor to achieve success.

 
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