The dangers of confined space work have been written about since Roman times, when the Emperor Trajan was noted to have sentenced criminals to clean sewers, an occupation considered one of the worst. Working conditions have improved vastly since Trajan’s time, but the same hazards persist and result in workplace injuries and fatalities each year. According to the Bureau of Labor Statistics nearly 100 work fatalities occur in permit-required confined spaces. In addition, for every victim who dies in a confined space, 3 would-be rescuers lose their lives trying to rescue a victim.
Even though you’ve met all the requirements for a safe confined space entry: you have an attendant, an entrant, and a supervisor, you have the space clearly marked and protected as a confined space, you are monitoring atmospheric conditions, you’ve made sure the entrant has a harness, tripod, tag-line and winch in place, and you have a correctly completed confined space entry permit, you aren’t done. The only requirement remaining is completion of the rescue plan. Most municipalities usually complete the rescue plan by writing “CALL 9-1-1.” That is not sufficient.
Relying solely on 9-1-1 as your means of emergency rescue is essentially planning for a body recovery, not a rescue. To prevent injuries and fatalities, the Occupational Safety & Health Administration (OSHA) requires a specific plan of operation for confined space rescue. These operations must be established by the employer (municipality)¹. If 9-1-1 is part of your emergency plan, the employer is to, among other things, do the following:
· Evaluate the emergency responder’s ability to respond in a timely fashion
- OSHA expects emergency care to be administered to the victim in 3-4 mins²
· Ensure the responder has the equipment and training to enter the specific confined space you are working in
- Even though you are in a small community and the fire station is just around the corner, that doesn’t necessarily mean that your local firefighters have the training and equipment to respond to a confined space rescue
· Ensure the responder is proficient in performing the needed rescue services
- OSHA standards require that the owner of the confined space ensure that the emergency responders are proficient at conducting rescues from the specific types of spaces
- OSHA lists 24 types of confined spaces depending on the size of the opening, shape of the opening, and location with respect to the space
- The OSHA term “Proficient” means the employer has certified the responder as being proficient in conducting rescues from the specific type of confined space encountered
Municipalities, like private employers, have two options when considering permit-required confined space rescue, since for most, “9-1-1” is not a viable option for emergency confined space response and rescue operations.
- Train your employees to conduct permit-required confined space rescue operations and provide medical assistance, or
- Hire a third-party Rescue and Response company to provide those services for your municipality.
¹OSHA Confined Space Regulations for General Industry: 1910.146(k)(1) – 1910.146(l)(2)
²OSHA Confined Space Regulations for Construction 29 CFR 1926.1211(a) – 1926.1211(d)