How to Comply with Confined Space Emergency Response Plan Requirements

Date First Published on SafetySmart Compliance: February 21st, 2012
Topics: Confined Spaces |

You never should let a worker go into a dangerous confined space—what OSHA refers to as a “permit-required confined space”—unless you’re darn sure you can rescue the guy if he gets into trouble. But there’s even more at stake. About 3 in 5 people killed in confined spaces are would-be rescuers. That’s why the OSHA standard for confined spaces requires making provision for rescuing workers who enter permit spaces. Here’s a look at the requirements and how to comply with them.

 

What OSHA Requires

If you let workers enter permit spaces, you must have an entry program establishing safe entry procedures and other engineering and work controls for workers who go inside the space. Among other things, the entry program must include procedures for summoning rescue and emergency response services for (Sec. 1910.146(d)(9)): i. rescuing entrants from permit spaces; ii. providing rescued employees needed emergency services; and, iii. preventing unauthorized personnel from attempting rescue.

Emergency response and rescue can be provided for either by relying on outside providers or using internal personnel. If you go with the former option, you must verify that the service you choose is adequately equipped and capable of responding to emergencies at the space in a timely manner.

If you use your own personnel for rescue, you must ensure they’re equipped with all needed PPE and equipment—at no cost to themselves—and adequately trained to perform their duties.

The ANSI Confined Space Standard

Of course, there’s more to life than OSHA. ANSI/ASSE Z117.1-2009, Safety Requirements for Confined Spaces, provides for more stringent emergency rescue provisions. The new version of the standard requires a written Emergency Response Plan to provide for “timely evacuation, retrieval or rescue of entrants in confined spaces.” Such a plan must include, at a minimum:

  • Mandatory evacuation instructions in case certain hazards are identified;
  • Retrieval by trained crew members using methods different from those used for the original entry; and
  • Rescue to be provided by trained emergency response personnel.

ANSI also requires evaluating the space in advance to determine if the rescue procedure should be horizontal or vertical. The latter methods include use of fall protection and/or suspension of rescuers from above. Like OSHA, ANSI requires atmospheric monitoring once rescue begins to ensure the safety of rescue personnel.

4 Things You Must Do to Comply

There are 4 things you should do to comply with confined space emergency response requirements:

Step 1: Create and Implement a Written Emergency Response Plan

Although it’s not specifically required by OSHA, ANSI and best practices dictate the establishment and implementation of emergency response plan—especially when you’re relying on your own personnel to carry out rescue operations. Indicate when rescue procedures are triggered, including when:

  • An alarm is activated;
  • The oxygen level within the confined space changes; or
  • The concentration or percentage of hazardous substances in the confined space changes significantly.

It’s important for emergency procedures to consider:

> All hazards in the confined space previously identified in a risk assessment;

> Dimensions of the space;

> Location of entry and exit points;

> Obstacles to removing an injured worker;

> Rescue equipment required;

> PPE for rescuers, including appropriate respirators;

> Communication between workers, rescuers, the supervisor and people on standby;

> Procedures to follow immediately after an incident;

> Possible hazards that may arise during rescue, appropriate evaluation of these hazards and control methods for them; and

> Rescue methods for a worker who’s unconscious, unresponsive or distressed.

Make sure the written plan also covers how the entry team and emergency response members will effectively communicate with each other, when emergency team members performing specific roles will be deployed, how the equipment needed to rescue entrants will be brought to the site, set up and operated and the emergency medical care and materials that will be available to treat the injured on site.

(Click here for a Model Confined Spaces Emergency Response Plan.)

Step #2: Provide Equipment Required by the Plan

The emergency plan should require the use of specific PPE and rescue equipment during an emergency, such as respirators, lifelines, harnesses, stretchers and lifting equipment. OSHA requires that you actually provide such equipment.

 

Step #3: Train Workers on Plan

If you rely on outside rescue personnel, you don’t have to train them in rescue operations but you do have to ensure that somebody has.

If you rely on your own employees to provide permit space rescue and emergency services, you must ensure rescue personnel successfully complete the training required for authorized entrants. (Click here to review authorized entrant training requirements)

You must also train rescue personnel to perform their assigned rescue duties and in basic first aid and CPR. In addition, at least one member of the rescue team must hold a current certification in first aid and CPR.

Step #4: Conduct Practice Drills

When using internal personnel to perform rescue and emergency response, require them to practice permit space rescues at least once every 12 months by conducting simulated rescue operations involving the removal of dummies, manikins or real persons from actual permit spaces or spaces with the same basic opening size, configuration and accessibility.

Conclusion

Taking steps to protect workers while they work in confined spaces is a good—and necessary—first step. But we all know that safety incidents can occur despite our best efforts. And when a worker gets hurt or an emergency arises in a confined space, having an effective emergency plan can mean the difference between life and death for both the worker and members of the rescue team who come to his aid..