OSHA has issued a final rule amending the 1910.146 Permit Required Confined Space regulation effective February 1, 1999. The Clarification addresses three areas - 1)enhanced employee participation in the employer's permit program; 2)authorized entrant observation of any monitoring/testing associated with permit entries; and 3)a strengthening and clarification of the criteria employers must satisfy when preparing for the timely rescue of incapacitated persons from the permitted spaces. Since this rule also impacts rescue from elevated structures, fall protection, and spaces with existing or potential IDLH environments, this article will concentrate its focus on the rescue aspects of the regulation and its impact to rescuers. To truly understand the regulation's intent, it is crucial to note both the Preamble to the new rule as well as the newly added Non-Mandatory Appendix F.
Paragraph (k), Rescue and Emergency Services, has been substantially revised to clarify rescue criteria requirements for both host employers (that own or control the permitted spaces) as well as rescue service employers (who provide a team for rescue from those spaces). Obviously, rules that effect the employers will necessarily affect the rescuers - no matter who they work for. OSHA's goal was clear - provide clearer guidance for the selection of a properly prepared rescue service that must demonstrate that it is rescue capable. The rule breaks down the employer's responsibility into two types of selection evaluations - one for determining a prospective service's qualifications while the other determines the service's actual performance capabilities. Let's look at the revised regulation point by point to determine how this must be accomplished.
NOTE: The regulatory points below have been paraphrased by the author. Quotation marks designate exact OSHA wording. The Impact statements are the author's summations.
- The host employer who must choose a rescue service must first evaluate the prospective service(s) ability to respond in a timely manner based on the specific hazard(s) associated with each entry.
Stand-by rescue (trained, equipped rescuers standing by) will now be required for all entries with IDLH atmospheres (or that can quickly develop into IDLH atmospheres) or those inwhich the "circumstances and hazards" of the entry would dictate a rescue plan requiring stand-by rescue. In all other entries, "a response time of 10 to 15 minutes might be adequate."
- The host employer choosing a rescue service must also evaluate the prospective service(s) qualifying abilities "to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified."
This employer appraisal must consider the state of training and the service's rescue equipment. Does either the on-site or off-site service posses adequate training and equipment to make an efficient rescue without harming entrants or rescuers? And, has the service trained in or have a plan for the types of permit spaces for which they must respond? The plan must contain the anticipated "rescue related tasks" (job assignments) with the appropriate rescue equipment.