4.3 Choosing a rescue service, and 911 is not one

1 The sentence

Appendix F, section A(I): the employer should meet with the prospective rescue service to facilitate the evaluations required by 1910.146(k)(1)(i) and (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. And then:

It is worth being precise about what this does and does not say. It does not say never call 911. It says that relying on it as the rescue arrangement is not compliance with (k)(1) — because (k)(1) requires four things a phone number cannot do.

2 The four duties a rescue arrangement has to satisfy

1910.146(k)(1), and 1926.1211(a) with one addition:

1. 1
   Evaluate the prospective rescuer's ability to respond to a rescue summons in a timely manner, considering the hazards identified — (k)(1)(i).
2. 2
   Evaluate the 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 — (k)(1)(ii).
3. 3
   Select a service from those evaluated that has the capability to reach the victims within a time frame appropriate for the hazards identified, and is equipped for and proficient in performing the needed rescue services — (k)(1)(iii). Construction adds (a)(3)(iii): the service agrees to notify the employer immediately if it becomes unavailable.
4. 4
   Inform each rescue team or service of the hazards they may confront when called on to perform rescue at the site — (k)(1)(iv) — and provide access to all permit spaces from which rescue may be necessary so the service can develop appropriate rescue plans and practice rescue operations — (k)(1)(v).

Duty 4 is the one that makes the arrangement concrete. A rescue service that has never seen the vault cannot have a plan for the vault. And a municipal fire department that has walked your spaces, been told about the hydrogen sulfide and practiced on a representative manhole is a perfectly good answer to (k)(1) — the problem was never the fire department, it was the assumption.

3 The space decides what the service has to be able to do

Appendix F ends with four characteristics used both to judge a rescue service and to decide whether a practice space is truly representative of a real one. They are the fastest structured way to describe a space as a rescue problem rather than as a work location.

Those two numbers — 4 feet and 24 inches — are the only dimensions in Appendix F, and they are worth memorizing. They are also why 1910.146(k)(2)(iv) insists that a representative practice space simulate the real one with respect to opening size, configuration and accessibility: practising on a 36-inch hatch teaches nothing about a 22-inch one.

4 The initial evaluation, as a set of questions

Appendix F(A)(II) is a list of ten questions. Condensed, with the paragraph each comes from:

• What response time do we need? Counting notification, arrival, set-up and readiness to enter. IDLH, or able to become IDLH quickly, means standing by at the space; ten to fifteen minutes may do where the danger is mechanical injury — (II)(1).
• How quickly can they actually get here? Location, quality of roads, bottlenecks and traffic, reliability of the vehicles, training and skill of the drivers — (II)(2).
• When are they not available? Times of day, situations, the chance that key personnel are away — and can they notify us mid-entry so we can tell the attendant to abort the entry immediately? — (II)(3).
• Do they meet (k)(2)? If not, is there a plan to get there, and how soon — (II)(4).
• Are they willing to do it? An employer may not rely on a rescuer who declines — (II)(5).
• Can we reach them without delay, and how soon after notification can they dispatch? — (II)(6).
• What are they breathing? For significant atmospheric hazards where entry, patient packaging and retrieval cannot be safely accomplished in a relatively short time — the appendix says 15 to 20 minutes — employers should consider airline respirators with escape bottles for the rescuers and to supply rescue air to the patient. If SCBA is used, does the service have ample replacement cylinders and procedures to enter and exit well within the air supply limits? — (II)(7).
• Vertical over 5 feet? Can they perform entry rescues there, with the technical knowledge and equipment for rope work or elevated rescue? — (II)(8).
• Medical skills? Medical evaluation, patient packaging and emergency response — (II)(9).
• Whose equipment? Does the service have what it needs, or must the employer provide it? — (II)(10).

Any one of those questions you cannot answer is a phone call to make before the next entry, not a gap to discover during one.

5 The performance evaluation, and the practice requirement

Appendix F(B) covers what you have actually seen the service do. Rescue services are required by 1910.146(k)(2)(iv) to practice at least once every 12 months, and the appendix says that as part of each practice session the service should critique the practice rescue, or have another qualified party do so, so deficiencies in procedures, equipment, training or number of personnel can be identified and corrected — and that the results should be given to the employer, so the employer can decide whether the service can be upgraded or must be replaced.

The construction wording at 1926.1211(b)(4) is slightly different and worth reading carefully: practice before attempting an actual rescue, and at least once every 12 months — except that practice is not required where the affected employees properly performed a rescue operation during the last 12 months in the same permit space the entrant will enter, or in a similar one.

And where the rescuers are your own employees, 1910.146(k)(2) and 1926.1211(b) set four measures, all at no cost to those employees:

Requirement (ii) is the one that catches organizations by surprise: a rescue team must be trained to at least authorized entrant level for the spaces it may be called into. Rescuers who have never been trained as entrants do not know the hazards they are walking into.

6 And then verify it again, today

All of the above is arrangement. The last step is per-entry, and it belongs to one person. 1910.146(j)(4): the entry supervisor verifies that rescue services are available and that the means for summoning them are operable. 1926.1210(d) adds that the employer will be notified as soon as the services become unavailable.

Two words carry the weight. Available means on duty and reachable now, not contracted in principle. Operable means somebody tried the radio or the phone from the location where they will have to use it — and a signal at the trailer is not a signal at the bottom of the access road.

The confined space rescue plan generator is built from this chapter: it records the Appendix F space characteristics, derives the capabilities the service must have from them, holds the initial and performance evaluation checklists item by item, and prints the summoning procedure and the entry supervisor's verification at the top of the page where they can be read from the portal.