3.4 Rescue: the plan that exists before the fall

1 The requirement is a duty, and it is short

1926.502(d)(20): "The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves." The general industry counterpart, 1910.140(c)(21), uses nearly identical words: "The employer must provide for prompt rescue of each employee in the event of a fall."

Non-mandatory Appendix C to Subpart M reinforces it twice: paragraph (a) tells employers that the availability of rescue personnel, ladders or rescue equipment should be evaluated in a planned fall rescue operation, and paragraph (f) states that employers must ensure prompt rescue capability, evaluating the personnel and equipment available.

Notice what the standard leaves to you: the word "prompt" has no number attached. That is not a loophole. It means the adequacy of your arrangement will be judged against the actual hazard — how high, how remote, how long the fire department takes to reach that part of that structure, and whether they can physically get to the worker when they arrive.

2 Why time matters: suspension trauma

OSHA published a Safety and Health Information Bulletin, SHIB 03-24-2004 (updated in 2011), titled "Suspension Trauma/Orthostatic Intolerance." It explains that suspension trauma is a subset of orthostatic intolerance, caused by a reduction in the circulation of blood through the body. Following a fall, a worker may remain suspended in a harness; the sustained immobility can lead to unconsciousness, and depending on how long the worker remains suspended and immobile, the resulting orthostatic intolerance may lead to death.

The bulletin's recommendations are addressed to employers, and they are the shape of a rescue plan: develop a plan that includes procedures to prevent prolonged suspension, train workers to recognize the signs and symptoms, and perform rescue and treatment as quickly as possible.

Two practical consequences. First, prevent prolonged suspension comes before rescue in that list — suspension relief straps, deployed by the suspended worker to take weight off the leg straps, exist for that reason and cost very little. Second, this is a medical subject and this course is not medical training: read the bulletin, and get the treatment side of your plan from your emergency medical provider and your occupational health advisor rather than from a training slide.

3 The three options, ranked

Notice that the first two are things you buy and train, and the third is something you verify. All three can be part of one plan; what cannot be part of a plan is the third one alone, unverified.

One warning about assisted rescue: a rescue that requires a second worker to expose themselves to a fall hazard to reach the first one is how a single-fatality incident becomes a double. The rescuer's own fall protection, anchorage and clearance are part of the plan, not an afterthought.

4 Writing a plan that is one page long

A rescue plan that runs to fifteen pages will not be read at the moment it is needed. It should fit on one page, be specific to the work area, and answer six questions.

1. 1
   Where can a fall happen today? The specific locations, from the same map that identified the anchors in Chapter 3.1.
2. 2
   Who raises the alarm, and how? A named role, a radio channel or phone number, and the words to say — location, level, how many.
3. 3
   Who performs the rescue? Named people on shift, not a job title that may be off site. What happens when they are at lunch is part of the plan.
4. 4
   With what equipment, from where? The rescue kit's storage location, and the anchor the rescue system will use — identified in advance, because you will not be evaluating anchors during a rescue.
5. 5
   How does the casualty get to definitive care? Where the ambulance meets you, who guides them in, and who has the site address and gate.
6. 6
   How do you know it works? The date of the last drill. A plan that has never been walked through is a hypothesis.

5 Drilling it, and the paperwork afterwards

Drill the plan with a weighted dummy or a volunteer in a controlled suspension at low height, and time it from the alarm to hands on the casualty. The number you get is almost always two or three times what people guessed. That is the point of the exercise.

Do it at the start of the job, with the crew who will actually be there, and do it again when the work area changes. A drill run once at induction and never repeated tells you what the induction crew could do on a clear day in an area that no longer exists.

Two things reliably fail in a first drill: nobody can find the rescue kit, and the rescue anchor turns out to be unreachable from where the casualty is hanging. Both are cheap to fix in advance and expensive to discover during an incident.

After any real fall, the obligations stack up quickly:

• 1926.502(d)(19) — every component subjected to impact loading is immediately out of service, and stays out until a competent person determines it is undamaged and suitable for reuse. In practice, scrap it.
• 1926.502(k)(10) — if the work was under a fall protection plan, the employer must investigate the circumstances of the fall or other serious incident to determine whether the plan needs to change, and implement those changes.
• Reporting. Under 29 CFR 1904.39, employers must report a work-related fatality to OSHA within 8 hours, and an in-patient hospitalization, amputation or loss of an eye within 24 hours.
• Retraining. 1926.503(c) requires retraining where inadequacies in an employee's knowledge or use of fall protection indicate the training did not hold.

And the one that is not in any standard: tell the crew what happened and what changed. A fall that produces a paperwork trail and no visible change teaches everyone on that site that the system does not respond.