Date: Thu, 5 Oct 2006 11:36:34 -0400
Reply-To: "Mary M. Cavanaugh" <cavanaughmm**At_Symbol_Here**APPSTATE.EDU>
Sender: DCHAS-L Discussion List <DCHAS-L**At_Symbol_Here**LIST.UVM.EDU>
From: "Mary M. Cavanaugh" <cavanaughmm**At_Symbol_Here**APPSTATE.EDU>
Organization: ASU Safety & WC Office
Subject: Re: [aihaih-list] Confined Space Rescue
In-Reply-To: <001401c6e4da$d2437ec0$6401a8c0**At_Symbol_Here**CC152476B>

After lengthy discussions with our state OSHA rep (we are a state-plan state
that just copies the fed regs on confined space), and researching numerous
OSHA letters of interpretation, I came to the same conclusion several years
ago as your colleague did; if you rely on an outside rescuer, the harness
and rescue line are not required.

HOWEVER, our policy nevertheless requires entrants to wear a harness and tie
line unless they can demonstrate that it will create an unsafe condition
while they are working in the confined space.  This is because I discussed
the options with our rescue service (the local fire dept), and they felt
quite strongly that if a downed entrant was wearing a harness (and, whenever
possible, was attached to a rescue line), they would be able to get that
person out a lot more quickly.  Makes sense - you can imagine trying to
remove an unconscious person out of a tight space without anything to grab
onto!  That in turn would save valuable minutes in their efforts to save
that person's life.

Then I had the rescue service come out and do a mock rescue with our guys
and we all learned good stuff that made them more amenable to this change in
policy -- for example, they showed how most people wear the harness much too
loose, and that a loose harness is actually more uncomfortable when being
lifted vertically.  Since a tight harness is also less likely to get hung up
on obstructions, this change in the way they wear their harness also
eliminated virtually all occasions when they might otherwise have argued
that the harness would get in their way and cause a hazard.

I'm not sure if this helps in your quest for answers, but I hope the info is

Mary M. Cavanaugh, CIH
phone  828.262.6838
email  cavanaughmm**At_Symbol_Here**

-----Original Message-----
From: DCHAS-L Discussion List [mailto:DCHAS-L**At_Symbol_Here**LIST.UVM.EDU] On Behalf Of
Chris Marlowe
Sent: Saturday, September 30, 2006 5:53 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU
Subject: Re: [DCHAS-L] [aihaih-list] Confined Space Rescue

I won't disagree with anything you wrote, or opine originally. I wanted to
share a reaction when OSHA published its draft PRCS standard (in 1993). 
At that time, one of our crews did a horizontal entry into a large-diameter
brick sewer. OSHA published a position that employers must plan to perform
non-entry rescue for every entry. If one of my crew fell face-down 100 yards
from the opening we would have dragged him on his face across a rough and
contaminated surface. I determined that we would rely on entry rescue for
that space.
Stay healthy,


Chris Marlowe
42 Highlander Dr
Scotch Plains, NJ  07076
908 / 754 - 5160 (home)
732 / 539 - 8128 (cell)



From: aihaih-list**At_Symbol_Here** [mailto:aihaih-list**At_Symbol_Here**] On
Behalf Of Gary M. Kehoe
Sent: Friday, September 29, 2006 6:58 PM
To: DCHAS-L**At_Symbol_Here**LIST.UVM.EDU; aihaih-list**At_Symbol_Here**; ih**At_Symbol_Here**
Subject: [aihaih-list] Confined Space Rescue

I was having a discussion with a colleague the other day about confined
space entry and non-entry rescue. My understanding of the OSHA standard was
that all permit required CS entries (non-IDLH) had to be done with a harness
and method to initiate non-entry rescue UNLESS the harness and/or retrieval
system presents a greater hazard. My colleague basically agreed except he
held a caveat that if the employer chooses not to perform non-entry rescues,
a harness and retrieval system is not required and reliance on an on-site or
off-site rescue service is acceptable as long as they can fulfill meet the
"timely" response requirements. I also vaguely recall OSHA specifying the
hierarchy of rescue as being 1) self-rescue, 2) non-entry rescue, 3) entry
rescue although I can't find that written anywhere. Anyone know that

Opinions? Isn't it weird what some people will talk about over lunch? I
think I scared my intern this summer with IH geeky discussions like this.

Gary M. Kehoe, CIH
Senior Industrial Hygienist
Midwest Generation EMG
312-925-1813 (C)
312-788-5533 (F)

[Non-text portions of this message have been removed]

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