Rescue From IDLH Spaces: Always Required?

Rescue From IDLH Spaces is Technically Demanding.

IDLH Spaces Rescue

IDLH Spaces Rescue is technically demanding.

The requirement to provide a means of rescue when workers enter permit-required confined spaces is well known aspect of the OSHA regulations. But employers, who are rarely rescue experts, often do not know how these teams should be equipped and trained.

The short answer, according to OSHA, is that the employer must evaluate the specific permit spaces, their hazards, and associated work activities, and then determine the types of equipment and training needed. This is a reasonable approach and speaks to the fact that OSHA simply specifies that there be a means of rescue, but aren't going to specify how to train and equip the team which can leave an employer with lots of questions.

Performing effective rescues from permit spaces that are IDLH (Immediately Dangerous to Life and Health) while wearing SCBAs is a technically demanding undertaking.

One question is whether the confined space regulations require them to develop and maintain the capability to remove an entrant from a permit space that contains hazards that are Immediately Dangerous to Life and Health (IDLH). These hazards are basically those which have an immediate impact on the health of the entrant and prevent him or her from exiting the space. This designation is usually applied to atmospheric hazards such as low oxygen levels or high concentrations of toxins.

Typically, removing patients from IDLH environments requires rescuers equipped with supplied-air respirators and other PPE. These operations are technically demanding since that they expose the rescuers to the same IDLH hazards that overcame the patient.  Training and equipping teams who can perform at this level requires a major commitment of time and money.

So which locations need to develop and maintain this high-level of rescue? Clearly any employer who sends workers into IDLH spaces to perform work (common in the petroleum and chemical industries) must have rescuers standing by the space ready and equipped to retrieve the entrants (according to the respiratory protection standard).

But what about a plywood mill or a food processing plant or any of the many other locations which do not send workers into IDLH atmospheres?

The answer  has several parts. We must begin by asking whether the space in question has a potential for developing an IDLH atmosphere due to the design or the work activities. But if this is the case, shouldn't we be investing our time and resources in changing the design of the space or the work procedures to eliminate the hazard potential? After all, prevention or elimination before the event is a much better way of dealing with hazards than using PPE such as SCBAs.

But what if there's a fire? Shouldn't the rescue team be able to cope with that hazards? I'm not so sure. Trying to perform a rescue from a smoke-filled, oxygen-depleted space poses serious risks to even professional firefighters (who are invariably trained to a much higher level than almost all industrial rescue teams).

So in my opinion, asking a millwright or pipe-fitter to don an SCBA and enter an IDLH space under emergency conditions doesn't pass the "Son Test." So what's the Son Test? It's a thought experiment that I use to judge the safety of a given situation. I basically ask myself if I'd want my son to perform whatever action is being proposed given the available equipment, procedures, and training (and for the record I'm fond of my son).

So in this case, would I want my son (or yours for that matter) to strap on a cumbersome piece of equipment (which he probably hasn't had enough training on and may not be recently fit-tested for) to go into an extremely hazardous environment look for someone who is probably already dead? Would I trust him to deal with the adrenalin and associated physiological/psychological changes that emergencies induce? Would he panic and use up all his air? Would he get hopelessly tangled in an air line or make some other simple error that can kill someone in this, the most unforgiving of environments?

Short answer: It's possible, maybe even likely. And the over riding goal of any rescue effort is first and foremost to not injure or kill anyone else, specifically, members of the rescue team. Once that's assured (to the extent possible), you can focus on extracting the patient.

Therefore my pre-plan in these situations would be to ascend the hierarchy of controls and eliminate/control the IDLH hazard before entry by blowing as much air into and through that space as possible. Once the IDLH environment is abated, the likelihood of not hurting or killing a member of the rescue team improves dramatically.

Remember that employers have, under the General Duty clause, the responsibility to identify hazards and control/eliminate exposure. It seems to me that expecting non-professionals to perform highly-technical rescue operations under supplied-air, in almost every case, does not meet the intent of this clause.

Jim Johnson

CEO: D2000 Safety, Inc.

Jim Johnson July 8, 2014

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