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Confined Space Rescue
Confined Space Management

by: Mike Jaurena

It seems when we solve one issue we create the beginning of another. Case in point, we finally agree that additional training and skills are necessary for response to confined space incidents and now there are various options in receiving this training, but how many personnel do we train and who''s responsibility is it?

First we must understand the two levels of confined space training: Confined Space Awareness and Confined Space Entry Rescue. Confined Space Awareness training provides personnel the knowledge necessary to perform routine confined space operations; i.e., clean, inspect, repair, support, etc. Awareness trained personnel may perform any one of the three recognized roles of Entry Supervisor, Attendant or Entrant. Confined Space Entry Rescue (CSER) training requires additional specialized training up and above the Awareness training and is designed to provide the skills necessary to perform rescue or recovery from a confined space incident. The confusion comes when planning a rescue team how many personnel do you need so you can do the response?

The regulations do not provide a specific number on what constitutes a confined space rescue team, but they do specify personnel must receive training prior to performing rescues. The degree of complexity of the incident will also be a significant factor to the number of personnel necessary to perform a rescue. Disregarding the complexity of the incident lets focus on the regulations. The question of who is responsible is clearly stated in the Federal OSHA 1910.146(k). Regulations require the "Host Employer" of the space to be entered to ensure emergency rescue services are trained in making rescue from permit spaces and they are available as a part of their entry permits emergency action plan. It further provides the "Host Employer" two options for rescue services:

  • Host Employer''s employees enter permit spaces to perform rescue, or

  • Host Employer arranges to have persons other than the host employer''s employees perform permit space rescue

Cal-OSHA Title 8, Article 108, 5157(k) also provides the "Host Employer" the same options but further states "The employer shall ensure that at least one standby person at the site is trained and immediately available to perform rescue and emergency services." Before we move on lets define "at the site and immediately available". Based off case history and the intent of the regulation "at the site and immediately available" is defined as able to respond to the incident location within 4-6 minutes of notification. This allows the standby person the ability to perform other duties while the permit space is being entered but must be able to stop what they are doing and respond to the incident within the allowable time frame. So with this as base line data lets build from here.

As just discussed we now know the regulations require at least 1 person trained, at the site and immediately available to perform confined space operations. The Confined Space Regulations also requires the same structure be in place for rescue as is for normal entry operations, therefore you must have an Entry Supervisor, Attendant and Entrant. Fed-OSHA 1910.146(k)(1)(i) and Cal-OSHA 5157(k)(1)(B) both require the rescue service shall be trained to perform the assigned rescue duties and to utilize rescue equipment. This brings the number up from the one standby person to a minimum of 3 CSER trained personnel to perform an non-hazardous material entry rescue. Team members will have to be supplemented with support personnel who have training in specific functions like confined space awareness, ventilation, monitoring, site security, etc., as the incident becomes more complex.

As mentioned 3 CSER trained personnel is now the minimum number of rescue members for a non-hazardous material entry rescue, now lets look at a hazardous material incident. According to National Institute for Occupational Safety and Health (NIOSH)1 1983-1993 field investigations of fatal work-related incidents 80% of the confined-space incidents had hazardous atmospheres. This study included all industries, when you focus on manufacturing 92% of confined-space incidents had hazardous atmospheres; 82% being toxic or flammable (hazardous materials) and the remainder 18% being oxygen deficient.

Hazardous material confined-space incidents require a different minimum level of staffing due to the complexity of the response and the regulatory requirements. When dealing with Haz-Mat events we must explore and focus on two additional regulations: Fed OSHA Respiratory Protection Standard 1910.134 and Fed OSHA Hazwoper Standard 1910.120.

Fed OSHA Respiratory Protection Standard 1910.134(e)(3)(i) states "in areas where the wearer, with failure of the respirator, could be overcome by a toxic or oxygen-deficient atmosphere, at least one additional man shall be present." It further defines in sections 1910.134(e)(3)(ii)&(iii) when personnel enter an immediately dangerous to life or health (IDLH) atmospheres with a self-contained breathing apparatus or supplied air respirator that additional standby personnel are required with equal protection to standby "at the nearest fresh air base for emergency rescue".

The Fed OSHA Hazwoper Standard 1910.120 requires response to IDLH atmospheres by the use of the "buddy system" (2). The "buddy system" requires each employee of the work group be designated to be observed by at least one other employee in the work group. The Hazwoper standard also requires the use of an Incident Command structure and the appointment of a Safety Officer. The Safety Officer must be knowledgeable in the operations being implemented at the emergency response site, therefore they must also be confined space rescue trained.

Based off the previous information lets build our response team to a confined-space Haz-Mat event, first lets look at non-IDLH atmospheres.

  • Incident Commander - Hazwoper Incident Commander Trained

  • Operations Section Chief - Hazwoper Incident Commander Trained

  • Entry Supervisor - CSER trained / Hazwoper FRO

  • Attendant - CSER trained / Hazwoper Technician (NOTE: may also be only confined space awareness trained if additional duties specific to incident response have been clearly communicated and individual can perform them)

  • Entrant, Primary - CSER trained / Hazwoper Technician

  • Entrant, Standby - CSER trained / Hazwoper Technician

  • Safety Officer or Assistant Safety Officer - CSER trained / Hazwoper Technician

Therefore a Haz-Mat, non-IDLH atmosphere will require a minimum of 4 people confined space entry rescue trained if, in the pre-plan, you have assigned and addressed the attendant roles and responsibilities to a non-CSER trained person during the confined-space incident. Again rescue team members will have to be supplemented with support personnel who have training in Hazwoper and confined space awareness as well as training in specific functions like, ventilation, monitoring, site security, decontamination, etc., as the incident becomes more complex.

Now lets build our response to a confined-space Haz-Mat event with IDLH atmospheres.

  • Incident Commander - Hazwoper Incident Commander Trained

  • Operations Section Chief - Hazwoper Incident Commander Trained

  • Entry Supervisor - CSER trained / Hazwoper FRO

  • Attendant - CSER trained / Hazwoper Technician (NOTE: may also be only confined space awareness trained if additional duties specific to incident response have been clearly communicated and individual can perform them)

  • Entrant, Primary #1- CSER trained / Hazwoper Technician

  • Entrant, Primary #2- CSER trained / Hazwoper Technician

  • Entrant, Standby #1 - CSER trained / Hazwoper Technician

  • Entrant, Standby #2 - CSER trained / Hazwoper Technician

  • Safety Officer or Assistant Safety Officer - CSER trained / Hazwoper Technician

Your minimum number now jumps to 6 people confined space entry rescue trained. This takes in assumption you have preplanned and have assigned and addressed the attendant roles and responsibilities to a non-CSER trained person during a confined-space incident. Again rescue team members will have to be supplemented with support personnel who have training in Hazwoper and confined space awareness as well as training in specific functions like, ventilation, monitoring, site security, decontamination, etc., as the incident becomes more complex.

In conclusion the answer to the original questions are as follows, the level of confined space entry rescue staffing is on a sliding scale and is dependent on the risk(s) associated with the confined space job itself. Confined spaces by their nature seem to concentrate hazards. The more preventive and exposure mitigation measures that are in place reducing the risk associated with the job will impact the minimum staffing necessary for rescue services. The assumption that atmospheric hazards are more complex and manpower intensive than physical hazards is poor judgment, they, in fact, are usually more time and labor consuming. What is important is preplanning, which includes involvement of the confined space entry rescue services, strict use of a hazard analysis, proper contingency planning, and strict use of written safety and environmental programs and policies.

Finally the accountability and responsibility clearly lies with the "Host Employer" of the space to be entered. Although the regulation allows the rescue services to be farmed out, the accountability still remains with the "Host Employer". In responses where there is no "Host Employer" of the space to be entered, like the child who falls into a sewer system, then it is the jurisdictional responding agencies administration that becomes in essence the "Host Employer" and is now accountable in providing the training for rescue teams or providing a contingency plan for such responses.

  • 1 NIOSH: Worker Deaths in Confined Spaces, Page 20, Publications Dissemination, DSDTT, Cincinnati, OH, 1984, phone: 1-800-35-NIOSH.

  • 2 Occupational Safety and Health Administration (OSHA) - Letters of Interpretation, Briefing Package-OSHA Policy Concerning Responses to IDLH Atmospheres, John B. Miles, JR., Director Directorate of Compliance Programs, 05/16/1996


Mike Jaurena is currently the Safety and Environmental Training Coordinator for a major Petrol-Chemical Company on the West Coast. His duties include development, implementation and deployment of Safety and Environmental programs and policies for the companies employee's and contract personnel. Mike's coverage includes 5 offshore platforms and 2 onshore gas and oil processing facilities that require compliance with Federal, State, and Local agency regulations.

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