Occupational (OSHA) and Environmental Hazards/Confined Space Rescue
QUESTION: Are the members of a confined space rescue team required to sign an entry permit prior to initiating a confined space rescue?
ANSWER: Subject: Confined Space Rescue
Question: Are the members of a confined space rescue team required to sign an entry permit prior to initiating a confined space rescue?
Answer: The answer is not simple. You must look to two sources for your answer. The first of course are the requirements of OSH A (Occupational Safety and Health Administration). The section on confined spaces is contained in Standard Number 1910.146. The second place to look are the rules developed by a company or agency to ensure that the codes are properly followed. (Note: Some states such as Washington, California and Oregon have a state run OSHA program but their rules must be at least equal. In that case there may be a statutory requirement that exceeds the basic federal OSHA requirement. You should in that case review the codes applicable in your state.) All persons involved at all levels should be knowledgeable of all the requirements of the standard (a thorough review of this section should be a part of the periodic review as well as initial training for all involved in confined space work).
As I read through the standard I find reference to the signature of the "entry supervisor" and individual conducting any and all testing being required but not the signature of each employee. However, if I were to administer a confined space program I would require that each and every person involved sign the permit. The reason for this would be to have a quick and simple record to be able to meet the various requirements that all members of the rescue team were properly trained, equipped and certified for the process, equipment, etc..
So the answer is - under OSHA I could not find a requirement that each employee on a confined space rescue team sign the entry permit but under "good safety practices" the signatures would be required. If you have any further questions please feel free to ask.
Michael Brown, CSP Retired
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QUESTION: I may have substituted the term "signature" with the term "listed" in my origin question. While I understand the requirement to have work task related entrants listed on the confined space entry permit, my question is it is required to list the members of a rescue team on the entry permit in the event of an emergency entry in which they perform a rescue? I do not see a requirement for the completion of an entry permit for rescue team activities in the regulations.
Subject: Confined Space Rescue
Question: I may have substituted the term "signature" with the term "listed" in my origin question. While I understand the requirement to have work task related entrants listed on the confined space entry permit, my question is it is required to list the members of a rescue team on the entry permit in the event of an emergency entry in which they perform a rescue? I do not see a requirement for the completion of an entry permit for rescue team activities in the regulations.
Answer: You are correct but what are you going to provide to an inspector when they say "Let's talk about your rescue team activities. How do you know who was on the team for the rescue on August 25th at 7:35 PM in the recovery boiler surge tank? Can you provide the safety training records for each member of the team involved? How do you know only the properly trained employees were involved?" A list of the employees involved will go a long ways toward providing the answers to those and other questions. The inspector will be looking for positive proof that your procedures ensure only properly trained individuals are involved in any and all rescue efforts. A very valid concern that crops up is how do you record the names of those involved without extra paperwork or wasting time in an emergency situation. One approach to this would be a listing on the permit (perhaps the reverse) of all individuals in the operation who are qualified to take part in a rescue entry and then have the names checked-off or circled for the actual rescue entry. This allows for differences in shift assignments, operational areas as well as vacations etc. If you have an emergency department like some large operations do then the assumption is that all members of this group are properly trained and equipped for any and all rescue operations but a record of who was involved in each instance is still recommended (in this case payroll records may work to show who would have been on duty.
Yes, the paperwork requirements can seem like a royal pain in the backside, but in the world of rules and regulations they have become necessary. Plus having been involved in these operations as a once young and foolish safety director in a plant on swing shift when a major chlorine leak occurred one of the first laws of safety was impressed on me - "If it can go wrong ..... it will." Since that night I have been a very firm believer in written procedures covering ALL possibilities and extensive training so that the proper way does not require much thought. I hope this will cover your question but if further explanation or thoughts are desired, please feel free to ask.
Michael Brown, CSP Retired