Q&A: Requirements for confined space entry rescue planning
What are the requirements for confined space entry rescue planning? Can a local fire department be used as an off-site rescue service if they are notified of the confined space entry and confirm that they are available to provide rescue services if needed?
29 CFR 1910.146(k)(1)(i) requires that an employer evaluate a prospective rescuer’s ability to respond to a rescue summons in a timely manner, considering the hazard(s) identified. OSHA does not define what a “timely manner” is specifically. 29 CFR 1910.146(k)(1)(ii) requires that employers evaluate a prospective rescue service’s ability, in terms of proficiency with rescue-related tasks and equipment, to function appropriately while rescuing entrants from the particular permit space or types of permit spaces identified. Again, OSHA does not define what this means exactly.
However, OSHA does provide a letter of interpretation dated May 23, 2008 that gives some guidance. In the letter, OSHA is asked whether an off-site fire department may be used as a rescue service. OSHA responded that the employer must evaluate and select an off-site rescue service that has the capability to respond in a timely manner to the particular hazards at issue and to the types of emergencies that may arise in the employer’s confined spaces. The criteria employers can use in evaluating and selecting a service include determining whether the service is unavailable at certain times of the day or in certain situations, the likelihood that key personnel of the rescue service might be unavailable at times, and, if the rescue service becomes unavailable while an entry is underway, whether the service has the capability of notifying the employer so that the employer can instruct the attendant to abort the entry immediately.
Compliance may require the employer to be in close communication with the off-site rescue service immediately prior to each permit space entry. In the scenario you describe, the employer must ensure close communication with the rescue service during entry operations so that if the rescue service becomes unavailable while an entry is underway, the employer can instruct the attendant to abort the entry immediately. Entry operations cannot resume until the entry supervisor verifies that rescue services are able to respond in a timely manner.
Refer to Appendix F to § 1910.146 – Rescue Team or Rescue Service Evaluation Criteria (Non-Mandatory) for guidance on rescue service criteria for your local fire department.
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