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OSHA 1910.146AppF

Rescue team evaluation criteria

Subpart J

20 Questions & Answers
10 Interpretations

Questions & Answers

Under 1910.146(k)(1), what must an employer do before relying on an off‑site rescue service for permit‑required confined space entry?

The employer must contact and plan with the off‑site rescue service so the evaluations required by 1910.146(k)(1)(i) and 1910.146(k)(1)(ii) can be performed rather than just posting a number or planning to call 911 at the time of an emergency. See Appendix F to 1910.146 for guidance.

  • OSHA guidance makes clear that mere posting of a phone number or informal plans to use 911 does not satisfy the standard's evaluation and coordination requirements. 1910.146(k)(1) requires proactive contact and planning with prospective rescue services.
  • Practical steps: arrange meetings, walk through likely permit spaces, document response times and capabilities, and confirm willingness to perform rescues at your site.

Under 1910.146 App F, how should an employer decide whether to maintain an on‑site rescue team versus hiring an off‑site service?

The employer should use an initial evaluation comparing the on‑site team's cost, availability, and capabilities to those of an off‑site service and pick the option that can perform timely and effective rescues for the types of permit spaces at the facility. See Appendix F to 1910.146 and 1910.146(k)(1).

  • Consider response time, specialized equipment, number and training of personnel, medical skills, and vertical or restricted‑portal rescue capability.
  • If a practice rescue shows deficiencies, Appendix F recommends selecting another service or forming an internal team.

Under 1910.146 App F, what response‑time factors should an employer evaluate for a prospective rescue service?

The employer should evaluate notification time, travel time from rescuer location to the site, and setup time so the service can be ready for entry within the timeframe required by the hazards (for IDLH atmospheres this may mean standing by at the space). See Appendix F to 1910.146 and 1910.146(k)(1).

  • Consider road quality, traffic congestion, vehicle reliability, driver skill, and whether the service can dispatch immediately on notification.
  • For spaces that can rapidly become IDLH, Appendix F advises that rescuers must be standing by at the permit space.

Under 1910.146 App F, can an employer rely on 911 for confined space rescue services?

No — an employer may not rely solely on 911 or simply posting an outside service's number; the employer must contact and coordinate evaluations with the prospective off‑site rescue service as required by 1910.146(k)(1). See Appendix F to 1910.146.

  • Appendix F explicitly states that merely planning to rely on 911 does not comply with paragraph (k)(1).
  • Employers must verify the service's willingness to perform rescues at their workplace, response times, equipment and training, and availability during entries.

Under 1910.146(k)(2), what ongoing practice requirement must rescue teams meet if they have not performed a real permit space rescue in the previous 12 months?

Rescue teams must practice permit space rescues at least once every 12 months if they have not successfully performed a permit space rescue during that time, and each practice should include a critique and corrective actions. See 1910.146(k)(2)(iv) and Appendix F to 1910.146.

  • Appendix F specifies that practices should identify deficiencies in procedures, equipment, training, or personnel and that results and corrections be shared with the employer.
  • Documented critiques help the employer decide whether the service can meet rescue needs or whether another service is required.

Under 1910.146 App F, what equipment and air supply considerations should employers check for rescuers entering atmospherically hazardous spaces?

Employers should verify whether rescuers will use SCBA or supplied‑air (airline) respirators with escape bottles, that rescuers have ample replacement cylinders or air supply, and that procedures exist to enter and exit within the respirators' air limits. See Appendix F to 1910.146 and 1910.146(k).

  • For spaces that may be IDLH or where rescue and patient retrieval cannot be completed in 15–20 minutes, Appendix F recommends considering airline respirators with escape bottles to supply rescue air to the patient.
  • Confirm the rescue service's stock of spare cylinders, air‑resupply procedures, and practiced swap/evacuation techniques.

Under 1910.146 App F, what should an employer verify about a rescue service's ability to perform vertical or elevated rescues?

The employer should verify that the rescue service has the technical knowledge, personnel training, and rope or elevated‑rescue equipment to perform rescues into spaces with vertical entries over 5 feet or other high‑angle conditions. See Appendix F to 1910.146 and 1910.146(k).

  • Appendix F advises employers to check capability for rope work, elevated patient packaging, and safe retrieval from vertical portals.
  • Include practical checks such as demonstration of confined‑space descents/ascents and patient packaging drills during performance evaluations.

Under 1910.146 App F, how should an employer evaluate a rescue service's medical and patient‑packaging skills?

The employer should confirm that rescue personnel have training and demonstrated competence in the first aid and medical skills needed to treat victims likely to be encountered in the facility's permit spaces and can package patients safely for removal. See Appendix F to 1910.146 and 1910.146(k)(2).

  • During performance evaluations, check for training certificates, practical patient packaging drills, and ability to stabilize victims in restricted openings or obstructed interiors.
  • Appendix F specifically asks whether the service can package and retrieve victims from spaces with limited openings (less than 24 inches) or internal obstacles.

Under 1910.146 App F, what does 'representative practice spaces' mean for rescue team drills?

'Representative practice spaces' are training environments that mimic the critical physical features of your actual permit spaces — such as internal configuration, elevation, portal size, and access — so the team can practice realistic rescues; Appendix F also allows practicing in worst‑case or most restrictive spaces. See Appendix F to 1910.146 and 1910.146(k)(2)(iv).

  • Appendix F lists characteristics to consider: open vs. obstructed interiors, elevated vs. non‑elevated portals, restricted (<24 in) vs. unrestricted portals, and horizontal vs. vertical access.
  • Choosing a ‘‘worst‑case’’ practice space helps reveal equipment or procedural limitations before an actual emergency.

Under 1910.146 App F, how should an employer evaluate communications between attendants and rescue services?

The employer should verify that there is a reliable method to communicate a rescue request from the attendant to the rescue service without delay and that the service can dispatch quickly after notification, consistent with 1910.146(k)(1). See Appendix F to 1910.146.

  • Test communication devices during initial coordination (radios, pagers, landlines, mobile phones) and confirm backup methods.
  • Appendix F asks employers to determine how soon a rescuer can be dispatched once notified and whether the rescuer can notify the employer if it becomes unavailable while an entry is underway.

Under 1910.146 App F, what should an employer check about a rescue service's availability and notification if it becomes unavailable during an entry?

The employer should confirm the rescue service's hours of operation, circumstances when it may be unavailable, the likelihood of key personnel being unavailable, and whether the service can promptly notify the employer to abort entry if it cannot respond. See Appendix F to 1910.146 and 1910.146(k)(1).

  • Ask the service about mutual aid agreements, backup crews, and their procedures to communicate unavailability.
  • Employers must have plans to abort entries immediately if the arranged rescuer becomes unavailable during the entry.

Under 1910.146 App F, how should employers evaluate a rescue service's ability to test atmospheres and recognize IDLH conditions?

Employers should confirm that rescue personnel are trained and equipped to test atmospheres and determine whether conditions are IDLH, and that they can recognize signs, symptoms, and consequences of hazardous atmospheres in the facility's permit spaces. See Appendix F to 1910.146 and 1910.146(k)(2).

  • Appendix F specifically asks whether team members can properly test the atmosphere to determine IDLH and recognize atmospheric hazard indicators.
  • Verify training records, instrument types/calibration, and practical testing demonstrations during performance evaluations.

Under 1910.146 App F, what portal size issues must employers consider when selecting or evaluating a rescue service?

Employers must determine whether the rescue service can safely enter or retrieve victims from portals that are restricted (24 inches or less) or unrestricted (>24 inches), because restricted portals may prevent SCBA entry and normal spinal immobilization. See Appendix F to 1910.146 and 1910.146(k)(2).

  • Appendix F notes restricted portals are too small for a rescuer using SCBA and complicate normal spinal immobilization; employers should confirm alternative patient‑packaging and retrieval methods.
  • Performance evaluations should include drills through the actual portal dimensions or worst‑case mockups.

Under 1910.146 App F, what documentation should an employer get after a rescue service practice rescue?

The employer should obtain the practice critique, documentation of identified deficiencies, and records of corrective actions the rescue service took so the employer can determine if the service can be upgraded or should be replaced, as recommended by 1910.146(k)(2)(iv) and Appendix F to 1910.146.

  • Appendix F suggests the critique can be performed by the service or another qualified party and that results and corrections be shared with the employer.
  • Keep records of practice dates, attendees, scenarios, findings, and corrective measures to support employer decisions and regulatory compliance.

Under 1910.146 App F, how should an employer evaluate rescuer capability for spaces with internal obstructions?

The employer should verify that the rescue service has experience and demonstrated procedures for maneuvering around obstructions (like baffles or installed equipment), including appropriate patient packaging and retrieval techniques for obstructed interiors. See Appendix F to 1910.146 and 1910.146(k)(2).

  • Appendix F defines obstructed interiors and warns that equipment placed inside the space for work purposes may increase rescue difficulty.
  • During performance evaluations, practice rescues should simulate the specific obstructions present in the employer's permit spaces.

Under 1910.146 App F, what should employers check about a rescue service's willingness to perform rescues at their workplace?

Employers must confirm that off‑site rescue services are willing to perform rescues at the employer's workplace, because relying on a service that declines to respond does not comply with 1910.146(k)(1). See Appendix F to 1910.146.

  • Ask the service in writing if they will respond to rescues at your address and under what conditions or limitations.
  • If a service refuses, the employer must find an alternative that is willing, trained, equipped, and timely.

Under 1910.146 App F, what personnel‑training items should an employer confirm for rescue team members?

Employers should confirm that rescue team members are trained as permit space entrants at a minimum, understand hazards of the site's permit spaces, are trained in PPE and rescue equipment use (SCBA, ropes, backboards), and have necessary medical and first‑aid skills. See Appendix F to 1910.146 and 1910.146(k)(2).

  • Appendix F lists specific checks including recognition of hazardous atmospheres, PPE competence, first aid/medical skills, and ability to identify information pertinent to rescue from permits and MSDSs.
  • Require proof of training and observe practical demonstrations during performance evaluations.

Under 1910.146 App F, how should employers judge a rescue service's ability to identify hazards from outside the space?

Employers should verify that rescue personnel are informed of and can recognize hazards to entrants from outside the space (for example, adjacent hot work or nearby operations) so they can plan rescues safely and avoid secondary hazards. See Appendix F to 1910.146 and 1910.146(k)(2).

  • Appendix F asks whether the rescue service has been informed of outside hazards that might affect rescue operations and whether they can use entry permits and hot work permits to gather pertinent information.
  • Include scenario‑based drills that introduce outside hazards so the team practices hazard recognition and scene management.

Under 1910.146 App F, how often should employers re‑evaluate the rescue service's initial capabilities?

Employers should perform an initial evaluation before relying on a rescue service and then use performance evaluations (practice rescues at least annually if no real rescue occurred) to re‑assess capabilities; Appendix F recommends at least yearly practice and critiques per 1910.146(k)(2)(iv). See Appendix F to 1910.146.

  • Use the annual practice to verify training, equipment condition, response time, and corrective actions.
  • If performance evaluation reveals deficiencies, re‑evaluate more frequently or consider a different service.

Under 1910.146 App F, what should employers do if a rescue practice reveals deficiencies in a service's procedures or equipment?

If a practice identifies deficiencies, the employer should obtain the critique and corrective‑action plan from the rescue service and decide whether the service can be upgraded promptly or whether a different rescue capability is required, per 1910.146(k)(2)(iv) and Appendix F to 1910.146.

  • Appendix F recommends that the critique identify deficiencies in procedures, equipment, training, or staffing and the corrections made.
  • Employers should document corrective actions, set timelines for fixes, and follow up with a re‑evaluation or select a new service if needed.