OSHA requirements are set by statute, standards and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional employer obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov.

January 13, 2003

Mr. John Randall
Water Pollution Control Facilities
7525 Bertram Road South East
Cedar Rapids, Iowa 52403-7111

Dear Mr. Randall:

Thank you for your August 23, 2000 letter to the Occupational Safety and Health Administration's (OSHA's) [Directorate of Enforcement Programs (DEP)]. This letter constitutes OSHA's interpretation only of the requirements discussed and may not be applicable to any questions not delineated within your original correspondence. You had specific questions regarding OSHA's Respiratory Protection Standard, 29 CFR 1910.134. Your paraphrased statements and questions are presented below followed by our responses. We apologize for the delay in response.

Statement 1: 29 CFR 1910.134(g)(3)(iii) states, "...an employee trained and equipped to provide emergency rescue" and 29 CFR 1910.134(g)(3)(vi)(B) states, "appropriate retrieval equipment for removing employee(s) ..."

Question 1: What is OSHA's definition of appropriate training and equipment for an employee standing outside while another employee enters an area with an atmosphere that is immediately dangerous to life or health (IDLH)?

Response: The Respiratory Protection Standard mandates that employees who are required to wear respirators must receive comprehensive training that they understand. The employees must be informed of the following:

  • the reason why the respirator is necessary,
  • the limitations and capabilities of the respirator,
  • how to inspect and maintain the respirator,
  • how to put on and remove the respirator,
  • how to recognize medical signs and symptoms that may prevent the effective use of the respirator,
  • the requirements of the respirator standard, and
  • how to use the respirator effectively, including situations in which the respirator malfunctions.

In addition, prior to entering an IDLH environment to provide an effective emergency rescue, standby employees must be informed of the following:

  • the person to notify for necessary additional assistance, how to protect themselves against the IDLH atmosphere if an emergency arises,
  • how to provide emergency assistance,
  • how to use the appropriate rescue devices as well as communication devices, and
  • worksite specific procedures developed by the employer.

Standby employees must be equipped with the appropriate equipment such as pressure-demand or other positive-pressure self-contained breathing apparatus (SCBA), or a pressure-demand or other positive-pressure supplied-air respirator with auxiliary SCBA.

29 CFR 1910.134(g)(3)(vi)(B), which addresses retrieval equipment, is a performance-based standard; there are no requirements for specific rescue equipment. The employer is required to use appropriate retrieval equipment, unless its use would increase the overall risk associated with rescue from the IDLH environment.

Statement 2: Rooms or buildings which do not meet the criteria for confined spaces but which, on occasion, may contain IDLH atmosphere as a result of a failure in a system or process, may require re-entry for maintenance, clean up, etc.

Question 2: In cases where a retrieval line is inappropriate, what other type of rescue or retrieval equipment, if any, is typically used? Would it be adequate to have at least two emergency standby employees in SCBAs trained to simply remove the entrant to fresh air as quickly as possible?

Response: OSHA's Hazardous Waste and Emergency Response Operations (HAZWOPER) standard, at 29 CFR 1910.120(q), would apply to the emergency situation described in the above statement. Section 1910.120(q)(3)(vi) is a performance-based standard that requires the employer to select and provide appropriate rescue equipment based on the anticipated circumstances. Examples of other types of appropriate rescue equipment are chest or full body harness, wristlets, and a lifting device or anchor. Section 1910.120(q)(3)(v) states "...operations in hazardous areas shall be performed using the buddy system in groups of two or more." If SCBAs for the backup personnel can effectively permit safe rescue, then that arrangement meets OSHA's requirements.

In addition, the following personnel must also be readily available: backup personnel with equipment ready to provide assistance or rescue, and first aid support personnel with medical equipment and transportation capability as stated in 29 CFR 1910.120(q)(3)(vi).

Question 3: Is training for standby personnel limited to rescue and retrieval equipment, or are there other training requirements such as cardiopulmonary resuscitation and first aid?

Response: OSHA's Hazardous Waste and Emergency Response Operations (HAZWOPER) standard, at 29 CFR 1910.120(q), provides that standby personnel responding to emergency situations must have advanced first aid training as evaluated by a competent professional. Training must be tailored to the specific needs of the workplace conditions. Individuals trained to this level should be capable of providing basic first aid involving maintenance of the airway, control of bleeding, immobilization of fractures, CPR, and similar duties, which do not require the use of medical equipment carried on ambulances. An example of a course which meets the intent includes the U.S. Department of Transportation's Emergency Medical Services: First Responder Training Course.

Statement 3: The duties and responsibilities for standby personnel during an IDLH entry are not as clearly defined in 29 CFR 1910.134 as for those of an attendant during a permit-required confined space entry in 29 CFR 1910.146. The roles are similar, but the expectations and outcomes in an emergency are clearly different.

Response: The duties of an attendant under a permit-required confined space (PRCS) entry can be found at 29 CFR 1910.146(i). The standard allows an attendant to enter a PRCS only if non-entry rescue is not possible and only if the attendant has been trained and equipped for rescue operations as required by paragraph (k)(1) and only if they have been relieved by another attendant as required by paragraph (i)(4).

Separate rescue and emergency services need to be readily available during any permit-required confined space entry into an IDLH atmosphere. They must be suitably equipped and capable of responding in a timely manner. Under the respirator standard, the outside personnel maintain communication with the entrant and may perform outside rescue, but are required to be trained and suitably equipped to enter the IDLH , if needed to provide emergency rescue. The expectations and outcomes in an emergency should be the same in either case.

As you may know, the State of Iowa is administering its own occupational safety and health program under a plan approved and monitored by Federal OSHA. States are required to adopt occupational safety and health standards at least as effective as those promulgated by Federal OSHA. Iowa has adopted its own respiratory protection standard identical to Federal OSHA's respiratory protection standard, 29 CFR 1910.134. Thus, the Iowa Respiratory Protection Standard is currently in effect in your state.

In addition, Iowa offers free on-site consultation services to those employers who request guidance on compliance with occupational safety and health standards. For information regarding either the consultation services or the requirements of the Iowa Respiratory Protection Standard, you should contact:

Byron K. Orton, Commissioner
Iowa Division of Labor
1000 E. Grand Avenue
Des Moines, Iowa 50319-0209
Phone: (515) 281-6432
Fax: (515) 281-4698

Thank you for your interest in occupational safety and health. We hope you find this information helpful. OSHA requirements are set by statue, standards, and regulations. Our interpretation letters explain these requirements and how they apply to particular circumstances, but they cannot create additional obligations. This letter constitutes OSHA's interpretation of the requirements discussed. Note that our enforcement guidance may be affected by changes to OSHA rules. Also, from time to time we update our guidance in response to new information. To keep apprised of such developments, you can consult OSHA's website at http://www.osha.gov. If you have any further questions, please feel free to contact the Office of Health Enforcement at (202) 693-2190.

Sincerely,

Richard E. Fairfax, Director
Directorate of Enforcement Programs

[Corrected 2/23/2004]