Fifteen Minutes
Why Your Rescue Plan Probably Isn’t One
by Stephen Zasadil, WSRCA Safety Consultant, President, SNK Services LLC
(Editor’s Note: Stephen Zasadil spent ten years as a safety of flight operator with the United States Navy before beginning his career as a safety compliance consultant in 2009. He currently works with companies across the United States to provide OSHA compliance information, documentation, and training.)
It’s 9:40 on a Tuesday morning. Your crew is tearing off a low-slope roof on a two-story commercial building. Everyone is tied off. The Job Hazard Analysis was completed and signed at 6:30. Fall protection is in place. From a compliance standpoint, everything looks right. Then a laborer steps backward onto a soft section of deck near an old curb penetration. The deck gives way. He goes over the edge.
His fall arrest system does exactly what it was designed to do. It stops the fall. Now he is hanging 14 feet above a landscaped area on the north side of the building, conscious but unable to rescue himself. The clock started the second he stopped falling.
The Gap Between Compliance & Rescue
The Occupational Safety and Health Administration’s (OSHA) requirement under 29 CFR 1926.502(d)(20) is simple: employers must provide for prompt rescue of employees in the event of a fall or assure employees can rescue themselves. That is the requirement. OSHA does not define prompt. It does not tell us who the rescuer must be, what equipment must be used, or how many minutes a rescue should take. ANSI/ASSP Z359.2 provides additional guidance, but it still cannot write the rescue plan for the building your crew is standing on today.
That gap is where boilerplate tends to live. Open enough fall protection plans and you will eventually see some version of this: a competent person will initiate rescue procedures and emergency services will be contacted. That sounds good in a binder, but it is not really a rescue plan. It is a sentence saying somebody will figure out the rescue after the fall has already happened.
Many contractors rely on the local fire department for rescue whether their written plan says so or not. There is nothing necessarily wrong with that, but the capability should be verified before someone is hanging off the building. Call the department that actually covers the project. Ask whether they have technical rope rescue capability and how it is staffed. Some smaller municipal and volunteer departments may rely on mutual aid, which can add substantial response time. A technical rescue team available at 2:00 in the afternoon may also be staffed very differently at 6:30 in the morning when the roofing crew starts work.
Then ask what a realistic response time is to the actual jobsite, not the district average. Finally, ask whether their equipment can physically reach the side of the building where a worker could be suspended. An aerial truck is only useful if it can get there. Street setback, landscaping, fences, overhead power lines, soft ground, locked gates, narrow access, and inaccessible rear elevations can all change the answer.
If the answers are good, put that information into the site-specific rescue plan. If the answers are bad, it is much better to learn that before the emergency.
What the Clock is Doing
A worker hanging motionless in a harness can experience reduced venous return as the leg straps place pressure on the legs and blood begins pooling in the lower body. The worker may become lightheaded, disoriented, or unconscious.
How quickly that occurs is unpredictable. Heat, dehydration, fatigue, harness fit, and injuries sustained during the fall can all make the situation worse. That should sound familiar to anyone who has worked roofing in July.
The commonly referenced 15 minute figure should be treated as a planning target, not an OSHA requirement or a guaranteed medical threshold. Nobody should be standing on the roof looking at a watch and thinking, “We still have 12 minutes.” The goal is simpler than that: get the worker down as quickly and safely as possible.
There has also been changing guidance over the years regarding how a worker should be positioned after suspension. Rather than building a rescue plan around disputed medical theories, contractors should focus on rapid rescue, activation of EMS, and emergency care consistent with current medical direction.
What a Real Rescue Plan Looks Like
A useful rescue plan answers some very basic questions. Who is getting the worker down? Not a competent person. Give me a name. Then give me a backup. If the designated rescuer is also one of the employees most exposed to the fall hazard, you have a single point of failure. What happens when he is the one hanging?
The next question is whether that person can actually perform the rescue. Having rescue equipment and having rescue capability are two very different things. If someone watched a short video and was handed a rope bag, you do not necessarily have a trained rescuer. The designated person should be able to operate the equipment under load and without step-by-step coaching. The first time someone uses a descent device under tension should not be when a coworker is hanging off the side of a building.
Then look at where the equipment is staged. This sounds obvious until you run a drill. The rescue kit is in the gang box on the opposite side of the roof. The key is in the superintendent’s truck. Or worse, the key is on the belt of the worker who just went over the edge. Rescue equipment needs to be where it can actually be reached quickly.
Suspension relief straps can be useful, but they are not a rescue plan. They do little for a worker who is unconscious, injured, or unable to reach them. Someone also needs to be assigned to call 911, and someone should be designated to meet emergency responders and direct them to the correct access point. That person should know the exact address, gate codes, jobsite hazards, and where the suspended worker is located. These are simple assignments, but during an emergency simple things are exactly what get missed.
Put a Clock on It
A rescue plan that has never been executed is still mostly a theory. Run a drill. Use the real site, the real equipment, and the real crew. Use a weighted rescue dummy and start the clock at the simulated fall. Stop it when the load reaches the ground or another designated safe location. Then write down the time.
You may discover the planned rescue anchor will not work. The equipment is too far away. Nobody remembers the address under pressure. The designated rescuer cannot operate the device as smoothly as expected. Good. That is why we drill.
Finding those problems during practice is not failure. Finding them at 9:40 on a Tuesday morning while someone is hanging 14 feet off the ground is. A rescue plan sitting in a binder may satisfy an auditor. It will not lower anybody off the side of a building.
Name the rescuer. Verify the fire department. Stage the equipment. Run the drill and put a clock on it. Because when someone asks whether you have a rescue plan, the better question is: how long does it take?
