CalOSHA and Emergency Escape Breathing Apparatus

Over the past year, CalOSHA has been educating the ammonia refrigeration industry regarding their expectation for complying with the Emergency Action Plan (EAP) requirement for “procedures to be followed by employees performing rescue or medical duties” (Title 8 CCR §3220(b)(4)). CalOSHA has made it clear that they expect ammonia refrigeration facilities to have rescue capabilities, should such a situation arise. Clyde Trombettas,  Statewide Manager and Policy Advisor, communicated OSHA’s position at the 2018 Central Valley Chemical Safety Day in Turlock, CA. At the event, Clyde explained that in order to comply with the “rescue duties” requirement in the EAP regulation, employers must do one of the following:

• Response Time – Demonstrate that first responder response time would be < 5 min.
• SCBA – Ensure that self-contained breathing apparatuses (SCBAs) are available to rescue employees if needed. Select facility employees would need to be trained in proper SCBA use, be fit tested, and be medically evaluated per Title 8 CCR §5144. For a typical ammonia refrigeration system, SCBAs should be readily available outside the machinery room and other areas where employees are likely to be exposed to ammonia.
• EEBA – As an alternative to SCBAs, facilities could purchase emergency escape breathing apparatuses (EEBAs) and place them in strategic locations where ammonia exposure is likely (e.g. machinery room). EEBAs, commonly referred to as “escape hoods”, are intended to provide an opportunity for a person to “self rescue”, but must not be used to perform a rescue of another person. Since EEBAs are not classified as a “respirator”, the training and administrative requirements for this approach are notably less than for using SCBAs.

Use this information as an opportunity to review your facility layout and emergency plans. Be prepared for an OSHA visit and have an explanation ready for the posture that your facility takes toward emergency response and rescue situations.

One response to “CalOSHA and Emergency Escape Breathing Apparatus”

1. Mike Doering, CIH SSE, says:

   February 28, 2023 at 2:46 pm

   Very good documentation. However, I do not agree with the 5 minute response time. Might want to add at least 10 minutes to response time in order to get actual rescue time. Most likely the victim dies waiting for the fire dept. Better to install self rescue EEBA on the back wall.

   Mike Doering SSE DOSH PSM

   Reply