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Rescue Requirements for Floating Roof Tank Inspections

According to section 1910.146 of the Code of Federal Regulations, paragraph (d) Permit-required confined space program, requires each employer with a confined space to develop and implement procedures for rescuing entrants from permit spaces, provide necessary emergency services to rescued employees, and provide necessary rescue and emergency equipment. Paragraph (k) of this section, Rescue and emergency services, further requires a mechanical retrieval system or method whenever an entrant enters a permit required confined space five or more feet deep.

The District considers all floating roof storage tanks containing crude oil or other petroleum products to be permit-required confined spaces. The District also considers the provision of rescue and emergency services essential to access for the purpose of performing inspections on floating roof tanks.

The purpose of this bulletin is to ensure that all tank operators are aware of these requirements and to make it clear that tank operators must provide rescue personnel and equipment during the entire period that District personnel are in these confined spaces. In some cases in the past, local fire departments have been relied upon for these services. If this arrangement will be used in the future it will be necessary for the Fire Department personnel to be fully dedicated to the tank inspection and not available to respond to any other events during the inspection period. Further, Fire Department personnel must have demonstrated proficiency in rescue operations from external floating roof tanks as required by section (k) of 1910.146. Properly trained and equipped in-house personnel or contract personnel provided by the host is an acceptable alternative.

If you have any questions about these requirements or wish to discuss them, please contact the following individual in the Compliance Enforcement Department

Dave Baldwin, Supervising Air Quality Inspector

34946 Flyover Court
Bakersfield CA 93308
(661) 392-5500