I currently have an indoor safety shower, and want an outdoor safety shower just outside the building, does the supply need to be sized in case both showers are used at once?
OSHA’s applicable regulation is 1910.151(c): “Where the eyes or body of any person may be exposed to injurious corrosive materials, suitable facilities for quick drenching or flushing of the eyes and body shall be provided within the work area for immediate emergency use.”
This is a performance based regulation because it states what the safety shower must accomplish to meet the regulation. This is different from a prescription based regulation that defines an action or a limit, like the occupational noise exposure limit of an 85 decibel limit over eight hours. A prescriptive regulation is the result of a threshold being tested enough times to ensure safety within the stated limit.
The key word to the regulations is “suitable”, meaning the emergency shower has to work good enough considering the hazards at that particular worksite. OSHA explains its stance in an interpretation of the regulation:
“29 CFR 1910.151(c) does not provide specific instruction regarding the installation and operation of emergency eyewash and shower equipment. Therefore, it is the employer’s responsibility to assess the particular conditions related to the eyewash/shower unit…to ensure that the eyewash/shower unit provides suitable protection against caustic chemicals/materials to which employees may be exposed.”
Over the years OSHA has published several interpretations on this regulation, answering questions submitted to them.
In them OSHA refers employers to ANSI Z358.1. The American National Standards Institute (ANSI) is a private organization that develops voluntary standards. Unlike others, OSHA did not adopt this standard, but refers employers to it as a guide with detailed information for installing and operating emergency eyewash and shower equipment. But that means any citation will be the result of not having a suitable emergency shower for the workplace condition.
The 2015 NFPA 70E standard for workplace electrical safety is now making the rounds, and depending on when the authority having jurisdiction (AHJ) you report to, may be adopted at any time in the next three years.
The foreword of the new standard lists 20 major changes. One change introduces the concept of “contact release” in the emergency response training. Employees exposed to shock hazards must be trained, every year, how to safely break a connection an electrocution victim may have with exposed parts. A person may freeze onto the conductor when the electricity coursing through the body causes muscles to contract, and if the current is strong anyone else who directly touches that person may be electrocuted as well.
Contact Release Training
Everybody needs to know to quickly turn off the power and safely rescue the victim without direct contact. Touching an electrocuted person may cause the second person to be shocked.
The first option is to turn off the power source at the disconnect switch, circuit breaker, power cord. Call for 911 and then have trained employees provide first aid, CPR, or AED assistance. Because sometimes the power source may be unknown or the disconnect switch can’t be located, every employee should know where they are in the case of an emergency.
The second option is forcibly removing the victim in a safe way if the power can’t be disconnected quickly enough to save the victim from breathing or heartbeat paralysis, and flesh and internal organ damage. This may mean dislodging, hitting or prying the victim with a nonconductive material while remaining in a safe location.
First examine the scene looking for other hazards especially stored energy, fire and hot surfaces.
Ideally your hands and feed should be dry, you are wearing protective equipment and be standing on a clean dry non-conductive surface like a rubber blanket or other insulating material.
Then knock, pry, or drag the victim from the conductor with nonconductive material which can be a dry wooden board, nonmetallic conduit, insulated tools, hot sticks, shotgun sticks or some nonconductive rope or an insulated extension cord. Loop the cord around their body or the grasping arm and pull strong enough to break their grip.
The victim needs to be cared for until qualified emergency response personnel arrive. Check for breathing and pulse and if necessary administer CPR or use an AED up to your level of training. Once CPR has been started, continue until emergency personnel arrive.
Stay with the victim until help arrives and conduct additional first aid, according to training. If conscious, keep the victim still, warm and comfortable, they could suffer from insufficient blood circulation and go into physiological shock. They could also suffer heartbeat irregularities or a heart attack up to several hours later even if the shock isn’t enough to immediately disrupt the heartbeat.
Other Safety School articles that examine the more academic concepts of occupational safety:
According to the DOL, the failure of workers to wear hard hats is one of the most commonly cited OSHA violations. Employers need to be steadfast in their enforcement of safety rules to protect their workers and themselves. A recent incident certainly reinforces the message that hard hats matter.
Earlier this month a worker delivering drywall to a construction site was killed when he was struck in the head by a tape measure that had fallen 50 stories. According to witnesses, the victim wasn’t wearing his hard hat at the time, having left it in his vehicle.
The instrument, which fell nearly 500 feet, was travelling at about 140 mph when it struck a piece of construction metal about 10 feet above ground. The tape measure then ricocheted off the metal and struck the victim, who had been leaning into a car window to talk to someone and had just pulled his head out when he was struck. The worker was rushed to the hospital, but died later of cardiac arrest.
Although the OSHA standards do not specifically identify occupations or applications where hard hats are required, 29 CFR 1910.135 states, “Each affected employee shall wear protective helmets when working in areas where there is a potential for injury to the head from falling objects.
This fatality is being investigated and among the questions that will be asked are:
Was a hard hat requirement posted at the job site?
What were the contractors and suppliers PPE policies?
Were the policies enforced?
Have either the contractor or supplier been cited for PPE violations before?
Employees occasionally may have issues with wearing hard hats, particularly when the weather gets hot or cold. Some of these issues can be remedied by providing cooling or winter liners, but it’s important to use only approved liners to ensure they don’t compromise the protective characteristics of the hat. By being diligent with their PPE enforcement program, companies can avoid injuries, OSHA violations, and prove that hard hats matter.
OSHA recently reported that more than 4,000 workers died from workplace accidents last year, and nearly three million others were injured, or became ill, due to work-related actions. This reinforces why accident investigation needs to be an integral part of any company’s health and safety program.
Accident investigation is critical, not only because of the legal reporting requirements, but also to correct any conditions or procedures in order to prevent a recurrence of the problem.
The National Safety Council provides the following definitions:
• ACCIDENT – An undesired event that results in personal injury or property damage.
• INCIDENT – An unplanned, undesired event that adversely affects completion of a task.
• NEAR-MISS – Incidents where no property was damaged and no personal injury sustained. These should be considered warning signs.
Although OSHA doesn’t have specific standards regarding accident investigation, 29 CFR 1960.29 suggests that all accidents should be investigated, including those involving property damage only. The level of the investigation should be based on the seriousness of the event.
KEYS FOR INVESTIGATION
An effective accident investigation procedure should include the following components:
Who should investigate?
Companies should establish an investigation team to investigate any occurrence. The team should include the Safety Officer or a Safety Committee member, the supervisor in charge of the area where the accident occurred, employees knowledgeable with the work that was being performed, and a union representative, if applicable.
Safety personnel and supervisors should be trained on the basics of accident investigation, and each of these personnel should have a prepared investigation plan.
Accident Investigation training should provide the team members with information on how to:
• Survey the scene (assess the condition of the injured, determine and eliminate any continuing hazards)
• Get help for the injured (contact emergency-response personnel or provide first aid)
• Secure the scene (protect the evidence)
• Collect evidence as soon as possible (document the scene; interview witnesses; review procedures, as well as equipment information and condition)
• Analyze data (determine sequence of events)
• Determine surface and root causes
• Prepare an accident report with the details of the accident (date, time, location, a description of operations, photographs, interviews of witnesses), and recommended corrective actions needed to reduce or eliminate the hazard.
• Follow up (eliminate hazards); accident reports are not closed until corrective actions are taken
Accidents are usually caused by a number of factors, all of which should be examined during the investigation. They are:
It’s important to remember that the sole purpose of accident investigation is to determine and eliminate the cause of an accident, not to assign blame. Disciplinary action should be handled separately from accident investigations.
Too often companies are told that they need to have a custom safety manual to protect them from OSHA violations, and while that’s true, understanding how that works is just as informative to a safely run company as having all the right words and regulations in a policy.
During an inspection, the inspector will ask for the written safety policy and all documentation of training, inspections and discipline. This documentation becomes important after the inspection, when a company can challenge or attempt to mitigate any possible penalties.
In legal terms you have “negating defenses” and “affirmative defenses” to argue any possible citations. The negating defense is simply arguing that that an allegation wasn’t a violation or it didn’t happen. More interestingly there is an affirmative defense, which admits the violation occurred but provides a justification. In a criminal case, “self-defense” is an affirmative defense.
So if an employee is spotted performing an unsafe action and a violation has been assessed, the inspector can look at the safety manual and training documents and ask:
Is there is a system in place?
Are employees trained in it?
Do you inspect the worksite and enforce the policy?
As an example, if the inspector cites an employer for a worker not wearing a hard hat, the company can challenge it with a policy stating that all employees must wear hard hats, evidence that employees are trained to know it’s a requirement, and evidence of inspections to enforce the policy with discipline when an employee doesn’t follow it.
Just having the policy isn’t enough; it needs to be backed up with ongoing application and training.
Safety Key Performance Indicators (KPI)
To go a step further, another way to demonstrate a commitment to safety in your policy is to track it.
Every company has its Key Performance Indicators (KPI). An easy way to know if a company prioritizes safety is to see if they track any safety KPIs such as:
Days since last incident
Number of regulatory violations
Annual change in percentage of training compliance
Annual change in the Total Case Incidence Rate (TCIR)
A company’s safety performance is the same as any other metric. Have you heard the saying,” what gets tracked is what gets done”?
When you track these safety KPIs, this information can be used in annual safety policy reviews of your manual. Use this information to see if there are incidents or close calls being repeated, or if the current manual and policies cause different hazards not planned for, or if there is something that changed in the last year that needs its own safe work practices.
Other Safety School articles that examine the more academic concepts of occupational safety:
Fire safety is important business; losses due to workplace fires total nearly $3 billion each year and take more than 350 lives, according to National Safety Council figures.
There is a long and tragic history of workplace fires in this country. One of the most notable was the fire at the Triangle Shirtwaist Factory in New York City in 1911 in which nearly 150 women and young girls died because of locked fire exits and inadequate fire extinguishing systems.
History has repeated itself recently in the fire in Hamlet, North Carolina, where 25 workers died in a fire at a poultry processing plant. It appears that here, too, there were problems with fire exits and extinguishing systems.
To protect employees from the perils of workplace fires this article will examine the different classes of fires and the type of extinguisher to use on those fires.
1. Class A
Class A or Ordinary Combustible fires involve blazes using fuels such as wood, paper, plastic, rubber, and cloth. The fire extinguisher symbol for this class of fire is a green triangle with the letter A in the center. Also a wood pile is used to symbolize Class “A” fires.
2. Class B
Class B fires involve flammable and combustible liquids or gases. This includes any hydrocarbon- or alcohol-based liquids that will support combustion. A red square with a capital “B” and a pictogram with a fuel can and fire are commonly used to symbolize Class “B” fires.
Older extinguishers were generally B-C types and had Carbon Dioxide in them. Carbon Dioxide is an inert gas.
3. Class C
A class C fire is one that involves energized electrical equipment. A BLUE CIRCLE with a capital “C” and a pictogram with an electrical cord and plug, and a flaming receptacle are commonly used to symbolize Class “C” fires. When the fuel source is de-energized, it can then be classified as “A”, “B”, or “D”.
4. Class D
A class D fire is one that involves combustible metals. Examples of these types of metals are: zirconium, titanium, potassium, and magnesium. A YELLOW STAR with a capital “D” (no pictogram) is commonly used to symbolize Class “D” fires. Within this fire classification, the extinguishing agent may vary, and it must be compatible with the anticipated use.
5. Class K
Class K is for fires in unsaturated cooking oils in well insulated cooking appliances in commercial kitchens. Class “K” has no related symbol as yet, but it can be identified by a pictogram of a flame in a frying pan.
These extinguishers utilize a “misting wand” to deliver the extinguishing agent in a fine mist onto the surface of the hot cooking oil. These extinguishers are usually filled with potassium acetate diluted with water. Dry types have potassium bicarbonate.
For anyone standing at the bottom of a trench and looking up at the sheer face of a column of freshly exposed dirt it becomes clear how important it is to establish proper protections considering the consequences of a cave-in.
And it is apparent that in both photos, neither employee is adequately protected. But let’s look at how cave-ins occur and why each worker is in violation.
Physics of a Cave-in
The stress of a cubic foot column of soil is 100 lbs. per square foot (psf). So the vertical load of that one-foot-by-one-foot column of soil five feet down is 500 psf. When an excavation is cut, the soil in the wall begins to move, however slowly, into the excavation. Cracks will eventually develop away from the excavation’s edge, and the weight of the soil between the excavation and the crack is no longer carried by the soil behind the crack. This causes the lower part of the excavation wall to fail first, the upper part of the wall then falls, and a third cave-in can quickly occur.
Each cave-in can be the one that buries an unprotected worker at the bottom of the trench.
The worker in the first image is more than five feet deep and there is no shoring, sloping, or shielding. Employees who work in an excavation five or more feet deep and not in solid rock must be adequately protected from cave-ins. 1926.652(a)(1)
He also doesn’t appear to have a harness with a lifeline to get him out, as required when entering a deep and confined footing excavation. 1926.651(g)(2)(ii)
The worker also needs to be protected from loose rock or soil that can fall or roll into the excavation. This can be done by removing the loose material piled up at the edge of the excavation and keeping it at least two feet from the edge of the excavation, or using retaining devices or equipment to keep back the soil. 1926.651(j)(2)
So much seems to be right in the second photo, where trench boxes are constructed to shield workers inside them from a collapsing excavation. And everything apparently complies with the shielding regulations: the excavation isn’t two feet below the bottom of the box, the top of the box is higher than the excavation, and it looks to be able to withstand subjected loads of an excavation without lateral movement. 1926.652(g)
But once the worker leaves the trench box, he is exposed to the hazards of the trench collapsing. The worker needs to stay inside the trenchbox to complete the task, and if that is not possible, the employer needs to extend the shielding.
It’s up to the employer to provide a safe work environment and ensure that employees follow safety procedures, but it’s also up to the employee to follow safety regulations and the employer’s safe work procedures. This is outlined in OSHA’s General Duty Clause. Section 5 Duties(a)(b)
Nail guns are used every day on construction jobs. They are effective tools, but also cause tens of thousands of serious injuries each year. Nail gun safety is critical because more injuries to construction workers are caused by nail guns than any other tool. These injuries are often not reported or treated properly.
SEVEN MAIN FACTORS CONTRIBUTE TO NAIL GUN INJURIES:
Accidental nail discharge from double fire
Accidental nail discharge from bumping the safety contact with the trigger depressed
Nail penetrating through lumber
Nail ricocheting after contacting a defect or foreign object
Missing the work piece
Awkward position nailing
Bypassing safety mechanisms
AIR PRESSURE: Pneumatic nail guns can operate at an air pressure of 100 P.S.I., defective hoses and connectors can result in hose whipping or even accidental firing.
NOISE: Nail guns produce short but loud “impulse” noise peaks. These loud short bursts can contribute to hearing loss
PHYSICAL DISORDERS: Nail guns can weigh up to 8 pounds. Holding that weight for long periods can cause soreness or tenderness in the fingers, wrist, or forearm.
PROTECT YOURSELF FROM INJURY
Use a full sequential trigger gun: Research has shown that the risk of injury is twice as high when using a multi-shot contact trigger as opposed to a single-shot sequential trigger nailer.
Be fully trained: Make sure that nail gun tool labels and instructions are understood and followed. Workers should Understand:
o How nail guns work and how triggers differ.
o How to operate the air compressor
o How to fire the nail gun
o How to hold lumber during placement work
o How to recognize and approach ricochet-prone work surfaces
o How to handle awkward position work
Establish nail gun work procedures
o Avoid awkward work positions
o Use a hammer if you can’t reach the work while holding the nailer or for work at face or head height
o Position ladders as close to your work as possible. Don’t over reach.
o Check the tool and air source before use
o Check the workpiece for knots or anything else that could cause a ricochet
o Keep your hands at least a foot away from the nailing point.
o Keep the gun pointed away from your body and from co-workers.
o Set up operations so that others are not in the line of fire from nail guns
Disconnect the compressed air when:
o Leaving a nailer unattended
o Climbing up and down a ladder or stairs
o Passing the nail gun
o Clearing jams
o Performing any maintenance on the gun
Use the right Personal Protective Equipment (PPE): Safety shoes, Hard hats, High Impact eye protection ( safety glasses or goggles), Hearing protection (earplugs or earmuffs)
Report all injuries and close calls: Reporting helps ensure that employees get medical attention. It also helps to identify unrecognized job site risks that could lead to additional injuries.
Get first aid and medical treatment: 25% of hand injuries involve bone damage. Nail strip glue, plastic, clothing can be left in an injury and lead to infection.
Barbs on nails can also cause secondary injuries if the nail is removed incorrectly.
There are times when a PFAS doesn’t make sense, such as not having a good place to anchor the lifeline. But, when working at six feet or more above the ground in construction, an effective form of fall protection or supported scaffolding training is always needed. This can be accomplished with scaffold guardrails that are high and strong enough to save an employee who loses his balance.
Because no proximity alarm or insulating link/device has been developed that meets a Nationally Recognized Testing Laboratory (NRTL) standard for cranes or derricks working near power lines – a requirement of the current standard – OSHA is making a temporary enforcement policy that has been in effect from July 26, 2012 to November 8, 2013, permanent until it changes the rule to address the unavailability of the required equipment.
This enforcement policy is effective April 30, 2014 and will continue until further notice.
The policy states that a crane or derrick may use a proximity alarm and an insulating link/device along with another measure.
Additional measures include:
A dedicated spotter that is positioned to gauge clearance distance with visual aids like line of site landmarks and can give timely information to the operator through direct communication.
Range control warning device
A Range of movement limiting device that prevents encroachment
An elevated warning line visible to the operator
Also an employer may use an insulating link/device manufactured on any date with additional protections such as adequately insulated gloves. The current regulation as it is written puts the cut-off date of non NRTL devices at November 8, 2011.
As they start the rulemaking policy for a permanent solution, OSHA will follow this temporary policy for:
Proximity alarm use under 1926.1407-Power line safety (up to 350 kV) assembly and disassembly
Proximity alarm and insulating link use under 1926.1408 power line safety (up to 350 kV) equipment operations
Proximity alarm and insulating link use under 1926.1409 power line safety (over 350 kV) through 1926.1407 and 1926.1408
Insulating link/device use under 1926.1410 power line safety (all voltages) equipment operations closer than the Table A zone.
When the Cranes and Derricks in Construction regulation went into effect on November 8, 2011, OSHA expected there to eventually be proximity alarm or insulating link devices that pass NRTL requirements, but because that did not happen OSHA created the temporary policy on July 2012 to last until November 8, 2013. But that deadline has come and went, so the current interpretation will now be practiced indefinitely while OSHA starts the process of changing the current rule.
In addition to creating new and updating current regulations, OSHA publishes interpretations and answers to questions about existing rules. Here is what has been released in 2014: