Category: Fall Protection

Stand-Down for Safety

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From May 4 – 15, OSHA is promoting its second annual National Fall Prevention Stand-Down program. This program is to increase awareness of the fall hazards associated with construction work. Falls from heights continue to be one of the top causes of workplace fatalities. In 2013, 291 workers died from falls, with 25 percent of those occurring from a height of 10 feet or less.
The goal of the National Fall Prevention Stand-Down program is to raise awareness about fall hazards, and remind workers of the importance of using proper fall protection equipment and safe practices. Companies are encouraged to take time during this period to talk to employees about fall protection and prevention.
Businesses should schedule safety meetings to refresh workers’ knowledge of the proper use of fall protection equipment, climbing techniques, and ladder safety. This is also an excellent time to conduct inspections of fall protection PPE and create or review their respective rescue plans.
By ensuring proper steps are taken, workers can be protected. Roofers should be reminded to always:
• Wear a harness and stay connected
• Make sure the harness fits
• Use guardrails or lifelines
• Inspect all fall protection PPE before use
• Ensure all holes, openings, and skylights are guarded
When working from ladders, ensure workers:
• Choose the right ladder for the job
• Maintain three points of contact
• Secure the ladder
• Always face the ladder
For this year, the OSHA goal for the stand-down program is to have more than 20,000 companies participate, to reach an estimated 3 million workers, or roughly 40 percent of the affected workforce. Companies that take part in the stand-down are also eligible to receive a certificate of participation from OSHA.
Whether employees are working on roofs, scaffolds, or ladders, fall protection is essential. Falls can be prevented by planning, effective training, using proper equipment, and following safe work practices.
The more workers are aware of fall hazards the less likely they are to be injured. With commitment to fall prevention and participation in the stand-down program, it may be possible to remove fall injuries and deaths from the OSHA top-ten list.

Spotting Safety: Scaffolding Toprails

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Spotting-Safety-Scaffolding-Toprails-Photo-5.5.14-JA

This photo of a man on a scaffold, re-bricking a chimney, crossed my desk from a friend who questioned whether the man should be wearing a fall protection harness.

The truth is that, while a correctly used Personal Fall Arrest System (PFAS) is very effective, federal OSHA regulations don’t require it in this situation.

According to the Construction Scaffold regulations, bricklaying work from this type of scaffold requires either guardrails on all open sides of the scaffold or a PFAS. 1926.451(g)(1)(vi).

However, the toprail on this scaffold reaches only up to the man’s knees, so it doesn’t pass these tests for effective fall protection:

  • Handrails and toprails must provide an adequate handhold for employees to grab onto and keep themselves from falling. 1926.451(e)(4)(iii)
  • Toprails must be between 38 and 45 inches high. 1926.451(g)(4)(iii)

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.

All Spotting Safety Articles:

  • Excavation Cave-ins
  • Scaffolding Footing
  • Scaffolding Toprails
  • Earthmoving Equipment Training
  • Self Supporting Ladders
  • Forklift Counterweighting
  • Power Tool Trigger Guards

Spotting Safety: Self Supporting Ladders

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Spotting-Safety-Self-Supporting-Ladder-Blog-photo-4.7

Because they are so versatile, ladders can be the most incorrectly used tool at a worksite. Working with a ladder on a regular basis, you can become very familiar with the tool and learn how to get really creative with using it to reach some tough locations.

I’ve seen people “walking” while on a ladder: torquing their body to lift up the legs one side at a time to take steps down the wall, essentially using the ladder as if they are on stilts, instead of climbing off the ladder and repositioning it properly. I’ve also seen ladders on top of scaffolds and people standing on the top step without holding onto anything to reach that one last spot.

And in this photograph, this man is definitely putting himself in harm’s way by using the ladder incorrectly. But, because of what he may have gotten away with before, he may not understand the risks he’s taking or exactly what he’s doing wrong.

Ladders 1926.1053

First off OSHA states that ladders should only be used only in the ways they are designed — 1926.1053(b)(4) — and this self-supporting ladder is designed to have all four legs on the ground.

  • “The ability of a ladder to sustain the loads … shall be determined by applying or transmitting the requisite load to the ladder in a downward vertical direction” 1926.1053(a)(1)(i)
  • “Ladder rungs, cleats, and steps shall be parallel, level, and uniformly spaced when the ladder is in position for use.” 1926.1053(a)(2)

And if you do correctly use a ladder on an unstable and level surface, then OSHA requires it to be properly secured to prevent accidental displacement. 1926.1053(b)(6)

Fall Protection 1926.501

Beyond incorrectly using the ladder, because the worker has more than a six-foot fall to the ground, he needs to be protected with some type of fall protection: a guardrail, safety net or personal fall arrest system. 1926.501(b)(1)

Easy Solution

Instead of climbing into a harness and trying to find a good way to anchor the lifeline in, or hoping that the ladder doesn’t break from unusual stress, or one of the legs doesn’t slip, I would just put the roller on an extension pole and stay safely behind the railing to easily reach that last bit of unpainted wall.

All Spotting Safety Articles:

  • Excavation Cave-ins
  • Scaffolding Footing
  • Scaffolding Toprails
  • Earthmoving Equipment Training
  • Self Supporting Ladders
  • Forklift Counterweighting
  • Power Tool Trigger Guards

OSHA Interpretation: Employees Must Be Protected From All Impalement Hazards

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Impalement-blog-photo

This recent clarification on impalement hazards from OSHA on March 18, 2014 is a perfect example why all employers must know and take to heart the General Duty Clause (section 5(a)(1)).

The International Association of Bridge, Structural, Ornamental and Reinforcing Iron Workers asked OSHA if it recognized objects other than reinforcing steel as impalement hazards.

This is because, OSHA has only two construction hazards that mention impalement:

  1. 1926.701 (b) says about reinforcing steel: “All protruding reinforcing steel, onto and into which employees could fall, shall be guarded to eliminate the hazard of impalement.”
  2. 1926.25 (a) says about protruding nails: “During the course of construction, alteration, or repairs, form and scrap lumber with protruding nails, and all other debris, shall be kept cleared from work areas, passageways, and stairs, in and around buildings or other structures.”

But where specific regulations may fail to cover every situation, OSHA’s General Duty (or “Elastic Clause”) requires employers to keep the workplace free from known hazards that can cause serious harm or death. OSHA even pointed out a few examples: steel stakes and metal conduit.

OSHA referred to a similar response they provided in 1999, which states that it would consider its requirement for protective devices for rebar – cover or a wooden trough that can stand at least 250 pounds dropped from 10 feet to meet the 1926.701(b) requirement – to also apply to other sharp objects.

In short, OSHA has determined that employers are required to protect employees exposed to impalement, whether or not specific examples are contained in their standards, or simply implied by the General Duty Clause.

2014 Interpretations

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:

  • Construction’s Electrical Power Regulations Final Rule
  • Cranes and Derricks Near Power Lines
  • Recordkeeping for Multiple Business Establishments
  • How to Decide It’s a Workplace Injury
  • Safety Data Sheet (SDS) Reporting of Petroleum Streams
  • Combustible Dust Labeling Requirements in Hazard Communication Standard (HCS)
  • OSHA Definition of A HNOC Clarified for the HCS
  • General Duty Clause Covers All Impalement Hazards
  • Employer Responsible for Determining Qualified Rigger Status

OSHA Focuses on Communication Tower Worksites Citing Skyrocketing Death Rate

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Communication-Tower-blog-photo-3.14

Noting the alarming statistics in a Feb. 14, 2014 open letter to Communication Tower Employers that 2013 saw 13 workers killed at communication towers (more than the previous two years combined), and four more deaths to start 2014, OSHA is backing safety standard compliance with heightened enforcement.

They’ve also created a web page dedicated to communication tower safety.

Letter to Communication Tower Employers

Because of the rapid increase in communication tower work from upgrades to the cell tower infrastructure, OSHA is concerned about a trajectory of even more deaths and is working with industry organizations like the National Association of Tower Erectors to reverse the recent trend. OSHA has also contacted relevant employers to remind them of their responsibilities, providing the following action points:

  • Prior to initial assignment, adequately train newly hired employees on safe work practices and monitor them to ensure they are followed.
  • Provide appropriate fall protection and training on its effective use, and consistently supervise and enforce their use.
  • Select contractors based on the use of safety criteria and subcontractor oversight. Actively evaluate the contractor’s ability to provide safety, beyond providing “check the box” contracts.

OSHA told employers that, in addition to falls, workers have been injured or killed by: falling objects, equipment failure and collapsing towers. These are hazards that employees need to be protected against.

The organization warned that during inspections, OSHA will pay particular attention to contract oversight and identify the company performing work on the tower, the tower owner, carrier and other responsible parties.

Increased Attention on Communication Tower Worksites

In a memo on Nov. 8, 2013, regional administrators were instructed to tell the compliance officers to inspect all communication tower worksites when they are aware of them to ensure the owners are taking responsibility for workers’ safety.

OSHA considers the fall hazards obvious, well known and potentially fatal, so when workers are not using fall protection they should cite the owners for applicable willful fall protection and general duty clause violations.

Inspectors will also identify as far as possible all relevant parties up the contracting chain, including the name of the company performing the tower work, the tower owner, and carrier including the entity whose signal was being worked on.

Inspectors will contact OSHA’s national office as soon as possible when a communication tower incident occurs.

To gather better tracking data the following information will be gathered at each incident.

  • Victim(s) age and sex
  • Type of tower involved (i.e., monopole, lattice, guyed, etc.)
  • Number of employees present at the time of the incident
  • Description of incident and known causes
  • Description of the use of fall protection (Was fall protection provided? Was it provided but not used? Was it used, but did it fail? What was the height of the fall?)
  • Contract chain information
  • Was a base mounted drum hoist in use for personnel?
  • Weather conditions
  • Additional employee information (length of employment in industry, level of training, etc.)
  • Ambient Radio Frequency (Was ambient RF present? Were employees wearing any measuring or warning devices to protect against ambient RF?)

Fatal Facts

In an advisory PDF, OSHA described the following representative scenario of how workers are dying in communication tower incidents.

“A worker was climbing down a 400-foot telecommunications tower when he lost his footing. The ladder safety device or system (consisting of the carabineer, carrier rail, safety sleeve and body harness) he used failed to arrest his fall. The safety sleeve did not activate correctly to stop the worker’s fall, the chest D-ring ripped out of the body harness, and he plunged 90 feet to his death.”

The web page where you can download this PDF provides the applicable regulations and information on OSHA’s communication tower incident investigations.

Construction Industry 1926 Subpart M Fall Protection

  • 1926.501, Duty to have fall protection
  • 1926.502, Fall protection systems criteria and practices
  • 1926.503, Training Requirement

1926 Subpart E – Personal Protective and Life Saving Equipment

  • 1926.104 – Safety belts, lifelines, and lanyards
  • 1926.105 – Safety nets

General Industry

  • 1910.268 Telecommunications
  • 1910.132 Personal Protective Equipment General requirements

Q&A On Interpretations of Fall Protection for Steel Erection

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Steel Erection Blog Photo 2.6.14 JA

When it comes to OSHA’s fall protection requirements in steel erection, the final word can be found in the code at 1926.760. But good luck deciphering all the jargon with references to appendixes and other regulations.

In fact our Safety Manuals are partly an interpretation of this dense legalese into a personalized policy, combined with best practices and explanations of the tricky parts with important charts and forms to help ensure compliance.

But in the application of these rules, there are situations that arise where OSHA has to explain how their regulations work in the real world. And since the latest version of this final rule was published on January 18, 2001, OSHA has issued several interpretations from private businesses asking questions about problems they have come across.

Following is a summary of these interpretations in a Question and Answer format:

Q. How far from the unprotected edge of a surface that is 15 ft. above the lower level does a worker need fall protection?

A. There is no safe distance from an unprotected edge that renders fall protection unnecessary.

Q. Is moving from one point to another on a concrete wall to make initial connections of structural steel considered connecting work?

A. Because a connector is defined as an employee who working with hoisting equipment is placing and connecting structural members and their parts, they are considered a connector and at heights up to 15 ft. do not have to need fall protection, and at heights of over 15 to 30 ft. must be provided with a Personal Fall Arrest System (PFAS) and wear equipment necessary to be tied off (or be provided with another means of fall protection), and at heights above 30 ft. be protected by fall protection.

Q. Can an employer require employees to use fall protection at less than 15 ft.?

A. An employer’s company policy can set stricter standards than the minimum requirements in OSHA, such as requiring employees to use a PFAS at 6 ft.

Q. Can employees install a curtain wall in a Controlled Decking Zone (CDZ)?

A. Only employees who are connectors – because they are installing metal decking – are allowed in a Controlled Decking Zone (CDZ) and are exempt from the general steel erection fall protection threshold of 15 ft. high in favor of the connector threshold of 30 ft. or two stories.

Because installing a curtain wall doesn’t  meet the metal decking definition, those employees are not allowed in the CDZ and must have fall protection at 15 ft.

Q. Can a guardrail system be used instead of a safety cable to meet the requirement for a perimeter safety cable?

A. OSHA regulations state that perimeter safety cables must be installed at the final interior and exterior perimeters of floors on multi-story structures as soon as the metal decking is installed. OSHA believes this system has several advantages, but other guardrail systems, such as wooden guardrails suffice as long as the following conditions are met:

  1. Workers installing the system are protected from falls
  2. System meets guardrail requirements
  3. It is durable to the conditions, such as weather and other steel erection work
  4. It doesn’t create a greater hazard during initial steel erection.

Q. Do perimeter columns have to extend beyond the roof level when the building has topped out, to meet the requirement of extending at least 48 inches above the finished floor?

 A. The requirement to extend 48 inches above the finished floor is to permit installation of perimeter safety cables prior to erecting the next tier, so when the final tier is erected that requirement doesn’t exist because it applies to floors and not roofs. Still fall protection is required on the roof level at fall over 15 ft.

Q. Why is the steel erection fall protection threshold 15 ft. where the general construction threshold 6 ft.?

A. The special circumstances of steel erection can make conventional fall protection very difficult to deploy below 15 ft. The work usually starts at the top level, meaning anchor points above foot level are often limited or unavailable, and because of the nature of the structure, the available fall arrest distance is usually 15 ft.

Q. Is a CDZ control line a rigid structure? What can constitute a control line?

A. Control lines, that define the CDZ, are intended mainly as a visual warning. They can consist of ropes, wires, tapes or equivalent materials and must be rigged so it doesn’t sag less than 39 inches (1 m) from the floor and isn’t any higher than 45 inches from the floor. A non-mandatory Appendix advises that the material have a minimum breaking strength of 200 pounds, but this is to ensure it can withstand the conditions and not for direct physical contact like a warning line, which is erected 15 ft. from an edge and must have a minimum strength of 500 pounds.

Control lines may be cables, ropes, wires or tapes such as plastic tape. They do not have to be a horizontal cable, but can be a perimeter wall, guardrail system, or even a restraint system rigged so non-leading edge workers can’t access the area.

OSHA has interpreted the rule to say that high-visibility construction cones are not control lines because the gaps between the cones do not control access.

Q. Can an entire floor be designated a CDZ by limiting access to the entire floor, eliminating the need to mark the perimeter of the entire floor with control lines?

A. The regulation states a CDZ must have clearly marked boundaries and be 90 ft. by 90 ft. or less to ensure non connectors do not ignore the CDZ to do non-decking work. But because limiting access to an entire floor by controlling access points with a sign restricting access to CDZ workers and installing conventional fall protection as soon as each 90 ft. x 90 ft. section is completed, designating the entire floor a CDZ would be considered a de minimis violation (having no direct or immediate relationship to safety or health) because it would be a more effective way to decrease the likelihood other workers will enter the CDZ than limiting the size of the CDZ.

What Regulation Do You Find Confusing?

Practically every OSHA Regulation has a series of interpretations that at least one person needed clarification on. If there is a regulation that you want me to look at their interpretations, please leave a comment and check this space on a regular basis.

Other Question & Answer articles:

  • Emergency Shower Installation Requirements
  • Lockout Procedures At Shift Change
  • OSHA Interpretations of Steel Erection Fall Protection Regulations

Download Whitepaper of the Top 10 OSHA Violations of 2013

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Top OSHA Violations 2013 Whitepaper

Are you confident that your business will survive an OSHA inspection without falling for the same violations that account for 45% more citations for the top 10 in 2013?

All it takes for people to start asking questions is a workplace injury, or a complaint, or to do business in a high risk occupation.

The current 10 Most Dangerous Jobs by fatal injury rate (number of fatal occupational injuries per 100,000 full-time equivalent workers) are:

  1. Logging 127.8
  2. Fishers and related fishing workers 117.0
  3. Aircraft pilots and flight engineers 53.4
  4. Roofers 40.5
  5. Structural iron and steel workers 37.0
  6. Refuse and recyclable material collectors 27.1
  7. Electrical power-line installers and repairers 23.0
  8. Driver/sales workers and truck drivers 22.1
  9. Farmers, ranchers, and other agricultural 21.3
  10. Construction laborers 17.4

The PDF Whitepaper is a collection of the following articles that describes each regulation that made the top 10 for last year, and provides information about how to better avoid injury and follow the letter of the law.

Top 10 OSHA Violations for 2013 Reveal Increase in Citations

Released Figures for 2012 Workplace Fatalities Show Fewer Deaths Except Construction

1. Fall Protection (1926.501)

2. Hazard Communication (1910.1200)

3. Scaffolding (1926.451)

4. Respiratory Protection (1910.134)

5. Electrical, Wiring (1910.305)

6. Powered Industrial Trucks (1910.178)

7. Ladders (1926.1053)

8. Lockout / Tagout (1910.147)

9. Electrical, General (1910.303)

10. Machine Guarding (1910.212)

Library Shut Down by OSHA

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A public library in Orange, New Jersey was shut down by the States Department of Occupational Safety and Health last month due to numerous safety issues.

“It was a threat and a safety issue to patrons and workers in there,” Orange Mayor Dwayne Warren told the Jersey Journal.

The inspection results were not immediately available, but according to Warren the issues with the library include roofing problems, electrical issues with live wires, boiler and heating system trouble among other deficiencies.

The mayor estimates that the town will need to spend more than $1 million to repair the library.

The inspection of the library was spurred after council president Tency Eason fell in the library and alerted state inspectors to possible safety violations.

Eason stated her fall occurred when she “turned around to get up” but faltered due to the rail missing, falling instead into a glass cabinet.

The closure is the second of the library in the past five years. The first occurred in 2012, when the doors on the institution were closed for two months because of issues with lead paint and asbestos.

Safety Services Company Offers Poster to Raise Workplace Violence Awareness

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In order to raise awareness about workplace violence Safety Services Company is offering a free downloadable poster entitled zero tolerance.

“Violence in the workplace is one of the leading causes of death, yet it is entirely preventable,” said Safety Services Company Spokesman Michael Rich. “It is our hope that this poster will help spread the message about workplace violence.”

In 2011, the most recent year for which data is available, 780 workers lost their lives to workplace violence. The number represents nearly 20 percent of all workplace fatalities.

In addition to those who lose their lives nearly 2 million more Americans report being a victim of workplace violence each year.

Safety Services Company is a provider of occupational health and safety training and compliance materials. One of the company’s top product lines is “Do-it-Yourself” safety training programs designed to help companies meet OSHA requirements.

Yet despite violence being one of the top causes of deaths and injuries, Rich said that doesn’t translate into sales.

“Many companies only focus on the training that is required by law and unfortunately workplace violence doesn’t fall into that category,” Rich said.

The Zero Tolerance” poster Rich’s company is offering attempts to spread the message of how impactful workplace violence is on the workplace through a series of statistics.

To download the poster click here.

In addition to offering the poster, Rich said his company is offering 25% off their workplace violence training program all month.

It is time we recognize workplace violence as a true occupational hazard,” Rich said. “Hopefully by offering this poster and a discount on training we can help prevent the spread of violence in the workplace.”

For more information of workplace violence prevention training call 877-201-8923.

OSHA extends temporary fall protection measures a third time

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The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA announced Dec. 12 it will extend for three months its temporary enforcement measures in residential construction.

The temporary enforcement measures instruct OSHA inspectors who find residential roofers not complying with the new residential fall protection directive, but following the old directive (Plain Language Revision of OSHA Instruction STD 3.1, Interim Fall Protection Compliance Guidelines for Residential Construction, STD 03-00-001), to do the following:

  • Allow an additional good faith reduction in penalties of up to 10% for employers engaged in residential construction. In addition to the safety and health management system good faith determination in Chapter 6 of the Field Operations Manual, the Area Director shall consider examples of attempting to comply in good faith to include: requesting and scheduling an On-site Consultation visit, ordering protective fall equipment for its employees, or performing a documented evaluation of feasible means of abatement. This good faith reduction does not apply in cases of a fatality, catastrophe, or serious injury resulting from a fall during residential construction activities.
  • Allow residential construction employers at least 30 days to correct fall protection violations identified under the new residential fall protection directive. During that time, if such employers are not in compliance at that site or another site, no additional citations or repeat citations shall be issued. This policy does not apply in cases of a fatality, catastrophe, or serious injury resulting from a fall during residential construction activities.

OSHA put these temporary enforcement measures in place Sept. 22, 2011 with an expiration date of March 15, 2012. The government agency then extended the measures to expire Sep. 15, 2012 and the extended the measures to expire Dec. 15, 2012.

The new extension will keep the temporary measures in place until March 15, 2013.

The new regulations, 29 CFR 1926.501(b)(13), require all workers engaged in residential construction over six (6) feet above the ground level are to be protected by conventional fall protection. For roofers, the 25 foot, ground to- eave height threshold no longer applies, nor do slide guards as an acceptable form of fall protection, regardless of the roof pitch or height of the roof eave.

These new requirements replaced the Interim Fall Protection Compliance Guidelines for Residential Construction, Standard 03-00- 001 were in effect since 1995 and allowed residential builders to bypass fall protection requirements.

To help companies meet the fall protection imitative Safety Services Company offers affordable “Do-It-Yourself” fall protection training program. For more information call 877-201-8923.