Now that spring is here and the weather is warming, it’s time to get training into full swing. No, we’re not talking about baseball; we’re talking about safety training. If your business has been in winter hibernation, now is the time to get your employees in shape for the regular season.
It’s time to review your training records and see if you have any equipment operators that are due for re-certification or need to be trained on new equipment. This is a good time to schedule refresher training on the fundamentals of general safe work practices such as the use of PPE, material handling, fire prevention, and electrical safety. If there have been any changes in the types of protective equipment workers will use they will need training on them.
If your work includes using ladders or scaffolds, retrain everyone on safe climbing procedures and fall protection. Verify that employees who will be responsible for assembling, moving, and disassembling scaffolds have retained the knowledge necessary to perform that work safely.
You should also review your list first aid providers to make sure it’s current, and determine if you want to increase the number of certified personnel. Since certification or refresher, training for your responders will likely require scheduling the training with an approved organization (i.e. the Red Cross or St. John Ambulance), now is the time to contact them and either schedule a company training session or enroll employees into existing classes.
While we’re on the subject of first aid, you should take this opportunity to inspect, inventory, and replenish your first aid kits. Make sure you have enough kits of the right size for the upcoming jobs, and that all of the kit contents are there and haven’t expired or been damaged.
Scheduling training now, before it gets busy, could save you a lot of time or money later. It’s going to be a long season, make sure your team is ready to go the distance and is bringing their “A” game.
Two scaffold safety organizations have developed a concise scaffolding code of safe practices that would beneficial for employers to post at worksites, follow and instill in all applicable workers.
With enough content to fill a small poster, the code covers general guidelines as well as erection, use, and dismantling. Download it here now, and put it to use.
The rules don’t go into all systems so any manufacturer guidelines also need to be followed. Instead this is a way to reinforce basic rules that should be common sense, but can easily be broken without proper education and constant reminders.
In the general guidelines is a step to survey and correct job site hazards looking for: untamped earth fills, ditches, debris, high tension wires, and unguarded openings. In the erection section is a reminder that free standing scaffold towers need to be restrained from tipping if they vertically exceed four times the base, with a 3 to 1 ratio for other agencies such as CAL/OSHA. Dismantling guidelines remind workers to be mindful that the scaffolding isn’t made unsafe in the process, visually check planks, not accumulate excess equipment on each level, or remove ties until the level above is dismantled…
An Industrial Hygienist (IH) is a safety expert whose three main jobs are to anticipate hazards, evaluate the worksite for risks, and work out the best way to control them. Do you need an IH at your worksite, and if you do, are they operating ethically according to these guiding principles?
1. Follow Recognized Scientific Principles.
Industrial Hygienists shall practice their profession following recognized scientific principles with the realization that the lives, health, and well-being of people may depend upon their professional judgment and that they are obligated to protect the health and well-being of people.
Base conclusions on principles and practices that protect employees health and safety.
Do not deceive, falsify, misrepresent, or leave out facts.
2. Provide Guidance Based on Facts.
Industrial Hygienists shall counsel affected parties factually regarding potential health risks and precautions necessary to avoid adverse health effects.
Gather facts on potential hazards from trusted sources
Review the known information
Take the necessary steps to communicate the risks to affected parties: management, clients, employees, subcontractors, and other employers at the worksite
3. Keep Employee and Company Information Confidential
Industrial Hygienists shall keep confidential personal and business information obtained during the exercise of industrial hygiene activities, except when required by law or overriding health and safety considerations.
Relate necessary information to protect worker health and safety
Notify employer, client or appropriate authority when overruled judgment may endanger someone’s health and safety.
Obtain the information owner’s unambiguous authorization before releasing confidential personal or business information, except where a law or regulation requires its release.
4. Prevent Conflicts of Interest
Industrial Hygienists shall avoid circumstances where a compromise of professional judgment or conflict of interest may arise.
Immediately disclose potential conflicts of interest to affected parties
Don’t accept financial benefits from anyone who may want to influence a decision
Do not offer valuable considerations to get a job
Warn employers when you think a project will not successfully improve conditions
Do not accept work that hinders ability to finish current jobs
Always resolve conflicts in a way that protects the health of affected parties
5. Stay Within Your Expertise
Industrial Hygienists shall perform services only in the areas of their competence.
Only carry out jobs when properly qualified – through education, training, or experience – or have sufficient qualified assistance
Earn the necessary qualifications required by federal, state and local regulatory agencies before starting related work
Only attach or authorize the use of their seal, stamp or signature when the document is prepared by them or someone directly under their control
6. Uphold the Integrity of the Profession
Industrial Hygienists shall act responsibly to uphold the integrity of their profession.
Don’t do anything that will discredit the profession
Don’t lie to the public
Do not connect your name to a person or firm that you believe is being dishonest
Don’t lie about your education, experience or credentials
Don’t promote expertise or services in a way that misrepresents or leaves out a fact needed to keep the statement from being untrue
Do not allow employees or employers to misrepresent your professional background, expertise or services
Other Safety School articles that examine the more academic concepts of occupational safety:
Federal OSHA regulations are simply the minimum standard. About half of the U.S. states have taken advantage of their own authority to make stricter, or additional, rules.
Maryland OSHA (MOSH) is one of the “state plan” states that administer their own “mini-OSHA.” MOSH has beefed up their regulations on everything from:
Asbestos in protective clothing
Smoking at work
Powered equipment training
Reporting toxic substances
Medical surveillance testing for lead poisoning, to
Tree care and removal
The designs for sloping, benching and support, shields, or other protective systems designed from tabulated data or a registered professional engineer need to be at the worksite while they are being constructed, according to the Federal government.
MOSH wants employers to keep those designs at the worksite even longer to include while they are being used in the larger construction project.
Asbestos in Protective Clothing
Asbestos is as useful as it is deadly, and before its carcinogenic hazards were fully known, asbestos was utilized as heat insulating protective clothing. But because asbestos protective clothing that is improperly maintained can expose employees to that hazard, Maryland has banned employers from buying, using, requiring a worker to use or even keeping any asbestos clothing at a place of employment.
Smoking at Work
Every state has its own smoking laws. Some ban smoking within 20 feet of a business’s entrance; some have exceptions for bars and restaurants – but not Maryland.
MOSH makes it clear that smoking is not allowed in any indoor place of employment, and that there must be a “No Smoking” posted at each entrance.
OSHA’s 1910.146 regulation defines confined and permit required confined spaces, with employer and employee responsibilities.
Maryland decided to eliminate some guesswork and make a rule that, with limited exceptions, requires there to be at least one other person immediately nearby when someone enters a manhole.
The exception to this rule is if the employee can go into the manhole with cables or equipment to take readings, perform housekeeping or an inspection, or complete some other safe task.
Powered Equipment Training
OSHA has specific training regulations for some heavy equipment such as: forklifts and cranes. However, for earthmoving equipment such as scrapers, loaders, tractors, bulldozers, off-highway trucks, graders and similar equipment, the training requirements are vague, and you have to refer to General Safety and Health Provisions training element, 1926.21, which requires employees are able to recognize and avoid unsafe conditions in their work environment.
For its part, Maryland, has established some training elements for what it defines as power equipment: backhoes, bulldozer, front-end loader, skid steers, gradalls, scraper pans, cranes, and hoists.
The employer must develop and carry out a program of the standards needed to safely operate power equipment including: limitations and use; rated load capacities; and special hazards.
Companies need to keep on file a written description of the program, as well as where and when employees received safety training on file.
Employers must also post applicable manufacturer specifications for power equipment, and any required operating instructions.
Reporting Toxic Chemicals
Part of OSHA’s Hazard Communication regulations includes a provision to compile a list of the hazardous materials that employees may be exposed to while at a worksite.
MOSH wants all employers to take that list, (arranged alphabetically by the common name, with the chemical name, where it can be found, and the date it was first brought to the worksite), and send it to the Maryland Department of the Environment every two years.
Lead Testing Medical Surveillance
Where an employee may be exposed to lead (e.g. lead-based paint, old houses) OSHA has a medical surveillance program to initially test employees with periodic testing against that baseline.
Some of the additional testing that Maryland requires is to carry out initial testing before any assignment to an area with airborne concentration at the action level. This is in addition to the federal testing requirement of at least every two months for the first six months, and then every six months after that.
Maryland also wants employers to test employees at the termination of employment.
Federal guidelines have a process for temporarily removing employees with elevated lead levels from the exposure site for medical protection, with follow up tests for up to 18 months until a final decision is made. Requirements after that period are not defined.
Maryland instead directs employers to obtain a medical determination and continue to provide medical removal benefits until the decision is made about whether the employee can safely return to the same work.
Tree Care and Removal
OSHA doesn’t have regulations for every job, and tree care and removal are examples. The employer often must look at the potential hazards and cobble together safe work procedures.
MOSH decided that risks of tree care (e.g. cutting, pruning, tree removal) were enough that it codified the requirements for that type of work. The requirements include regulations on fall protection, the equipment used, personal protective equipment, fire protection, traffic control, power lines, tree and brush removal, chipping, and training.
Although it’s impossible to discern exactly what led to this overturned skid steer, an experienced operator can tell you that it can be easy to upset earthmoving equipment like this. Because of the weighted back end, if you go too fast uphill or backwards downhill, and have the bucket lifted high enough to raise the center of gravity, you can pop a wheelie or roll completely over which makes having a proper earthmoving safety training kit important.
A correctly trained operator should know this.
OSHA forklift regulations explain the training required in 1910.178(l). It’s up to the employer to ensure their operators have successfully completed a training program under an instructor who has the knowledge, training, and experience to teach and evaluate the operator. Training should include formal instruction, practical training, and performance evaluations.
Truck related topics include: operating instructions, warnings, precautions, differences between the truck and an automobile, controls and instrumentation, engine operation, steering and maneuvering, visibility, attachment operation, vehicle capacity and stability, inspections and maintenance, refueling/recharging, and operating limitations.
Other applicable OHSA regulations include:
The employer shall instruct each employee in the recognition and avoidance of unsafe conditions and the regulations applicable to his work environment to control or eliminate any hazards or other exposure to illness or injury. 1926.21(b)(2)
The employer shall permit only those employees qualified by training or experience to operate equipment or machinery. 1926.20(b)(4)
Because this vehicle moves earth, it isn’t automatically regulated under the General Industry Powered Industrial Trucks regulation 1910.178 (forklifts), but instead fits under 1926.602 for Construction Material Handling Equipment. And there, operator training requirements are identical to the PIT training requirements — 1926.602(d).
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.
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)
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.
The increasing diversity in today’s workplace is putting more and more focus on issues regarding language and literacy. A constant concern for supervisors and managers is determining whether their safety training for non-English speaking employees is adequate. In other words, do the workers really understand?
In April 2010, OSHA released a memorandum requiring all employers to offer OSHA training in a language that all employees understand. The new rules require OSHA compliance officers to monitor the effectiveness of on-site training for non-English speakers.
Do you or your supervisors know how to communicate safety training to employees whose first language may not be English? Do you understand the legal requirements for teaching these important policies?
Hispanic construction workers with limited English skills suffer more accidents on the job. Workers who don’t speak English, or have limited proficiency, can’t communicate as effectively with English-speaking supervisors, co-workers, or customers. They may also find it difficult to comprehend the requirements of their jobs, if conveyed in English.
Some employees may also not read English proficiently, and some may only be able to read very little in English or even their first language.
Unless these language and literacy issues are addressed by management, it can be difficult or perhaps impossible for some employees to work effectively and safely.
Language comprehension and compatibility issues can also complicate interaction and effective teamwork among employees.
This means training comprehension takes on even greater significance when the topic is safety. Inadequate safety training of non-English-speaking employees can result in lower productivity, more errors, and in injury or death.
How can managers be more confident non-English speakers understand safety training? Here are some things to keep in mind when it comes to training your non-English speaking workers:
Don’t assume employees can read. Although one way to assist non-English speakers is to display signs and posters in Spanish, although this is not always helpful. Employees with limited English skills may also be unable to read in their native language, meaning that written safety materials translated into another language would not be that useful. Consider conducting assessments on employee language and literacy ability in a lawful manner. If necessary, make sure you provide both written and verbal safety instruction to all employees.
Give them all of the training. Don’t shortcut training or provide non-English speaking workers with bare-minimum instruction on what needs to be done. Most jobs require some level of decision making. If workers don’t have all of the information, their ability to make correct decisions decreases and the likelihood of accidents increases.
Be aware of cultural differences. Cultural differences can create concerns regarding employee safety.
The meaning of certain colors and symbols may differ by culture
It might be considered rude to ask questions or question authority
Modes of dress may interfere with safe work practices
Recognizing these differences and taking them into account can be very important.
Think beyond Spanish. Many employers accommodate two languages, English and Spanish, but many workers speak other languages. If you have employees whose first language is neither English nor Spanish, you may need to provide them with the necessary training by using translation services (both written and verbal).
When training employees with limited English skills, take specials steps to make sure the training is effective:
Speak slowly, explain and repeat important points several times.
Choose the simplest words and avoid technical expressions. If you have to use technical terms, explain them as simply as possible.
When instructing employees who have only minimal or limited English skills, consider using a translator.
Another helpful step in training employees with limited English proficiency is to use visual aids, such as pictures and props, to supplement your words.
Encourage participation. Be patient and help employees express their thoughts and questions about the topic.
Have employees demonstrate new skills during the training session so you can verify they’ve understood.
Be sure to get feedback to confirm comprehension, and allow extra time for questions.
Give the trainees handouts in the language or languages they can understand.
Follow up on the job to make sure there have been no misunderstandings, and that employees correctly apply what they’ve learned.
Effective safety training is not just important to your company and workers, it’s a requirement. Know the needs of your employees, and find the best training solutions available.
A new clarification from OSHA on March 18, 2014 shed more light on why it is the employer’s responsibility to ensure an employee is a “qualified rigger” when working with cranes and derricks in construction.
Last year, an international association of bridge workers asked if a “qualified evaluator (third party)” that provides training and qualification for a signal person could do the same for a person who wants to be a “qualified rigger”.
OSHA’s answer was a heavily qualified yes, but on just the training. They said the qualified third party can provide the training, and an employer may consider the training and evaluation of a qualified third party evaluator in its assessment of the employee, but it is always the employer’s responsibility to decide whether that employee is a qualified rigger.
OSHA went on to explain, that although the third party may provide high-quality classroom and hands on instruction, they must be capable to work safely on the specific lift they are assigned to. This depends heavily on the type of rigging and worksite conditions and being able to recognize and resolve rigging issue at that particular worksite.
The regulation defines a “qualified rigger” as: a rigger who meets the criteria for a “qualified person”.
Which leads to a “qualified person” being: “a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, successfully demonstrated the ability to solve/resolve problems relating tot he subject matter, the work, or the project.”
This distinction shows the difference in the standard between determining a qualified rigger and a qualified signal person. The regulation allows for documentation from a “qualified evaluator (third party)” to determine a qualified signal person, but determining a qualified rigger is ultimately up to the employer even though they can take into consideration outside training.
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:
I hope you’ve never seen this before: a zip lock used to lock down a trigger, either replacing a missing one or on a tool that was never meant to have a trigger lock.
Sure several hours of holding that trigger down while grinding away at a big job can be tiring, but this is not the answer for obvious reasons. Just lose your focus for a second on your grip and you have a dangerous power tool running without anybody controlling it. Or maybe you leave this tool plugged in when the power is out, and can come to life when power is supplied.
In short, only use trigger locks that are part of the power tool that are supposed to be there, and ensure they are used correctly. OSHA recommends constant control switches that have to be held down for the tool to operate, as the preferred device. OSHA is also specific about which tools can have an “on-off” control switch, a constant pressure switch or a “lock-on” control switch.
Tools may only be equipped with trigger locks if they can also be shut off in a single motion using the same finger or fingers. This zip lock clearly does not meet that requirement.
Also some hand-held power tools – circular saws, chain saws, and some percussion tools that don’t have actively locked accessories – can only have a constant pressure switch.
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?
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?)
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