March 18th, 2010
Worker climbing metal fabricated stairs placed in sidewalk, behind a barrier and running along facade. (Photo: Jan Thomas)
Thanks to Adam Thompson for posting a Circle Safety blog while I’ve been traveling. Adam has an environmental specialty that adds nicely to the safety and health services we provide. Sometime soon he will post his ideas on how the LEED industry and safety match-up.
Meanwhile, let me show you some of my travel photos… As readers know, I like to take photos of construction sites. On my recent trip to France I paid particular attention to construction. Was it happening? How large were the sites? How many tower cranes could I count from the Eiffel Tower or Montmartre Cathedral?
My impression is that construction is steady. There are many sidewalk barricades for building and storefront renovations. In the central districts the count was at least one every other block. Plenty of tower cranes were in use but this was probably due to a lack of ground. And what is “normal” in the old world? Construction vans, superintendents’ trailers, haulage equipment and excavators—even barricades—are all small. Almost like toys.
Small tower crane on a tight footprint of new construction where old facade was maintained. Along Avenue des Champs-Élysées. (Photo: Jan Thomas
What about safety? On the larger jobsites safety – as we know it – is present. On the small store front renovations… o’la, la… OSHA would be saying something to the small “white van” construction guys.
These two photos are from a “large” site where an older building came down – they left the front façade and entrance arch and are building a new interior.
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March 12th, 2010
Good use of silt fence as inlet protection and matting for erosion control.
We have a substitute blogger for this week. Jan is out of the country and hopefully enjoying herself. This blog will focus on an environmental compliance issue that is of concern to the construction industry in Virginia and beyond. Stormwater management can be a major headache in the planning process for new construction, and new legislation is being considered right now in the Virginia General Assembly. You all need to know what you need to do.
Stormwater is a major pollutant of our nation’s groundwater. A lot of that pollution comes directly from construction sites. Sediment, suspended solids, nutrients, oil and grease, pesticides and metals are all common pollutants from stormwater runoff. These things end up in our drinking water! I don’t think I want to pour a glass of iced “Roundup” rather than iced water. Yuck!
So, what does a construction company need to know? Well, first off, you need a permit. But only if the area of disturbed land is equal to or greater than one acre. Now if you are in an area subject to the Chesapeake Bay Preservation Act, and your disturbance area is equal to or greater than 2,500 square feet, then you need a permit. Check these in the planning stage of work.
The most important part of this permit is the requirement for a Stormwater Pollution Prevention Plan (SWPPP). Your SWPPP outlines how you will comply with the permit. This document serves as your “bible” in ensuring the protection of groundwater from pollutants in your site’s area. The Department of Conservation & Resources deals with the permits and, along with the Environmental Protection Agency, may perform inspections of your site.
Basically, you need your permit and your SWPPP before you start work, and you need to follow that SWPPP as closely as possible to avoid citations. Remember, you wouldn’t want to be drinking in metals and oils on a hot summer day, so do your part to protect our drinking water!
Refer to http://www.dcr.virginia.gov/soil_and_water/vsmp.shtml for more info on Stormwater Management.
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February 10th, 2010
Housekeeping not so good. And how many hazards can you find? (Photo: Jan Thomas)
You’re driving into the worksite, getting out of your vehicle and walking to the office. Maybe you are the insurance agent on an annual audit, or maybe the corporate safety director doing the rounds, or a third-party safety auditor. Or you’re the newest employee reporting for duty, or the OSHA officer entering the site. The general first impression of the facility or construction site or office complex or any other workplace really gives the first clue as to how safety is valued.
I’ve been saying this to clients for years. Get your housekeeping in order! Build good looking guards! Keep the PPE looking “sharp.” Make it look good and you will also make it safe! Don’t you think the next photo provides a better first impression?
This site was so well organized there were very few suggestions for improvements. (Photo: Jan Thomas)
Tags: Housekeeping
Posted in All Industries, Safety Advise | No Comments »
February 1st, 2010
Hand lamp being used as an extension cord at welding table in a heavy equipment repair shed open to the weather. (Photo: Jan Thomas)
I don’t like this type of portable lamp for several safety reasons. First, I’ve done one too many accident investigations that involved an incandescent bulb “trouble light.” The classic accident involves the mechanic that takes this lamp under the hood or under the equipment/vehicle and begins to work on the fuel system. Dripping fuel + hot electrical bulb = explosion & pain.
Aside from applicable OSHA standards we have support from Underwriters Laboratory which specifically states that “these products are not intended for outdoor use unless marked “Suitable for Wet Locations,” or for use in hazardous (classified) locations…” (UL 298, the Standard for Safety of Portable Electric Hand Lamps).The other reason for worrying about employee use is that the handle on many lamps provides a plug – supposedly for attachment of a small appliance like a shop radio or small bench tool – but which is misused in industrial and construction sites as an “extender” for extension cords (see above). The hand lamp is now susceptible to being dragged around on the floor or hitting metal.
And, as a special side note… I usually find misuse of this type of equipment paired with a lack of GFCI protection, thus doubling the risk.
The solution – purchase heavy duty portable lighting with proper bulb protection and NO outlet on the handle. Use GFCI!
Tags: GFCI, Hand Lamp Safety
Posted in All Industries, Consensus Standards | 1 Comment »
January 13th, 2010
As per the eLCOSH Use Policy – this is a screenshot of the browse page at CPWR — The Center for Construction Research & Training, elcosh.org/images.
One of the difficulties faced by safety professionals is finding the right image to show during training and other times—whenever conveying a safety message to others. I’ve been consciously building a photo gallery of the “good, bad and the ugly” for over 30 years. My early OSHA compliance photos got left in the Federal files and anyway, they suffered from the media of their day (Kodak Instamatic or Polaroids).
When I switched to digital I began my current collection which now suffers from my lack of time to organize it and digitally enhance or correct some images. Even though I’ve got enough of my own shots to support this website (although I still waste time finding the right one) I’m always on the lookout for others’ helpful collections. Voila.
Just this month The Center for Construction Research and Training (eLCOSH) added a free-of-charge image library to their already helpful website. It provides high resolution, downloadable photos of hazards on construction sites. Each photo has been fully described and the site is well organized and searchable by key words. Find it at www.elcoshimages.org.
Be sure to read the “Use Policy” before you download. Thanks, eLCOSH, and thanks to all the contributing photographers.
Tags: Safety Photography
Posted in All Industries, Construction | No Comments »
January 6th, 2010
Forty feet up or more. (All photos by Jan Thomas)
I’ve dipped into my photo collection to start out this year’s blogging. It’s been several years since I took this series of pictures from a public street near Circle Safety’s Richmond offices.
Look closely… Two guys, on an aluminum work board (not a two-point suspended scaffold), one with a hard hat and PFAS in use, the other getting a good suntan. The horizontal white lines you see are ropes strung through small diameter PVC pipe, one on each side of the work board. Acting or at least looking like guardrails? Look closer and you’ll see more problems.
The biggest problem could be missed but I believe is the root cause of the observed hazards – these guys are working for the company that won the low bid to do cleaning and painting of this tower. I don’t know for sure but I’ll bet they were required to provide their own equipment.
I want to say right now that although I do have my “hazard radar” turned on almost all the time, I very rarely make a referral of an unsafe condition to OSHA. It has to be a true imminent danger situation which I believed this to be.
(In a later blog I would like to speak to the issue of a “duty to respond.” I have spoken with many professions including enforcement officers, emergency responders and public officials who have admitted to the dilemma of not always knowing if they should ignore something or get involved.)
It wasn’t my jobsite or my client, but on this day I decided that I had to save two lives. I took the photos and contacted my local VOSH office. Within half an hour, these lucky workers were on the ground talking to a VOSH inspector.
Rock climbing equipment attached to wire rope….
I say “lucky” because the photo below is a close-up of their sole anchor point.
What do you think?
Tags: Incorrect Suspended Scaffold, Unsafe PFAS
Posted in All Industries, Construction, General Industry | No Comments »
December 25th, 2009
How many of you know the origin of the ironworkers’ “Topping Out Ceremony”?
I’ll bet most of the public and construction folks don’t realize that the tradition of putting an evergreen tree on the last big beam of steel being swung in place is a European custom handed down through the carpentry guilds from pre-Christian European times. (Find out more by using search term: Topping Out).
Today, a Topping Out Ceremony will usually start with a party on the ground that includes the placement of the evergreen and the nation’s flag on the last large beam to be swung into place. The beam is then signed in chalk or marker by the “dignitaries” and trade workers. And, if the General Contractor is really in the know, he or she uses this opportunity to remind workers of the safe job they have done so far with an appeal for the same awareness as the structure continues into the next phases.
Along with the blessing of the tree-spirits, I wish you a safe and prosperous new year. Jan Thomas
Tags: Topping Out Ceremony
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December 21st, 2009
- We call this our Haz Mat Christmas Village… we are sorry about the cow. (Photo: Jan Thomas)
Happy Yule!
Merry Chanukah!
Joyful Kwanzaa!
Prosperous New Year!
And, Safety & Peace For All!
From Circle Safety & Health Consultants
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December 14th, 2009
Trim carpenter set up to work by himself with his hard hat parked at the door. Hmm… Please don’t hang your hat on the switch wiring even though it’s not hot, and don’t run your cord across the metal door frame unless you protect it. (Photo: Jan Thomas)
I keep a list of what I call “challenge questions.” When I’m looking for a blog topic I can always find inspiration as well as frustration by looking at my list. When I’m walking a construction site and encounter crews who have not worked with me before—and don’t already know my response, I’m often asked one of these questions.
Here is an example: “So, I’ve always been told I don’t have to wear a hard hat if no one is working around me. Why are you telling me different now?”
Those of you who have been reading my blog know my bottom-line answer to this and similar questions is – “Our company/site policy goes beyond OSHA standards. In this case, our policy is to wear hard hats 100% of the time with only a few exceptions.” It’s the part about “a few exceptions” that leads to long discussions, which I try to use as “teaching moments.”
I start by acknowledging that the main OSHA hard hat requirements are found in two places – General Industry’s §1910.135 & Construction’s §1926.100. Both require employers to determine the need for PPE and sometimes this leads to the evaluation that there is no possible danger if a person is working alone, or in the cab of a well-protected piece of equipment, or under a cabinet fitting a fixture. And, yes, OSHA said in 1983 that “where employees are not exposed to possible head injuries, head protection is not required by OSHA standards.”
Yet, typical hazards are not always anticipated, such as the hot electrical connection not seen yet touched by the worker’s head, or the rock that ricochets into the open window of the excavator’s cab, or the worker’s own dry wall hammer bouncing off a stud into his forehead. Ouch.
Believe me, I’ve seen all of these happen more than once. That’s why I try to convince my clients and all I contact in workplaces to wear their hardhats all the time (okay, except for maybe when they are sitting in the lunch trailer or in their car taking a nap).
Tags: Hard Hat, OSHA, PPE
Posted in All Industries, Construction, General Industry | No Comments »
December 4th, 2009
A city block of construction with security fences and traffic control devices (Photo: Jan Thomas)
We usually think about safety on construction sites with the focus on workers. The federal or state OSHA jurisdiction on commercial construction begins where an employer-employee relationship exists. In addition,
CPL 2-0.124 –Multi-Employer Citation Policy dictates overall jobsite safety between contractors. So, when we need some basic guidance on safety we grab the OSHA standards.
But what about safety of the public – on adjoining streets or sidewalks, or across the fence in the school yard, or even across the intersection? What about invited visitors on site? OSHA is almost silent.
Some of the OSHA rules for protecting workers do secondarily protect the public. For example, OSHA requires placarding of parked equipment, barricading of open trenches or the swing-radius of a crane, and using flaggers at traffic work zones. But these are few and indirect.
What may be needed is an actual plan for public safety, especially at sites where the public is ever present (city streets) or in high-risk areas (near schools). Common sense may help guide such a plan but you may want to also check out a little-known consensus standard – ANSI/ASSE A10.34-2001 (R2005) Protection of the Public on or Adjacent to Construction.
Here is a quick review. The public is defined as “All persons and property not affiliated with the construction project. This includes invitees to the construction project who are not employed by the project constructor or contractors.” What about trespassers? They are excluded from the definition of the public. But, be sure to put up those No Trespasser signs to defend your property rights.
The consensus standard provides guidelines for developing a site-specific public hazard control plan and emergency action plan. Fourteen specific hazards are identified and the standard’s appendix provides a checklist. The consensus standard is fairly short but is a great place to start your thought process for extending safety beyond the boundaries of your construction site.
(Note: this was first posted on November 6, 2009 at the Construction Law Musings blog – see http://constructionlawva.com/. My thanks to Chris Hill for continuing to invite me to provide guest posts).
Tags: Construction Safety, Multi-Employer Job Site, OSHA
Posted in Construction, Safety Topics | No Comments »
