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Researching the “Parapet Rule”

Monday, October 5th, 2009

Great example of guarding the parapet edge when its dimensions don’t add up to the “parapet rule.” And, note the professional carpentry! This is a Taylor & Parrish job where the guardrails are always the best. (Photo: Jan Thomas)

I think all professionals have a tendency to pass-on answers based upon “rules” they have been told about but have not researched for themselves. Such is the case with a “flat roof/parapet height rule” I was told to use back in my OSHA compliance days (hint – it’s not in the OSHA standards).

Yet, when I started consulting, I also started to check my advice to clients, being ready to pull out the necessary documents supporting my statements. It’s so much easier to do this today with a robust internet but still some of the provenances of these “rules” are obscure. And, not only are they hard to trace but many are not regulatory rules, only guidelines. For example, if you have a flat roof with a parapet that is at least 30 inches tall and at least 18 inches wide, you may have sufficient protection, if you have limited exposure. I added the part about limited exposure as I’m not truly comfortable with this “parapet rule.”

I believe this formula started as an architectural guideline. Fall protection expert Dr. Nigel Ellis has discussed the parapet solution through all 3 editions of his Introduction to Fall Protection book (1988, 1993, 2001). On May 2, 2003, OSHA published a proposed rule change for Subparts D and I of 29CFR1910. At proposed Appendix A – Fall Protection Systems, you will find the following schematic with formula:

parapet rule

I emailed Dr. Ellis recently to see if he still used this 30-inch + 18-inch rule – he calls it a flopguard. He advocates that we all start using a 45-inch minimum high guardrail system – people around the world are getting taller! Thanks, Dr. Ellis. It is great being able to converse with an expert.

So, to wrap up this blog, I want to say that I really do enjoy researching these fine points for our clients and I’ve got a list of them – almost all of which will make great future blog topics! If you have an obscure “rule,” let me know and I’ll add it to the list!

Tags: Dr. Nigel Ellis, Fall protection, OSHA, Parapet protection
Posted in All Industries, Construction, General Industry, Safety Topics | No Comments »

Solving the Mystery of the Missing Fire Extinguisher Inspection Tag

Friday, September 11th, 2009

A typical store-bought fire extinguisher with the manufacturer’s info and tag, usually left in the box. The insert is a replacement tag we provide our clients. (Photo by Jan Thomas)

We’ve all walked by a fire extinguisher at work which is fully charged but is missing its inspection tag. There are many good reasons why OSHA, ANSI, NFPA, local fire codes – the list goes on – all require monthly and annual inspections. Some standards and organizations even require daily inspections to make sure the equipment is in place and ready to be used. For the monthly and annual inspections we can use the tag to document the inspection. (See our Fire Extinguisher Inspection Safety Talk).

The problem is, those tags sometimes disappear or never get put on in the first place.

I’ve found that the professional fire equipment service and recharging companies securely attach their inspection tags but these tags may not be waterproof or durable enough to survive your work conditions. So ask for special tags or tag protectors when necessary.

The real puzzle of the “missing inspection tag” starts when a worksite decides to purchase their extinguishers from the hardware or big box store. The brand new fire extinguisher is packaged in a cardboard box. The box is brought to the job, opened and the extinguisher is pulled out. It comes with mounting equipment which may or may not be used.

What is NOT used is the Inspection Tag which is usually attached to a small, folded “operator’s manual.” I’ll bet that 99% of the time this information and tag are left inside, at the bottom of the box, not even noticed by the person pulling out the equipment. Even if it is used, the tag is so lightweight that it disintegrates with the first water exposure or after a few months of inspection use.

We recommend that you either laminate the manufacturer’s tag or, if that went “missing,” make up your own tag with space for 12 months of visual inspections and a reminder that the extinguisher needs an annual maintenance check. Laminate it, punch a hole at the top, and use a small plastic zip-tie to keep it secured to the pin. If the store-bought extinguisher has a loose pin, secure that with one twist of a twist-tie.

Now that this mystery is solved, you just need to remember to inspect! Be sure you use a permanent marker on the tag or you will have to solve the “mystery of the disappearing ink.”

Tags: Fire Extinguishers, Inspection Tags
Posted in All Industries, Construction, General Industry, Safety Topics | 1 Comment »

Jan’s “Humor, Junk and Keep It!” File

Friday, September 4th, 2009

Curious relics of safety from bygone years. (Photo by Jan Thomas)

Around the offices at Circle Safety there are many signs of my years of service within the ranks of the safety and health professions, from framed diplomas and certifications to old photos and safety memorabilia, including rusting, cracked crane hooks. But what may be most telling is my collection of “Humor, Junk and Keep It” files – some of which are shown above.

I know I’m not alone in this habit. I’ve shared and swapped items with old safety friends for years.

Yes, I’ve got lots of versions of the “Cowboy After OSHA” cartoons, as well as Gary Larson’s The Far Side. That guy knows how to nail safety! But, my collection runs further afield. One example is my cherished children’s book, Safety Can Be Fun by Munro Leaf—a 1961 “New, Revised Edition” that was originally published in 1938!

I even have a complete copy of American Standards Association, August 31, 1966 Safety Code and Requirements for Dry Martinis. Unfortunately, I’ve been told by ANSI that it is still under copyright so I can’t share it (but I will find a way to divulge its safety rules at a later date, so stay tuned).

So, what do you have in your Humor, Junk and Keep It file?

Tags: Safety Humor, Safety Trivia
Posted in All Industries | No Comments »

A “Consensus of Concerned Interests”

Friday, August 28th, 2009

A local skateboard park… wait, this will make sense by the end of this blog. (Photo by Brian Evans, our IT manager and a park patron)

I came across this wonderful turn of phrase while doing some recent research in an American Society of Mechanical Engineers (ASME) standard. It so precisely explains the what, how, and why of our nation’s non-governmental, consensus standardization process.

Unfortunately, I’ve found that most people in the workplace who make reference to a consensus standard developed by, say, ASME, ASTM, or ASSE (I’m only naming a few) don’t actually understand the distinctions between these organizations’ documents and ANSI (the federation or “mother ship” of concerned interests). There is further confusion when we try to delineate clear boundaries between an OSHA standard that has been taken in part, adopted in whole, or referenced to a national consensus standard such as ANSI or NFPA.

A little “consumer education” will help. We all buy consumer products, many of which show “accredited manufacturer’s” stamps (e.g., ASTM for toy safety). But, does the general public know what those stamps indicate? Safety professionals will understand what a manufacturer’s tag means when it says “always wear eye protection that meets ANSI Z87.1 requirements.” But, again, do the majority of professionals understand the distinctions between ANSI and one of its accredited Standards Developing Organizations (SDO) such as ASSE? (Note: The official numbering for the eye protection standard is ANSI/ASSE Z87.1).

This topic of standardization and consensus development could take up a whole college course – maybe even one that I’ll get an opportunity to teach someday. Such a course is not improbable since ANSI and its SDO’s are promoting “standards education.”

So, get off that social networking site and spend some time reading the educational information on the consensus standard websites. It’s actually all very interesting! I suggest starting with http://www.ansi.org/about_ansi/introduction/history.aspx?menuid=1. There is a simpler version at http://www.ansi.org/consumer_affairs/history_standards.aspx?menuid=5. Then check out the new ASTM F2334 – 09 for Above Ground Public Use Skate Park Facilities… and you will view the above photograph with deeper appreciation. A standard such as this guides the construction, operation and safety equipment required at a public use skate park and is just one example of a national consensus standard for all “concerned interests.”

Tags: ANSI, ASME, ASSE, ASTM, Consensus Standards, NFPA, OSHA
Posted in All Industries, Consensus Standards | No Comments »

When To Flag – Virginia’s New Reverse Signal Rule

Thursday, August 20th, 2009

(An excellent example of a crew working safely within vehicle backing zones. Photo: Jan Thomas)

See the ready mix truck on the left? Thirty years ago, I did a fatality investigation of a worker on foot who was run over by such a vehicle. Virginia averages two fatalities per year involving what has become known as “reverse operations.” Sure, there are multiple causes to all such fatalities but it’s still accurate to say that we’ve been running over workers for decades because we have made pedestrians mainly responsible for their own safety.

The OSHA standards (except for an exception in logging) have used what I call the “one solution” approach to keeping workers safe in a vehicle’s backing zone. Up until now, it’s pretty much been about back-up alarms or maybe a flagger. Three years ago, VOSH threw down the flag and started the public process to develop Virginia-specific Reverse Signal Operation Safety Requirements. The new rule uses a multiple-strategy approach and requires action from drivers, ground guides as well as all workers on foot. Emphasis is placed upon employee training!

VOSH starts enforcement on September 18, 2009, but don’t panic if you didn’t know about this. The Virginia Department of Labor and Industry has developed and published excellent outreach and training materials and promises to use a phased-enforcement strategy. When to use a designated observer or ground guide can be a complex and confusing issue but VOSH has already gone a long way to helping us understand when to flag and when to train. Start here http://www.doli.virginia.gov/vosh_enforcement/reverse_signal.html .

By the way, a big Hi-Vis Fluorescent Yellow star goes to the contractor whose crew is shown above (I believe this is Jack L. Massie Contractors out of Williamsburg, Virginia). Even their yellow hard hats give the drivers one last chance to spot the workers on foot.

Tags: Reverse Signal Rule, VOSH, Worker On Foot
Posted in All Industries, Safety Topics, VOSH | No Comments »

Moving from Compliance to Excellence

Friday, August 14th, 2009

Circle Safety Screenshot Here is a screenshot of our website logo and our company slogan. Looking back on our 14 years of safety and health consulting, I can actually see how our own professional development, attitudes, practice, and recommendations to clients have moved across an arc – from a focus upon regulatory compliance to excellence as the motivation.

There are so many stories and examples of our successful work with clients. See our client list for examples of those who have moved from worrying about OSHA compliance and are now meeting their business goals while incorporating excellence in safety and health.

But, our stories of failures are also illustrative. Every once in a while we meet with company or agency managers who “want safety” and a proposal from us to “do some work.” At Circle Safety, we try to accommodate all sizes of organizations, work cultures, management styles, and budgets. We want to help but negotiations sometimes fail when management just isn’t ready to dedicate the time and resources or the leadership! One of the early clues that we may not be able to help is reflected in the language being used – examples of which I just pointed out.

We, too, are a business; we seek new clients and we will usually work with anyone who needs help. Still, what we enjoy most is working with those who already envision moving toward Excellence.

Tags: OSHA, Safety Management
Posted in All Industries | No Comments »

Checklists for Compliance

Friday, July 24th, 2009

A screenshot from http://www.doli.virginia.gov/ media_room/annual_reports/2008/ annualreport_08.pdf

I don’t like checklists, especially when used to guide a safety professional’s hazard audit or inspection. If you just look for what is on the paper, you will miss what is right in front of you. One of the best inspection tools is the “What If?” analysis – but I’ll save that for a later blog.

Nonetheless, check-lists do have their place. At Circle Safety, we sometimes use them during our OSHA 10 and OSHA 30 hour training sessions as handouts to be taken away and reviewed later. We also sometimes use them when Safety Mentoring, but only as “training wheels.” And, they are helpful as a reminder for a step-by-step series of tasks, such as those I’ve created for our construction clients at “Setting up Site Safety.”

Oh, speaking of checklists. The Virginia Department of Labor and Industry has just published their 2008 Annual Report. In it you will find VOSH’s General Industry and Construction lists for their “25 Most Frequently Cited Standards” – follow the link just below the screenshot. We recommend that you use these as a check-list!

Tags: Hazard Auditing, OSHA, VOSH
Posted in All Industries, Construction, VOSH | No Comments »

First Aid/CPR – New Requirements in Virginia

Friday, July 17th, 2009

Kristian, our FA/CPR Training Coordinator caught while cleaning and repacking the CPR manikins. Photo: Kathy Redfern

While we are on the topic of Emergency Action Plans – and I have your attention with this weird photo, I want to highlight the recent changes to First Aid/CPR training requirements adopted on April 16, 2009 by the Virginia Safety and Health Codes Board for use by the Virginia Department of Labor and Industry’s VOSH program. (See http://www.townhall.state.va.us/L/ViewMeeting.cfm?Meetingid=12584 )

Right now, if you read the federal OSHA standards – general industry or construction – you will find that they have different requirements and have been interpreted differently. VOSH has been using these same requirements but has decided it’s time to standardize and modernize. As a long time emergency responder, all I can say is YES! And, it makes sense. Common practice in many US worksites is to have first aid and CPR trained workers immediately available to respond.

VOSH’s new regulations will require First Aid/CPR services when employees are exposed to serious occupational hazards in construction and general industry. The test appears to be “if you could get seriously hurt at this workplace, you need immediate first aid response…. No waiting around for 911 to send help.” The new standards also provide employers with some flexibility to make arrangements for services; for example, you can make arrangements with your on-site security contractor to provide first aid.

The new rules also clarify questions we always have about mobile crews and individuals out working alone. And, since current OSHA regulations do not require CPR training for designated first aid providers, in Virginia that requirement is now clearly stated!

By the way, if you need CPR and First Aid training, call Kristian at 804.355.7255 and she will get you enrolled in one of our monthly open enrollment classes or schedule a special class for your workforce.

Tags: First Aid & CPR, VOSH
Posted in All Industries, Safety Topics | 1 Comment »

Plan For The Panic – Provide a “911 Script”

Friday, July 10th, 2009

Emergency Action & Fire Prevention Plan

In the previous blog, I provided a link to our poster version of an Emergency Action & Fire Prevention Plan which is especially appropriate for use on construction sites and small fixed businesses. I’d like to take this opportunity to highlight its special feature – the second line that starts with “here is how to find this site….”

I’m a volunteer member of a rural rescue squad and I have lots of horror stories concerning how my unit has driven all around the countryside, trying to find our patient. Enhanced 911 systems can’t help locate the emergency caller who is using a cell phone while standing on the side of an unidentified road or in the middle of a site being cleared for construction or in other scenarios where a land-line phone is not available.

How do you tell the 911 operator where you are? Even when using a land-line phone during an emergency, it is very helpful to have posted by the phone a neatly written and well-thought-out “script” to read from. People panic during emergencies – give them as many tools as possible to make the job of proper response as easy as possible.

(By the way, thanks go to one of our clients – Taylor and Parrish, Inc. of Richmond, Virginia. I believe it was Superintendent Roy who improved our poster by adding the 911 script.)

Tags: Emergencies, Emergency Action Plan
Posted in All Industries, Construction, General Industry, Safety Topics | No Comments »

Emergency Action Plans – Outdated or Up-to-date?

Friday, July 3rd, 2009

Old Civil Defense biscuit containers found during a demolition project. Photo: Jan Thomas

While conducting a recent safety audit at a demo project, I came across this box containing 75 pounds of “survival ration biscuits” which had been located in the building’s Civil Defense Shelter. You can hardly see it but the expiration date on the box says “Jan 1963.”

I originally took this as a funny picture showing a piece of history quickly being bulldozed out of our memories. But then I got to thinking about how this old box of outdated emergency supplies can actually be a lesson for those of us responsible for writing, implementing, and using workplace emergency action plans.

There is not much difference between this outdated cardboard box and a chapter in a out-of-date safety manual that only provides generic responses for a few OSHA-required emergency plans. All are outdated and won’t be helpful if an emergency strikes.

Instead, we like to see the general written EAP policies supplemented at the level of endeavor – the job site level on construction projects and department or shift level for fixed worksites – with posted information and lots of training and drills. Click here for one example of a simple EAP poster for a small construction site.

Emergency Numbers Poster

Note: here is an interesting link http://www.civildefensemuseum.com/ .

Tags: Emergencies, Emergency Action Plan
Posted in All Industries, Construction, General Industry | No Comments »