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Archive for the ‘Construction’ Category

What will they think of next?

Friday, October 30th, 2009

Jobsite trying to do the right thing by getting electrical power in early. (Photo: Jan Thomas)

Sometimes you just have to stand back and see the humor in a situation. Laugh a little and then go talk to someone about the dangers. In this case, the GC asked the electrical contractor to provide the main panel and some GFCI outlets early in the job (that’s good). The concrete guys hadn’t gotten there yet, but were on their way (that’s typical). What to do with the panel box set on the ground already wired and running the temporary lights? Here is one solution – not so typical.

After checking out the unusual suspension system, I found that there was no strain on the actual wiring although the height of the service entrance cable and its installation needed to be improved. The ladder access to reach the main breaker might be a little short but that depended upon who was using the ladder. Framing and other construction exposures were going to be a little tricky around this whole installation.

The pad got laid and cured, the electricians came back and reset the panel, the superintendent was asked not to be so creative next time, and I got a funny picture.

Tags: Construction Safety, Electrical Safety, OSHA, Safety Management
Posted in Construction, Safety Topics | 1 Comment »

Ban the Wire!

Tuesday, October 20th, 2009

Good example of “gambling with wire” while stringing up temporary lights (Photo: Jan Thomas).

While teaching electrical safety in our OSHA 10/30 classes I like to throw out the question “Who thinks putting metal and potentially exposed electrical together is a good idea?” On all worksites I’ve seen a slow evolution to the use of nonconductive tools and equipment. For example, the replacement of metal ladders for fiberglass, the repair of extension cords with molded plastic replacement plugs, the use of plastic cages on temporary light strings instead of metal guards. All good, but in today’s photo we have short lengths of wire being used to hang the sting lights.

Is this a problem? The string lights are from a reputable manufacturer. Built-in molded plastic hanger eyes are provided. But, check the manufacturers’ literature- the plastic hanger eye is provided for use with “messenger cable or hooks.” Messenger cable??? Why bother with that when we can just hang the lamps using some bits of wire?

Look closely – this is not a usual case – the lamp assembly is pulled over and tied off to a metal stud with a spare length of wire pointing into the aisle, ready to catch a worker or hit the bulb. Then there is a small twist of wire being used to lock the clam shell type cage. Why is wire being used when plastic zip ties and bits of string are readily available in the workplace?

The installation shown above might pass OSHA inspection since the wire is passing through the manufacturer’s establish plastic eye (reference OSHA 1926.405(a)(2)(ii)(F) Temporary lights shall not be suspended by their electric cords unless cords and light are designed for this means of suspension).

My suggestions – stop arguing about OSHA compliance. Instead, fool proof everyone’s safety by setting up a worksite rule that says “ NO wires” when setting up temporary lighting or extension cords, that keeps everyone from making a random mistake that could lead to electrical shock.

Tags: Electrical Safety, OSHA, Safety Management
Posted in All Industries, Construction, Safety Advise, Safety Topics | 1 Comment »

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 »

Safety at the Uptown Dig

Friday, September 18th, 2009

C.T. Purcell, Inc. of Montpelier, Virginia, looking good at a challenging excavation job. (Photo: Kathy Redfern)

There is more to this photo than meets the eye. C.T. Purcell, Inc. is a local excavating and grading company that started up a few years ago and immediately established safety as part of their corporate philosophy. Mrs. Sagle Purcell, the company’s CEO and co-founder, originally contracted with us for services and she remains our corporate point of contact. As safety professionals, we rarely get a chance to come in at “the ground level” and help establish the safety culture, so it has been a delight to work with Mrs. Purcell as well as Mr. Tup Purcell and his crews.

So, this is obviously an urban trenching job. It’s at the center of VCU’s medical school and hospitals, and near the trauma center. Assume busy streets, pedestrians who jay-walk, no storage space and lots of underground utilities. What’s not obvious is the fact that this is the historic heart of Richmond, Virginia – the White House of the Confederacy is around the corner and the State Capitol is two blocks away. C.T. Purcell, Inc. really had to pay attention to what they were digging.

And, this photo is also a good example of when we should be protecting the trench edges. OSHA tells us at §1926.501(b)(7) that we may need to do this “when excavations are not readily seen because of plant growth or other visual barrier.” But, we also need to do this when employees or members of the public could easily get too close to the trench. C.T. Purcell, Inc. makes great use of the cattle gates as perimeter protection. The workers are all dressed professionally and in high visibility vests. The site looks good – both from the perspectives of what you can and cannot see.

Tags: Excavation Safety, Safety Management, Small Business Safety, Trenching Safety
Posted in Construction, Uncategorized | 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 »

Don’t Fall Into the “Where Does OSHA Say I Have To Do That?” Trap

Friday, August 7th, 2009

Photo – OSHA

Every once in a while Circle Safety gets a follow-up question after one of our site hazard audits. It usually goes like this – our client’s representative walks around with us and we all note minor and major issues as well as obvious disregard of company safety policies – some or all of which may be violations of OSHA standards. Later, that rep calls or emails, saying there has been some pushback concerning one of our recommendations. Someone is now insisting that we support our recommendation with a reference to a specific OSHA standard.

It’s interesting to note that we are not being asked to give citations to all of our recommendations for improvements – just to someone’s special issue. No problem. We can usually dredge up some reference from OSHA to prove our stance to the doubter, even if we have to point to the General Duty Clause or to the VOSH ARM.

But, I always take this opportunity to remind our client that we were walking around making observations based upon common sense, common industrial practices, and their own written company practices. OSHA standards are at the very bottom of our template for a safe worksite. Sad but true.

I call this kind of pushback the “where does OSHA say I have to do that?” trap.

The question shows both a misunderstanding of modern safety management practices as well as a self-limiting mind-set that started almost 40 years ago and is still being passed on. I have some suspicion that the OSHA Outreach Classes maybe maintaining the “where does OSHA say I have to do that?” trap (but more on that later).

While we wait for OSHA to “reset” (and I have faith that will start to happen), I want to remind all safety professionals to continue to update their own organization’s policies and programs to track with the latest US and International consensus standards and to always use manufacturer’s safety guidelines. And, be ready for The Trap Question by having a ready response. Maybe something like “Joe, our company rules go beyond the minimum requirements of law – that’s what you need to focus on.”

Tags: OSHA
Posted in Construction, General Industry | No Comments »

Is this a Contract Question or a Safety Question?

Friday, July 31st, 2009

Core construction at Number 2 reactor; North Anna Nuclear Power Station, Louisa County, Virginia; summer 1975 (photo by Jan Thomas)

This is a slightly edited version of a originally posted at Construction Law Musings http://constructionlawva.com/ on April 17, 2009. It represents my first blogging experience. Thanks to Chris Hill for giving me that opportunity.

Although I’m not an attorney, I am a safety professional with almost 35 years of construction safety experience and therefore I know a lot about worksite safety and its legal aspects including OSHA/VOSH compliance and best management practices within the trades. As a result, I often get calls from clients and others seeking my advice. Recently, a steel erection company representative I occasionally work for called and wanted to chat about a “safety issue.”

The company had set up their crane and had started erection and decking work at a GC’s site. This sub had worked for the GC before, using similar contract terms of work. I was told that nothing but the price of work had changed until this week when the GC’s safety representative held a site safety meeting and informed the steel erection crew that they could no longer “engineer and site-build” their rat lines (horizontal safety lines). Instead, they had to either buy and use manufactured horizontal anchors or provide a PE’s certification of safety. The steel erection safety representative didn’t think the GC could or should change the rules and he wanted my opinion. (I’m skipping over some of our discussions of §1926.502(d)(15), including how to meet the definition of a “qualified person” and how to go about engineering anchorages.)

“Sorry,” I told him. “The GC, and in fact any employer, site-controlling or otherwise, can institute safety requirements that go above those required by OSHA.” After a little more chatting, I think he understood that there were really two parts to his dilemma. The first, from my point of view, concerns the safety of his iron workers while they are using a field-built system that could be made up of incompatible components with different load ratings. The second issue on which he was focused was whether or not the GC could change the old contract agreement which merely required they “meet OSHA requirements.”

I made sympathetic noises… yes, it appeared unfair that the GC was changing the rules. But then I laid out his options:

Delay fixing the safety system in question and get written up by the GC and risk having an OSHA willful violation paper trail, and
Stubbornly continue to work against the GC’s safety request and risk getting kicked off the job and never being invited back for more work, or
Call your company attorney and get the safety language in the contract more clearly negotiated for the next job (but in the meantime, I recommend following the GC’s safety request).

Tags: Safety Management
Posted in Construction, General Industry | 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 »

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 »