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Low Bid = High Risk?

Wednesday, 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 »

That Old Hard Hat Rule & A Few Exceptions

Monday, 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 »

Looking a Little Closer at Laser Safety

Monday, November 23rd, 2009

Laser warning sign, laser safety glasses and safety instructions – all rare sights in the workplace. (Photo: Jan Thomas)

Lasers are taking over! They are incorporated into kid and pet toys and will probably be a very popular holiday season gift for the DIY tool collector. Their presence in the industrial and construction worksites has been growing too. But, I believe workplace safety awareness has actually decreased as laser use has become more common place.

Lasers used to be a rare sight on construction sites. When they were used, a warning sign was often posted. The user was sometimes “certified” by the manufacturer. Other workers stayed out of the posted area. The laser safety glasses were in the carrying case although hardly ever used. And, no one really knew much about the potential dangers other than “you shouldn’t look into the beam.”

Most of these conditions have remained the same except that I now see more lasers in use, no warning signs, and a lack of training or qualification to use. But, the OSHA laser standard remains the same and requires all of this – see 29 CFR 1926.54.

Typical leveling lasers seen on construction sites today are rated at less than 1mW and therefore fall into a Class II category as per the Laser Hazards- Section III: Chapter 6 of the OSHA Technical Manual.

Quoting from it “CLASS II: low power visible lasers which emit above Class I levels but emitting a radiant power not above 1 mW. The concept is that the human aversion reaction to bright light will protect a person.” The referenced “human aversion reaction” is a fancy way to say “eye blinking.”

So, bottom line…. We want the laser operator trained with documentation. The user is to post a notice telling us what Class laser is in use. All employees in the area need laser safety awareness training. And, what about those weird red glasses? If the equipment is Class III or IV then we will probably need special laser eye protection depending upon the exposure. BUT, if it is Class I or II – everyday construction laser – then all we need to do is be aware a laser is in use and not try to out stare it.

By the way, I’ve not referenced OSHA’s Technical Manual on this blog before – it’s the official go-to guide for the OSHA compliance officers and therefore is of use to us.

Tags: Construction Safety, Laser Safety, OSHA
Posted in All Industries, Construction, General Industry, Safety Advise | No Comments »

When is a Prefabricated Scaffold Frame Also an Access Ladder

Monday, November 9th, 2009

Masons need safe access and a few other things too. Photo: Jan Thomas

When is a Prefabricated Scaffold Frame Also an Access Ladder?

I’ve been in the safety profession long enough to remember how we used to do it 30 years ago. And yes, we used to climb those end-frames that look like ladders. Heck, the more agile workers climbed the cross-bracing (and some still do).

If we follow OSHA’s 1926.451(e)(6) or the less informative OSHA 1910.28(a)(2), we know that we need prefabricated scaffold access frames that have evenly spaced rungs at least 8 inches wide and not more than 16 3/4 inches tall from one rung to the next. Where in the world do they get these dimensions from?! ANSI standards, of course, but there is one other body of knowledge guiding us in this example.

A normal ladder has rung spacing at 12 inches on center, a rung width from 15 to 20 inches, and a tread thickness of 1 3/8. These numbers represent our “cultural expectations” (that’s a fancy ergonomics principle). Cultural expectations should be followed as close as possible on workplace equipment that may compromise safety, such as a ladder substitution.

Test yourself on the following examples of prefabricated scaffold frames.

CropperCapture[32]

Tags: ANSI, Consensus Standards, Construction Safety, Ladders, Scaffolding
Posted in Construction, General Industry | No Comments »

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 | No Comments »

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 »

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 »