A fairly typical example of a Hazard Communications’ MSDS “station” put up and never used or dusted.

Industrial sites put up the “Right-To-Know Information Station,” shelf or cabinet while construction companies haul around a copy of their binder in a job box or on the shelf of the office trailer.  It doesn’t matter what sector of employment or how the employer stores the Material Safety Data Sheets (MSDS) because the truth is the information is not used as it was intended by OSHA.  I’ll guess that 99% of the binders out there are collecting dust just like the one in the photo.

MSDS sheets had their true time and place in the mid-1980’s when they were first required by OSHA in the Hazard Communications Standard (1983) and by the EPA’s Emergency Planning & Community Right-to-Know Act (1986) – and for good reasons as this information was not easily available.  But, that time has gone; electronic media has made the dusty old collection of data sheets obsolete. 

I’m not discounting OSHA’s requirement for an employees’ right-to-know.  A review of an MSDS sheet makes for a great safety talk.  (Hint:  before you review an actual chemical being used on site, go over an MSDS for something fun like beer or fireworks or even WD-40).   And, if there are “exotic” chemicals on site – Yes, the MSDS must be reviewed on a regular basis so employees will remember what to do when handling or during emergencies.

But aren’t there better ways to provide the MSDS information – inexpensively – without hauling these dusty binders around that no one updates or looks at?

Framing a multi-story residential building with the guardrail and window rail already in place. (Photo: Jan Thomas)

Many construction framers like to think that they fall into the “residential exemption” at 1926.501(b)(13) and .502(k) where they explain in a written fall protection plan that it is infeasible for them to use conventional fall protection systems.  I’ve seen one too many companies search for excuses instead of finding solutions. 

As I’ve pointed out in the past, there are so many products available today that provide common and leading edge fall protection.  Once the initial expense for this equipment is taken the crew’s production can increase and everyone goes home at the end of the day.

Or, you can do what this company has done and design and fabricate your own portable guardrail system.  I watched this job while 2 men installed lengths of their perimeter guarding system while working from a personnel hoist. Right after it was installed the team of framers came in and deck and set the outer walls.  It was precision, quality and production all based upon planning and design, not excuses.

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)

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

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.

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.