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Protecting the Public in Proximity to Construction Sites

Friday, 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 »

Workplace Violence Trends in Virginia

Thursday, December 3rd, 2009

Some of the Workplace Violence resources I have collected through the years. (Photo: Jan Thomas) Earlier this week I conducted a three-hour training session on workplace violence for local businesses. It was a good chance for me to review the very latest facts on this widely acknowledged employment issue.

Workplace violence was first studied by NIOSH and then OSHA in the late 1980’s. Issues and characteristics as well as preventions and controls were researched and promoted, and then the topic faded from the public’s radar although it continued to be of interest to data collectors, if not safety and human resource managers. Since I was one of the first people to research this issue in Virginia (during my university professor days), I have also been quietly monitoring the ups and downs of this subject in the Commonwealth and I’m getting more concerned.

Take a look and decide for yourself. The easiest place to start is at the Bureau of Labor Statistics (BLS) and their Injuries, Illnesses, and Fatalities Report (IIF). Workplace homicides have declined more than 50 percent since 1994 but the most recent IIF report offers preliminary data for 2008 and shows 37 fatalities coded as workplace violence in Virginia! This appears high and well above the national average of 10-12 per state.

The most recent, fully investigated year of BLS data is for 2007—the year of the Virginia Tech massacre. In 2007, there were 21 workplace violence fatalities. Included in this year’s data were five of the 32 deaths at Virginia Tech. These five were faculty/employees and were counted by BLS. Yet, despite Virginia Tech being the deadliest of public shootings in Virginia (as well as in the United States) its number of workers dead is less than a quarter of those who died by violence in Virginia workplaces in 2007.

In 2006, there were 32 cases of workplace violence in Virginia. Put these 3 data points together – 2006 (32 cases), 2007 (21 cases), 2008 (37 cases) and while we don’t necessarily see an increasingly upward trend, we do notice a tendency toward large numbers. Workplace violence and some of its precursors – highly stressed individuals are still present and may be growing, due to the hard economic times and the tension of possible layoffs.

It’s a good time to dust off the workplace violence policies and revamp them for current issues and modern technology. More on this topic later.

Tags: Workplace Violence
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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
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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 »

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 »

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 »

When an expensive ladder can become even more costly

Friday, June 26th, 2009

Six-foot industrial-rated (ANSI IAA) fiberglass A-frame in use without extending and locking the legs.

Here at Circle Safety we spend equal amounts of time in the office (or classroom) and in the field. We joke that keeping our boots muddy keeps us honest. You can see for yourself in the photo what we mean about muddy boots.

We are better trainers because of our muddy boots. We know the realities of the workplace. Sometimes it can be hard to get the job done and make the work safe, too. And, our muddy boots enable us to discuss with management why they should give more time to safety training, safety supervision and third-party monitoring. Again, the photo provides an excellent example.

The crew using this ladder works for a company that cares about safety—and shows it. They provide appropriate tools, regular training and on-site safety auditing.

As we all know, ladder manufacturers provide lots of labeling and warnings on the side rails. These are visible to employees if the ladders are maintained properly. But, do the employees read these labels or take them seriously? Sometimes they do not.

In the case above, one or more workers did not follow the OSHA standard or manufacturer’s guidelines for fully extending and locking legs on an A-frame and for not using the top rung as a step. When we talked with the crew, they agreed that with a little more thinking and time spent during set up, they could have improved ground conditions (with some plywood) and correctly extended the legs (parallel to the wall).

If this photo had been taken by an OSHA inspector, the muddy bootprints on the ladder would have been sufficient for proving “employee exposure” and would have supported a citation. Even more costly than the OSHA penalty could have been an injured worker’s compensation claim. Luckily, both were avoided in this case by Circle Safety’s on-the-job safety training and our own muddy boots.

Jan Thomas, PhD, CSP
President and Consultant

Safety Topics:
ladder-inspectionsrev2005
fall-protection-ladders-scaffoldingrev2005

Tags: ladder, ladder safety, OSHA
Posted in All Industries, Construction, Safety Topics | 1 Comment »