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)

Hand lamp being used as an extension cord at welding table in a heavy equipment repair shed open to the weather. (Photo: Jan Thomas)

I don’t like this type of portable lamp for several safety reasons.  First, I’ve done one too many accident investigations that involved an incandescent bulb “trouble light.”  The classic accident involves the mechanic that takes this lamp under the hood or under the equipment/vehicle and begins to work on the fuel system.  Dripping fuel + hot electrical bulb = explosion & pain.

Aside from applicable OSHA standards we have support from Underwriters Laboratory which specifically states that “these products are not intended for outdoor use unless marked “Suitable for Wet Locations,” or for use in hazardous (classified) locations…” (UL 298, the Standard for Safety of Portable Electric Hand Lamps).The other reason for worrying about employee use is that the handle on many lamps provides a plug – supposedly for attachment of a small appliance like a shop radio or small bench tool – but which is misused in industrial and construction sites as an “extender” for extension cords (see above).  The hand lamp is now susceptible to being dragged around on the floor or hitting metal. 

And, as a special side note… I usually find misuse of this type of equipment paired with a lack of GFCI protection, thus doubling the risk.

The solution – purchase heavy duty portable lighting with proper bulb protection and NO outlet on the handle.  Use GFCI!

As per the eLCOSH Use Policy – this is a screenshot of the browse page at CPWR — The Center for Construction Research & Training, elcosh.org/images.

When I switched to digital I began my current collection which now suffers from my lack of time to organize it and digitally enhance or correct some images.  Even though I’ve got enough of my own shots to support this website (although I still waste time finding the right one) I’m always on the lookout for others’ helpful collections.  Voila.

Just this month The Center for Construction Research and Training (eLCOSH) added a free-of-charge image library to their already helpful website.  It provides high resolution, downloadable photos of hazards on construction sites.  Each photo has been fully described and the site is well organized and searchable by key words.  Find it at www.elcoshimages.org.

Be sure to read the “Use Policy” before you download.  Thanks, eLCOSH, and thanks to all the contributing photographers.

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?

I’ll bet most of the public and construction folks don’t realize that the tradition of putting an evergreen tree on the last big beam of steel being swung in place is a European custom handed down through the carpentry guilds from pre-Christian European times.  (Find out more by using search term: Topping Out).

Today, a Topping Out Ceremony will usually start with a party on the ground that includes the placement of the evergreen and the nation’s flag on the last large beam to be swung into place.  The beam is then signed in chalk or marker by the “dignitaries” and trade workers.   And, if the General Contractor is really in the know, he or she uses this opportunity to remind workers of the safe job they have done so far with an appeal for the same awareness as the structure continues into the next phases. 

Along with the blessing of the tree-spirits, I wish you a safe and prosperous new year.   Jan Thomas

We call this our Haz Mat Christmas Village… we are sorry about the cow. (Photo: Jan Thomas)

Happy Yule!

Merry Chanukah!

Joyful Kwanzaa!

Prosperous New Year!

And, Safety & Peace For All!

From Circle Safety & Health Consultants

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).

A city block of construction with security fences and traffic control devices (Photo: Jan Thomas)

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).

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.

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.