Tying off on Scissor Lifts in Virginia

November 16th, 2009
Only one of several types of tie-off instructions put on modern scissor lifts. (Photo: Jan Thomas)

Only one of several types of tie-off instructions put on modern scissor lifts. (Photo: Jan Thomas)

Last Friday I received a call from a client’s superintendent asking me to go over the reasoning and authority for tying off on scissor lift and other personnel hoists. This is the same question I’ve been answering for years and I’ve been answering it in the same way for years… specifically, “Despite what OSHA says, if the manufacturer has provided anchors points, please use them as they have been put there for your safety!”  

In Virginia, in the fall of 2006, my answer became a little stronger as I could now point to the “authority” of VOSH when someone wanted to argue with me that OSHA doesn’t require tie off on scissor lifts. 

Earlier this year I wrote our clients a memo on this topic – it applies to industrial worksites, construction and all sectors of employment in between.  Here is a link to that memo

By the way, the superintendent was being questioned by one of his disbelieving subs.  So I reminded him that the true answer to “Why do we have to tie-off?” is “Because it’s our rule!”

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When is a Prefabricated Scaffold Frame Also an Access Ladder

November 9th, 2009
Masons need safe access and a few other things too. Photo: Jan Thomas

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.

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What will they think of next?

October 30th, 2009
Jobsite trying to do the right thing by getting electrical power in early.  (Photo: Jan Thomas)

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.

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Safety for Volunteers

October 23rd, 2009
A volunteer at the 2009 Richmond, Virginia Folk Festival helping keep the public safe at a crosswalk while being safely identified with high visibility vest. (Photo: Jan Thomas)

A volunteer at the 2009 Richmond, Virginia Folk Festival helping keep the public safe at a crosswalk while being safely identified with high visibility vest. (Photo: Jan Thomas)

I attended the recent folk festival in Richmond.  Good time, great music, world cuisine and wonderful photo opportunities.  The large crowds were being assisted by people identified by their “Volunteer” t-shirts. Of course, I noticed the “behind the scenes” details and started thinking once again about the safety of this special group of “workers.”  It’s a topic I’ve been aware of for a long time.

In the early 80’s, when I was the VOSH Administrator, I had to sort through the jurisdictional issues involving the fatality of a volunteer.   On a more personal level, in 1985, I joined my local volunteer rescue squad where my EMT training emphasized the safety and health of the emergency responder. 

I can tell you from these early experiences and years of following this issue that volunteers are normally exempt from OSHA regulations due to a lack of employer/employee relationship.  The one clear exception to this rule was created by the U.S. Congress in 1989 through EPA and directed at fire departments (career, volunteer or combination services).  That focus remains on hazardous materials emergency response.

But what about unpaid student interns, hospital, hospice or disaster volunteers, animal shelter or food bank unpaid assistants, fund raiser and community activity helpers?  Who protects or watches out for the safety of these populations in the U.S.

Sad to say, promotion of safety for U.S. volunteers is only happening at the individual organizational level.  There are few incentives other than tort liability, some insurance industry awareness, and the professionalism of volunteer-rich organizations such as the American Red Cross or my local music festival organizers.

This is not necessarily the case in other developed nations.  For example, in the UK, the Health and Safety Executive mandates that employers and the self-employed protect their employees and their volunteers.  An independent organization – Volunteer England – provides a “good practice” bank of safety suggestions to assist.  Hmm…. a national, cooperative model to consider when next we smile at a volunteer.

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Ban the Wire!

October 20th, 2009
Good example of “gambling with wire” while stringing up temporary lights (Photo: Jan Thomas).

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.

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Beware the “Fresh Breeze”

October 9th, 2009
Roofers several stories up, trying to batten down their materials during high gusts. (Photo: Jan Thomas)

Roofers several stories up, trying to batten down their materials during high gusts. (Photo: Jan Thomas)

The trees outside my office window are being blown by a “fresh breeze,” fall leaves whipping off.  The local weather station reports 18 to 20 mph gusts.  Last night I watched a Weather Channel report on workers in Japan being blown about by typhoon-generated winds of more than 85 mph.  All this reminds me that I’ve been meaning to write a blog on how to determine when windy conditions are safe for workers, cranes, and other outdoor material handling.  I’ve seen plenty of guys trying to carry sheets of plywood during high wind.  And, I really get concerned when the unloaded crane hook is swinging in the breeze.

I’m always being asked, “What’s OSHA’s rule on wind speed?”  That’s easy – there is NO general rule.  In fact, current OSHA General Industry and Construction standards say very little other than a few minor mentions in outdated crane standards.  That will change when OSHA finally adopts the new Subpart CCCranes and Derricks in Construction. (You saw that right – OSHA’s going into double alpha for their subparts.)

For example, proposed §1926.1417(h) states “when a local storm warning has been issued, the competent person shall determine whether it is necessary to implement manufacturer recommendations for securing the equipment.”  Suddenly, we have at least 3 entities that can help us make a decision – the National Weather Service, the on-site competent person, and the crane manufacturer!   The conditions of each crane pick are different and do depend upon on-site decisions.  Several sources, too numerous to list here, indicated that by the time wind gets to 20 – 25 mph it is getting too risky to operate cranes.

And, what about those workers lifting plywood and other materials on the roof?  When should they be concerned?  This should be obvious, but sometimes not to the supervisor tucked away in the office.  Check out the Beaufort Scale for land wind conditions.

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Researching the “Parapet Rule”

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)

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!

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Flu & Cold Season – Take Mom’s Advice

September 28th, 2009
I’m dedicating this week’s post to my mother, Mary Prehn, RN (1926-2004), who traveled throughout the world with my Dad during his US Navy officer’s career.  We five kids were extremely lucky to see the world in the company of a nurse and her gentleman.

I’m dedicating this week’s post to my mother, Mary Prehn, RN (1926-2004), who traveled throughout the world with my Dad during his US Navy officer’s career. We five kids were extremely lucky to see the world in the company of a nurse and her gentleman.

 

 

Circle Safety helps organizations plan and write infectious disease threat response documents.  But some of the strategies I personally use to avoid colds, tummy bugs, and flu (vectors of droplet, airborne, and contact transmission) were first taught to me by my mother.

As “Navy Juniors” traveling the world, we knew that regular immunizations were part of the drill.  As then, so now…  I just got my seasonal flu shot and I’m waiting for the H1N1 vaccine series to be released.  In the safety profession, as in my mother’s nursing profession, we know that planning and prevention are the best strategies.

So, our offices have taken in a new supply of tissues and hand sanitizers (check to make sure yours are at least 60% alcohol-based).  Several of us have started using personal coffee or water cups, cleaning them, and storing them in our desks so we longer just grab one off the kitchen shelf (who cleaned this last, and how thoroughly?). The latest guidance from CDC is posted over the kitchen sink. 

Infection control goes beyond the office environment.  I carry hand sanitizer in my car, ready to use when I finish on-site auditing (think about all the hands shaken, all the PPE equipment picked up to inspect, all the handrails used).  I also remind myself of a rule learned while volunteering on my rescue squad – never contemplatively chew on the end of the pen or pencil  – you may have just used it to point out a laceration on your patient’s face.  Same holds true in a workplace where we tend to call attention to hazards with the end of the pen before logging it in on our inspection notes.  Oh yes, and my Mom always said, “Please keep your hands out of your mouth”…

She also indoctrinated all of us in proper handwashing techniques, using soap and water or just water and friction if soap was not available.  It was family practice to wash before meals, after using the toilet, after we had been running around in very public places, if we were sick and sneezy, and before we went to bed.  She showed us how to walk from the sink in public toilets to the door and use a paper towel to turn the handle, avoiding immediate recontamination of our hands.  We always threw away tissues and paper towels in a sanitary fashion and never littered. And we always recycled, although it wasn’t called that back then.

She told us about her mother living through the 1918-1919 “Spanish Flu” and other great epidemiological tales such as Typhoid Mary (1900-1915) and the 1859 cholera outbreak in London that was due to the now infamous Pump Handle.  I see now how her early training and stories have helped guide me.  Thanks, Mother.

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Safety at the Uptown Dig

September 18th, 2009
From	Subject	Received	Size	Categories

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.

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Solving the Mystery of the Missing Fire Extinguisher Inspection Tag

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)

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.”

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Please Note: Analysis and opinions expressed are specific to the current discussion only. Different facts, changes in standards and codes, or other circumstances may lead to different results.