Posts Tagged ‘OSHA’

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)

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!

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

A “Consensus of Concerned Interests”

Friday, August 28th, 2009
A local skateboard park… wait, this will make sense by the end of this blog. (Photo by Brian Evans, our IT manager and a park patron)

A local skateboard park… wait, this will make sense by the end of this blog. (Photo by Brian Evans, our IT manager and a park patron)

 

I came across this wonderful turn of phrase while doing some recent research in an American Society of Mechanical Engineers (ASME) standard.  It so precisely explains the what, how, and why of our nation’s non-governmental, consensus standardization process.  

Unfortunately, I’ve found that most people in the workplace who make reference to a consensus standard developed by, say, ASME, ASTM, or ASSE (I’m only naming a few) don’t actually understand the distinctions between these organizations’ documents and ANSI (the federation or “mother ship” of concerned interests).  There is further confusion when we try to delineate clear boundaries between an OSHA standard that has been taken in part, adopted in whole, or referenced to a national consensus standard such as ANSI or NFPA.

A little “consumer education” will help.  We all buy consumer products, many of which show “accredited manufacturer’s” stamps (e.g., ASTM for toy safety).  But, does the general public know what those stamps indicate?  Safety professionals will understand what a manufacturer’s tag means when it says “always wear eye protection that meets ANSI Z87.1 requirements.” But, again, do the majority of professionals understand the distinctions between ANSI and one of its accredited Standards Developing Organizations (SDO) such as ASSE?  (Note: The official numbering for the eye protection standard is ANSI/ASSE Z87.1).

This topic of standardization and consensus development could take up a whole college course – maybe even one that I’ll get an opportunity to teach someday.  Such a course is not improbable since ANSI and its SDO’s are promoting “standards education.”    

So, get off that social networking site and spend some time reading the educational information on the consensus standard websites.  It’s actually all very interesting!  I suggest starting with http://www.ansi.org/about_ansi/introduction/history.aspx?menuid=1.   There is a simpler version at http://www.ansi.org/consumer_affairs/history_standards.aspx?menuid=5.  Then check out the new ASTM F2334 – 09 for Above Ground Public Use Skate Park Facilities… and you will view the above photograph with deeper appreciation.  A standard such as this guides the construction, operation and safety equipment required at a public use skate park and is just one example of a national consensus standard for all “concerned interests.”

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

Moving from Compliance to Excellence

Friday, August 14th, 2009

Circle Safety ScreenshotHere is a screenshot of our website logo and our company slogan.  Looking back on our 14 years of safety and health consulting, I can actually see how our own professional development, attitudes, practice, and recommendations to clients have moved across an arc – from a focus upon regulatory compliance to excellence as the motivation.

There are so many stories and examples of our successful work with clients.  See our client list for examples of those who have moved from worrying about OSHA compliance and are now  meeting their business goals while incorporating excellence in safety and health. 

But, our stories of failures are also illustrative.  Every once in a while we meet with company or agency managers who “want safety” and a proposal from us to “do some work.”   At Circle Safety, we try to accommodate all sizes of organizations, work cultures, management styles, and budgets.  We want to help but negotiations sometimes fail when management just isn’t ready to dedicate the time and resources or the leadership!  One of the early clues that we may not be able to help is reflected in the language being used – examples of which I just pointed out.

We, too, are a business; we seek new clients and we will usually work with anyone who needs help. Still, what we enjoy most is working with those who already envision moving toward Excellence.

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

Don’t Fall Into the “Where Does OSHA Say I Have To Do That?” Trap

Friday, August 7th, 2009
Photo – OSHA

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.”

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

Checklists for Compliance

Friday, July 24th, 2009
A screenshot from http://www.doli.virginia.gov/media_room/annual_reports/2008/annualreport_08.pdf

A screenshot from http://www.doli.virginia.gov/ media_room/annual_reports/2008/ annualreport_08.pdf

I don’t like checklists, especially when used to guide a safety professional’s hazard audit or inspection.  If you just look for what is on the paper, you will miss what is right in front of you. One of the best inspection tools is the “What If?” analysis – but I’ll save that for a later blog.

Nonetheless, check-lists do have their place. At Circle Safety, we sometimes use them during our OSHA 10 and OSHA 30 hour training sessions as handouts to be taken away and reviewed later. We also sometimes use them when Safety Mentoring, but only as “training wheels.”  And, they are helpful as a reminder for a step-by-step series of tasks, such as those I’ve created for our construction clients at “Setting up Site Safety.”

Oh, speaking of checklists.  The Virginia Department of Labor and Industry has just published their 2008 Annual Report.  In it you will find VOSH’s General Industry and Construction lists for their “25 Most Frequently Cited Standards” – follow the link just below the screenshot.  We recommend that you use these as a check-list!

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

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.

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

  • Delicious
  • Digg
  • Facebook
  • MySpace
  • LinkedIn
  • Ping
  • StumbleUpon
  • Twitter
  • Share/Bookmark

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.