Safety Tidbit #46 – Illumination of Emergency Exit Signs

Safety Tidbit #46 – Illumination of Emergency Exit Signs

I have a short topic this week.  In Safety Tidbit #8 I wrote about emergency exits.  However, I wish to discuss a very specific point this week – illumination.

By way of review, and as most of you are aware, each exit must be clearly visible and marked by a sign reading “Exit [1910.37(b)(2)]. And each doorway or passage along an exit access that could be mistaken for an exit must be marked "Not an Exit" or similar designation, or be identified by a sign indicating its actual use (e.g., closet) [1910.37(b)(5)]. Furthermore, if the direction of travel to the exit or exit discharge is not immediately apparent, signs must be posted along the exit access indicating the direction of travel to the nearest exit and exit discharge. Additionally, the line-of-sight to an exit sign must clearly be visible at all times. [ 1910.37(b)(4)]

So what about the signs themselves?  Each exit sign must have the word "Exit" in plainly legible letters not less than six inches (15.2 cm) high, with the principal strokes of the letters in the word "Exit" not less than three-fourths of an inch (1.9 cm) wide. [1910.37(b)(7)] And lastly, each exit sign must be illuminated to a surface value of at least five foot-candles (54 lux) by a reliable light source and be distinctive in color. Self-luminous or electroluminescent signs that have a minimum luminance surface value of at least .06 foot-lamberts (0.21 cd/m²) are permitted. [1910.37(b)(6)]

So the question came to me, does the exit sign have to be lit?  Answer: “Illuminated to a surface value of at least five foot-candles by a reliable light source.”  Foot-candles are a measurement of light at an illuminated object. For instance, the illumination on a very dark day may be 10 foot-candles. Whereas, Twilight may be only 1 foot-candle. (http://www.engineeringtoolbox.com/light-level-rooms-d_708.html) So, if your company only works one shift during the day your exit sign probably has enough natural light on it.  However, if you have no windows or your company works after sundown then electricity or electroluminescent signs will be necessary.

Remember the objective is to get people out of the building as quickly and efficiently as possible. Which brings up another point, what is the purpose of putting floor plans showing the exits and exit routes by an exit? More on that at a later date.

Hope this was helpful and thanks for reading Safety Tidbits  ~ Bryan

Safety Tidbit #45 – Multi-Employer Worksites

Safety Tidbit #45 – Multi-Employer Worksites

Reference: OSHA Directive - CPL 02-00-124 Multi-Employer Citation Policy

In a brief paragraph (page 3-19) in OSHA’s Field Operations Manual they state the following:

“On multi-employer worksites (in all industry sectors), more than one employer may be cited for a hazardous condition that violates an OSHA standard. A two-step process must be followed to determine whether more than one employer is to be cited. See CPL 02-00-124, Multi-Employer Citation Policy, December 10, 1999, for further guidance.”

Step One: Determine whether the employer is a creating, exposing, correcting, or controlling employer. Always remember that any employer can be any or all of these roles.

Step Two: If the employer meets one of the types of employers in Step One were the employer’s actions sufficient to meet their regulatory obligations? The extent of the actions required of employers varies based on which category applies. Note that the extent of the measures that a controlling employer must take to satisfy its duty to exercise reasonable care to prevent and detect violations is less than what is required of an employer with respect to protecting its own employees. 

So what are the four categories of employers:

The creating employer is an employer that causes a hazardous condition that violates an OSHA standard (this includes the General Duty Clause).

The exposing employer is an employer who has employees in harm’s way.

The correcting employer is responsible for correcting hazards on a worksite.

The controlling employer has general supervisory authority over the worksite with the power to correct safety issues or require others to correct the hazard.

I think the most tenuous type of employer is the Controlling Employer especially in general industry. For example, when an employer contracts work out (or sub-contracts as the case may be) and puts language into their contracts that tell the contracted employer must follow all applicable safety regulations. This simple statement does not absolve the employer of responsibility.  Actually, they become a controlling employer by definition. 

As the controlling employer they must ensure they conduct periodic inspections of the worksite to become aware of hazards; second, implement an effective system to promptly correct hazards; third, enforce the compliance of contracted employers.

So, as an employer, if you have a particularly nasty job and decide to contract the work out so you don’t expose your own employees, remember your responsibilities as the controlling employer.  Ultimately, you must be diligent in your duty to challenge the contracted company’s safety procedures to ensure no worker (yours or someone else’s) is hurt at your facility.

Thanks for reading and I hope this was informative ~ Bryan

Safety Tidbit #44 – Personal Protective Equipment Requirements for Temporary Workers

Safety Tidbit #44 – Personal Protective Equipment Requirements for Temporary Workers

Source: OSHA Temporary Worker Initiative Bulletin #2

Similar to Safety Tidbit #10 – Recordkeeping Requirements for Temporary Workers, Temporary workers, are entitled to the same protections under the Occupational Safety and Health Act of 1970 (the OSH Act) as all other covered workers. When a staffing agency supplies temporary workers to a business, typically, the staffing agency and the staffing agency’s client (also known as the host employer) are joint employers of those workers. Both employers are responsible to some degree for determining the conditions of employment and for complying with the law. In this joint employment structure, questions regarding which employer is responsible for particular safety and health protections are common.

As joint employers of temporary workers, both the host employer and the staffing agency are responsible for ensuring that adequate PPE and associated training is provided. The host employer will usually have the primary responsibility for selecting, providing and ensuring the use of adequate PPE for the process(es) or operation(s) to which workers have been assigned because: 

The host employer is most familiar with the workplace hazards that the temporary workers will encounter.

The host employer generally controls the workplace hazards and the worker’s activities around

, and interaction with, those hazards.

The host employer is usually best situated to perform the hazard assessment required for determining if PPE is necessary and will likely have already done so for its permanent staff.

The staffing agency shares responsibility for its workers’ safety and must take reasonable steps to ensure that the host employer conducts the appropriate hazard assessment and provides adequate PPE. To this end, the staffing agency should become familiar with the hazards at the host employer’s worksite and maintain communication with its workers and the host employer. Such pre-planning and ongoing communication also alerts the staffing agency to persistent or newly-created workplace hazards that may need to be addressed.

The staffing agency and the host employer may agree to have the staffing agency supply some or all of the PPE and provide PPE training as long as the host employer ensures that the PPE is appropriate for the worker’s assigned tasks and that it is provided at no cost to the worker. Such an agreement should be made during the pre-planning meeting(s) and detailed in writing. However, neither employer may escape liability for its ultimate responsibilities under the OSH Act by requiring another party to perform those responsibilities. Both employers may still be liable if adequate PPE and training are ultimately not provided to the workers, regardless of which employer agreed to provide the PPE and training.

In construction, when reading temporary workers above this could be Union Hall workers picked up for a job. Where the Union Hall is the staffing agency and the employer at the job site is the host. Also, I know the practice in construction is to pick up “day laborers.” Although I feel this is a practice that our society needs to abandon, there is no staffing agency, and therefore, the entire burden falls on the host employer to provide all PPE and training.  We need to be vigilant when on sites to inquire if there are temporary workers and inquire about their training and evaluate their PPE usage.

As an Industrial Hygienist, my curiosity lies with the temporary or union hall worker that must wear a respirator. Who is responsible for their medical surveillance to evaluate the effects of the airborne hazard?  Medical qualification and fit-testing can be taken care of by the contract between the host and staffing agency. I haven’t seen anything about evaluating the worker to ensure they have not, in fact, been exposed. Whether that is because of inadequate, inappropriate or misused PPE. Until we address all of the aspects of PPE usage, the worker is only partially protected.

Hope this was informative and thanks for reading.  ~Bryan

Safety Tidbit #43 – PRCS - Use of forced air to reduce atmospheric hazards

Safety Tidbit #43 – PRCS - Use of forced air to reduce atmospheric hazards

Can I reduce my PRCS requirements by using forced air in my permit-required space since the only hazard is a hazardous atmosphere and I think I can blow that away?  The good news according to OSHA’s Permit-Required Confined Space standard [1910.146(c)(5)(i)] is that you may do that. However, a few items need to be in place. First, you need to demonstrate that continuous forced air ventilation alone is sufficient to maintain the space safe for entry [146(c)(5)(i)(B)]. Second, develop a monitoring and inspection data to support that the space is safe [146(c)(5)(i)(C)]. And third, when your workers do enter they must be appropriately protected [146(c)(5)(i)(F)].

The appropriate protection involves the following: test the atmosphere for oxygen content, flammable gasses, and then toxic gasses before any worker goes into the space [146(c)(5)(ii)(C)]. No worker be within the space if there is a hazardous atmosphere [146(c)(5)(ii)(D)]. Clean, fresh forced air can be used to render the space clear [146(c)(5)(ii)(E)]. Also, the atmosphere must be tested periodically to ensure the forced air is still effective.

So, although you don’t need to comply with paragraphs (d) through (f) and (h) through (k) you still have quite a bit of preplanning and evaluation to perform. Also, although not specifically required by OSHA, remember if something goes wrong you need to be able to get the worker out of the space.  So please plan ahead.  If you wish to rely on the local fire department, it is best to coordinate with them ahead of time to make sure they have the necessary equipment to rescue a worker from your confined space.  Lastly, contact the fire department before entry to alert them and have them on standby.  The last thing you need if you must rescue a worker is the PR nightmare from a bunch of flashing lights and sirens coming to your facility.  Also, once the call goes on the dispatch airwaves, the media may decide to investigate. Being on the evening news because of poor prior planning probably is not the publicity you want.

Thanks for reading and I hope this was helpful.  ~Bryan