Safety Tidbit #50 - Heat

Safety Tidbit #50 – Heat

As I drove across Iowa yesterday, in preparation to begin the RAGBRAI (Register’s Annual Great Bicycle Ride Across Iowa)  this weekend, I was profoundly reminded of the effects of heat.  This was the screenshot from OSHA’s heat app on my iPhone.  Please remember to:
 train all employees on the signs and symptoms of heat related illnesses.
drink plenty of water.
Have shade and other places available for workers to escape from the heat.

 OSHA’s mantra is Water-Rest-Shade. However, also pay attention to the workload, clothing (e.g., PPE) usage and ensure workers have adequate sun protection for exposed skin. First line supervisors need to pay close attention to signs of dehydration possibly due to excessive alcohol consumption or drug (prescription or otherwise) use. Decongestants (Sudafed) and NSAIDS (Advil) can all aid in dehydration.

Have a great week and stay safe out there!

Thanks for reading and next Friday I will still be pedaling across Iowa so there will be no Safety Tidbit. This marks the end of my first year of writing Safety Tidbits. Hope you learned something and have enjoyed the topics. See you in a week or two to start year two! ~Bryan

Safety Tidbit #49 – NEP on Amputations

Safety Tidbit #49 – NEP on Amputations

In 2015 there were 2644 amputations in the workplace (Year One of OSHA’s Severe Injury Reporting Program: An Impact Evaluation).  Last year OSHA revised its National Emphasis Program on Amputations. Within Section D of the emphasis program, Inspection Procedures, OSHA is very specific about telling the compliance officers how to begin their inspections.

To begin with, at the opening conference, the CSHO must verify with the employer if they have any of machinery and equipment in Appendix A of the NEP. However, more broadly, the CSHO is also directed to verify if there are any other machinery and equipment that could cause amputations present in the workplace. Further, if there are any machinery and equipment associated with amputations, the CSHO is to exercise professional judgment in conducting an inspection of the machinery and equipment with particular attention to employee exposure to nip points, pinch points, shear points, cutting actions, and other point(s) of operation.

The CSHO should consider and evaluate employee exposures during any of the following:

ü  Regular operation of the machine;

ü  Setup/threading/preparation for regular operation of the machine;

ü  Clearing jams or upset conditions;

ü  Making running adjustments while the machine is operating;

ü  Cleaning of the machine;

ü  Oiling or greasing of the machine or machine pans;

ü  Scheduled/unscheduled maintenance; and

ü  Locking out or tagging out.

As consultants and safety professionals in the field, we need to vigilantly look for amputation hazards in the workplaces we visit. However, we also must take the time to train all employees to recognize what a nip, pinch or shear point looks like. And they need to understand what work activity takes them and their fellow workers into or near these points of operation exposing themselves or their fellow employee to the amputation hazard. Specifically, when there is a guard present we need to ask when does that guard come off? And subsequently, is there any chance for a worker to come into contact with the hazard when the guard is off?

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

Safety Tidbit #48 – Fixed Ladders

Safety Tidbit #48 – Fixed Ladders

If you ever had to vertically climb up the side of a building or a water tower you know that once you get up 20-30 feet it is no easy feat.  Now ladders typically do not require fall protection but 40 or 50 feet or more on a tower you need something, right? The three-points of contact method is great but climbing that high is very fatiguing.

Well OSHA has a regulation for that.  1910.27(d) states that “when ladders are used to ascend to heights exceeding 20 feet (except on chimneys), landing platforms shall be provided for each 30 feet of height or fraction thereof, except that, where no cage, well, or ladder safety device is provided, landing platforms shall be provided for each 20 feet of height or fraction thereof. Each ladder section shall be offset from adjacent sections. Where installation conditions (even for a short, unbroken length) require that adjacent sections be offset, landing platforms shall be provided at each offset.” 

Furthermore, all landing platforms must be equipped with standard railings and toeboards, giving safe access to the ladder. Platforms shall be not less than 24 inches in width and 30 inches in length. [1910.27(d)(2)(ii)]

However, there are always exceptions. “Ladder safety devices may be used on tower, water tank, and chimney ladders over 20 feet in unbroken length in lieu of cage protection. No landing platform is required in these cases. All ladder safety devices such as those that incorporate lifebelts, friction brakes, and sliding attachments shall meet the design requirements of the ladders which they serve.” [1910.27(d)(5)]

Personally, I like cages because if you fall backwards you have something to keep you close to the ladder and grab onto. If this is a new construction, prudent practice would be to incorporate additional safety measures through the use of cages, ladder safety devices, and landings into the design even if not required.

Ultimately if your workers must routinely climb fixed ladders you should evaluate them and for their physical ability to climb the ladder (e.g., is the worker a smoker?). Also, remember how are you going to get the materials and tools to the top? It is hard enough to climb the fixed ladder, but to require the worker to carry the additional weight of tools and materials is unreasonable.  Not to mention, the encumbrance if they are to hand-carry these items, at least use a backpack.

One last thought, it was 93 degrees with high humidity yesterday, did you think about heat stress?

 Hope this was helpful and thanks for reading!  Have a safe day ~ Bryan

Safety Tidbit #47 – Scissor Lifts and Fall Protection

Safety Tidbit #47 – Scissor Lifts and Fall Protection

Source:  OSHA Hazard Alert – Working Safely with Scissor Lifts

Employers need to assess the worksite to identify all possible hazards in order to select the appropriate equipment for the task. Employers who use scissor lifts need to evaluate and implement effective controls that address fall protection, stabilization and positioning. Only trained workers should be allowed to use scissor lifts, and employers should make sure that those workers show that they can use a scissor lift properly. Safe scissor lift use includes properly maintaining the equipment, following the manufacturer’s instructions, providing workers training and needed personal protective equipment (PPE), and implementing safe work practices.

Scissor lifts must have guardrails installed to prevent workers from falling [see 29 CFR 1926.451(g) or 29 CFR 1910.29(a)(3)(vii)).1910.66 Appendix C (10)]

Furthermore, employers should train workers to:

·      Check to see that a guardrail system is in place before working on the scissor lift.

·      Only stand on the work platform; never stand on the guardrails.

·      Keep work within easy reach to avoid leaning away from the scissor lift.

So what happens when you know the operation that the scissor lift is being used for requires the worker to lean over. The guardrails on the scissor lift are designed to keep them safe when the worker is inside. Ultimately, you want to protect them, right?? So what do you do? You put them in personal fall protection? However, make sure the personal fall arrest system meets all of the requirements.  Specifically, what are they going to tie off to?

Anchorages to which personal fall arrest equipment is attached shall be capable of supporting at least 5,000 pounds per employee attached, or shall be designed, installed, and used as part of a complete personal fall arrest system which maintains a safety factor of at least two, under the supervision of a qualified person. I recently had two clients (almost back to back) that were using the top rail of the scissor lift as their anchorage points. The guard rail on a scissor lift meets the same requirements as any other guard rail in order to keep the worker inside and protect them from falling out. Specifically, the anchoring of posts and framing of members for railings of all types shall be of such construction that the completed structure shall be capable of withstanding a load of at least 200 pounds applied in any direction at any point on the top rail. [1910.23(e)(3)(iv)]

Now take a step back, remember how this Safety Tidbit started “assess the worksite to identify all possible hazards in order to select the appropriate equipment for the task.” You might want to use a boom lift instead. A boom lift gives the worker elevation and the ability to move the basket closer to where they need to be therefore, leaning outside of the basket may become unnecessary. Furthermore, all boom lifts have a properly engineered anchorage point so use of personal fall protection now can be done properly.

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

http://safety-tidbits.blogspot.com/

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