Load Limits for Structurally Supported Surfaces

LarochellePosted by Greg LaRochelle, WCP

The last line of the lyrical refrain in the 1968 hit song “The Weight” by Canadian-American rock group The Band reads, “You put the load right on me.”  In the context of a work environment with a mezzanine storage platform, this verse conjures up a mental picture of disaster for anyone who might happen to be underneath the platform if it were to suddenly collapse.  OSHA addresses this load limit concern in their recently updated Walking-Working Surfaces standard, 29 CFR 1910.22, general requirements, as follows:

    1910.22(b) Loads. The employer must ensure that each walking-working surface can support the maximum intended load for that surface.

It’s important to note the previous general industry rule, 1910.22(d), required that “a plate of approved design indicating the floor load capacity must be posted.”  In a letter of interpretation, OSHA states, “There is no longer a requirement for a floor loading sign; however, the employer must ensure that employees involved in warehousing or storage activities know the intended load limits. This applies to ‘structurally supported surfaces.’”  

The general requirements of the standard also cover inspection, maintenance, and repair with the employer to ensure:

  • Walking-working surfaces are inspected, regularly and as necessary, and maintained in a safe condition;
  • Hazardous conditions on walking-working surfaces are corrected or repaired before an employee uses the walking-working surface again. If the correction or repair cannot be made immediately, the hazard must be guarded to prevent employees from using the walking-working surface until the hazard is corrected or repaired; and
  • When any correction or repair involves the structural integrity of the walking-working surface, a qualified person performs or supervises the correction or repair.

While there are several online resources for calculating floor load capacity, it is advisable to have a professional engineer calculate the maximum intended load.  In a manner of speaking, maintaining the structural integrity of a storage platform along with ensuring its maximum load capacity is not exceeded is intended to ensure “the last waltz” doesn’t happen to an employee working on or under the supported structure.

MEMIC policyholders have access to a General Industry Self Inspection Checklist in the Safety Director Resource Library.  



Confined Spaces in Construction: The "Whole" Story (Cont.)

Stephen Badger 2014 Posted by Stephen Badger, CSP, OSHT

OSHA’s New Confined Space Regulations (Part 3 of 3)

Part 1 of this three-part series on Confined Spaces in Construction identified the existing confined space standard in Construction (29 CFR 1926.21(b) and the newly adopted Final Rule, 29 CFR 1926 Subpart AA, that goes into effect on August 3, 2015. 

Part 2 reviewed a few of the key definitions and concepts related to the new standard.

Part 3 of this series examines some of the key requirements for employers under the new confined space regulations:

  • Before starting work a contractor must have a competent person identify confined spaces in which its employees may work. The competent person must evaluate the hazards of that space and conduct air testing as necessary. In addition, the employer must post warning signs and prevent unauthorized employees from entering those spaces. (29 CFR 1926.1203(a-c).
  • An employer must ensure through a written certification process that it is safe to remove a cover from a confined space and then block the entrance to ensure no one can enter the space before it is deemed safe. The confined space must be tested for oxygen, flammable gases and potential toxic air contaminants. If the air within the space does not meet minimum standards no one can enter the space until it is deemed safe. If a hazard is detected during entry the employer must ensure that employees can exit in a safe manner. (29 CFR 1926.1203(e)(2)(i – ix).
  • Before entering any confined space, the controlling contractor must obtain all information regarding the hazards of that space from the host employer. This information must then be given to each employer that has to enter that space. After completing the entry process, each employer must relay all related information and hazards encountered to the controlling contractor. (1926.1203(h)(1-5).
  • The employer must develop a written confined space program that addresses (but is not limited to) the identification of confined spaces, testing procedures, entry procedures, employee training, and emergency rescue. (29 CFR 1926.1204(a-n)

For more information on confined spaces in construction, MEMIC customers are welcome to attend our free webinar entitled “Confined Spaces: The Whole Story” on August 12, 2015.

Confined Spaces in Construction

Confined Spaces in Construction: The "Whole" Story (Cont.)

Stephen Badger 2014 Posted by Stephen Badger, CSP, OSHT

OSHA's New Confined Space Regulations (Part 2 of 3)

Part 1 of this Three Part Series on Confined Spaces in Construction identified the existing confined space standard in Construction (29 CFR 1926.21(b) and the newly adopted Final Rule 29 CFR 1926 Subpart AA that goes into effect in August 2015. This installment reviews a few of the key definitions and concepts related to the new standard.

In the definition section of the Final Rule, OSHA identifies a competent person as “one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them.” While the concept of a competent person is not new within the OSHA standards, this is the first time it has been included in any of the confined space standards.

OSHA defines a controlling contractor as “the employer that has overall responsibility for construction at the worksite. Note: If the controlling contractor owns or manages the property, then it is both a controlling employer and a host employer.”2 The term controlling contractor isn’t new to the multi-employer worksite citation process or 29 CFR 1926 Subpart R but this “entity” will be responsible for certain activities before and during mobilization to a worksite.

The definition of host employer is important to facility owners/operators as this entity has the responsibility of notifying contractors about the hazards within their confined spaces. OSHA’s definition and note follows: “Host employer means the employer that owns or manages the property where the construction work is taking place. Note: If the owner of the property on which the construction activity occurs has contracted with an entity for the general management of that property, and has transferred to that entity the information specified in §1203(h)(1), OSHA will treat the contracted management entity as the host employer for as long as that entity manages the property. Otherwise, OSHA will treat the owner of the property as the host employer. In no case will there be more than one host employer.”3

Part 3 of this series will explore key sections of the Final Rule and how they will affect employees, employers and facility owners.






Confined Spaces in Construction: The "Whole" Story

Stephen Badger 2014 Posted by Stephen Badger, CSP, OHST

OSHA’s New Confined Space Regulations (Part 1 of 3)

For years, many of us in the Construction field have heard the same old excuses from contractors working unsafely in confined spaces. Statements like “We don’t have a confined space standard in Construction”, have been heard countless times by safety consultants and Compliance Officers alike.

In reality, OSHA has had confined space rules for many years that have been all but overlooked because it consisted of just two sentences. 29 CFR 1926.21 (b)(i) requires that “All employees required to enter confined or enclosed spaces shall be instructed as to the nature of the hazards involved, the necessary precautions to be taken, and in the use of protective and emergency equipment required. The employer shall comply with any specific regulations that apply to work in dangerous or potentially dangerous areas.”

While underwhelming in details, the regulation does require construction employers to determine what hazards might be lurking in a confined space and instruct their employees on how to recognize and avoid these hazards. Because of this lack of detail many contractors chose to adopt the General Industry standard for confined spaces (29CFR1910.146) as this has been considered “best practices” for entering these spaces.

On May 1, 2015 OSHA announced the Final Rule for Confined Spaces in Construction (29 CFR 1926 Subpart AA).1 In a prepared statement Dr. David Michaels (Assistant Secretary of Labor for Occupational safety and Health) stated that it is expected that nearly 800 serious injuries a year will be prevented in confined spaces by the new rule and the standard will be effective on August 3, 2015.2

In the next two installments we will look at some of the new definitions associated with confined spaces and some of the new rules that contractors will be required to follow.




Combustible Dust: Good Housekeeping Practices Could Save Your Business

Luis Pieretti 2014 Posted by: Luis Pieretti, PhD, CIH, CSP

Good housekeeping practices not only help to maintain clean work areas, but in some cases, may prevent potential catastrophes.  In 2008, we were witnesses of the dangers of combustible dust with the explosion at the Imperial Sugar refinery in Georgia where 14 employees were killed and 42 were injured. But this is not a new hazard.  The first recorded combustible dust explosion dates back to December 14, 1785 at a flour warehouse in Italy.  A worker was using a shovel to transfer flour and a lighted lamp to work by.(1)  All the necessary elements for a combustible dust explosion were present:

  • Heat: The lighted lamp and/or possibly electrostatic charges due to the dry season.
  • Fuel: Flour and other agricultural dust/products are  combustible dusts.
  • Dispersion: Flour was likely suspended in the air during the transfer.
  • Confinement: The warehouse structure  confined the cloud of suspended combustible dust. 
  • Oxygen

It’s not just agricultural products/dust that can be classified as combustible dust but also plastic dusts, chemical dusts, metal dusts and carbonaceous dusts.  Recent explosions relating to metal dust occurred in 2010 at a titanium plant in West Virginia killing 3 employees, and in 2011 at a metal powders facility in Tennessee where 5 employees were killed. In 2012, a combustible dust explosion occurred at an ink plant in New Jersey where 7 employees were injured.

As of October 2014, there is no OSHA standard addressing combustible dust, but it is a known occupational hazard in which a compliance officer can cite under Section 5(a)(1) under the OSH Act.  OSHA is, however, developing  a standard. It should be noted that it is at the early stages, still a long way to go before it becomes a law--if it survives the rulemaking process.

The National Fire Protection Association has published a series of standards for the prevention of fire and dust explosions and they can be viewed for free through the association’s website.  The series of standards include: 

  • NFPA 61: Standard for the Prevention of Fires and Explosions in Agricultural and Food Processing Facilities
  • NFPA 484: Standard for Combustible Metals
  • NFPA 654: Standard for the Prevention of Fire and Dust Explosions from the Manufacturing, Processing, and Handling of Combustible Particulate Solids
  • NFPA 655: Standard for Prevention of Sulfur Fires and Explosions
  • NFPA 664: Standard for the Prevention of Fires and Explosions in Wood Processing and Woodworking Facilities

For more information about combustible dust and how it can be identified and controlled, visit the OSHA website or  The US Chemical Safety BoardMEMIC policyholders can watch a webinar on combustible dust at MEMIC Safety DirectorThe US Chemical Safety Board has developed videos detailing the causes of the explosions they have investigated including an educational video entitled, Combustible Dust: An Insidious Hazard:



(1) RK Eckhoff. (2003). Dust explosions in the process industries, Third Edition: Identification, Assessment and Control of Dust Hazards. Burlington, MA: Gulf Professional Publishing.



Tool Safety: Hand Held Circular Saws

Peter Koch 2014 Posted by Peter Koch

A hand held circular saw is one of the most common and potentially dangerous tools on the jobsite.   Ease of use and versatility of this saw are factors that drive decisions which put the operator at risk of injury.  It’s called a “skill” saw for a reason and not every operator has the necessary skill to safely produce quality work, in a timely manner. 

As one of the necessary “tools of the trade” it is critical that the operator has the skill and ability to use the saw correctly, ensuring their safety and the quality of the work.  So, to help maintain balance between the demands of quality, productivity and injury prevention review the following before you pick up a saw:


  • Make sure that you have read all safety materials that come with your saw.
  • Inspect the saw for serviceable condition.
  • Always wear safety glasses.
  • Check the blade guard; ensure it is working freely.
  • Ensure that the blade is proper for the material being cut.
  • Check the saw for proper blade installation and rotation.
  • Set the depth of the blade (while the saw is unplugged) so that the lowest tooth does not extend excessively beneath the wood.
  • Keep all cords clear of cutting area.
  • Use two hands to operate saw.
  • Mechanically secure stock being cut. 
  • Keep eyes on the saw while in use.
  • Remove nails, screws, fasteners, and other metal before cutting stock.
  • Let the saw come to rest before removing from the stock being cut.


  • Operate an unsafe tool or one that does not meet the manufacturer’s serviceable condition standards. 
  • Place your hand under the shoe or guard of the saw. 
  • Remove guard or prop open.
  • Hold retracting lower guard in the open position while cutting.
  • Rotate the saw up to change or check alignment while the saw is running. 
  • Force the saw in the material while cutting.
  • Carry the saw with a finger on the trigger switch. 
  • Overreach. Keep proper footing and balance. 
  • Support the work piece on your knee.  
  • Rip stock without securing the stock from movement

This is not a complete list.  Be sure to take a MEMIC Minute, go over the safety tips above, and be safe when you operate a circular saw.  For additional guidance check out the training resources from the Power Tool Institute.

Circular Saw power tool cut

Residential Construction Fall Protection

Koch Peter 1 Posted by Peter Koch

What relevance does an OSHA announcement about Construction in 2010 have in 2013?   Think fall protection. 

According to OSHA falls accounted for 259 out of 738 total deaths in construction for CY 2011 1992 through 2005, fatal falls in construction have only increased, even though in 1995, OSHA provided interim fall protection guidelines for residential construction that allowed contractors to develop non-conventional methods to protect workers from falls.

Given that the construction season is in full swing, the new residential fall protection requirements announced December 16, 2010 which replace the Interim Fall Protection Compliance Guidelines for Residential Construction are being enforced as of March 15, 2013.

Under the requirements, workers engaged in residential construction six feet or more above lower levels are to be protected by “conventional fall protection methods”, such as restraint systems, guardrails, safety nets, personal fall arrest systems (PFAs), or scaffolds.  Fall plans and slide guards (roof brackets) are not considered conventional methods.

The delay between the announcement and enforcement has provided time for employers to conduct training and adopt the new standards.

In order to use unconventional fall protection methods builders must show that OSHA’s standard methods are infeasible or would create a greater hazard than unconventional methods.  When this is the case, the burden of proof falls to the employer who then must provide a written explanation of why the conventional fall protection systems are infeasible or pose a greater hazard.  This must be outlined in a site-specific fall protection plan.

The following are links to the Residential Construction Fall Protection standards and OSHA Q&A:

The bottom line is, unless they can be proved to be infeasible, (Infeasible - impossible to perform the work while using a conventional fall protection system, or that it is technologically impossible to use a conventional system), conventional methods must be used when the worker is or can reasonably be expected to be exposed to a fall hazard of 6ft or more.

Making Road Construction Safe for Everyone

Road construction projects and the summer season seem to run on the same schedule, often to the distress of many of us trying to go about our daily lives. Indeed, billions of dollars and millions of man-hours will be spent on road work in 2013, the bulk of it scheduled for the warmest months of the year.

While traffic delays may be frustrating, drivers must stay alert to the hazards inherent to road construction. “All work zones are dangerous, especially if you’re not paying attention or taking proper precautions,” said Rod Stanley, a Director of Loss Control and Safety for workers’ compensation insurer MEMIC. “Whenever you have workers interrupting the flow of traffic, and who are very near moving vehicles, there’s risk,” he continued, indicating that there are hundreds of fatal crashes in work zones each year.

Road construction is filled with moving parts, between flaggers, surrounding vehicles, and onsite workers. While it’s not possible to control all of these parts around you, you can approach any work zone with confidence by following these guidelines.

  • Be on the lookout for flaggers. Most road construction projects that alter the flow of traffic will use flaggers to direct vehicles safely. Typically located at the shoulder of a work site, flaggers should be easy to spot in their reflective gear. With 20 flaggers killed by motorists each year, though, it’s clear that drivers must be more vigilant about keeping watch for these workers.
  • Put down your cell phone. Mountains of data illustrate the dangers of using a mobile device while driving. Texting while driving, for instance, makes the likelihood of crashing 23 times higher, according to the US Department of Transportation. Circumstances can change at a moment’s notice in a construction zone – don’t compromise your reaction time with cell phone use.
  • Watch your speed. A car driving at 30 miles per hour will likely require over 100 feet to come to a complete stop. Driving more slowly will give you additional time to navigate confusing traffic patterns and react to necessary emergency stops.
  • Maintain a safe distance from workers and other motorists. Transportation incidents account for 40 percent of occupational fatalities in the United States. 70 percent of those are characterized by a motorist hitting a pedestrian worker. By allowing for plenty of space between yourself and others, whether they’re on foot or in a vehicle, you can create a buffer zone for any stops or quick alterations you may have to make.
  • Be courteous. Yes, road construction can be maddening, but flaggers and onsite workers are simply doing their job. Rushing angrily through detours, though, will only increase the likelihood of an accident.

 Road construction is unpredictable. Dangerous situations can seem to pop up out of nowhere. By allowing yourself plenty of space to react and limiting distractions, you can ensure a safer interaction with everyone on the road.

It's That Time Again: Post Your OSHA 300 Log Summary

Koch Peter 1 Posted by Peter Koch

OSHA's  29CFR 1904.1  requires all employers with more than 10 employees to keep a record of workplace injuries and illnesses.  All employers are required to complete this recordkeeping unless they have 10 or fewer employees during all of the last calendar year or the business is classified in a specific low-hazard retail, service, finance, insurance, or real estate industry.  Click on the following link to see a list of Partially Exempt Industries.

Because the OSHA Record Keeping Rule has many facets, this blog will only outline what OSHA requires for forms and posting.  More detail regarding definitions, requirements, timelines, and forms can be found at the OSHA Recordkeeping web page.

As we close the book on 2012 it's time to review the workplace injuries that occurred over the past year, enter recordable injuries on the OSHA 300 Log, and post the summary.  In the Recordkeeping Standard, OSHA outlines:

  • What is considered a recordable injury
  • How injuries are categorized
  • Forms, on which, injuries are recorded
  • How long to post the summary, and
  • How long to keep the forms

Following is a general outline of the steps you have to take to complete the required forms:

  1. Review your OSHA 300 log for 2012 (relevant injuries that occurred January 1, 2012 through December 31, 2012) - 29 CFR 1904.29.
  2. Complete the OSHA 300a Summary form by February 1, 2013 - 29 CFR 1904.32.
  3. Post the OSHA 300a Summary form from February 1, 2013 to April 30, 2013 - 29 CFR 1904.3.
  4. Fill out the OSHA 301, or equivalent form (some state workers' compensation first reports may be acceptable), for each OSHA recordable injury on the OSHA 300 log.

Some businesses receive an Annual OSHA Injury and Illness Survey.  This must be completed as directed in the survey and returned to OSHA or the stated designee [1904.41(a)], in addition to the forms/logs described above.

The forms, instructions, and the OSHA standard can also be found through the following links:

The standard is well written and in a question and answer format. 

A New Year's Resolution we can all benefit from... Improve your Safety Program

EricGrant Posted by Eric Grant

As we begin 2013, if you are like most people, you have probably made a New Year’s Resolution.   Consider the same for your business and more specifically, your injury prevention program.

Consider these ideas or brainstorm with your safety committee and/or leadership team:

  • Focus on company specific exposures - Work with your agent to review injury claims and loss runs.   Refer to your OSHA 300 log to determine areas of opportunity.
  • Develop a formal safety training agenda - OSHA compliance is a start but should not be the finish. Remember 15% of claims are associated with unsafe conditions, but 85% are caused by unsafe behaviors.
  • Conduct quality Event Investigations - Determine root cause and take corrective actions. Remember, look for the Facts, not Fault and operational involvement is key to an effective program. (Visit the MEMIC Safety Director for program materials)
  • Utilize your resources - Internal (supervisors/experienced workers, safety committee, leadership, HR) and external (MEMIC loss control, state consultation services, private consultants, your insurance agency). 
  • Recognize and reward positive behaviors - Consider implementing a formal program that reinforces positive actions taken by employees at all levels.
  • Pre-plan activities with a focus on safety & injury prevention - Have you considered implementing a Job Hazard Analysis Program? This may be the year to get it done!
  • Provide leadership accountability training - Integrate safety with business goals.  Management commitment is one of the foundations of a comprehensive health and safety program.
  • Explore ways to increase employee involvement - Examples include safety committees, routine self-inspections, participation in training agendas, and company sponsored activities/programs.
  • Implement a formal routine self-inspection program - What does OSHA want from businesses? Identify hazards and correct them! Get out there and inspect your workplace and implement follow up corrective actions. 

Reduce injury claim frequency and severity by implementing these nine objectives and communicating them as part of a formal SMART Goal.  To learn more about SMART goals, check out a 2008 Smart Goal posting from the Safety Net, or search online, keyword- SMART Goal (Specific, Measurable, Attainable, Realistic, Timely).

Have a Happy, and SAFE, New Year!