Working Safely Over or Near Water

Posted by Greg LaRochelle, WCP

With recent hurricanes Harvey and Irma altering the landscape from sinister storm surges and unforgiving flooding rains, it is clear some form of work will need to be conducted over or near water. Whether that means making repairs to a bridge or mending a breach when the levee breaks, in either case, construction contractors and other employers need to safeguard their employees from the danger of drowning.

 

OSHA addresses this hazard in its Working over or near water standard, 29 CFR 1926.106, as follows:

• Employees working over or near water, where the danger of drowning exists, shall be provided with U.S. Coast Guard-approved life jacket or buoyant work vests. (106 [a])
• Prior to and after each use, the buoyant work vests or life preservers shall be inspected for defects which would alter their strength or buoyancy. Defective units shall not be used. (106 [b])
• Ring buoys with at least 90 feet of line shall be provided and readily available for emergency rescue operations. Distance between ring buoys shall not exceed 200 feet. (106 [c])
• At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water. (106 [d])

While the standard is brief in its stated requirements, OSHA has published 18 letters of interpretation since 1990 pertaining to questions on its content posed by the regulated community. One particular letter of interpretation answers a question on the need for a life jacket/buoyant work vest for employees working over water less than two feet in depth as well as the requirement for a lifesaving skiff in shallow water.

OSHA’s stance is as follows: Section 1926.106(a) does not specify a minimum depth of water where a danger of drowning would exist. However, several factors are relevant to determining whether a danger of drowning exists. These include the type (i.e., a pool, a river, a canal), depth, presence or absence of a current, height above the water surface, and the use of fall protection.  

Depending on the factors present, there are some circumstances where a drowning hazard could exist where workers are near or over water that is less than two feet in depth. For example, where workers are not using fall protection and are 10 feet above a river, a worker may fall and be knocked unconscious. Without the use of a life jacket or buoyant work vest, a worker in such a scenario could drown.

However, OSHA adds that if the drowning hazard can be completely removed through the use of 100 percent fall protection (without exception), life jackets/vests would not be required. With regard to the need for at least one lifesaving skiff, OSHA answers the question, in the case of shallow water less than two feet deep, by stating:

"This provision does not state a minimum depth of water required before a lifesaving skiff is necessary. Unlike §1926.106(a), this provision does not include the phrase 'where the danger of drowning exists.'"

"As discussed in the previous question, in certain circumstances, such as where the worker is at a height where a fall could cause significant injury or unconsciousness, drowning in shallow water can result. The purpose of §1926.106(d) is to facilitate the rapid rescue of workers who fall into the water. Even in shallow water, a skiff will greatly reduce the amount of time it takes to reach an employee in the water (unless the employee is working in an area very near the water's edge)."

Of course, if the water were so shallow that rescuers could simply run in (and a skiff would foul on the bottom anyway), a skiff would not be required.

With roughly 71 percent of Earth’s surface covered in water, the destructive power of natural disasters will unfortunately continue to cause hardship for many. For employees involved in cleanup and repair, working over or near water does not need to add personal injury to the insult of devastating property damage.  

 

Only You Can Prevent… Skin Cancer!

 Posted by Peter Koch

These sunny summer days are great. The bright summer sun gives us light, energy, and increases our vitamin D production. However, the same sun that gives us so much can be a hazard for outdoor workers. What are the hazards? Beyond heat stroke and dehydration, the ultraviolet light from the sun can also be hazardous.  Even though we all react differently to sun exposure, statistics show that the stronger the source and more frequent the exposure, our risk of melanoma or skin cancer will increase.

The American Cancer Society estimates that there will be more than 87,000 new cases of melanoma diagnosed in 2017. They also forecast that around 10,000 people will die from melanoma this year.   Lastly, since 2009 there has been a 20 percent increase in new cases of melanoma.

What can you do as an employee? Remember the Smokey Bear slogan about forest fire prevention, “Only You Can Prevent Forest Fires”? Well, only you can prevent skin cancer. The Skin Cancer Foundation and the Canadian Dermatology Association have published some great information on prevention. Heed the warnings and take these preventative measures: 

• Cover up – wear loose clothing, long sleeves and pants
• Protect your eyes – use UV protective eyewear
• Cover your head, neck and ears – wear a wide brimmed hat or a hard hat with a brim and use a neck flap
• Take your breaks in the shade – get out of the sun when you can, especially between 11am-3pm, when UV is the strongest
• Use sunscreen and lip balm – use at least an SPF 30 broad spectrum, water-resistant sunscreen and don’t forget to reapply
• Be skin safe – report changes in skin spots and moles to your doctor as soon as possible – early detection is important

You would think that with all of the information out there, we would take precautions and this alarming trend would begin to decline. However, according to a small scale survey from the Skin Cancer Foundation, only 51 percent of men reported using sunscreen in the last 12 months and 70 percent did NOT know the warning signs of skin cancer. With these survey results, you can imagine this terrible trend in new cases and deaths from melanoma will continue.

What can you do if you’re an employer?

• Educate
  • Inform your staff about sun exposure hazards
  • Provide resources to get their attention
• Provide Opportunity
  • Allow staff to take breaks in the shade
  • Provide ways to create shade where none is occurring naturally (like road construction)
  • Help staff find reasonably priced sunscreen or provide some to them
  • Help staff find reasonably priced clothing that can help block UV rays
  • Consider modifying schedules to limit work during the times when exposure is greatest

If we work together as employer and employee we can help reverse the trend. Here are a list of resources that can help you get started.

Skin Cancer Prevention for Outdoor Workers

Prevention Strategies

Sun Safety and Outdoor Workers

Resources for Outdoor Workers

CDC – Sun Safety

MEMIC Safety Net

Gravity Has A Hold On You

Posted by Richard Berthiaume

Fall-related construction worker fatalities are on the rise despite focused inspections and training, increasing 36% from 2011 to 2015 according to the Center for Construction Research and Training (CPWR). This increase outpaced an increase in construction employment and total industry fatalities.

Employment in the construction industry climbed to 10.3 million workers in 2016, a 16% increase from 2012 states CPWR. Meanwhile, the construction industry experienced a 26% increase in overall fatalities from 2011 to 2015. A total of 367 construction workers suffered fatal falls in 2015.

Data from the Bureau of Labor Statistics includes other findings: 

• 55% of fatal falls came from heights of 20 feet or less.
• 33% of fatal falls involved falls from roofs; 24% involved ladders; scaffolds and staging accounted for 15%.
• Roofers had the fourth highest fatality rate of all civilian occupations in 2015.

The National Institute for Occupational Safety and Health (NIOSH) states falls are the leading cause of death among construction workers, accounting for 37% of deaths in the industry.

Fall prevention and fall protection strategies are commonplace today, but clearly not every employer is compliant with federal OSHA standards or industry best practices.  Requiring employees to be protected 100% of the time should be the rule, not the exception. 

The statistics are staggering and emphasize the need to reduce falls and the importance of ongoing safety awareness training in the construction workforce.  The need for production should never outweigh the need to stay safe on the job site.

Check out these additional resources from Stopconstructionfalls.com, the OSHA Construction eTool, and The Center for Construction Research and Training. 

 

 

Ladder Safety

 Posted by Tonya Hawker

Falls from ladders are a leading cause of workplace fatalities in the United States.  According to the Centers for Disease Control statistics published in 2014, 43% of fatal falls in the last decade involved ladders.  Additionally, ladder use contributed to 20% of non-fatal injuries among the nation’s workers.  It’s not surprising to learn that the leading occupation impacted by ladder falls is construction.  However, the industry following close behind is “Installation, Maintenance and Repair” operations. 

Nearly every business in America includes some level of “Installation, Maintenance or Repair” activity in order to ensure productive and efficient processes.  Whether your industry is Healthcare, Hospitality, Manufacturing, or Construction--- Everyone uses ladders! 

To prevent ladder use injuries, employers should consider the following safe-use practices:

Ladder Condition

Inspect the ladder before each use and include ladders in general site safety inspection routines.  Any damaged ladders should be tagged and removed from service immediately.

• Are all rungs and steps intact and in good condition?
• Are steps clean and free of grease/oil?
• Are support braces, rivets, bolts, and screws in place and secured?
• Are sharp edges or splinters removed?
• Are ropes on extension ladders in good condition (no fraying)?
• Are spreaders and other locking devices in good condition and adequately secured?
• Are safety feet in place?

Ladder Selection

Ladders come in all shapes and sizes, and different work environments require certain ladder types.  Choose the right ladder for the job! 

Ladder Length

• Use stepladders for heights up to 20 feet.
• Use one-section ladders for heights up to 30 feet.
• Use an extension ladder for heights up to 60 feet. (sections must have overlap)

Ladder Rating- ratings are based on weight capacity (worker + equipment)

• Type IAA (Extra Heavy Duty) = 375 lbs
• Type IA (Extra Heavy Duty)= 300 lbs
• Type I (Heavy Duty)= 250 lbs
• Type II (Medium Duty)= 225 lbs
• Type III (Light Duty)= 200 lbs (not recommended)
• Label must always be attached to ladder

Environment

• Don’t use a metal ladder near live electric wires or in corrosive environments.
• Place the ladder on firm level surface.
• Keep area surrounding ladder clear of trash, debris, tools, equipment.

Ladder Set-up

• Extend a straight ladder three feet above the top support.
• Anchor the top of the ladder to prevent displacement.
• Secure the ladder footing or have someone hold the ladder secure.
• Don’t rest a ladder on a window or in a door way.
• Angle straight ladders at a 4:1 slope (distance from bottom to wall= ¼ the ladder’s working length)
• Position an extension ladder before extending it.
• Never use a step ladder (self-supporting ladder) as a straight ladder. Always fully open a step ladder.

Ladder Usage

• DON’T stand on boxes, chairs or anything else. If you don’t have a ladder, get one.
• Wear clean, slip resistant shoes.
• Only allow one person on ladder at a time.
• Always face ladder when climbing up or down.
• Always keep three points of contact with the ladder.
• Carry tools up on a rope or use a tool belt (don’t carry tools in your hands).
• Never use multiple ladders at the same time, or in conjunction with each other.
• Keep your body centered on the ladder (keep belt buckle between side rails).
• Don’t move a ladder while standing on it.

Ladder injuries are preventable.  Human error is the leading cause of ladder injuries.  If you plan ahead, use the right ladder for the job, and train workers to use ladders safely these injuries can be prevented.  For more information on ladder safety, check out these resources from OSHA, Washington State DOL Ladder Safety Guide, Ask This Old House, and the NIOSH Ladder Safety App. 

 

It’s Road Construction Season Once Again

Posted by Randy Klatt, WCP®

While many areas of the country experience road construction year-round, summer generally means an uptick in highway projects.  Summer also brings an increase in traffic as people head out on vacations.  This is especially true this year with the lowest July gas prices since 2005.  Combined increases in both traffic and construction poses obvious challenges for both motorists and construction crews.

According to the Bureau of Labor Statistics, there were 2,054 workplace fatalities in 2015 involving transportation (42% of all workplace fatalities in 2015).  Roadway incidents involving motor vehicles and pedestrians struck by vehicles accounted for 1,553 of those fatalities, and 130 of those fatalities occurred at road construction sites.  Total fatalities in work zones, including pedestrians and motorists not at work, totaled 700.  Needless to say, more focus is needed in an industry where workers on foot are intentionally placed in close proximity to moving traffic.

Source:  https://www.workzonesafety.org/files/documents/crash_data/Alliance_roadway_fatalities_graphic.pdf

Each year speeding is found to be the most common cause of traffic crashes.  Since nearly half of roadway fatalities result from employees being struck by moving vehicles a reasonable recommendation is to slow down!   Highway work zones often have reduced speed limits posted, and many states double the fine amount for exceeding those limits.  Motorists must be more vigilant when approaching construction sites.  Expect workers and heavy equipment to be moving around the site frequently and adjust speed accordingly.  Driving more conservatively will get you to your destination, and avoid the frustration and increased risk of a crash that comes with driving faster.  By the way, it will also save money in fuel and car

Following flagging personnel direction is also critical for everyone’s safety.  Flaggers have an important role and distracted or impatient motorists make the job much more difficult and hazardous.  Look for these workers along the roadway and expect stop and go traffic.  Leave a safe following distance between vehicles and avoid other distractions. 

Employers should be setting up work zones in accordance with the Manual on Uniform Traffic Control Devices (MUTCD) and any applicable state supplements, or state MUTCD publications as applicable.  Ensuring flaggers are properly trained and equipped is also vital to safe operations.  Flaggers should never assume that motorists see them.  In fact, flaggers should assume that passing motorists don’t see them.  Stay out of the traffic lane and always be alert for oncoming traffic and never turn your back to oncoming vehicles.    

More information can be found from OSHA on their Highway Work Zones and Signs, Signals, and Barricades webpage, the National Work Zone Safety Information Clearinghouse, the Federal Highway Administration, and the National Institute for Occupational Safety and Health (NIOSH).  By working together this summer we can all enjoy the great outdoors and family vacations, and keep our road workers safe as they build and maintain our roadways.  Take your time, be courteous and patient, drive sober and well rested, and we’ll all Arrive Alive.

 

 

Load Limits for Structurally Supported Surfaces

Posted 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.)

 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: The "Whole" Story (Cont.)

 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.”¹  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.

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¹ https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

² https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

³ https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf

 

Confined Spaces in Construction: The "Whole" Story

 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.

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 ¹ https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf
 ² https://www.osha.gov/confinedspaces/index.html

 

Combustible Dust: Good Housekeeping Practices Could Save Your Business

 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 Board.  MEMIC policyholders can watch a webinar on combustible dust at MEMIC Safety Director.  The 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:

 

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