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OSHA Issued Alert: After Dorian

In the aftermath of Hurricane Dorian, this OSHA issued alert is a great reminder of ways to practice site safety.

OSHA Issued Alert

Recovery efforts after the storm may involve hazards related to restoring electricity and communications, removing debris, repairing water damage, repairing or replacing roofs, and trimming trees. Only individuals with proper training, equipment, and experience should conduct recovery and cleanup activities.

Protective measures after a weather disaster should include:

  • Evaluating the work area for hazards;
  • Assessing the stability of structures and walking surfaces;
  • Ensuring fall protection when working on elevated surfaces;
  • Assuming all power lines are live;
  • Keeping portable generators outside;
  • Operating chainsaws, ladders, and other equipment properly; and
  • Using personal protective equipment, such as gloves, hard hats, and hearing, foot, and eye protection.

“The risk of injuries, illnesses, and fatalities during storm cleanup can be minimized with knowledge, safe work practices, and appropriate personal protective equipment,” said OSHA Regional Administrator Kurt Petermeyer, in Atlanta.

OSHA maintains a comprehensive website with safety tips to help employers and workers, including an alert on keeping workers safe during flood cleanup. Individuals involved in response and recovery efforts may call OSHA’s toll-free hotline at 800-321-OSHA (6742).

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for American working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.

The mission of the Department of Labor is to foster, promote, and develop the welfare of the wage earners, job seekers, and retirees of the United States; improve working conditions; advance opportunities for profitable employment; and assure work-related benefits and rights.

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Fall Protection General Requirements #1 Citation

Fall protection general requirements remains the #1 OSHA citation in 2019. The NSC unveiled this list at this year’s National Safety Council 2019 Congress & Expo in San Diego. This is the ninth consecutive year that fall protection general requirements has been at the top of the list.

OSHA Top 10 2019 – Live from San Diego

Posted by Safety+Health Magazine on Tuesday, September 10, 2019

The top 10 violations cited from October 1, 2018, through August 31, 2019 are:

  1. Fall protection (construction)—general requirements (29 CFR 1926.501): 6,010 violations. The duty to provide fall protection has been OSHA’s top citation for several years. According to Kapust, common violations under this standard included failure to provide fall protection near unprotected sides or edges and on both low-slope and steep roofs. Many of the citations were issued to roofing contractors, framing contractors, masonry contractors, and new single-family housing construction contractors.
  2. Hazard communication (29 CFR 1910.1200): 3,671 violations. Hazard communication has been in the number-two spot for several years. Common deficiencies include lack of a written program, inadequate training, and failing to properly develop or maintain safety data sheets (SDSs). Auto repair facilities and painting contractors were among the industries that received many hazard communication citations.
  3. Scaffolds (construction)—general requirements (29 CFR 1926.451): 2,813 violations. Common violations included improper decking, failing to provide guardrails where required, and failure to ensure that supported scaffolds are adequately supported on a solid foundation. Masonry, siding, roofing, and framing contractors were particularly prone to scaffolding violations.
  4. Lockout/tagout (29 CFR 1910.147): 2,606 violations. Many employers cited under this standard failed to establish an energy control procedure altogether, while others were cited for failing to provide adequate employee training, failing to conduct periodic evaluations of procedures, and failing to use lockout/tagout devices or equipment.  Violations were common among plastics manufacturers, machine shops, and sawmills.
  5. Respiratory protection (29 CFR 1910.134): 2,450 violations. Failing to establish a program, failing to perform required fit testing, and failing to provide medical evaluations were among the most frequently cited issues. Auto body refinishing, masonry contractors, painting contractors, and wall covering contractors received many citations under this standard.
  6. Ladders (construction) (29 CFR 1926.1053): 2,345 violations. Common deficiencies included failure to have siderails extend 3 feet (ft) beyond a landing surface, using ladders for unintended purposes, using the top step of a stepladder, and ladders with structural defects. These violations were common among roofing, framing, siding, and painting contractors.
  7. Powered industrial trucks (29 CFR 1910.178): 2,093 violations. Violations commonly addressed deficient or damaged forklifts that were not removed from service, failing to safely operate a forklift, failing to retain certification of training, and failing to evaluate forklift drivers every 3 years as required. Forklift violations were widespread across a number of industries, but were particularly prevalent in warehousing and storage facilities, fabricated and structural metal manufacturing, and among framing contractors.
  8. Fall protection (construction)—training requirements (29 CFR 1926.503): 1,773 violations. Commonly cited issues include failing to provide training to each person required to receive it, failing to certify training in writing, inadequacies in training leading to the failure of retention by the trainee, and failing to retrain in instances where the trainee failed to retain the training content.
  9. Machine guarding (29 CFR 1910.212): 1,743 violations. Violations included failing to guard points of operation, failing to ensure that guards are securely attached to machinery, improper guarding of fan blades, and failing to properly anchor fixed machinery. Machine guarding violations occur in many industries, but common targets include machine shops, and fabricated metal manufacturing.
  10. Personal protective and lifesaving equipment (construction)—eye and face protection (29 CFR 1926.102): 1,411 violations. A newcomer to OSHA’s top 10 list in 2018, eye and face protection made the list again in FY 2019. Commonly cited issues included failing to provide eye and face protection where employees are exposed to hazards from flying objects; failing to provide eye protection with side protection; and failing to provide protection from caustic hazards, gases, and vapors.
Fall Protection General Requirements
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Personal Fall Arresting Systems

Fall protection is required for any construction employee working at a height of 6 feet or more above a lower level. Personal fall arresting systems are an active style of fall protection that is made up of three components:

  1. A full body harness
  2. A shock-absorbing lanyard or retractable lifeline
  3. A secure anchorage point

When used properly personal fall arresting systems will save a life and prevent injury should a fall occur. Learn more about these components here.

Personal Fall Arresting Systems
Personal Fall Arrest System

When Should Personal Fall Arresting Systems Be Used?

According to OSHA a personal fall arrest system should be used in any situation in which a worker is:

  • Exposed to a vertical drop of 6 feet or more to a lower level
  • Cannot be protected by other passive fall protection, such as guardrails

Personal fall arrest systems should also be used with training from a competent person as part of a fall protection program.

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Fall Protection Changes Happening Slowly

Fall protection changes in the workplace are slow to happen after changes by OSHA. Falls fatalities are the highest they’ve been in recent years which has an increased focus on fall protection in the workplace.

fall protection changes
Overhead Rigid Rail Fall Protection

In 2016, fall protection and fall prevention regulations were modified by OSHA. The fall protection changes require employers to assess worksites for fall hazards, as well as keep records of compliance.

With the increased risk of exposure for organizations, why is there a delay in implementing fall protection changes? The numbers of fatalities are in fact growing. In 2017, according to the Bureau of Labor Statistics, fatalities reached an all-time high of 887. This is an increase of over 36 percent of what was reported in 1995.

fall protection changes
Indoor Access & Platforms with Fall Protection

“I think (employers) are still getting the updates to their facilities into their budgetary cycles,” said Thomas E. Kramer, managing principal of LJB Inc., a firm that provides engineering safety consulting out of its Miamisburg, Ohio, office. “Plus, for roof fall hazards, the most economical time to address these issues is during a reroofing, so this may take a generation of roofs, 10 to 20 years, before we’ve seen significant changes.”

The most significant change from OSHA is that worksite assessments now include fall protection, including hazard identification. By identifying fall hazards on worksites, there is a greater probability that they can be addressed prior to an accident, injury, or fatality.

fall protection changes

After a fall protection hazard has been identified there are several products available with different features and benefits. It is important to have a thorough understanding of the hazard is, whom it affects and how, as well as how often. The greater the knowledge is, the more strategic and cost-effective the solution will be. Contact FPS to learn more about identifying fall hazards and strategic solutions.

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Willful OSHA Violations

A roofing company was found with two willful OSHA violations. The proposed fine for Brad McDonald Roofing & Construction is $274,215.

Willful OSHA Violations

According to OSHA a willful is a violation in which the employer either knowingly failed to comply with a legal requirement (purposeful disregard) or acted with plain indifference to employee safety.

Brad McDonald was cited last year for failing to use guardrails, safety nets, or personal fall arrest systems for workers on a house roof. The fine of $49,796 has not been paid and has since been sent to debt collection.

McDonald has been cited a total of 10 times for not providing fall protection to employees on roofs. However, none of them have been repeat violations. The only repeat violation from the company was for employee’s using pneumatic nail guns without any eye protection.

Rooftop fall protection is readily available via the FPS online store and available at many different price points. Please contact us if you need any assistance with purchasing fall protection for rooftop workers.

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Indoor Fall Protection

Don’t overlook the importance of fall protection in the manufacturing industry. Indoor fall protection is just as necessary as outdoor fall protection when it comes to safety in the workplace. Overlooking the need for indoor fall protection can prove costly both physically and financially.

indoor fall protection
Indoor Swing Away Fall Protection

Indoor industrial work areas such as factories, warehouses, and manufacturing plants are just as likely to sustain slips trips and falls. EHS Today identified the following best practices when it comes to fall safety and indoor fall protection:

  • Maintain good housekeeping practices with clean and clear flooring.
  • Clutter free aisles, walkways and exits are very important.
  • Proper lighting is imperative so workers can see what they are accessing.
  • Utilize the correct fall protection system. Depending upon the application and frequency of use, there are many various options when it comes to proper indoor fall protection from PPE to passive guardrails.
  • Proper training is imperative when it comes to safety and fall protection. Identifying hazards, eliminating them when possible, and awareness are part of a strong safety culture.
loading dock safety gate 01
Indoor Loading Dock Fall Protection
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Fall Hazard OSHA Violation

In a press release early this week, Five Star Roofing Systems has been issued over $200k in fines for a fall hazard OSHA violation. The city is based out of Hartford City, Indiana and was performing commercial roof work in Lake Barrington, Illinois.

Fall Hazard OSHA Violation

During the OSHA inspection, willful, repeated, and serious violations were found:

  • failure to provide head, face, and fall protection
  • improper use of warning lines during low-sloped roof construction
  • lack of guards on belts and pulleys
  • unsafe use of ladders
  • failing to designate a safety monitor

“This company has violated required safety standards repeatedly and placed employees at risk for serious injuries,” said OSHA’s Chicago North Area Director Angeline Loftus. “Employers must develop and implement safety procedures on every jobsite to ensure that employees are protected from falls and other workplace safety hazards.”

Per OSHA regulations the company has 15 business days from receipt of the citations and penalties to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

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OSHA Barge Fall Protection

Preventing injuries & illnesses on barges is important for employers. Approved OSHA barge fall protection keeps workers safe from falls while working at elevated heights. Approximately 4,000 deck barges operate in the United States using a variety of equipment for different operations.

An adequate guard rail should be installed or employees should wear Personal Fall Arrest Systems when work is being performed above a solid surface (e.g., to prevent falls from the barge to the dock).

OSHA, Deck Barge Safety
OSHA Fall Protection System
Approved OSHA Barge Fall Protection System from FPS

A deck barge is a manned or unmanned barge that has a continuous, flat main deck. It is used to carry deck cargo and is also used in the marine construction industry for such work as pier or bulkhead construction, dredging, bridge construction and maintenance, and marine oil service. These types of vessels are not self-propelled.

Regulation of Workplace Safety on Deck Barges

For construction barges underway and other “uninspected vessels,” the U.S. Coast Guard oversees fire and lifesaving equipment and overall navigational matters. Its regulations for uninspected vessels are found in the Code of Federal Regulations, 46 CFR Part 25:

  • Life Preservers and Other Lifesaving Equipment [46 CFR 25.25]
  • Fire Extinguishing Equipment [46 CFR 25.30]
  • Backfire Flame Control [46 CFR 25.35]
  • Ventilation [46 CFR 25.40]
Deck Barge Fall Protection
Overhead Rigid Rail Fall Protection for Barges

The U.S. Occupational Safety and Health Administration (OSHA) exercises its authority to regulate employers for all working conditions not covered by U.S. Coast Guard regulations on these vessels, provided that the vessel is in the geographic jurisdiction of OSHA. OSHA regulations that apply are in 29 CFR Part 1910, with the following exceptions:

  • For ship repair, shipbuilding, and shipbreaking, 29 CFR Part 1915 standards apply.
  • For longshoring and cargo handling operations, 29 CFR Parts 1918 and 1919 standards apply.
  • For marine construction activities, 29 CFR Part 1926 standards apply.

OSHA standards can be found at www.osha.gov

Slips, Trips and Falls | Deck Barge Fall Protection

Slips, trips and falls are major causes of workplace injuries in the maritime industry and can lead to overboard incidents.

  • A slip occurs when the foot skids, usually on a wet or slippery surface (e.g., ice) and the person falls backward or forward.
  • A trip occurs when an obstacle stops the foot and the person falls forward.
  • Same-level falls can be the result of an unrecoverable slip or trip. Another type of same-level fall is a step and fall, when the front foot lands on a surface that is lower than expected. In this type of fall, the person usually falls forward.
  • Elevated falls include falls from stairs, equipment, ladders, and falls through holes in decks, and uncovered or unguarded hatches.

Many factors can contribute to slips, trips, and falls on a barge. Some of these are gear and equipment on the deck, changing walking speed or direction, slippery surfaces (oil, ice and snow), fatigue, carrying heavy objects, visibility, and unsuitable footwear.

Preventing Elevated Falls |OSHA Barge Fall Protection

  • Always maintain three-points of contact on a ladder—two hands 9 and a foot, or two feet and a hand—so that only one limb is in motion at any one time.
  • Avoid overextending the body when performing tasks such as checking sounders, checking lights, and wiring rigging, which can lead to falls from ladders.
  • Falls from portable ladders are one of the leading causes of occupational fatalities and injuries.
  • An adequate guard rail should be installed or employees should wear Personal Fall Arrest Systems when work is being performed above a solid surface (e.g., to prevent falls from the barge to the dock).

Download the OSHA Deck Barge Safety Handbook.

OSHA barge fall protection
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3M™ DBI-SALA® Recall Update

3M™ DBI-SALA® has announced this recall update on the Twin-Leg Nano-Lok™ edge Self-Retracting Lifelines.

3M Fall Protection is pleased to announce it has resolved the partial deployment of the energy absorber that led to the immediate stop use and recall of the 3M™ DBI-SALA® Twin-Leg Nano-Lok™ edge SRL issued in North America on July 25, 2019. A robust solution has been identified, tested and certified to the ANSI standard Z359.14. With this solution, the energy absorber of these units will deploy properly under all circumstances of use for which these products are intended. The affected units can now be repaired and safely returned to service.

recall update

Due to regional regulatory requirements, this solution is currently available ONLY in regions that recognize the ANSI standard. As other regulatory certifications are received, this solution will be made available in those regions. Until your unit has been repaired or replaced as described above, the “Stop Use and Recall” remains in effect and these units must be removed from service. The original Notice and a list of affected products by part number and regulatory standard can be found at www.NanoLokEdgeRecall.com Note: At the time of this update, the solution described above does not include the Twin-Leg Nano-Lok™ Wrap Back SRL or the Twin-Leg Nano-Lok™ edge Tie Back versions.

Users/Owners: Please go to www.NanoLokEdgeRecall.com and follow the instructions on how to return your device. We will inspect and repair or replace your unit and return it to you at 3M’s expense. If our inspection determines that your Nano-Lok needs to be taken out of service for reasons unrelated to the stop use/recall, we will inform you of that fact. To minimize any disruption to your business, we will also provide you a list of authorized repair centers near you that can complete the inspection and repair. Note that cash is no longer an option for owners/users of ANSI versions of the affected units for which a solution is available. The cash option remains available until a solution has been certified for the remaining SKUs (see website for a complete list of SKUs that can be repaired at this time).

Please contact 3M Customer Service for assistance, additional recall information, or alternative solutions at 1-833-638- 2697 or 3musfpserviceaction@mmm.com.

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Construction Industry Fall Protection

Construction industry fall protection information provided by OSHA part 1.

The Continuing Need for Fall Protection

Why Does OSHA Have a Standard for Fall Protection?

Historically, falls are the leading cause of fatalities in construction, accounting for about one-third of all fatalities in the industry. For example, the Bureau of Labor Statistics reported that there were 291 fatal falls to a lower level in construction in 2013, out of 828 total fatalities. OSHA recognizes that incidents involving falls are generally complex events, frequently involving a variety of factors. Consequently, the standard for fall protection deals with both the human and equipment-related issues in protecting workers from fall hazards. This publication is intended to help workers and employers better understand the Fall Protection in Construction standard’s requirements and the reasons behind them.

What Subpart M – Fall Protection Covers

What is Subpart M?

Subpart M lays out the requirements and criteria for fall protection in construction workplaces. For example, it applies when workers are working at heights of 6 feet or more above a lower level. It also covers protection from falling objects, falls from tripping over or falling through holes, and protection when walking and working around dangerous equipment without regard to height. Subpart M provisions do not apply, however, to workers inspecting, investigating, or assessing workplace conditions prior to the actual start of work or after all construction work has been completed. The provisions of Subpart M can be found in Title 29 Code of Federal Regulations (CFR) Subpart M – Fall Protection, 29 CFR 1926.500, 29 CFR 1926.501, 29 CFR 1926.502, and 29 CFR 1926.503. OCCUPATIONAL SAFETY AND HEALTH ADMINISTRATION 2

What are Employers’ Responsibilities to provide Fall Protection?

Initially, employers must assess the workplace to determine if walking or working surfaces have the necessary strength and structural integrity to safely support the workers. Once it is determined that the work surfaces will safely support the work activity, the employer must determine whether fall protection is required (using the requirements set forth in 29 CFR 1926.501) and, if so, select and provide workers with fall protection systems that comply with the criteria found in 29 CFR 1926.502.

When must employers provide Fall Protection? The 6-foot rule.

Subpart M requires the use of fall protection when construction workers are working at heights of 6 feet or greater above a lower level. It applies at heights of less than 6 feet when working near dangerous equipment, for example, working over machinery with open drive belts, pulleys or gears or open vats of degreasing agents or acid.

What construction areas and activities does Subpart M cover?

The standard identifies certain areas and activities where fall protection or falling object protection may be needed. For example, it might require fall protection for a worker who is: on a ramp, runway, or another walkway; at the edge of an excavation; in a hoist area; on a steep roof; on, at, above, or near wall openings; on a walking or working surface with holes (including skylights) or unprotected sides or edges; above dangerous equipment; above a lower level where leading edges are under construction; on the face of formwork and reinforcing steel; or otherwise on a walking or working surface 6 feet or more above a lower level. The standard may also require fall protection where a worker is: constructing a leading edge; performing overhand bricklaying and related work; or engaged in roofing work on low-slope roofs, precast concrete erection, or residential construction. In addition, the standard requires falling object protection when a worker is exposed to falling objects.

What kinds of Fall Protection should employers use?

Generally, fall protection can be provided through the use of guardrail systems, safety net systems, or personal fall arrest systems. OSHA refers to these systems as conventional fall protection. Other systems and methods of fall protection may be used when performing certain activities. For example, when working on formwork, a positioning device system could be used. OSHA encourages employers to select systems that prevent falls of any kind, such as guardrails designed to keep workers from falling over the edge of a building.

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