Tag: OSHA

Confined Space Fatality

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Some time ago, OSHA received notification of a construction site fatality where an employee was found at the bottom of a newly installed manhole. The employer was a small construction company that installed water and sewer lines, and was completing a project laying sewer pipe and constructing manholes for a new housing development.

There were six employees on-site the day of the incident. Five of the employees were laying pipe over the hill from the manhole where the incident occurred. The victim was grouting the manhole.

The work area was previously farmland and was slightly hilly. The manhole was placed in the terrain with a slope of 1-4, and was adjacent to entrance ramps to a highway. The manhole had four sections, with a total height of approximately 17 feet when measured on the outside (per drawings). The inside measurement was 16½ feet when measured with a trench pole. All of the sections were made of concrete and were coated with a water proofing substance. Ladder rungs were present in the interior surface.

At the time of the incident and the inspection activity, the inlets were plugged. The project manager installed a vacuum pump at the opening of the manhole and pulled a vacuum to test the tightness of the joints. Because the test failed, the joints required grouting. Workers didn’t follow confined space protocols. Everyone thought there was no hazard because the manhole was new.

Further investigation revealed the vacuum pulled in-ground gasses that suffocated the worker as he descended into the manhole. In the Midwest, acidic soil can combine with limestone (calcium carbonate) causing a neutralization reaction that produces carbon dioxide (CO2). The vacuum test pulled a higher-than-normal level of this CO2 into the manhole space, which displaced the oxygen.

The moral: Be aware that hazards exist in new construction. Confined space protocols were developed to eliminate these hazards. Make sure you understand when and where you should use these protocols.

Download the recording form here.

Powered Industrial Trucks

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OSHA defines powered industrial trucks (PITs) as “any mobile, power-propelled truck used to carry, push, pull, lift, stack or tier materials.” Regardless of the trade, every construction company uses PITs.

Most people think of PITs as forklifts. Forklifts come in many shapes and sizes, and are all regulated under OSHA’s Powered Industrial Truck Standard, 29 CFR § 1910.178. PITs also include man lifts, scissor lifts, boom lifts and motorized hand trucks. Though this Toolbox Talk will often refer to forklifts, the requirements apply to all PITs.

OSHA’S TRAINING AND CERTIFICATION REQUIREMENTS

 The employer must ensure that each PIT operator has had proper training and is competent to operate the truck safely in any environment.

  • Employees must have separate training for each type of PIT they will be operating; however, they do not need separate training to operate the same type of PIT made by a different manufacturer.
  • Employers must develop a written PIT operation training program, and conduct classroom training. They must observe the employee operating the assigned equipment under the physical conditions of their workplace, such as aisles, ramps, loading docks and construction sites.
  • Employers must provide a certificate stating the employee has completed the training.
  • Employees must be retrained and recertified at least every three years, or after an accident or near miss that resulted from an unsafe act.

MAINTENANCE AND INSPECTION REQUIREMENTS

 OSHA prohibits operating a forklift that is not in safe operating condition. The agency also recommends employers conduct an inspection of each forklift at the beginning of each shift, and following maintenance and accidents. Lift operators should use checklists when conducting an inspection and employers should review completed checklists periodically to ensure employees are utilizing them.

Employers must remove a forklift from service under the following conditions:

  • It is not in safe operating condition (example: controls aren’t operating properly);
  • It emits hazardous sparks or flames from the exhaust system;
  • The temperature of any part of the forklift exceeds the normal operating temperature; or
  • It has a leak in the fuel system.

Violations of the PIT standard are often the basis for an OSHA citation. Failure to follow this standard can expose an employer to potentially broad liability.

Download the recording form here.

Weather: Prepare for the Worst

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There’s a lot of talk these days about global warming, melting glaciers and the rising levels of the oceans, and almost every scientist has a different opinion about climate change and its effects. One thing we know for certain: at some point during almost every construction project, you’ll have to deal with severe weather. Because you could experience torrential rainfalls, hail storms, high winds or even a tornado, OSHA requires every company to have an emergency action plan on all jobsites where it schedules work for more than a few days.

Here are the elements that you should include in your emergency action plan, as required by OSHA specification 29 CFR 1926.35.

Emergency evacuation plan

Routinely explain your plan to everyone on the construction site, and clearly state the conditions that require evacuation. Employees should know their escape route assignments before an emergency occurs.

Critical operations

Do not simply abandon exposed electrical circuits or running machines. Account for these operations in your plan; give instructions on what to do; and provide the time you need to shut down safely.

Account for every employee

Appoint one or more individuals to make sure that every worker has left the jobsite if you need to evacuate. Appoint someone at the designated meeting place to account for everyone.

Rescue and medical duties

Make sure site supervisors know the location of medical supplies and the emergency numbers. Train supervisors to know what to do in situations requiring rescue services.

Reporting emergency situations

Communication is critical in an emergency. Your emergency action plan should outline procedures for communicating with employees about what’s happening and the actions they need to take.

Company representative(s) responsible for the plan

Clearly state in your plan who is responsible for each aspect of the plan, and train those individuals to carry out their jobs efficiently.

We cannot control the weather or predict every unsafe condition, but having an emergency action plan in place will help us respond to these conditions safely.

Danger: Fall Zone

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One of the most important steps in planning for, and making, safety a reality on the worksite is knowing where people are going to be working while high hazard activities are taking place. So far in the 2015 construction season, there have been several types of dangerous conditions taking place repeatedly. We must stop these behavior patterns before a life-threatening injury takes place. One of those dangerous behaviors is allowing non-essential personnel in fall zones.

Today we will talk about the necessity to keep the fall zone clear when we lift materials with a crane. The OSHA Crane Standard Subpart CC defines a fall zone as:

“Fall zone means the area (including, but not limited to, the area directly beneath the load) in which it is reasonably foreseeable that partially or completely suspended materials could fall in the event of an accident.”

Suspended loads can fall, and they can seriously injure anyone under, or near, the load in the fall zone. There are times when workers must be in a fall zone area, and OSHA regulations allow for this if they are working on an essential job related to the suspended load. The following standard identifies the essential jobs:

29 CFR 1926.1425(e)(2)

“Only employees essential to the operation are permitted in the fall zone (but not directly under the load.) An employee is essential to the operation if the employee is conducting one of the following operations and the employer can demonstrate it is infeasible for the employee to perform that operation from outside the fall zone: (1) physically guide the load; (2) closely monitor and give instructions regarding the load’s movement; or (3) either detach it from or initially attach it to another component or structure (such as, but not limited to, making an initial connection or installing bracing.)”

Only workers directly involved with managing or rigging the load should ever be in the fall zone. When workers are in the fall zone, the crane operator must know where they are in relation to where the load is and where it’s going. They should either be in the crane operator’s line of sight or in communication with the crane operator. All other employees should stay out of the fall zone until the crane operator delivers the load.

Plan ahead, and stay out of a fall zone. If the lift or rigging fails, you will have saved lives.

New OSHA Construction Standard – Part II

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Last week in our Toolbox Talk about the new confined space regulation (29CFR 1926.1204 Permit-Required Confined Space Program), we defined and listed examples of confined spaces we commonly find in construction activities. Briefly, a confined space is one that:

  • Is large enough and configured so that an employee can bodily enter it;
  • Has limited or restricted means of entry and exit; and
  • Is not designed for continuous employee occupancy.

Confined spaces can present many hazards or conditions that are hostile to your well-being. This week, we’ll cover steps to keep employees safe while working in a confined space.

Once the competent person has identified a confined space, it is the responsibility of the employer to do the following:

  1. Implement the measures necessary to prevent unauthorized entry.
  2. Identify and evaluate the hazards of the space before allowing employees to enter.
  3. Develop and implement the means, procedures and practices necessary for safe entry and operations in the space, including, but not limited to, the following:
    1. Specify acceptable entry conditions;
    2. Provide each employee authorized to enter (or his/her authorized representative) with the opportunity to observe any monitoring or testing of the space;
    3. Isolate the space and physical hazard(s) within the space; and
    4. Eliminate or control atmospheric hazards by purging, inerting, flushing or ventilating the space. [Note to paragraph §1204(c)(4): When an employer is unable to reduce the atmosphere below 10 percent lower explosive limit, the employer may only enter if he/she neutralizes the space to render the entire atmosphere non-combustible and the employees use personal protective equipment (PPE).]
  4. Put monitoring procedures in place that can detect an increase in atmospheric hazard levels in sufficient time for employee(s) to safely exit the space should the ventilation system stop working.
  5. Provide pedestrian, vehicle or other barriers as necessary to protect employees in the space from external hazards.
  6. Continuously verify conditions in the space are acceptable throughout the duration of the authorized entry.
  7. Ensure that employees have the appropriate PPE needed to work in a confined space with a hazardous atmosphere.

Remember: Manage or mitigate the hazards of a confined space before you enter. Your safety depends on it.

New OSHA Construction Standard – Part I

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OSHA published the final rule covering confined space in construction in the Federal Register on May 5. The rule will become law before the end of this summer. With this in mind, all workers and supervisors should understand the general expectations of the law and be ready to comply with the specific requirements.

We rarely encounter confined space issues in some types of construction work. However, because there is a new and specific regulation, compliance officers should be aware of the hazards of confined space and be watchful for possible situations where confined space protocols should be applied.

In order to understand the requirements for this new regulation, we must first understand the definition of confined space. A confined space is one that:

  • Is large enough and configured so that an employee can bodily enter it;
  • Has limited or restricted means of entry and exit; and
  • Is not designed for continuous employee occupancy.

Some of the more common confined spaces we encounter on construction sites include:

  • Pits (elevator, escalator, pump, valve or other equipment. A pit can have a wide-open top and still be a permit-required confined space.);
  • Manholes (sewer, storm drain, electrical, communication or other utility);
  • Tanks (fuel, chemical, water, or other liquid, solid or gas) and machinery (incinerators, scrubbers, concrete pier columns and sewers);
  • Vaults (transformer, electrical connection and machinery);
  • Ducts (heating, ventilation, air-conditioning and all forms of HVAC, air receivers, air preheaters and ID fan systems, bag houses and exhaust);
  • Storm drains (water mains, precast concrete and other pre-formed units);
  • Drilled shafts;
  • Enclosed beams;
  • Vessels;
  • Digesters;
  • Lift stations;
  • Cesspools;
  • Silos; and
  • Sludge gates.

This is by no means a comprehensive list. In fact, the basic definition of confined space can apply to hundreds of situations where workers might be in a hazardous situation, and escape would be difficult.

Part II of this discussion will cover programs to put in place that will provide maximum safety for workers in a confined space.