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Warehouse Forklift Safety Essentials


Forklifts, excavators, aerial lifts, dump trucks  – many of us work around these machines on a daily basis, whether it be as an order picker in a warehouse, a flagger on a construction site, or an inspector.  After a while, if we’re not careful, the equipment could begin to blend into the background.  When that happens, people get careless.  While there need to be safety precautions in place that make the operators of mobile equipment responsible for the well-being of people on the ground, the pedestrians themselves need to adhere to rules as well, in the interest of self-preservation.

Never Assume

The first thing needed to keep pedestrians safe is a simple “rule-of-thumb”: never assume an operator knows you are there.  Whether the operator actually knows or not is irrelevant if you don’t know that they know.  It would not take much for one of these machines to end your life, so why take the chance?  Even if you think an operator is aware of your presence, make sure they know.  Wave them down.  Make eye contact.  Indicate where you are going.  Let them know when you are clear.  We all know the old saying about assuming, but I assure you, if you assume wrong in this instance, it’s going to be a whole lot worse than just looking silly.

High-Visibility Clothing

Operators can’t look out for us if we aren’t visible.  Street clothes, muted colors, or colors that blend into the background all cause dangerous situations.  Anybody that needs to be on the ground near mobile equipment should be wearing high-visibility clothing.  Whether that means reflective vests or brightly-colored T-shirts really depends on a hazard assessment of your operation.  Once you determine what you need, however, enforce it.  Ensure your management personnel adhere to it, too.  They’re no more immune to being run over by a 5,000 lb. machine than is a member of the labor workforce.  Finally, have extras.  People are going to show up and need to get around your facility.  Some of them will not bring their own high-visibility gear.  Make sure you are prepared to offer them something you’ve got ready to go.

Limited Personnel and Dedicated Walkways

One of the best ways to protect pedestrians on your site is to keep the number of pedestrians there are to an absolute minimum.  An operator can’t run over somebody that isn’t there.  Ensure that work areas are only being accessed by the necessary personnel.  Ensure that anybody else accessing your work area is escorted by somebody who is used to your operations.  And, where possible, limit the places they can travel.  This may be easier in a warehouse than it is on a construction site, for example, but if you can delineate areas that are acceptable for pedestrians, then do so and enforce it.  If possible, a permanent barrier like railing and safety gates may be a good option. Make sure your delineations are easily recognizable and maintained.  A painted line on the floor is no good if it’s been worn away.  A flagged off area is no good if the rope has snapped and the flags have blown away.

Spotters

Where operators have limited visibility, use spotters who can stand somewhere that gives them a better vantage point on what’s going on around the equipment.  Train your spotters on hand signals so that your equipment operators can quickly communicate with them even if you have electronic communication.  Remember, electronics can fail and words can be misheard.  In an emergency situation, you may not have time to account for that.  One issue with spotters, though, is that they, too, are pedestrians. Your operator needs to be trained that if they are working with a spotter and they lose sight of that person, they stop the equipment immediately.

Backup Alarms

I put backup alarms low on this list for a reason.  First, they only operate when a piece of equipment is backing up.  They are there because the operator cannot see clearly (if at all) behind their machine, but it is assumed that they can see just fine moving forward.  Obviously, this isn’t always the case.  Second, on a construction site or in a warehouse these can be so prolific that people just start ignoring them.  These are great to have, but you cannot be dependent on them.

Training

This one is going to pop up on just about every list we make.  None of the things we’ve listed do any good if the people involved are not properly trained.  In this case, that could apply to somebody who is just making one quick stop to your site or facility.  It isn’t necessary to have a 2-hour long training, but talk to the person, make sure they’re wearing what they need to be wearing, and make sure they know about your walkways or controlled areas.  Do not allow anybody to walk out onto your site blindly.
Remember, in the battle of man vs machine, when it comes to a matter of brute force, the machine is always going to win.  People may need to be reminded of this.  There is a reason why “struck by” is one of OSHA’s Focus Four – because these terrible accidents occur.  Don’t allow your people to be careless around mobile equipment.

 

Warehouse Forklift Safety Essentials

Warehouse Forklift Safety Essentials


With the number of transient workers that come through warehouses, the hustle and bustle of getting orders shipped out and deliveries onto the racks, and a variety of other concerns, having a strong forklift safety program is essential.  A quick walk through many warehouses will show machines being driven faster than they should be, unsecured or uneven loads, forks being raised and lowered as lifts are turning, and random foot-traffic.  Remember, you, as a pedestrian, will not win against a machine that weighs thousands of pounds!  So, where can we focus our attention?

Training

No article can substitute for forklift operator training, which you know, all of your operators MUST have, right?  AND that they must be reevaluated at least every three years, right?  OK, good.  Just checking.  Too often, I have seen new warehouse workers put in a situation where they are just expected to figure it out.  Train your employees properly.  Observe them while they’re working.  Are they constantly going too fast, coming around corners or into intersections without slowing down or beeping, driving with their view obstructed, or raising/lowering loads while they’re moving?  That employee may need to be retrained.  If you don’t have somebody who is able to do that ongoing evaluation, you need to properly prepare somebody to fill that role.

So, what should training and evaluation of safe forklift operation focus on?  Speed (no faster than a person walking quickly), following distance (three forklift lengths), knowing the capacity of your lift and checking the load to ensure its within that capacity, stability of loads, stability of the lift and how it changes as the center of gravity changes, not raising or lowering forks while moving or turning, lift inspections, traveling backward and/or spotters, unattended lifts, use of lifts on slopes, lifting and setting of material, and fuel safety precautions.  After reading that list, are you still comfortable telling an untrained person to “just do it”?

Foot Traffic

It’s hard to operate a forklift safely if you have to constantly dodge unexpected pedestrians.  People randomly wandering the floor of your warehouse pose both a threat to themselves and a threat to the men and women on your forklifts.  In order to avoid this, you should have designated walkways and a restriction on who can be on the warehouse floor.  Sure, they will not be able to stay within these walkways 100% of the time, but if you have a restricted group that is allowed to be there, you can train them to take extra precautions when they have to leave the area.  Railing and safety gates may also be a viable option, restricting foot traffic to the designated walkways in certain high traffic areas.  Meanwhile, forklift operators know to take extra precautions around the walkways.  Also, make your pedestrians visible; require reflective vests or high visibility shirts for anybody who needs to be on foot.

Pallet Racks and Shelving

The ends of pallet racks are often damaged when a driver attempts to turn down an aisle and accidently clips or runs into a rack, resulting in significant damage to the rack and potential damage to the goods being stored on the rack.

Making sure your aisles are wide enough is a helpful first step when trying to avoid these types of accidents. Your driver may simply not have enough space to perform the maneuvers he needs to get around the warehouse.

Enforcing the speed limit we talked about earlier is also important. If the driver is going a reasonable speed, he is more likely to be able to correct a miscalculation before he actually collides with the rack.

Bollards
and impact barriers are also a good way to protect the corners of your racks. Not only by providing a barrier between the forklift and the rack, but also providing higher visibility.

Fuel

Some of the biggest hazards associated with forklift usage aren’t necessarily always from the forklifts themselves.  How are the forklifts in your warehouse powered?  Propane? Electric?  Diesel?  You’ll have a variety of reasons behind your choice, but be aware that each one poses a hazard that you must consider.  Diesel, gasoline, or any other internal combustion is probably a bad choice for most indoor uses.  We all know the byproduct of incomplete combustion, right?  Carbon Monoxide.  And while open overhead doors, ventilation, and large spaces may help mitigate the amount of carbon monoxide your employees are exposed to, what about the employee who takes that forklift into the back of a truck and leaves it running while they secure the load?  If you need to use this type of forklift, you’ll probably want to ensure you have the proper scrubbers on the exhaust, train your employees to recognize signs of carbon monoxide exposure, and prohibit running the engine in trailers or other confined areas.

LPG or propane burn cleaner, but pose their own hazards, flammability and skin exposure among them.  Propane and LPG are flammable and, being heavier than air, will seep along the floor until possibly finding an ignition source, rather than disperse up into the air.  Precautions need to be taken not just during their use, but also in the area in which you’re storing them to ensure you have proper firefighting methods available.

So with all the hazards that those fuels create, why not just go electric?  Keep it simple, right?  No fumes to worry about.  But, the reality is, of course, that electric forklifts have their own set of issues.  Now you have to worry about charging stations, ventilation of those stations, eye wash stations, training your people to properly handle the batteries and more. 

Unless you’re using manual lifts, you’re going to have fuel-related hazards and you’re going to have to train your people on those hazards and how to work safely.

Classified Areas

If you have areas in your warehouse that are classified as hazardous locations, you need to ensure that your forklift is designed to be operated in that area.  29 CFR 1910.178(b) and (c) designate 11 forklift classifications and a listing of classified locations in which each type of lift can be used.

Inspect, Inspect, Inspect

Just like any other piece of equipment, forklifts need to be inspected prior to use.  How are the tires?  Is there a properly charged fire extinguisher?  Do all of the controls work properly?  Do your blinkers and horn function properly?  Are your mirrors in place?  Are there any leaks?

But inspections are not just limited to the equipment itself.  What about the conditions of the warehouse you’re working in?  Is the floor level?  Are there any overhead obstacles you need to be concerned with?  Are there any ramps you will have to traverse?  Pipe leaks, leaks from other machines, or any other spill that could cause a problem for you?

And don’t forget trailers.  If you’re about to load or unload a truck, you have more inspections to do.  Is the floor of the trailer capable of supporting the weight of the lift and load?  Is it in good condition?  Are the wheels chocked or is the trailer otherwise secured?

Never take for granted that somebody else has checked the things that your safety and well-being depend on.  Inspect, inspect, inspect.

Conclusion

There is no lack of danger in a warehouse.  Forklifts will always pose some danger to warehouse workers, but that danger can be exponentially increased if the lift isn’t being operated properly.  Train your operators how to safely handle the machines and train your people on the floor how to behave around lifts.  If everyone works together, everyone goes home safe at the end of the shift.

 



How to Run an Effective Toolbox Talk

How to Run an Effective Toolbox Talk

Toolbox talks, tailgate meetings, pre-work safety meetings – whatever you want to call them, these brief safety sessions can be a valuable opportunity. They help focus your workforce on safety, prior to the beginning of their work shift, and they are an opportunity for you to ensure that all of your employees are fit for duty.

Or, they can be dreadfully boring, disorganized, snooze-fests.

Meetings for the sake of meetings are inefficient and often serve no purpose other than giving the workforce something to complain about.  Your toolbox talks need to be run properly to ensure that your workers are not just paying attention, but benefitting from the time spent.  They need to be run in a way that will remind your employees what they should be concentrating on or to impart brand new knowledge on them.  If your workforce is bored, distracted, or otherwise disengaged, you will achieve nothing other than keeping your people from working. 

So, how do you do it right?

Don't Read to Them

If you think grabbing the safety write-up that gets emailed to you weekly and reading it to the workforce is going to get the job done, think again.  Nothing is easier to tune out than somebody reading words off a page.  Unless you’re planning on doing impressions and cartoon voices, your employees will see this as nap time.  Doing it this way makes it harder for you to put any feeling into what you’re saying, difficult to make eye contact with the people you are addressing, and it puts the idea in the mind of your audience that maybe you don’t know anything about the material you’re trying to present to them.  Read those weekly mailings (if that’s what you’re using) ahead of time.  Familiarize yourself with the topic.  I know we’ve all got a love/hate relationship with the internet, but here’s an opportunity to take advantage of the “love” part of it.  Do some research.  Find news stories relevant to what you’re discussing and other supplemental information. Show your workers how your topic applies in the real world. If you need inspiration or ideas on what to discuss with your team, subscribe to the Simplified Safety newsletter. Just don’t read right off the page!

Engage your Audience

So, once you’re armed with all the information the internet can provide (from reputable sources, please!), what’s next? 

Have a conversation. 

Talk with your employees about the chosen safety topic, not at them.  Think back to your school days.  Which classes did you find more entertaining: the ones where your teachers engaged you and got you to participate, or the ones where the teacher stood in the front of the class and lectured at you…on and on and on?  I’m guessing the former.  And, make no mistake, entertainment is important.  No, you don’t have to tell jokes and juggle (though juggling would be cool…just not knives…or fire…these are safety meetings for Pete’s sake!), but you do need to give your audience a reason to want to pay attention.  Don’t speak in a monotone voice unless you want to lull your employees off to La-La-Land.  DO tell related stories from personal experience, ask questions of your audience, and have them tell their own personal anecdotes (but don’t let this run wildly off topic or take an inordinate amount of time - you still need to control the meeting).  Do all this and watch their attention grow.  The more they pay attention, the more they’ll learn.

Be Relevant

Does most of your work involve digging excavations?  Then don’t do a toolbox talk on steel erection.  Do you do a vast majority of your work at heights?  Then why are you discussing forklift safety?  If your topic doesn’t apply to the work you do, then why teach it?  Now, there are topics that don’t apply as much as other topics do or as frequently, but still apply.  You don’t need to eliminate those, though they may only serve more as backup topics once your main topics are exhausted. However, if the topic has nothing to do with what your people do then toss it.  Find a replacement.  Try and have a backlog of topics. The Simplified Safety blog archive is a great place to find inspiration.

There's a Time and Place

If my parents told me this once they told me a thousand times, “There’s a time and a place for everything.”  I’m sure many of you are nodding your heads in agreement.   And, most of the time it was followed by, “And this is neither the time nor the place!”  Well, luckily my judgment has improved over the years.  And you know what?  Mom and Dad were on to something.  When and where you hold your toolbox talks play a big part in how successful or unsuccessful they will be.  Holding a toolbox talk in the work area is a good idea because it may be easier to demonstrate something you’re teaching or it may just mean people are already focused on their work.  It can also be a terrible idea if the work place is loud, uncomfortable, or offers other distractions.  Immediately following lunch can be a great time to hold a meeting because you can find everybody in one place, but it could also be a terrible idea as everyone struggles to fight off their food-comas.  Make sure that the time and place you choose to hold your meeting is conducive to learning because that’s the ultimate goal.

Toolbox talks don’t have to be tricky.  Sure you might be a Pinterest-level demonstrator who’s got all kinds of fancy, outside the box ideas and visual aids, but you can hold a great toolbox talk without all that.  Just remember though, while it can be simple to have a great toolbox talk, it’s also fairly easy to turn a topic that had potential into a poor use of company time.  As the Boy Scouts say, “Be Prepared.”  Know your material, know your audience, know your environment, and make sure everything you plan works within those parameters.  If not, change it up.  Better to delay a toolbox talk and get it right, than to have your workers walk away from your meeting with nothing to show for it. 


The Hierarchy of Controls, Part Four: Personal Protective Equipment

The Hierarchy of Controls: Part Four

Of all of the controls in the Hierarchy of Controls, Personal Protective Equipment (PPE) is the one most people are familiar with.  Why?  Well, PPE is quick, easy, often less expensive than other options, and readily available.  What you might not realize, though, is that PPE is what OSHA considers to be a “last resort”.  When it comes to the Hierarchy, PPE is supposed to be used either a) while other controls are being implemented, b) in conjunction with other controls or c) when all other options have been exhausted.  In other words, a full body harness should not be your go-to fall protection solution. Yet, so many companies turn to PPE first.

Personal Protective Equipment really is exactly what the name implies: protection you use personally.  So, while a personal fall arrest system is considered PPE, a guardrail is not.  While a respirator is considered PPE, ventilation is not.  PPE includes most things required to be worn on the job, such as earplugs or other forms of hearing protection, hardhats, safety glasses or goggles, face shields, gloves, coveralls, steel or reinforced-toe boots, reflective vests, and so much more.  PPE is so prevalent among the workforce that you’d think injuries would be virtually non-existent, but they’re not.  Why?

Insufficient / Wrong PPE

PPE sometimes gets thrown at a hazard without really evaluating the situation.  Hearing protection is great, but does it do the necessary job?  Ear plugs are rated for noise reduction, so how do you know that grabbing that pack of earplugs out of the jar in the office will reduce the noise below acceptable levels?  Has a noise survey been performed?  If so, was the equipment selected based on that survey?  Or in terms of respiratory protection, has anybody determined what the dust in the air is composed of before deciding to buy a cheap box of dust masks?  Even if you know what the dust is made of, has anybody sampled to determine the levels to which your employees are being exposed?  PPE is not a game of guesswork, though it might seem that way if you were to wander into various workplaces throughout the United States.  Careful consideration needs to be taken to determine what PPE is appropriate to protect your employees from workplace hazards

PPE is Not Properly Cared For / Used

PPE is only as good as the user.  Safety glasses offer no eye protection if they are constantly left on top of the user’s hardhat.  A reflective vest offers no visibility if the user throws a coat over it when he or she is cold.  A respirator may do more harm than good if hazardous dust is allowed to accumulate on the inside of it and it is not properly cleaned.  A full body harness, rather than save your life, could cause serious internal damage and other bodily harm if it’s not worn properly.  Using PPE as a hazard control includes using it properly, maintaining it properly, and caring for it properly.  Harnesses are supposed to be kept hung in a cool, dry place, yet how many do you see lying around a jobsite or in the back of a truck exposed to sunlight (UV decay), rain, freezing temperatures, and more?  When that harness fails, is it because it was the wrong equipment?  No.  It wasn’t properly cared for.  Respirators should have change out schedules depending on the filters you are using and exposures your employees have.  Does your plan have one?  If not, how do your employees know when to get new cartridges.  Do they know to get new cartridges?  And can a user even use equipment properly if they don’t know if it should even be used in the first place?  Are your employees inspecting their PPE or are they just pulling it out of the toolbox and going to work?  How will they know if something has gone wrong if you do not have them doing inspections?  You can’t throw PPE at a problem and expect it’s going to help without the proper preparations.

Training

Which brings us to our next point: training.  How do you expect your employees to know how to properly inspect, use and care for their equipment?  If you don’t train them, there’s a good chance they may barely be able to figure out how to put a harness on, let alone how to put it on properly.  If you don’t train them, they could be using a respirator with cartridges that have broken through, but they have no idea because the hazard is not one they can smell or taste.  They may be using ear plugs that should do the trick, but have been inserted improperly.  You can’t assume people will just know what to do.  Not only is training a good idea, but it’s required by OSHA.  Take the time necessary to ensure your employees are able to keep themselves safe.  You don’t need to do an eight-hour training to show employees how to wear earplugs, but you do need to do some training. 
The Hierarchy of Controls is a phrase used often in the safety and industrial hygiene world.  If you weren’t familiar with it before this series, hopefully now you’re better informed.  Of course, now that you know what it is, there’s still a lot of work to do: you still need to investigate your hazards, you still need to determine what the best possible control is, you still need to design and implement that control, and you still need to train your employees.  A breakdown at any step could cause failure.  And, when human lives are at stake, failure is unacceptable. 

 


The Hierarchy of Controls, Part Three: Administrative Controls

The Hierarchy of Controls: Part Three

In the first two articles on the Hierarchy of Controls, we discussed controls that were intended to mitigate hazards at their source either through elimination, substitution, or an engineering solution that made it so the employee was no longer exposed.  With administrative controls, we take a little bit of a turn from that approach. At this point in the hierarchy, the reality is that the hazard is one that must be – or can be – lived with, so long as certain precautions are taken or certain levels of exposure are not exceeded.  Administrative controls, which may be used in conjunction with engineering controls and/or PPE, would also be required if work was to continue while engineering controls are being developed.  Ultimately, though, administrative controls are not the optimal solution and cannot be the selected method of abatement if a hazard, or employee exposure to that hazard, can be eliminated.

Examples of administrative controls are fairly simple: warning alarms, for example, are just that – alarms that let you know when something isn’t right.  An alarm might notify you of something as common as a guard being left open on a machine in a manufacturing process or it might be on the rotating structure of a crane working near power lines that could not be de-energized, to let you know you cannot swing any further.  Obviously, neither of these by themselves would eliminate a hazard, but they would provide an employee with a warning.  A more effective approach for the guard would be an engineering control: to have an interlock that prevented the machine from running when the guard was open. Without it, an employee could ignore the alarm and reach into the machine.  For the crane, the alarm would not prevent the crane from swinging closer to the power lines.  Instead, you are relying on the operator to heed the warning.

Labeling systems would also be considered administrative controls.  We see safety labels everywhere, but clearly they are not sufficient to protect workers.  Labels are often used along with other controls to keep employees safe.  Warning of high voltage, a certain chemical in use, or that an area is a high-noise area, among many other things, labels act as a good reminder for workers not to enter areas in which they do not belong, to follow certain procedures, or to wear certain PPE.  They, alone, will not protect a soul if they are not heeded by the employees.

This brings us to another form of administrative control: training.  You can put as many engineering controls in place as you want, you can require PPE, you can warn of hazards in an area, but if you don’t train your employees how to comply with the safety requirements, controls can still be bypassed.  Somebody who is not trained on the dangers of entering a high noise area may think it’s really not that big of a deal, for instance.  Perhaps you’ve substituted a non-silica product for sand in your sandblasting operations, but you still need sand in your facility for other applications.  If you don’t train your employees on the hazards of silica as well as what your new procedure is, how will they know to use the safer product (or why will they bother if they can’t find any, but sand is readily available)?  You may not have realized that training was an administrative control, but hopefully you’ve been using it all along.

One final method that needs to be discussed is a little more on the complicated side, compared to other administrative controls.  Reducing the amount of time somebody is exposed to a hazard can be an effective control, but it’s not as simple as placing a sign or adding a warning alarm.  For instance, hazards like noise and chemical exposure are often given permissible exposure limits (PELs) by OSHA that are measured in time-weighted averages (TWAs).  So for instance, Carbon Monoxide (CO) has a PEL of 50 parts per million (ppm).  This does not mean that the moment somebody is exposed to Carbon Monoxide in an amount greater than 50 ppm they are going to die, it just means that when you average out the amount an employee is exposed to over the course of an eight-hour day, it needs to be below 50 ppm.  There are also Short-Term Exposure Limits (STELs) and Action Levels (ALs) to be concerned with, and though we can see that determining an allowed exposure time might be a bit involved, we’d need more room/time than this article allows to go into detail on it.  Suffice it to say, as long as employee rotation through a job can keep the employee under all applicable limits, then it is an acceptable solution. While CO has a limit, in many cases, employers would find the source of emission and eliminate it because CO is much too dangerous.  A more common application of controlling exposure time might be in a high noise area or a hot work area.  By rotating other workers into these areas throughout the day or by simply putting a cap on the amount of time spent in them, workers can be kept below the allowable exposures for noise or heat.

Administrative controls can be simple, but remember, they are often not the best or sole solution.  Using administrative controls should almost always be looked at in the context of other controls that are being put in place to determine how they can be paired to provide employees with the best actual protection possible.  Now, with elimination, substitution, engineering controls, and administrative controls covered, we are left with one final level of the hierarchy in the next article: PPE.  Yet, if it’s the final level of the hierarchy, why is it that it is so often the first solution employers turn to?  The final article in our series will explain just that.

 


The Hierarchy of Controls, Part Two: Engineering Controls

The Hierarchy of Controls: Part Two

In the last article, we discussed the first level of control when it comes to protecting employees from recognized hazards: elimination or substitution.  The concept, while possibly difficult to implement, was simple to understand.  Unfortunately, this second step, engineering controls, is often more difficult in both concept and implementation.  (Note: there seem to be two schools of thought on this hierarchy or controls.  One is that substitution and elimination fall under engineering controls and the other is that they are separate.  For the purpose of this article series, we’ve chosen to separate them into different categories.)

Engineering controls, to put it as succinctly as possible, are methods designed to get as close to eliminating the hazard as possible, without actually eliminating it.  This is done by designing something into the facility, the piece of equipment, or the procedures themselves to reduce the hazard or the employee’s exposure to it.  As long as they are designed properly (and used by employees properly) they tend to be very reliable.

An example of an engineering control is isolating a hazardous portion of the process.  In manufacturing, for instance, a part of the process may be spray painting parts.  This task poses both health and ignition concerns.  In order to isolate the hazard, many manufacturers would utilize a spray booth.  The booth prevents the worker from inhaling the paint fumes and paint residue while also reducing the risk of explosions and fires.  A glove box for handling hazardous materials and chemicals is another example of isolation as the box allows the employee to do the work while not being exposed to the material/chemical.

A process change is also considered an engineering control.  This control is common (though maybe not common enough) when dealing with silica.  Using water to suppress concrete dust or a HEPA-filtered vacuum attachment to remove the dust from the air are not only good controls, they are – in ways – integrated right into the new silica standard.  Automating the hazardous work so that no employee has to be exposed is another example of a change in process.

Another option is ventilation, the most effective of which is local exhaust.  Local exhaust removes the hazard (in this case, a fume, gas, vapor, or dust) at its source, while general ventilation allows the hazard into the work area as it’s diluted to an acceptable level or as it’s pulled or pushed (depending on whether it’s a positive or negative pressure system) into an exhaust duct, door or window.  Dilution methods are really only able to be used in very low toxicity situations where employees are able to maintain a safe distance from the source.  General ventilation can be costly as large amounts of air need to be moved in larger spaces and that air often needs to be temperature controlled to keep the workplace comfortable.

Often, an engineering control doesn’t exist in a vacuum.  Some need to be used in conjunction with other controls, such as personal protective equipment, to ensure they are used and working properly.  Training is always required because no system is human-proof. In fact, engineering controls are definitely not a one-size-fits-all solution.  Before one is selected, it’s necessary to look at a number of factors.  How easy is it to use?  Your employees are going to be expected to use it properly.  An over-complicated system could greatly increase the possibility of human error or, worse yet, the possibility that your employees choose to attempt to bypass the system.  How reliable is it?  Engineering controls need to have a practically perfect rate of success.  If they don’t, not only are your employees not protected, but they may be operating under a false sense of security.   How much does it cost?  Yes, as safety professionals we like to think it’s “protect the employees, no matter the cost!” but in the end, employers do still exist to make a profit.  That’s not to say that a company will not implement necessary controls, but they’re not going to be happy if they spend a fortune on one solution only to discover that there is a cheaper and equally effective solution available.  Do your homework before selecting any one option.

Engineering controls are your best option when the hazard cannot be eliminated.  Ensure the safety of your employees by selecting/designing the proper solution and then train your people so that the control works as intended.  If the possibility of substitution, elimination, or engineering controls all fail – or if you simply as desire additional protection – administrative controls will be the next step.


The Hierarchy of Controls, Part One: Elimination and Substitution

The Heirarchy of Controls: Part One


If you’re a safety professional, it’s been ingrained in you since you were in diapers sitting through your first OSHA 30 hr. How many times have you caught yourself in a conference room shouting, “But don’t you understand?? PPE is a last resort!”?  Countless, I’d imagine, but the problem is that PPE is what people know.  PPE is easy and readily available.  Ask somebody what engineering or administrative controls they could have used to abate a hazard and they’ll look at you like you’re still wearing diapers (that is, assuming you’re not).

For those unfamiliar with the hierarchy of controls, a tiered approach to solving problems might seem alien.  Even for the initiated, some aspects of the hierarchy can be confusing.  So, rather than just tell you what the hierarchy is at face value, let’s take a more in-depth look at each level, starting with two of the easier concepts: elimination and substitution.

Elimination

The concept of elimination is easy, because it’s as simple as it sounds.  Take the hazard that your employees face and eliminate it. Done, piece of cake.

Right?

Maybe not.  The problem with elimination is that if the implementation of it was as simple as it sounds, everybody would be doing it, wouldn’t they?  What company would not choose to completely eliminate the chance of their employees getting hurt if doing so was simple?  Not many, I’d venture.  In fact, according to the hierarchy of controls, if Elimination is available to an employer, it is the option they must choose.  Remember, the employer has a duty to provide a workplace free of hazards to their employees.  If the employer is able to do that, but chooses not to, they could be looking at a Willful violation, should an OSHA inspection occur (not to mention employee injuries and fatalities that might occur due to your failure to remove the hazard).

If we are talking about elimination in terms of equipment or materials, such as removing some flammable gas containers from an area where hot work is being performed or eliminating an unnecessary blade on a machine, the solution should be 100% effective, as long as there isn’t a communication breakdown that allows somebody else to reintroduce the hazard back into the workplace or process.

Substitution

Again, this is pretty much what it sounds like.  With substitution, we are identifying a hazardous substance or piece of equipment and substituting a substance or piece of equipment that is not hazardous.  For instance, instead of a solvent-based paint, use a water-based paint.  Instead of sand-blasting, use a non-silica containing abrasive material.  If an alternative product exists on the market, substitution can be a very effective solution.

Except, there’s a reason why the hazardous versions still exist.  If the substitutions were perfect, they’d force the hazardous substances off the market.  So why don’t they?  Well, the downfalls of substitutions tend to usually be quality and cost.  Let’s take the paint example.  Paint used to be almost exclusively solvent based, but solvent based paints are high in VOCs (volatile organic compounds).  Over time, as VOCs were required to be reduced in solvent-based paints, other paints came on the market, such as water-based.  Early on, the quality of water-based paints was inferior to solvent based, so some companies probably continued to stick with the solvent-based to ensure a better job.  Unfortunately, something like that leaves a stigma and many people probably still believe to this day that solvent-based paints are superior despite the fact that with current technology, many water-based paints are not only equal to solvent-based but superior to.

Regardless of quality, though, cost can still be prohibitive.  Oftentimes, the production of a synthetic material costs more than the acquisition of a natural one, demand for the less hazardous version drives up its cost, or any other number of reasons that make the alternatives more expensive.  It’s this industry’s equivalent of why a grilled chicken salad costs $9.99 and a burger costs $5.  Cheaper usually does not mean better for you.

The other downfall to substitution is just because a material does not pose the same hazard as the one you’re replacing, does not mean it doesn’t pose a hazard at all.  An employer needs to do the necessary research to ensure that they are not replacing one hazard with another.

Elimination and substitution are not only great ways to abate hazards, but need to be your preferred way.  In other words, engineering controls, administrative controls, and PPE should not even come into the discussion until elimination and substitution have been ruled out (except in the case where PPE use is required at all times, like a 100% safety glasses policy).  Take the time to look at some of the solutions your company has come up with for the hazards in your workplace.  Are there situations where elimination or substitution could have been used?  You may be surprised how often your answer is “Yes.”

After you’ve done that, keep your eyes open and come back for our next article which will discuss what is meant by “engineering controls”.


Anatomy of a Fall

Anatomy Of a Fall


Anybody that comes in even the briefest of contact with the world of occupational safety knows that fall protection is a hot topic. There are blogs, social media groups, and even entire companies dedicated to it. While some topics are treated as an elective within an OSHA 10 or 30-hour course, fall protection is one that is required and it’s for good reason. Falls have been at or near the top of the list for occupational fatalities and at the top of the list for construction fatalities for years. Rather than getting better over time, the number of fatalities due to a fall is rising. According to the Bureau of Labor Statistic’s most recent data, occupational fatalities due to a fall to a lower level rose 11% from 2013 to 2014. Why do falls remain this great, mysterious thing? If workers truly understood where and why they happen, or what could be done to prevent them, we’d have no falls at all, right? Maybe understanding the fall itself can help prevent them. So let’s look at one step-by-step.

Prior to the Fall

Morning meetings have been held, tasks assigned, equipment distributed, and work is proceeding as usual. It’s during this time, however, that a bad decision is made. It’s at this point that you choose to climb to an elevated work area that is not guarded and do so without your personal fall arrest system. Maybe you aren’t trained in fall protection and either a) don’t know you’re supposed to have fall protection or b) are unsure of how to properly use it.  Perhaps management personnel knew that proper precautions weren’t in place, but put production ahead of safety. Perhaps, you actually brought your harness and lanyard but didn’t bother to hook up to the anchor point. Falls happen due to a lack of planning more than anything else.

At The Moment of The Fall

If you talk to people who don’t feel it necessary to use fall protection while working at heights, you’ll hear such things as, “I have very good balance,” or, “I have good reaction time; if I was going to fall I’d catch myself.” Agility and fast reactions aren’t enough however, as losing your balance often has nothing to do with a fall. Sometimes a platform gives way, or you’re struck by a falling object which knocks you unconscious. Sometimes you pass out or get lightheaded from a sudden drop in blood sugar due to a medical condition – maybe even a medical condition you did not know about. Sometimes a sudden gust of wind picks up and blows somebody clear off a roof. The fact of the matter is, balance means nothing against the forces of nature or a 5000 pound suspended load that went astray. Balance  won’t save you when, in reality, the moment of fall was probably one that you never saw coming.

If you can’t see something coming, how do you react? How do you “catch yourself”? Sure, maybe if you felt yourself losing your balance you could grab onto something to steady yourself. That’s obviously possible, but what if you just outright fell? What if you got knocked off a platform? The fact of the matter is that you’ve fallen 6’ in the blink of an eye and there’s nothing you’re going to be able to do to stop yourself.

The Impact

Let’s face it, the results of impact aren’t pretty. If they were, falls would not result in fatalities as often as they do. If you are “lucky” enough to survive a fall, you could be facing medical issues for the rest of your life. Not only can a fall break bones, it can rupture internal organs, cause severe concussions or another brain injury, and result in paralysis, a coma, or other permanent disabilities. And you don’t need to fall ten stories for this to be the case. According to one NIOSH study, more than 25% of all fatalities were the result of a 6 to 10-foot fall from a ladder. Make no mistake, other than the very rarest of exceptions, getting up and walking away unharmed from a significant fall is the stuff of action movies and cartoons.

The Aftermath

The immediate aftermath of a fall is chaotic and intense: people scrambling to call 911, others rushing to your aid, and still others are frozen in disbelief, panic, or shock. People are most likely not thinking clearly and may be putting themselves or others in danger while reacting to what just happened. Machine operators may leave equipment unattended, friends and co-workers rush through or into unsafe areas to get to you, some people may even be putting themselves in the same fall exposure you just had trying to get a glimpse of what happened to you.  Shortly after that, there’s the notification to your family and whether the fall was fatal or not. This is an extremely trying experience for both your family and the person tasked with making the call. Your spouse and children, your parents, your siblings, and your friends will be devastated. Counseling will be needed for many of them as well as co-workers. Those that witnessed the event may be traumatized and may never be able to return to that job themselves. For survivors, falls are life changing. If you’re able to work at all, you may never be able to work in your field again. Psychological issues are prevalent. Marriages fall apart. A fall affects so much more than just the physical well-being of the person involved.

In a fall, the moment of impact may seem like the end, but it’s really just the beginning. The fall may have involved just one person at first, but by the time it’s over dozens are affected. However, falls are preventable. There needs to be a willingness to plan in order to make sure the selected fall protection solution is appropriate. There needs to be a willingness to learn so an employee can ensure they know how to inspect their equipment and use it properly. There needs to be a willingness to do what’s right, even when it’s not the cheapest or quickest way to get things done. Given all that, maybe then, hundreds of lives a year won’t be lost on the job to fatal falls. Maybe then, hundreds of more people won’t have their lives shattered each year by the loss or debilitation of a loved one. Maybe then, the number of fall incidents will finally begin to decline.


Fall Clearance Pitfalls

Active vs Passive Fall Protection

If you use personal fall arrest systems (PFAS), you should be well-trained and well-versed in fall clearance.  If, by some chance, you’re not, you can get a nice refresher here.  Go ahead, we’ll wait. 

Back?  Great.

Now that you’re an expert, you must realize that you’re an expert in fall clearance calculation when done properly or in ideal conditions.  Unfortunately, as we all know, not everything goes exactly as planned.  In fact, it’s probably more accurate to say that pretty much nothing goes exactly as planned.  What follows are a few things you need to consider that could cause your fall distance planning to be dangerous miscalculation.

Location of Your Anchor Point

You’ve trained your personnel and they fully understand that they need to do to calculate fall distance.  All signs point to having enough room to go ahead and use 6’ lanyards with deceleration devices.  The workers head to their work area, fully harnessed, take their locking snap hooks and tie off…at their feet.

In this situation, your employees just took a workable situation and made it an unworkable one.  They took effective fall protection and made it ineffective.  Because of the choice of anchor point, two things just occurred:

  1. The fall distance is wrong.  If the calculation was made with the assumption that the anchor point was at D-ring height or above (as it should be), you’ve now subtracted 4-5 feet of distance.  If your height was 35’ and is now 30’, maybe that doesn’t seem like the biggest deal in the world (it is, see point 2), but if your height was 20’, it’s now 15’.  You’ve gone from a point where using a 6’ lanyard with a deceleration device was acceptable and effective to one where it is neither.  In a fall, your employee would now strike the ground.
  2. Your freefall distance is wrong.  In simplest terms, you are allowed a maximum freefall of 6’ (though, it is really based on Maximum Arresting Force).  With a 6’ lanyard and deceleration device, your freefall is 6’…PLUS the distance from your D-Ring down to your anchor point.  Why?  Because your fall will not begin to be slowed until your lanyard is at full extension – 6’ – but in order to get there, you have to first fall PAST your anchor point.  Even if your system protects you, you are facing a slew of other injuries, both internal and external.

SRL Over an Edge

Workers use self-retracting lanyards (SRLs) with a great deal of confidence, knowing that they are going to lock into place quickly, virtually eliminating any fall at all.  In many instances this will be true, but keep in mind that a certain speed…a certain amount of force…needs to be achieved in order for the locking mechanism to engage.  Think of a car seatbelt:  If you gently step on your brakes…nothing, but if you slam on the brakes, the belt locks into place, forcing you to uncomfortably and inhumanly press your body back into the seat in order to feed enough of the belt back into the casing in order for the mechanism to release.  An SRL works the same way.  Without that force, the braking mechanism does not engage.  When might this occur?  Well, it is very likely if your anchor point is directly behind you when working near the edge of a roof, for example.  If you fall, the SRLs cable or webbing over the edge of the building may be slowed to keep the forces low.  In this situation, your SRL can play out completely until you hit the ground.  Perhaps it was slow enough to prevent serious injury, perhaps not.  Ensure that your SRL use and anchor point selection do not allow for this to happen (there is potential for this situation over the rails of an aerial lift, too).

Dynamic Changes

We often talk about construction being a dynamic environment, but there are plenty of situations in other industries where things change throughout the day.  Where once you had proper fall clearance, you may no longer.  For example, what if you are working at the edge of a roof and have properly calculated your fall distance?  You are wearing the proper fall protection and you have plenty of clearance between you and the ground.  All sounds good, right?  What if the area over which you are working is a loading dock?  While you’re not paying attention, a truck backs in and unloading activities begin.  Suddenly, you fall.  Were your calculations effective?  Most likely, no.  Most likely, this change wasn’t taken into account.  It is very important to be fully aware of the activities that are occurring in your work area and plan accordingly if they should affect your situation.

Generally speaking, calculation of fall clearance is pretty simple and straightforward, but as the person determining that clearance, it is crucial that you are knowledgeable of things that could affect your situation and could nullify your planning.  Make sure you’ve thought out every possible scenario and, as always, make sure the end users are properly trained.  Falls are bad enough.  Pitfalls can be worse because they take you by surprise by sabotaging what you thought was effective planning.

When Will the New Walking/Working Surface Rules Arrive?

DIY Bathroom Shelf


“When will the new walking/working surface rules arrive?” is a question that’s been asked for many, many, many years (as in about 20), but it finally looks like we may have an answer.  According to a regulatory agenda published by OSHA in May of this year, the Administration plans to release the final rule for Walking/Working Surfaces this month (August 2016).  The rule had been so long in the making, that it essentially needed to go back to the drawing board in order to properly account for new technologies that did not exist in earlier versions.

So what is different this time?  Well, with the rule ready to go, despite the fact that regulatory agenda dates are often missed, the administration wants to try to take advantage of the Obama presidency to get this done.  Traditionally, Democrat administrations tend to be more regulation-friendly than Republican administrations and OSHA does not want to take a chance on the Presidential Election, hence the push for a release of the final rule this month.

What’s new?  Well, mostly fall protection.  It may come as a surprise that there is very little said about fall protection in the General Industry standards.  In fact, personal fall arrest systems are not mentioned at all.  Other than physical barriers and railings, there is no fall protection guidance.  The proposed final rule aims to change that.  In addition to addressing fall protection and personal fall arrest, the new rule includes updated national consensus standards and industry practices.

The actual changes will occur in two subparts: D (Walking/Working Surfaces) and I (Personal Protective Equipment).  Subpart D changes will simply be the requirement to have fall protection, while Subpart I will go into the performance requirements of that equipment.  Don’t worry about having new things to remember.  If you’re already familiar with construction and Shipyard standards, you will recognize much of what you see as some of the same language is being pulled in order to maintain consistency and avoid confusion.

While the implementing the new rules may cost money, OSHA fully expects that company savings will outweigh costs by almost a factor of 2.  And that’s for companies that are not already implementing any aspect of this.  Many forward-thinking companies that fall under the General Industry standard may already be using the Construction or Shipyard regulations as a model for their fall protection programs.  In this case, extra costs may not exist.

Regardless, OSHA expects the rule to have a big impact.  OSHA administrator David Michaels said so himself in an interview in the July issue of the National Safety Council’s Safety and Health magazine.  Aside from financial savings, the Administration expects the new rules to prevent 30 annual fatalities.  And, in the end, that’s the ultimate goal.  Saving lives.

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