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Selecting Non-Penetrating Rooftop Anchors

Selecting Non-Penetrating Rooftop Anchors

There are many rooftop anchors on the market, however, a number of them require you to penetrate the roof membrane in order to fasten the anchor to the structure.  That’s fine if the building owner allows it, but in a commercial application that is unlikely unless you are installing a permanent anchor point.  For something temporary, there is no way the owner is going to want you to compromise the integrity of the membrane.  So, what options do you have?

Non-penetrating roof anchors do exist.  From weighted anchor points, to parapet clamps, to roofing carts, there are options.  There are, of course, some things to consider before purchasing one, though:

Damage

Keep in mind that just because the method of securing the anchor does not involve roof membrane penetration, it does not mean that you won’t damage the roof.  Weighted anchors, for instance, are going to be heavy so they do have the potential to cause damage once assembled or if components are dropped during assembly/disassembly.  Take the utmost care in placing them and be sure you follow any manufacturer’s recommendations for protecting your roof during use.  A fall protection cart can also be used and will most likely not cause any damage unless a fall occurs, in which case many of these carts are going to dig into the roof membrane, as designed.  In this instance, I think patching a roof will be an acceptable alternative to having a fatality.  Even parapet clamp anchors can cause damage to your flashing, especially if used in a fall, so be sure to inspect the roof when you are finished.

Arrest vs Restraint

Understand the difference between fall arrest and fall restraint, and know which your anchor is designed for.  It very well could be that it’s designed for both, but you need to know how many it can support for each and if there is a different connection.  Fall restraint is preventing your workers from actually reaching the edge and falling over.  For this, they would need a fixed length lanyard or an SRL that – fully extended – was shorter than the distance from the anchor to the edge of the roof.  Fall arrest is stopping a fall after it occurs.  Anchors can be designed for either one of these or both.  For instance, some roofing carts are designed for three people: up to 2 for fall arrest and the rest for fall restraint.  In addition to there being a limit on the number of users for each type of protection, there are also often separate attachment points for each.  It is imperative that you follow the manufacturer’s requirements if you want the anchor to protect your workers in the event of an actual fall.

Number of Users

In the example above, the cart is designed to hold three people.  You cannot opt to add additional personnel to this just because there’s room for another hook.  Remember, anchor points are required to support 5000 lbs. per person attached (or a safety factor of 2), so if you continue to add users and multiple people fall, the entire cart system or anchor point can fail, sending all of the attached personnel plummeting to the ground.  Before you buy, know how many people you are going to need attached at once.  Some anchors are designed for one.  That may be fine for you.  Understand that, because of swing hazards, you are not necessarily going to be able to use one anchor for work in multiple locations without having to move it. So having something portable is great.  However, if you need workers in different locations working at the same time, you may require multiple anchor points.

Like every other piece of safety equipment, you can’t purchase anything without first planning what you’re going to need that equipment for.  Look at the situations you expect to be in, look at the number of employees you need to protect, and look at the distance they’ll need to be working from each other.  Most importantly, once you’ve purchased the equipment, train your employees on its proper use.  Buying an anchor does you no good if your employees overload it or tie off to it the wrong way because they had no idea how to use it.  Fall protection solutions are not one size fits all so make sure you’re speaking with the manufacturer, distributor, or a safety consultant if you aren’t sure what you need.  Don’t leave the lives of your employees to chance.


Common Hazards While Servicing Rooftop HVAC

Common Hazards While Servicing Rooftop HVAC

We’ve spoken often in this blog about general rooftop safety hazards and regulations.  We recently focused specifically on one rooftop activity when we posted about the hazards associated with washing roofs, and we felt that rooftop HVAC work deserved the same treatment.  How can we best keep our HVAC workers safe when servicing rooftop units?

Material Transfer

I know I probably haven’t, but I feel I’ve seen it all.  From tools being thrown to or from a roof, to a person standing on a parapet while hauling up tools and material on a rope, rooftop workers often put themselves at risk when getting the tools and materials they need.  Sometimes, this comes with the nature of the job.  A quick service or maintenance visit can mean that HVAC workers are up and down from the roof quicker than you might have even realized they were there, but that doesn’t mean they can’t get hurt or killed in that short period.  As an employer, the best way to avoid this is to ensure you have planned out how everything will get there in the first place.  Do not leave it to the workers in the field because the moment they are faced with doing something wrong or doing something quickly, quickly often wins out. 

Freight elevators are, of course, the easiest solution when there happens to be one because there is no setup involved so it doesn’t matter how long or short your work is going to be.  Unfortunately, more often than not they are not available.  So, what other ways can you safely get materials to and from the roof?  Do you have a rough terrain forklift on site that can reach the roof?  If not, does the property owner?  Do you have a crane coming out to set equipment?  If so, maybe you can utilize them to get tools and materials up.  If you don’t have anything of great size to raise to the roof, maybe it’s a matter of simply ensuring your workers have tool belts so that their hands aren’t full when they’re climbing ladders.  If all else fails, a material hoist is always an option. They are often quick and easy to set up, but be careful, you will need fall protection – whether personal fall arrest, railings, travel restraint or some other solution - while setting up the hoist and operating it since it will be at the edge of the roof (unless it is set up at a parapet that is high enough to serve as fall protection).

Routes of Travel - Slips, Trips, and Falls

Sometimes your work is in a completely safe, easily accessible place.  Sometimes it’s not.  Sometimes you have more than one location to work on the roof and traveling between them is where your hazards come into play.  Routes of travel that take you past skylights or near the edge of the roof have now exposed you to fall hazards.  Ensure, prior to beginning work, that you are familiar with the layout of the roof and that you have planned safe travel routes.  This may require portable railings or other means of fall protection.  Do not assume a cage over a skylight will protect you as many are not designed to serve as fall protection as you can read in our previous posts on skylight safety.

But falls aren’t the only problem when traveling on the route.  Slips and trips can also be a problem as a roof can have many uneven or slippery surfaces (morning dew anyone?).  Keeping an eye out where you walk or sticking to designated walkways that a building owner has established are the best ways to keep safe.  Carrying material or equipment that block your vision could very well keep you from noticing that low run of conduit in your path, or that bubble in the roof membrane.  Be vigilant.

Exhaust

You’re working on HVAC so we’re going to assume you’re very familiar with a building’s exhaust.  Sometimes exhaust is a nuisance, but sometimes it’s downright hazardous.  Sure, we can deal with getting covered in the smell of cooking grease wafting up from a kitchen, but what might you be inhaling if you’re on the roof of a pharmaceutical manufacturer or chemical manufacturer?  Ensure that you are fully aware of a facility’s roof work policies.  Do not attempt to bypass them in any way, even because you just forgot a tool on the roof, because those policies exist for a reason.  Some process plants can exhaust chemicals that can make you sick – or worse - immediately. 

Lockout/Tagout

As with exhaust, there are many other rooftop hazards that don’t involve falls.  Electrical and mechanical hazards are some of them.  In order to work on existing equipment, it should be de-energized and locked out in accordance with your company’s lockout/tagout program.  Again, this is something that should never be bypassed, not even if you just have some quick work to do.  If you can be harmed by the accidental startup of that equipment, regardless of how likely or unlikely that startup is, you must lock and tag it out in order to protect yourself.  If you don’t have a lockout/tagout program or are unfamiliar with the term, you are missing some critical training and procedures in order to work safely and be compliant with the law.

Roof Damage

You are working on somebody else’s roof, you should respect that.  Small things you do could cause damage to the roof membrane which can lead to leaks and bigger headaches for the building owner.  Be careful you don’t overload any one spot with materials.  Don’t wear or drop anything that could cut the membrane.  While keeping yourself safe is a top priority, you also don’t want to cause a problem that’s going to affect somebody else’s health or safety down the road.

Regardless of the length of time you will be on a roof, your employees must be protected.  However, putting protection in place may not be enough.  It is up to you to ensure that employees are properly trained to recognize, abate, or avoid hazards so they can get up, get the job done, and get down without incident.  Plan ahead.  It’s the best way to keep your workers safe.

Roof Distances By the Numbers

Is Your Safety Program Human-Proof?

Rooftop fall protection seems to consistently be one of the most confusing regulations.  When warning lines and monitors can be used to determining the width of your roof, something always seems to be missed – or at least misinterpreted.  So, here’s a quick and easy by-the-numbers guide for distances that come into play when discussing rooftop safety.  Keep in mind, this refers to work on low-slope and flat roofs (except where otherwise indicated).

19 Inches

Elevation Change: Any break in elevation 19” or greater, OSHA requires a step or ladder to be provided.  This is typically monitored carefully inside the average workplace, but rarely followed on the roof.  Take a look at any changes in roof elevation that you have.  Is there safe access to that elevation that does not require someone to step up/down 19” or more?  Also, look at any obstacles on your roof.  Are employees required to climb over them?  This may constitute a step greater than 19” as well.  These changes in elevation can be solved with stairs, ladders, and crossover platforms.  We recommend using stairs wherever feasible, as this typically provides the safest access for the worker.

4 Feet

Fall distance: In general industry, any fall hazard 4’ or greater, requires protection.  Period.  Unlike the construction code, there are no exemptions to this rule.

6 Feet

Edge distance for roofing work: Six feet is the minimum distance from the edge of the roof, or from a hole in the roof, at which you must erect a warning line during roofing work (if a warning line is your fall protection of choice).  Remember, a safety monitor, whose job it is to do nothing but ensure your personnel are not coming too close to the warning line, MUST be used in conjunction with a warning line.  Six feet is only allowable in situations where no mechanical equipment is being operated or parallel to the travel of mechanical equipment when it is in use.  Let me reiterate: this solution is only allowable to those on a roof for the purposes of performing roofing work.  This does not apply to, HVAC repairmen and installers, security camera or satellite dish installers, or any other types of work being performed.

Controlled Access Zone
: In addition, six feet is also the minimum distance for control lines used in Controlled Access Zones for leading edge work and precast work.  The maximum distances vary and are listed later in this article.

Fall Distance
: When performing construction work, any fall hazard 6’ or higher requires fall protection.  There are a couple of exceptions to this rule that are covered later in this article. 

10 Feet

Edge Distance for Mechanical Equipment: Ten feet is the minimum distance of a warning line from the edge of the roof, perpendicular to the travel of mechanical equipment.  This refers specifically to the edge you are driving towards, not alongside. All of the same rules for warning lines as stated above still apply.

Edge Distance for Overhand Bricklaying
: 10’ is also the minimum distance from the edge for a control line when engaged in overhand bricklaying operations.

15 Feet

Edge Distance for Non-roofing Activities: You won’t find this number in the regulations, but you will find it in Letters of Interpretation . Fifteen feet is the point at which OSHA will consider the use of a warning line for work other than roofing work as a de minimis condition, meaning that the spirit of the law was followed, just not the letter.  De minimis conditions do not include any fines or requirement to change.

Maximum Edge Distance for Overhand Bricklaying
: 15’ is also the maximum distance from the edge for a control line when performing overhand bricklaying.

25 Feet

Maximum Edge Distance for Leading Edge Work: Twenty-five feet is the maximum distance a control line can be from the edge during leading edge work.  A leading edge is essentially an unprotected edge that is “moving” as the building is being constructed.  For example, as a roof it being constructed, each new piece of roof decking that is installed becomes the new edge.

50 Feet

Roof Width: During roofing work, if your roof is no more than 50 feet in width, you may utilize a safety monitor without a warning line.  This is the only situation in which this configuration is acceptable.  If you are having trouble determining the width of your roof, you can refer to Appendix A to Subpart M of the Construction Regulations for guidance.  Keep in mind, this only applies to roofing work.

60 Feet

Maximum Edge Distance for Precast Concrete.  60’ (or half the length of the member) is the maximum distance a control line can be from the edge when erecting precast concrete members.

Infinity

Okay, that’s a little cheating on my part.  It’s not technically a number, but it represents the distance OSHA feels you can work from the edge of a roof safely without the need for fall protection.  That’s right, there is no distance OSHA deems as a safe distance from a roof edge, so technically you should be protected at all times.  With that said, in numerous letters of interpretation, OSHA does view 50’-100’ as a potentially safe distance with the proper work rules and training in place.  Be very careful using leveraging this as an excuse out of protecting a hazard.  The concern here is that OSHA wants a distracted worker (the worker at highest risk) to be protected.  If a worker is distracted, distance alone will not necessarily wake them up to their surroundings.  A railing or warning line would. 

Hopefully, this list can be used as a quick-reference guide for those readers involved in rooftop work.  Remember that not all trades and tasks are created equal on a roof.  Do not assume what is good for one group of employees or contractors is good for another.  Keep your numbers straight and keep your employees safe.

 

OSHA and Illegal Immigrants

Is Your Safety Program Human-Proof?

I recently had the opportunity to cross our southern border and experience Hispanic culture first hand.  I didn’t go to a resort or a hotel on some beach.  I went to stay with some dear Mexican friends who live in the mountains of Veracruz. An unintended consequence of the trip was a view into the immigration dilemma from their side of the border. While enjoying incredible hospitality, great food, and hardworking passionate people, I also saw crushing poverty. Making an average of $60-$80/month, the locals have little hope of ever buying many of the staple comforts we enjoy in America. For many Mexicans, owning land, a vehicle, a refrigerator, TV, etc., are all distant dreams. Dreams, that is, unless they decide to make the journey to the land of opportunity.  Unfortunately, many of these journeys are made illegally.

I know what you are thinking…Here comes another person publicly asserting their view of the immigration crisis.  On the contrary.  Although I have come to love the people of Latin America, I do not profess to know how to solve this problem.  Each person's beliefs and experiences provide a range of perspectives. These perspectives express a real sense of fear, injustice, inequity, or hope.

What I aim to bring into the spotlight is not immigration reform.  I want to draw our attention to some of the workplace difficulties that immigrants face when reaching America.  Since we are a safety company that is where I will focus.

The good news first.  America experienced a 2% increase in workplace fatalities from 2013 to 2014 (not the good news).  Latino workers, yet, experienced a 3.4% decrease.  

With that said, more Latino workers died in 2014 than 2009, 2010, 2011, and 2012 respectively.  Additionally, a disproportionate number of foreign-born Latinos lost their lives.  With the foreign-born population comprising only 35% of the total US Latino population, they accounted for 67% of the fatalities. Foreign-born Latinos are almost twice as likely to die at work than US-born Latinos.

A recent study performed by “Make the Road New York”, a Latino advocacy group, interviewed a number of immigrant workers and small business owners.  They found that nearly all workers interviewed believed they had worked in unsafe working conditions.  They also found that half had been injured on the job and half did not know OSHA existed.  Many of those interviewed also expressed a fear of retaliation or a belief that it is futile to make their safety complaints known.

Additionally, many Latinos find work in the construction and agricultural sectors.  These sectors have abnormally high fatality rates.  OSHA recently released a report that compares the number of hours worked against the number of deaths that occur in that industry.  The result may not surprise you.  When compared to the national average, workers in construction were almost 3 times more likely to suffer a fatal injury.  Workers in agriculture were 5-6 times more likely.

While it is not possible to change what types of jobs immigrant workers are accepting, it is possible for them to have a safer place to work.  For starters, let’s talk about what rights workers are afforded in the US under the OSH Act.
OSHA provides employees with the right to:

1.  Have a safe place to work

2.  Information (about hazards, past reporting, etc…)

3.  Training (how to work safely)

4.  Report hazards

5.  Be safe and free from retaliation


These rights are provided to workers – without regard to their immigration status.  Illegal immigrants are provided the same rights as legal immigrants. In fact, some states even provide workers compensation for injuries on the jobsite… again, without regard to immigration status.

In OSHA’s eyes, it does not matter how you arrived in the US – legal immigrants, illegal immigrants, and natural citizens are all covered by this Act.

The challenges around this issue can be complicated especially when the worker is here illegally.  They include:

1. Awareness of rights. As I already mentioned, many Latinos who were interviewed do not know OSHA exists.

2. Education of hazards. Dangerous work is a part of life for many Latinos – both in their home country and here. Education of immediate hazards may be an obvious place to start, but many are also not aware of hazards that could pose long-term health issues.

3. Confidence that there won’t be retaliation.


Back to the story of my trip to Mexico.  Here is where I want to make a special plea to employers.  I lived with a few of these men who had made the trip into the US.  I do not condone the breaking of the law, but I understand why they would do it.  Few of us wouldn't if in their shoes.  If you are in a position to bless those who have left their land in search for a better life, do so.
When they return to their families, make sure it is with their health intact.  Afford to them the same safety and security that you would want.  Protect their rights as sojourners in our land.  

I know that I am bringing up a topic that has many passionate supporters on both sides.  What I hope for, though, is to find a common desire to have our workplaces safe for the dads, moms, sons, and daughters that work there.  I think we can all agree on that.

How would you attempt to address this issue?  What additional challenges do you see?  


Is Your Safety Program Human-Proof?

Is Your Safety Program Human-Proof?

No safety program is perfect for one simple reason: people aren’t perfect.  No matter how many policies you put in place, no matter how much equipment you buy, no matter how much training you do, in the end you are depending on human beings to implement your safety program and human beings make mistakes.  Forget those that intentionally bypass the program, all it takes is for somebody’s timing to be off, their depth perception to be less accurate than they thought, their judgement of good and bad ideas to be less than ideal, and you have a failure.  And what of the physical failings of human beings?  Some aren’t as strong as they think.  Others, stronger.  Some could experience a medical condition they didn’t know they had, that came on suddenly, or that was exacerbated by the work environment.  These could also lead to program failures.

How should a company deal with the human factor?  The answer might be by human-proofing as much as possible.  You will never be able to do it 100%, but you can minimize your exposure to human failure in a number of ways.  Here are just a few examples:

Self-Closing Gates vs Chains

The less a person has to do to return an environment to a safe state, the better.  If you place a chain at the top of a ladderway or at the edge of a platform, it is possible that more often than not – whether out of laziness or forgetfulness, that chain will not be re-hooked.  Sure, you can put policies into place and issue disciplinary action to your workers.  You can post signs and hold training early and often.  But, in the end, you are creating a lot of unnecessary work for yourself.  If you had a safety gate that automatically closed behind the worker, your energy could be better expended elsewhere, in places where there might not be as easy a solution.  Of course, a person could still find ways to bypass this automatic feature, by wedging the gate open for instance, but they would have to go out of their way to do that and if they couldn’t be bothered to hook a chain, odds are they’re not going to be bothered to find ways to bypass a gate.  But, let’s say they do bypass it.  Where they might be able to argue that hooking the chain was just something they forgot to do, bypassing of the safety gate would be a clearly intentional act, making disciplinary action a much more clear-cut matter.

Guardrails vs Lifelines

Lifelines are fantastic.  They certainly help provide fall protection in many situations where it would be difficult to find any other way.  Still, they lend themselves to human failure.  In order to use a lifeline, the worker must be properly trained in fall protection, understand it, and use it perfectly.  And that’s not even counting the human errors that could have been made during design and installation of the system.  Railings, on the other hand, eliminate much of that human error.  Besides the fact that they actually prevent falls rather than arrest a fall that has already occurred (making them the clear winner, where possible, regardless), pretty much everybody knows how to use a railing.  Don’t walk into the rail.  Don’t run into the rail.  Don’t jump the rail. Don’t climb the rail.  Pretty simple.  With the lifeline, again – assuming it’s designed and installed properly, you have to worry about whether or not the user is wearing their harness properly.  Did he clip his snaphook where he was supposed to?  Did he clip his snaphook at all?  Are they overloading the line?  Are they taking chances they shouldn’t be taking?  Are they doing any work that can be affecting the integrity of the line?  Railings eliminate much of that headache.

Restricting Access

If areas are dangerous, don’t trust your employees will understand that.  Even if they understand it, don’t trust they’ll always use their best judgement.  Physically restrict access to dangerous work areas where possible by locking doors and gates.  Place signs.  Where necessary, place a watch outside the dangerous area to ensure nobody will enter, just as you would a confined space.  Why wouldn’t you use the same thought process if you’re working in an electrical room with live equipment, for example, just because the regulations don’t necessarily require you to do so?  Don’t just throw up a piece of caution tape.  It often gets seen as just something to move out of the way before passing through.  Use red danger tape for more impact, but also, use lots of it (whether ultimately deciding on Caution or Danger).  When you force people to have to think about what they’re doing and go out of their way to bypass the precautions put in place, they will think twice about it. 

Lock-Out/Tag-Out

Lock-Out is specifically designed to take human mistakes out of the equation when it comes to people being hurt in the workplace.  In fact, its very definition says so when it states that Lock-Out / Tag-Out is intended to protect workers who could be harmed by the unexpected energization or startup of machines or equipment.  Why would it be unexpected?  Because somebody did something they weren’t supposed to do, most likely.  That could be somebody physically starting the equipment or it could be the person working on the equipment forgetting to notify people, or expecting they could accomplish something before the power came on, etc.  By having a Lock-Out / Tag-Out program, assuming it is properly followed, you make it nearly impossible for an employee to be injured by unexpected startup.  Sure, somebody could go grab a pair of bolt-cutters and go cut off a lock, but you’d hope that the rest of your staff would be well enough trained to understand that this is NOT something you do and that there are very severe repercussions for bypassing somebody else’s lock.

Also, notice that I said that Lock-Out is specifically designed to eliminate human error as much as possible.  Tag-Out is, as well, when used in an actual Lock-Out / Tag-Out situation, but in the few instances where it is used as the only protection (for example, in a nuclear plant, there are often procedures that no equipment may be physically locked at any time), there is still a great deal of room for human error.

Until we reach that dystopian future where our world is run by robots and humans just sit around getting fat, we have to recognize that we need humans to run our businesses.  And, as wonderful a resource as those people are, the possibility for human error comes with them.  There is no way to completely human-proof your programs, because somebody who wants to violate it will always find a way, but you need to do everything you can to reduce the potential for human error or to reduce the severity of the impact a human error might have on your employees and production. 

Roof Washing: Hazards and Considerations

National Safety Stand Down

Roof washing is probably never on anybody’s top-5 list of ways to spend an afternoon, but it certainly can become a necessary evil.  If it were just a matter of aesthetics, you could almost write it off as vanity and leave your roof to become whatever filthy mess it was destined to become, but that’s not the case.  Historically, there are a number of reasons somebody might want to clean their roof. For example, preventing the buildup of food sources for birds and rodents or preventing chemical buildup that can damage the roof membrane. However, it’s become even more important in recent years with the emergence of energy-efficient buildings and construction.  Build-up of dirt, soot, algae, or other residue can alter the amount of light and heat your roof absorbs or reflects.  Washing it is necessary to keep it as efficient as when it was installed.  However, there are some things you need to consider:

Environmental Concerns

You may have local, state, or national regulations that govern the types of soaps you can use to clean the roof and what to do with the dirty water.  Unfortunately, it’s not as simple as lathering it up and letting it run down a drain.  Know what’s required in your area before beginning. You’ll also want to protect plants, shrubs, and other parts of your building that could be damaged by the run-off, especially if chemicals are being used.

Warranty

Most likely your warranty will not cover the roof if you’re washing it for aesthetic purposes, but it could if washing it is necessary to keep it as energy efficient as designed.  Know what will and what won’t negate your warranty before starting or hiring a contractor.  If this is the case, the manufacturer/installer of your roof may have recommendations or requirements for you to follow which will dictate what type of brushes to use, what pressure a pressure washer can be used at and more.  Any damage you cause is going to be on you, so be familiar with this.  As another option, your installer can help you write your cleaning plan or may actually offer cleaning services.  Weigh your options and the possible outcomes.

Safety

This is important because people not used to working on roofs may not take the precautions necessary.  Fall protection is going to be a major concern.  If you can do the job from a ladder and maintain three points of contact, you may not need fall protection, but I find it difficult to believe you’ll be able to apply the necessary soaps and water without letting go of the ladder.   If you use an aerial lift or do the work from the roof itself, you are going to need to have fall protection.  On a commercial roof, you may have the benefit of a parapet that meets the requirements for fall protection according to OSHA, but if not, you need to figure out how to protect your workers.  You will not only have open edges where you or your employees will be exposed to a fall, but slippery surfaces as well.  Remember, this is a concern on flat roofs as well as sloped roofs.  Personal fall arrest systems may be your best bet, but you need to determine a proper anchor point, ensure your employees are wearing their harnesses and lanyards properly, and ensure they have been trained in the proper use of their fall protection equipment.  If you are not capable of providing all of this, then it may be in your best interest to hire a licensed, trained contractor or to bring your installer back out for the process.  Don’t take this lightly.  Falls are a major cause of occupational deaths and the number one cause in construction. 

Sometimes, things seem simple.  If you need to wash your roof, you may think you just have to throw some soap up there and rinse it off with some water, how hard can it be?  Unfortunately, if you take a moment to look further into it, you could be putting yourself and your employees at risk.  The bottom line: Know what you’re doing or hire somebody that does.

Are All Hazards Created Equal?

National Safety Stand Down


OSHA regulations speak in absolutes: there is a hazard or there isn’t a hazard.  In reality, though, there are varying degrees of hazards because there are varying degrees of severity and varying degrees of likelihood that an incident will occur.  You will see this reflected by OSHA in their citations (De Minimis, Other than Serious, Serious, Repeat, Willful), but the regulations are written to protect against the very existence of a hazard, regardless of its likelihood or the severity of injury that could occur due to lack of compliance.

In order to determine what hazards you have and the means by which you will protect your workers, it is important to do an assessment.  Let’s take fall protection situations for example.  You could have multiple fall exposures in your facility, but budget, scheduling of contractors, etc. do not allow for you to immediately abate each and every one.  Just determining that there is a hazard does not help you decide which hazards to focus your efforts on.  However, if you assess your hazards based on frequency and severity, you start to get a better picture.

If you’re still confused, picture this scenario.  You have two locations that have an exposed drop of 20 feet.  One is the top of a ladder that is used all day, every day.  The other is the edge of a mezzanine that is only accessed by maintenance personnel when a repair is needed.  Both are indeed fall hazards.  The severity of a fall from either of them is pretty much equal.  The main difference here is how often your workers are exposed to the danger.  With the ladder, it is multiple times daily while with the mezzanine it is infrequent at best.  This points to the fact that your first priority should be to install a ladder gate near the top of the ladder.  You can then, at a later date, worry about protecting the edges of the mezzanine.  In the meantime, you can restrict access to the area and require any maintenance personnel needing to go on the mezzanine to utilize personal fall arrest systems.
So, what’s an easy way to do this?  The following chart is a good tool to help you determine which hazards are the most in need of attention:

National Safety Stand Down

As you can see, these may not be precisely measurable criteria, so you’ll need to estimate your responses or, better yet, come up with your own benchmarks for each category to help you better determine the severity of the hazard or frequency of your employees’ exposure.  For instance, the frequency with which your employees expose themselves to a hazard is directly proportional the certainty of injury – the more frequent the exposure, the more likely you are to have an incident occur.  Therefore, you could, if you wanted, change the categories along the top to Frequency of Exposure.  Then you could list them as Rarely, Annually, Monthly, Weekly, Daily (or you could just know in your head that those were the equivalent categories).  

Sometimes, what we see at first glance isn’t accurate.  Something can look like much more of a hazard than it is, while other things that don’t look hazardous can pose a big danger to your employees.  This tool keeps you from having to guess.  Without it, should something go wrong and you get asked the question, “Well, how did you assess the hazard?” or “Did you even assess the hazard?” you would have nothing to point to.  This chart makes your hazards measurable, which means you are making better decisions.  Better decisions mean your employees are better protected.  Isn’t that our end goal?


How to Address Safety Concerns with Your Employer

National Safety Stand Down

It’s inevitable.  If you are a safety-conscious worker, you will at some point in your career be faced with the task of presenting a safety concern to your employer.  If you’ve been given this responsibility, or if your company is truly supportive of safety efforts, then it’s easy.  However, not everybody is lucky enough to be in those situations.  Some employers are dismissive of safety concerns at best, and hostile toward those who bring them up at worst.  So, what’s the best way to bring safety issues to your employer’s attention?

The answer will, of course, depend on the nature of the hazard you are reporting.  If it’s not an immediate danger, you have flexibility in how you approach your boss.  However, if the safety issue is an immediate danger and somebody’s life or well-being is on the line, then you need to act accordingly.  In that situation, the best thing to do would be to make an attempt to get the employee exposed to the hazard, out of the situation first.  Deal with the consequences once they are safe, but waiting to get a supervisor if they are not immediately available could be the difference between life and death.  Yes, this could initially have a negative impact on your job (we’ll discuss employer retaliation in a bit), but you need to ask yourself if you want to live with the death of a co-worker on your conscience.  If your employer is not supportive of safety efforts, this situation will prove to be very complicated.

Let’s assume, though, that we’re not in an immediately life-threatening situation.  In that case, you should consider these suggestions:

Follow the Chain of Command

Nothing is going to upset your boss more than you going over his or her head.  Your immediate supervisor should be the very first person you address safety concerns with, even if you have a company safety director.  Give them the opportunity to fix the problem.  Let’s face it though, some of you have been working for your supervisors for a long time and you are fully aware of what their reaction will be.  If you are in this unfortunate circumstance, or if you do approach them and their response is simply unsatisfactory, then you may need to seek help elsewhere.  In a union shop, this could mean addressing the concern with your shop steward.  In either union or non-union situations, it could be addressing the issue with your safety manager or director.  A good safety manager will find a way to approach the situation without unnecessarily dragging your name into it.  When an employee reports a safety issue to a safety manager, it is a good idea for that manager to go and do a walk-through of the area before contacting the supervisor.  That way, when they contact the supervisor it is because they happened to be in the area and observed a safety violation, not because somebody went over the supervisor’s head.

Enlist an Ally

Some companies don’t have safety managers or shop stewards.  In these situations, you need to ask yourself, are there people in your company with influence that are strong proponents of safety?  Perhaps you can bring the issue to their attention, once you’ve unsuccessfully attempted to work with your supervisor.  Find a way to discreetly let them know what the problem is and maybe they will be able to run with it from their end. 

Make Sure You're Not Simply Complaining

One of my old bosses used to always say, “Don’t come to me with a problem, come to me with a solution.”  He had an extremely open door policy, but he didn’t want us just walking through his door to complain.  He wanted to see that we’d thought about the problem we were experiencing and had a suggestion to fix it.  Sometimes, we didn’t have suggestions and we would explain that, but what he was doing was showing us how to problem-solve.  It’s an important lesson that most likely helped lead to where I am today.  So, the next time you want to run to a supervisor to complain, first think about what it is you’re complaining about.  Are co-workers tied-off to unsuitable anchor points?  Maybe you can go in suggesting what a suitable anchor point might be or that railings may be a better option.  Do your co-workers seem to not understand what is required of them from a safety perspective?  Maybe you can go in and request a training class that would help everybody understand better.

Don't Be Argumentative, Be Cooperative

In line with going in and presenting a solution, your whole approach should be one of cooperation.  If you go in making accusations and attacking management, you can expect negative results.  Let your boss know that you wouldn’t be bringing something to his or her attention if it wasn’t important and that you did put a lot of thought into it, but you are really concerned.  Tell them what you believe to be wrong and give them a chance to explain.  Offer any solutions you may have and let them know that you will help them in any way you can to make sure the situation is corrected as efficiently and as quickly as possible.

Do Your Research

Know what you are talking about, plain and simple.  Don’t go and complain that the height of the railings are wrong when they’re not.  Don’t complain that an anchor point is insufficient when it’s not.  Do whatever research you need to do to back up your concern and have that backup in writing.  If you find the information you need on OSHA.gov, print that page up and bring it with you.  Show your boss what it says in the standard, but be careful, there can be old information out there that has possibly been superseded by new regulations or letters of interpretation.  Employees who are adept at navigating the internet have a world of information at their fingertips, but if you know a safety professional in the field, perhaps you can ask them for a little assistance to ensure that your information is up-to-date.  I have had many safety concerns brought to my attention in my career and, while many were valid, there were quite a few that weren’t.  If you get an explanation of why something is not unsafe and why it is compliant with the law, you may need to be willing to accept that.

Know You are Protected

As an employee, you have rights, and one of those rights is the right to a workplace free of recognized hazards.  Another is the right to voice concern for your safety without fear of retaliation – to your employer or to OSHA.  In the worst case scenario, where you have a safety hazard that your employer refuses to address, or refuses to address in a satisfactory manner, you have the right to contact OSHA directly and file a complaint.  In fact, every employer is required to post the OSHA poster that specifically tells you how to do this. The sad fact is, that not all employers are going to be willing to hear you out or be responsive to your concerns. 

Old-school thinking may cause them to label you as a trouble maker or a problem employee, but you need to stand by your convictions.  Simply put, your employer cannot retaliate against you in any way for bringing up safety concerns.  They cannot fire you.  They cannot transfer you to a less desirable position as a result.  They cannot reduce your pay.  They cannot change your working conditions to make you uncomfortable or unhappy.  If they do, OSHA has your back.  And, retaliation fines are steep.  This is not a slap on the wrist.  If a company is found guilty, the results are usually significant fines, full back-pay for the employee, and full reinstatement of the job.  Granted, nobody wants to be out of work waiting for the system to work, but sometimes you have no choice.

Voicing safety concerns to your employer is not only a good idea, but it is imperative if you want your company to have an effective safety program.  However, there are right and wrong ways to do things.  In these situations, diplomacy is key.  Follow the chain-of-command as long as it is effective.  Do your best not to hang anybody out to dry or throw anybody under the bus.  Remember that the goal is your well-being and the well-being of your co-workers.  Know that what you’re asking for is right.  Once you know this, be insistent, be fearless, and you might just save somebody’s life.

 

OSHA National Safety Stand-Down to Prevent Falls in Construction

National Safety Stand Down


With the coming of warmer temperatures in most of the country comes an increase in construction activity.  Unfortunately, if history teaches us anything, with increased construction activity comes increased worker injuries and fatalities.  Falls continue to top the list of fatalities in construction year after year, so OSHA has once again decided to roll out its “National Safety Stand-Down to Prevent Falls in Construction.”

For the past few years, OSHA has led this effort to get employers to talk to their workers about the hazards of falls and the administration’s desire to reach increasingly larger numbers of workers has been paying off.  The Stand-Down reached 2.5 million workers last year for the first time and now OSHA hopes to double that number.  If successful, they will be reaching half the construction workforce in the United States.  This year the National Safety Stand-Down runs from May 2nd to May 6th.

The event is voluntary and is whatever you make of it.  This is your opportunity as an employer to take time out from your busy
schedule and talk to your workers about falls.  Help them understand, through a tool-box talk, equipment inspections, a training class, or some other safety-related activity that falls kill – all too often. Make them understand how severe the consequences of one mistake can be, find actual incidents to relate to them to make it personal, let them know the cost – in life ­– that fall protection violations can incur.  In other words, make them understand – pun intended – the gravity of the situation.

We have a ton of safety resources and articles on this site to help your employees understand fall hazards.  Take advantage of them, you don’t need to reinvent the wheel.  Signup on the email list, and we’ll make sure you get them in your inbox on a weekly basis.

Don’t assume that your workforce knows and understands this just because you believe it to be common sense.  The idea of common sense is a fallacy.  Common sense is learned information, not something we’re born with, so if somebody has been learning something incorrectly his or her whole life then “common sense” could easily get them killed.  Taking the time to have this conversation will be well worth not having to find a body on the ground, to not have to look into the eyes of a grieving spouse and children, to not have to counsel your workforce on how to handle the traumatic death of a friend and co-worker.  Taking the time to have this conversation is well worth the value of saving somebody’s life.

There was a time where death was an accepted side-effect of construction.  That time is long gone.  Many companies now understand that their people are their greatest resource, but I say forget that.  You should be operating safely and training your workforce not because your people are a good resource for your company, but because your people are just that: people.  Human life is not an expendable commodity.  If you are in a position to protect it, then you should make every effort to do so.  If you’re not already making those efforts, then don’t wait for the Stand-Down.  You can start saving lives today. 

To find ways to participate, see what’s been done in the past, or share your story, go to https://www.osha.gov/StopFallsStandDown/.  Once complete, you will be able to download a certificate of participation.  And don’t stop at your own employees.  Spread the word on Social Media using the hashtag #StandDown4Safety.  Your voice could convince another employer to participate.  Your voice could save lives you never thought you could affect.

Workers’ Memorial Day 4/28/16 – Remembering Those We’ve Lost

Have You Seen These? We have...and they're dangerous

As I set out to write this article, I Googled the phrase “worker died,” figuring I would be able to find a couple of articles from the first quarter of this year to use as examples of the men and women we honor on Workers’ Memorial Day.  Instead, the first five fatalities I found barely took me back to mid-March.  I am a safety professional who is well aware of this country’s worker fatality rate, yet I was still astounded.

On April 2, 2016, a 56 year-old Georgia man died after becoming trapped in a machine during routine maintenance.

On April 1, 2016, a 21 year-old Brooklyn man plunged to his death down a shaft after being struck by falling debris.

On March 29, 2016, a 28 year-old Ohio worker died in a trench collapse.

On March 27, 2016, a rail yard worker died after getting pinned between two trains during a shift change.

On March 23, 2016, a worker in a seafood warehouse in Boston was found dead.  The fatality was attributed to an ammonia leak.

On March 21, 2016, a 32 year-old fire technician died while inspecting fire extinguishers.  The cause of death was suffocation as a nitrogen leak had brought the Oxygen levels in the area down to 4% (breathing air contains approximately 28% oxygen).

On March 15, 2016, a 40 year-old electrician was electrocuted in Kansas City, Missouri during construction.

Unfortunately, the list goes on and on.  During my research, I refreshed my Google search and brand new articles popped up.  The fact is, we lose more than 4500 workers a year in the United States (in 2014, the number was 4679).  That’s 4500 men and women that were just going to work, trying to provide for their families.  That’s 4500 husbands, wives, mothers, fathers, sons and daughters.  That’s 4500 best friends.  4500 favorite aunts and uncles.  4500 people who will leave a gaping hole in the lives of countless others.

And, for most, they will be a newspaper headline read today and forgotten tomorrow. But the families can’t forget.  That seat will be forever empty at the dinner table.  Somebody has to explain to little boys and girls why Mommy or Daddy will never be there to tuck them into bed again.  Grieving parents have to do what no parent should ever have to do – bury their children.  Husbands or wives will need to rebuild their lives and raise their children alone.

Why?  Because the equipment cost too much, or because the project was behind schedule, or because training took too much time away from the jobsite, or because nobody bothered to find out how to operate safely.  Sure, sometimes the loss seems to be squarely on the shoulders of the victim, but is it really?  Could better training have prevented their deaths?  Better management?   Better planning?  Better oversight?  More than likely.

Employers everywhere have the power to ensure that nobody dies on their watch, yet it keeps happening – again and again and again.  It needs to stop.  We are failing these workers.  We are failing these families.  We need to do everything we can to send our employees home each night to their loved ones and if “everything we can” isn’t enough, then we need to do more.  More than 4500 fatalities a year.  It’s unacceptable.  Be a voice for those we’ve lost.  Be a voice for the loved ones left behind.  Join together to cry out in one unified voice, “No More.”

And, on April 28th, let’s take the time to honor those we’ve already lost.  Let’s take a moment with our workforce to remember them and talk about them.  If you knew them, tell a story about what they liked to do and who they were to you.  If you didn’t, read up on them and share their stories with your workforce because they are your workforce.  They are you and me.  Let’s make sure they are remembered as people and not just words in a newspaper headline.  They are no longer with us, but we can help to make sure their memories remain alive – on Workers’ Memorial Day and every day.


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