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Using Portable Ladders Safely

Using Portable Ladders Safely


Whether you’re a plumber, painter, electrician, maintenance worker or any other number of trade professionals, the portable ladder is a go-to solution for difficult-to-reach work tasks.  Whether it’s an A-Frame or an extension ladder, we take for granted that they’re the safest way to do our jobs.  That may not be the case.  Ladders could be unstable, especially if they’re not being used properly.  In many cases, the Easi-Dec Portable Work Platform offers a much safer solution, but companies won’t invest the time or money needed to have them available.  Other times, companies are simply not aware there is another solution, so ladders continue to permeate our job sites.  Therefore, it is important workers know how to properly and safely use portable ladders.

Angles

Extension and straight ladders must be set at the proper angle in order to keep them from tipping back.  This angle is a 4:1 ratio.  In other words, for every 4 feet in height from the ground to the point the ladder makes contact with the structure, the base must be a foot away from the structure.  Now, most of the time, nobody is busting out a measuring tape.  There are two easy ways to tell if you’re at the proper angle.  1) Stand at the base of the ladder so that your toes are touching it.  Extend your arm at a 90 degree angle from your body.  If your hand touches a rung or a side-rail, you are approximately at a 4:1 angle.  2) Download the NIOSH ladder app.  Simply lean your phone along the rail of the ladder to see what angle you’ve set the ladder at.

Securing the Ladder

Most people are concerned about a ladder tipping backwards, but it’s much more likely it will actually shift laterally.  Therefore, it is important that you secure the ladder – near the top – to the structure to prevent it from shifting.  Do not use the ladder’s adjustment rope to secure it to the structure.  Ensure that somebody is holding the ladder in place during the initial setup.

Proper Height

Your ladder must extend 3’ above the level to which you are climbing, or there must be a grab rail that extends 3’ up.  While this is important when dismounting the ladder, it is even more important when mounting the ladder from the top.  The last thing you want is somebody walking to the edge of a building or platform and having to lean down to grab the ladder.  One moment of light-headedness could end in disaster.  To see if your ladder is properly extended, count the rungs.  There is approximately one foot between rungs.  

Setup

The ladder will never be a safe tool if it’s not set up in a safe location to begin with.  Make sure your ladder is on firm, level ground and that the safety feet are in place.  If you need to kick the feet up to dig into the surface material, that’s what they’re there for.  For an A-Frame ladder, ensure you’ve fully opened the ladder and locked it into place.  No A-Frame should ever be used while folded or partially closed.  This is not what the ladder is designed for and not how it’s tested.

Maximum Height

Your A-Frame ladder has a maximum working height.  You’ll notice a label that says “Do Not Work On or Above This Step.”  Pay special attention to the “On or Above” part.  Most people look at that and think that they can step on that step but not above it.  This is not the case.  And definitely, don’t ever straddle the ladder or sit on top of it.  In addition, the label on the side of the ladder contains a maximum working height in case you’re unsure.  If you can’t read the labels, that’s a whole different problem and you need new ladders.

Labels and Paint

Labels on the ladder must be legible.  If they are worn off or painted over, then you cannot use the ladder.  (NOTE: You do not need to destroy or throw away ladders because the label is illegible. Instead, call the manufacturer to get a new label shipped to you.) In addition, you must be able to inspect your ladder for cracks, defects, and damage.  Painting ladders with an opaque paint may prevent you from doing so, therefore do not paint your ladders.

Safe Use

You can set up a ladder as safely as you want.  If you don’t use it safely, you can still get hurt.  Always maintain three points of contact when climbing a ladder.  This means two feet and a hand, or two hands and a foot.  Doing this precludes you from carrying tools or materials in your hands – which is a good thing.  While working aloft, your tools should be at the very least in a tool belt or tool vest.  At best, they should be tethered to you.  Also, maintain your center of gravity between the side rails – no leaning off to one side or another.  Keep your eyes out for other hazards or unsafe conditions.  Many ladder accidents, for instance, occur when employees mount the ladder at the top by swinging around it.  Perhaps you can purchase ladder toppers to eliminate this hazard.  These toppers attach to the top of the ladder and extend the necessary 3’ above the surface you’re climbing to while allowing the worker to step THROUGH them instead of around.  Finally, only use ladders as intended.  Do not separate parts if they’re not intended to be separated.  Do not lash sections together.  Do not climb both sides of an A-Frame unless it is specifically designed for that.

Inspecting

Ladders are a tool, so you need to treat them like one.  Just with any other tool, you need to inspect your ladder prior to use and remove it from service if anything is wrong with it.  Do not take chances.  A new ladder is much more inexpensive than a broken bone or a lost life.

Training

Don’t believe that just because we use ladders at home that your employees know how to use them safely.  People use ladders wrong ALL THE TIME.  It is your responsibility as an employer to ensure that your employees are properly trained in the safe use of ladders and that you are designating a Competent Person(s) regarding ladders.  That Competent Person, according to OSHA, must be knowledgeable enough to recognize a hazard and must have the authority to correct it.

Ladders are a very familiar and very useful tool, but as such, people tend to become complacent when working with them.  Unfortunately, complacency can be safety’s mortal enemy.  Make sure that if you are going to choose ladders as the proper means for your workers to complete their work tasks that they are fully aware how to use them safely. Ladders are cheap.  People are not.


10 Safety Tips for Working at Heights

10 Safety Tips for Working at Heights


Whether you work at heights every day or just once in a while, your focus on safety during those times is of utmost importance. It takes one mistake to turn a routine work task into a fatality.  Falls are debilitating.  Falls are deadly.  You must be prepared to protect your employees each and every time they could be exposed.  Here are ten tips to consider if your employees work at heights.

1. Use Rails

When you can, use rails.  Passive protection is the easiest way to keep your workers safe and achieve compliance because there is nothing that they need to actually do to keep themselves safe (other than stay within the rails…and if your employees are climbing outside of protective rails, you’ve got bigger problems to address!).  Rails can be built by jobsite carpenters (as long as they meet the requirements set forth by OSHA) or pre-fabricated from a manufacturer and installed.  Pre-fabricated railings can be permanently affixed or portable to suit your needs.  Regardless of which type you use, once in place, you’ll find rails are the easiest fall protection system to use.

2. Select the Proper PPE

If you’re going to use Personal Fall Arrest Systems (PFAS), you need to ensure you’re choosing the proper equipment.  All full-body harnesses that meet ANSI standards will perform the same, despite their cost, however, that price differential is getting you something.  Sure, sometimes it’s just a name, but other times it’s functionality that you’re getting or sacrificing, such as extra D-rings, fireproof material, or arc-safe design.  Sometimes, a more expensive harness is more expensive simply because it’s been made to be more comfortable.  Do your research and decide what it is you need.  If you have workers welding at heights, then a standard nylon harness is probably not going to be what you need.  Perhaps Kevlar is the way to go.  And, don’t forget your workforce.  Perhaps comfort isn’t your main concern (though it’s certainly much easier to get cooperation from your workers if they are comfortable wearing the equipment), but that’s not the only consideration you need to make.  Harnesses are not one-size-fits-all.  Make sure your workers can properly adjust their harnesses so that they fit correctly.
Lanyards need to be properly selected as well.  Depending on the height at which you are working, a 6’ lanyard with a deceleration device will not protect your worker.  Instead, a retractable lanyard may be necessary.  Each situation is different, so you need to evaluate your working conditions and the task to be performed in order to give your employees something that will actually protect them.

3. Inspect Your PPE

Employees can use all the equipment they want, if they’re not inspecting it, it could fail at any time.  When it comes to harnesses and lanyards, while they need to be periodically inspected by a Competent Person (one with the knowledge to recognize the hazard AND the authority to correct it), they should also be inspected by the user prior to every use.  In order for this to happen, your users need to understand what it is they’re looking for, what is acceptable and what is not, and what to do when they find a problem.  The inspection should be thorough, but does not need to take a lot of time.  Even so, this brief pre-work check could save a life.

4. Ensure You Understand Fall Distance

You can wear all the fall protection equipment in the world, but if it allows you to hit the lower level before it engages, it’s pointless.  This may sound like a “common sense” statement, but you’d be surprised at how many people don’t seem to have “common sense”.  It is not unusual to go onto a construction site or observe a maintenance crew in a plant and see a worker at 10-12’ off the ground wearing a 6’ lanyard with a deceleration device.  While at first glance you might think that it should work, there are a number of reasons why it won’t.  First, you have to add 3.5’ of distance to account for the deployment of your deceleration device.  Already that means the lanyard itself is 9.5’ long.  Unless you are a 6” tall person, this is some pretty bad news.  Your actual fall distance needs to not only include the length of your lanyard when deployed, but also your body length below the D-ring and any sag in your harness and anchor system.  Count on a good 18.5’ minimum before you’re able to use a 6’ lanyard with deceleration device.

5. Ensure the Selection of Acceptable Anchor Point

As Grandpa said in The Lost Boys, “We’ve got rules!”  Sure, he was referring to drinking his root beer and not peeling the label back on the TV Guide, but he might as well have been talking about anchor points.  If you were to pick a construction site at random right now and see what they’re using as anchor points, you might assume there were no rules.  PVC pipe?  Not an anchor.  Decorative steel?  Not an anchor.  In fact, many more things will NOT be an acceptable anchor point than WILL be an acceptable anchor point.  Why?  Because the anchor point must support not just the weight of the person attached, but 5000 lbs. per person attached (or a factor of 2 if you’re having an engineer determine your anchor).  Many fixtures are not going to withstand those forces.  Structural steel using a proper beam clamp?  Sure.  A manufactured roofing cart or other manufactured anchor?  Sure, if installed properly.  Short of that, you’re going to need some documentation and/or an engineer’s approval to use something as an anchor point.

6. Ensure You Select the Best Means of Working at Heights (Scaffold vs Lift vs Ladder)

Just as harnesses are not one-size-fits-all, neither are fall protection solutions.  In some situations, a scaffold is going to be your best solution to work at heights.  If so, you’ll probably be able to equip them with rails, making your fall protection much easier to address.  Other times, scaffolds will be infeasible and you’ll find yourself on a lift.  Depending on the type of lift, you may or may not need to wear a harness and a lanyard (and properly tie off).  Still other times, you’ll need to use a ladder, at which point the requirements for fall protection become trickier.  In the end, thinking that a ladder is going to suffice no matter what situation you’re in (or a lift, or a scaffold, or any other means of elevation) is only asking for problems.  Evaluate your situation carefully and determine what the right piece of equipment is for that task in that location.

7. Use Ladders Properly

Don’t assume that just because you have a ladder at home, you know what you’re doing.   In fact, the safest way to live on this planet is to always assume you don’t know what you’re doing.  In most cases, you’re going to be right!  Ladders lie at the source of many industrial and workplace accidents simply because we take their use for granted.  Ladders are familiar.  You use them to hang your Christmas lights, paint the living room, change that annoying hard to reach high-hat bulb, and clean your gutters.  We use them so often that we must know what we’re doing because we’ve never gotten hurt before! Well, except for that one time you closed the A-frame on your hand.  Or that time, the ladder slipped out from under you.  Or that time you had a tool on top of that ladder that fell onto you.  Or that time….well, never mind.  Ladders are dangerous.  When improperly used, they’re REALLY dangerous.  First, make sure that ladders are the best way to do what you’re doing, then make sure your employees know how to properly use them.  3’ extension, 4:1 ratio, 3 points of contact, and secured.  If you don’t know what that refers to, you may not know how to use an extension ladder properly.  You know that sticker on a step ladder that says, “Don’t stand on this step or above.”?  If you think that means you can step there but no higher, you might not know how to use a step-ladder.  Provide proper training to your employees so that they use the tools they are being given the right way.

8. Know Your Roofing Regulations

Roofing regulations are some of the most misunderstood requirements.  Not only do roofers not know exactly what is required of them much of the time, but many other contractors working on roofs who are not roofers believe that certain methods of fall protection are available to them when, in reality, they’re not.  Warning lines at 6’ with a monitor are only allowed for roofers performing roofing work (and 10’ back from the edge if there is mechanical equipment traveling in that direction).  Notice the phrase “with a monitor” in the previous statement.  There is NO situation in which a warning line is an acceptable means of fall protection that does not also include a dedicated monitor being present.  There are a few that allow for a monitor with no warning line (low-slope roofs less than 50’ in width for instance), but none that allow a warning line with no monitor.  Also, notice the phrase “dedicated monitor” in that previous statement.  Monitors must have no duties that would distract them from performing as a monitor.  You see where I’m going with this?  There are many nuances to the rules for roofers.  If you are one, make sure you are familiar with the regulations and your requirements or speak to somebody who is.

9. Ensure Proper Use of Lifts

There are many ways in which a lift operator can do something wrong, so I won’t get into the actual operation of lifts here, but we do need to discuss fall protection in regards to lifts.  One thing that gets missed quite often is that any person in a boom lift, at any time, at any height, must be properly tied-off.  “Properly tied-off” not only means that they need to be secured to the engineered anchor point designed with the lift, but it means that they can’t wrap their lanyard around the rails and they need to have a lanyard that is actually going to protect them at the height at which they are working (see fall distance above).  With scissor lifts, things are a little different.  While the site you are working on or the owner of the facility/project may require you to tie-off in a scissor lift, there is no regulatory requirement to do so.  However, the moment you forget to close your gate or secure your chain, you are no longer protected by the rails and are now in a fall protection violation.  It’s that simple.  Also, keep your feet planted firmly on the platform.  Both of them.

10. Train, Train, Train

It’s been mentioned in various paragraphs above, but it can’t be stressed enough.  If you want your employees to work safely at heights, they must be properly trained.  Period.  The end.  Not only is training required by law, there is just too much room for error and confusion when it comes to a person without the proper knowledge trying to protect themselves at heights.  Falls are the leading killer in construction year after year.  Many people in other industries die from falls as well.  They are deadly.  Most of the time, there are no do-overs.  Arm your employees with the knowledge they need to keep themselves safe.
Working safely at heights does not come by chance.  It is not something you luck your way into.  Working safely at heights takes preparation, education, and determination.  Take this brief list and dive into some of the more in-depth articles it links to.  When it comes to fall protection, you can’t have too much information.


Creating a Safe Walkway

Protecting Warehouse Workers

Pedestrians are some of the most vulnerable employees in a warehouse setting simply because (as we’ve stated in some of our recent articles) in a physical battle between man vs. machine, the machine is going to win…especially when that machine is a rolling piece of equipment weighing thousands of pounds. Hoping pedestrians and operators are smart enough to avoid a tragic incident is not an acceptable – or very effective – safety precaution.  What, then, can be done to help ensure the safety of pedestrians?

One of the most important things you can do as a warehouse manager or safety manager is to control exactly where pedestrians are walking while in your warehouse.  Making pedestrian travel paths predictable helps to ensure that operators know where to expect people.  It’s not that operators should not be alert for pedestrians at all times, but walkways help the operators to know where the high foot-traffic areas are.

However, simply saying, “Stay close to the wall,” or “Don’t cross over there,” is not enough.  The first thing you’ll want to do is designate the walkway.  Very infrequently will you be able to put a physical barricade up along the entire walkway, but at the very least you can paint it so there is no mistaking where it is.  That being said, if you have the luxury of physically separating your people from your machines using rails or bollards, by all means do it.  Even if it’s just in certain places.  Systems like this Kwik Kit make it easy for you to erect an OSHA-compliant barrier in varying lengths or configurations. There is no substitute for a physical barrier.

Once you’ve painted your walkway and/or added rails or bollards, your personnel need to be trained.  Having walkways does you absolutely no good if people aren’t going to stay within the boundaries.  The walkways also do you no good if operators are going to barrel through them at high speeds.  Set time aside to explain to your employees the purpose of the walkways, the hazards they face if they were to travel outside of them, and what the disciplinary action will be if they violate your rules (whether as a pedestrian or as an operator).  No safety procedure is going to be successful if there are no consequences for those that don’t follow it.  And, it is important that if you are going to have disciplinary actions, that you follow through with them.  Anybody who is a parent is probably painfully aware of what happens when a violator realizes they are facing nothing but empty threats.

It is important to note that you will not be able to have walkways everywhere pedestrians need to walk, otherwise your entire floor would be painted, which would be as pointless as not painting them at all.  When you train your employees, you need to train them on what they need to do and/or where they need to go once they have to step out of a walkway.  Just like teaching a child to look both ways before crossing a street, ensure they understand that forklifts have the right of way because they simply may not be able to stop in time for them (at the very least not without losing a load). Also, pedestrians need to always ensure the forklift operator is completely aware of their presence before continuing by making eye contact with the operator.  Teach your employees not to place themselves immediately behind any machine or between any machine and a fixed object like a wall.  You never know when an operator is going to lose control, hit the gas instead of the brake, or back up when they mean to go forward.

Even though it is more difficult, none of this means that you still can’t control access to undesignated or more dangerous areas.  For instance, where your walkway crosses a highly traveled forklift path, you may choose to install safety gates.  These gates force the pedestrian to pause and ensure it is safe to proceed before automatically closing to prevent anybody else from wandering through.  In this day and age of walking and texting, physically preventing people from wandering into traffic has become a sad necessity.

Finally, make sure you know who is wandering through your warehouse.  There is no better way to keep a handle on the safety of everyone in your facility than by knowing who is in there at all times, that they are supposed to be there, they have been trained, and that they adhere to your policies.  Sending a random truck driver, for instance, to go to a bathroom in the middle of your warehouse can not only put your product at risk, but can put them at risk of physical harm as well.  This is your facility.  Ensure that anybody who sets foot in it goes home safely when they leave.

 


Protecting Warehouse Workers

Protecting Warehouse Workers


In a recent article, we discussed the overall hazards forklift use in a warehouse poses and what you need to do to have a successful safety program in such a situation.  However, let’s drill down a little further to see not only how we can protect our workers from forklift hazards, but also how to protect them from other hazards that exist in warehouse environments.

Impact Protection

One of the most prolific hazards in warehouse environments would be impact hazards, or what OSHA calls “Struck-By Hazards” (though, there is a fine line between struck-by and caught between – for instance, being hit by a forklift would be struck-by, while being pinned between a forklift and a wall would be a caught-between).  We know that powered vehicles pose a great risk, but so does product that’s being moved around and stacked up.  Poorly wrapped pallets, product stacked too high, and awkward shaped/weighted material increases the chance of having an incident. Aside from training your operators to stack material properly and drive safely, the most effective means of protection is to physically keep people away from areas that could be hazardous.

Various products exist that help to keep your machines and your people from any unwanted meetings with each other.  Bollards, for instance, are great for protecting an area from forklift entry while still allowing easy pedestrian access.  A battery charging station would be a great example of where you might want to use these.  You can set them close enough to the chargers to allow you to get the forklift where it needs to be, but still eliminate a collision with the equipment.  Meanwhile, your personnel can still get to the chargers without having to climb over anything or go around any significant distance.

For areas where you don’t necessarily need pedestrian access, there are other impact barriers available that resemble more of a sturdy fencing system.  These are great for use along pedestrian walkways where you don’t want a break in the protection. 

Sometimes, a change in operation leads to the need to protect an area you weren’t considering when designing your warehouse layout.  Luckily, products like this “Kwik Kit” are available.  Quick and easy to set up, these types of systems can be configured to whatever you need.  Whether a temporary work area to accommodate seasonal business or a new process that will be around for a while, one of these kits can be quickly assembled for fast, easy protection.

Fall Protection

Fall protection isn’t something that necessarily comes to mind when you’re first discussing warehouse safety hazards, but just like anywhere else, fall hazards exist.  Keep in mind, since warehousing and maintenance work fall under OSHA’s General Industry standards, all it takes is an exposure to a 4’ drop to require fall protection.  Warehouses that have mezzanines are especially susceptible to this.  Sure, a simple railing protects the edge, but what do you do when you need to get material up to that level? 
Unless you have the capability to drop pallets in over a railing, you are going to need to have a gate.  And, what happens when that gate opens?  Fall hazard.  Unfortunately, this fall hazard is often overlooked or ignored.  Standing behind a railing waiting for a load does nothing when there’s a break in the railing inches away.  One option is to ensure that all of your personnel on the mezzanine are tied-off whenever the gate is open, but this allows for human error.  A better option is to consider installing gates that don’t allow for exposure.  This method eliminates your personnel “forgetting” to tie-off, choosing a bad anchor point, or not properly inspecting their equipment.

Fire Hazards

Besides the storage of material that could be flammable, the very existence of powered equipment brings in a potential fire hazard (not to mention an atmospheric hazard if you’re using gas, diesel, or propane fueled machines).  It is important to ensure that your sprinkler systems are tested as required, that you are not stacking material too close to the sprinklers, that you are not stacking empty pallets too high (in many cases, a stack of empty pallets more than 6’ high could burn too hot for a sprinkler system to put out), and that you have enough fire extinguishers throughout your facility that are properly inspected and maintained.

Conclusion

While, for the most part, warehouse hazards tend to be similar in nature, where and how they happen can be as varied as the different types of product you store.  Evaluating your situation is critical before you begin operations, but if you haven’t done a thorough evaluation yet, now is the time to do it.  Remember, a good pedestrian in a warehouse walks cautiously, ensures operators know where they are at all times, sticks to designated walkways, and pays attention to mirrors mounted at blind corners.  The only problem is that not all pedestrians are good pedestrians.  Don’t leave safety to chance.  Evaluate, plan, implement, and review so that you can ensure the well-being of not only your employees, but everybody that sets foot in your facility.

5 Ways to Effectively Use Your Safety Budget

5 Ways to Effectively Use Your Safety Budget

Sometimes you may have the luxury of working for a company that says, “Safety? Whatever you need, you get.”  However, that is certainly not always the case.  More often than not, you will need to work within a budget to meet your safety needs.  While it’s nice to say that safety is of the utmost importance, therefore cost should never matter, the reality is that a company is in business to make money and if they’re not doing that, they won’t be around for very long.

When faced with the idea of meeting a budget, it’s important that you plan well to avoid being out of funds when something critical arises. Sure, you could try to “wing it”, and as long as you hit no major hiccups you could be fine, but if you misstep, the results could be disastrous.

Plan Ahead

As you have probably guessed, I’m not the biggest fan of the “wing it” methodology.  My suggestion?  Plan ahead.  There are a number of things you will easily know a year out.  For example, which training courses are you required to provide to your employees annually?  What medical surveillance needs to occur each year?  What PPE do you need to keep in stock?  What subscriptions and dues are you required to maintain?

Answering these questions could give you a good foundation for what you intend to spend over the upcoming year.  Keep in mind, though, that you’ll need to figure in turnover or expansion.  If you account for training based on the current size of your company, but your company intends to increase the workforce by 25% over the course of the year, you are going to fall short.  In the same scenario, if you based your PPE needs on the averages of the prior few years when your workforce was smaller, your numbers aren’t going to work.  It’s important to know the company’s plans and how they will affect yours.

All that being said, you can never account for every possibility, but you can use all of the information available to you to come up with a sound estimate.

Training

There are a number of ways to satisfy your training requirements for the year, the most cost-effective of which would be for you to handle training internally.  First, though, you need to ask yourself if this is feasible.  Are you, or is somebody in your company, qualified to teach your employees what is necessary?  Perhaps you can teach Hazard Communication just fine, but need to bring somebody in to do your Hazardous Waste Operations and Emergency Response courses.  If so, you’ll need to account for the 3rd-party trainer in your budget.  Is your budget tight?  Maybe you want to look at some online training (Side Note: I personally believe that online training cannot compare to real-world training and the interaction that occurs with a qualified, experienced instructor, but online training certainly can serve a purpose when you have financial restrictions). 

If money is a concern, it doesn’t hurt to weigh the cost of taking a train-the-trainer cost (for instance, for such things as First Aid/CPR/AED or the OSHA Outreach 10 and 30 Hour courses) versus bringing somebody in.  When making this decision, though, you also need to factor in the value of your time.  How much training will you be doing?  How invasive will it be into the rest of what you are trying to accomplish?  Is it better to be in the field and office concerning yourself with other issues while your employees cycle through classes with a third party trainer?  In other words, if you are tied up in training, does that prevent other important things from getting done?

Purchasing

There are definitely tricks to stretching your budget when it comes to purchasing PPE and other equipment.  In my opinion, skimping on quality isn’t one of them.  Look, a $30 full-body harness that meets ANSI requirements is going to, by definition, perform exactly the same as a $250 full-body harness that meets ANSI requirements, but there’s a reason for the price difference.  Whether it’s comfort, additional functionality, or some other reason, you’re sacrificing something to pay the lower price.  And, if it’s comfort, you’ve just made enforcement 1000x harder.  That’s not to say you need to spend $250 per harness, but make sure you know what you’re getting before you purchase.  Also, the key above is that they both meet ANSI standards.  Don’t be fooled by junk that makes its way to market.  Look for the ANSI standard numbers listed on the label or stamped into the equipment.

If you have the opportunity to buy in bulk, do it.  You will receive discounts.  However, even if you can’t buy in bulk, getting a representative with a supplier will often result in getting prices you can’t get off the website or in a store.

Wants vs. Needs

At some point, you have to determine what you want versus what you need and they definitely aren’t always the same.  Again, we’d all like to think that safety budgets should be unlimited but we need to work within the resources available to us.  Perhaps you’ve always splurged on fancy brand-name safety glasses that run you $10-$15/pair.  Well, it could be time to drop that down a notch, especially since you can probably find similar ones for less than $5/pair.   Do you turn every safety meeting into a two-day affair with breakfast and lunch?  Perhaps you need to look at if that is necessary.  Sure, we all want to keep our employees happy, but if you’re pressed for money, then maybe requiring students to bring lunch isn’t the end of the world or perhaps there’s just a less expensive way to feed them, rather than eliminating food altogether.

Efficiency Tools

There are many tools out there now that can help make you much more efficient in your work.  While you may look at some of them as an extra expense, what does it save you in your time or in money that bleeds out unnoticed because it’s in drips and drabs?  One example is an online SDS service.  Sure, you have to pay for a subscription, but how much time are you spending trying to make sure that you always have the most up-to-date SDS?  Most online services push new versions out to you as they become available.  And, if you’re not spending much time doing it, is your SDS book compliant?  Is it current?  Tools like this can make you more efficient, saving your company money. 

Training tracking software is another tool that may have some up-front costs but can save you a ton of time down the road.  If you’re using simple spreadsheets, not only do you have to spend time maintaining them, but you need to manually search to see who needs training refreshers and doing that way makes it easy to miss things.  Make sure you know what tools and technology are available to you so that your time and energy isn’t spent in the wrong places.

Conclusion

Budgets aren’t easy, and they certainly aren’t as much fun as being able to spend what you want when you want, but there’s no denying they’re a necessary evil.  Don’t go into them blind. Research, prioritize, and plan ahead.  You don’t always need more dollars, you just need to be able to get more out of the ones you already have.


Best Practice for Pedestrian Safety

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.

 


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