The Occupational Safety and Health Administration (OSHA) is tasked with ensuring safety for workers in the United States. It is in your best interests to comply as fully as possible with all applicable OSHA standards. By implementing a preventative occupational safety and health program we achieve a number of valuable results.
By taking steps to reduce the incidence of employee injuries and illnesses, employers show employees that they care for their welfare. If properly communicated to employees, a good program can lead to increased loyalty, job satisfaction and productivity and to decreased turnover.
To secure a safe work place and fight rising costs associated with injuries ad illnesses, your defense is a good offense. By instituting a comprehensive safety program and by preparing yourselves in the event that an OSHA inspection does occur, you can strengthen your business both financially and productively.
It is helpful to know some of the common forms of documentation OSHA requests during inspections so that they can be prepared ahead of time for maximum benefit and compliance. Consider enlisting outside help if any of these areas are deficient a your workplace.
1. Safety Program – A written safety program is the cornerstone to any effective workplace safety plan. The program should be specific to the employer, and address hazards that are particular to the worksite. The program should be reviewed periodically to be sure that it addresses hazards in the workplace in a meaningful way. There are resources available to help prepare an effective document, so you should resist the urge to adopt a program from another company, or to copy a program from the internet.
2. Recordkeeping – Each employer with ten or more employees must keep records regarding workplace injuries and illnesses. These are commonly referred to by their form number – the 300 Logs. Employers must keep logs up to date with any injuries and illnesses that meet the criteria set forth in the standard. At the end of each calendar year, the information must be compiled into the Summary (300A) Log and posted conspicuously in February, March, and April. Summary logs must be posted at each jobsite that lasts longer than one year. The logs must also be archived for at least five years.
3. Training – It is incumbent on the employer to provide training to employees regarding the safe performance of their duties. Although documentation for most types of training is not strictly required by the standards, it is a very good practice to retain documentation for any training that employees receive, including dates, topics, and attendees. Be especially aware of the requirements for specialized training like, powered industrial trucks, crane certifications, respirator use, hearing protection, etc. If you are not sure if your workplace requires specialized training, contact Comprehensive Safety Resource to schedule an audit of your jobsite.
4. Hazard Communication – Each employer must keep copies of Material Safety Data Sheets for most chemicals in use in the workplace available to employees. It is important that MSDS’s are reviewed at least annually to ensure that they are up to date and accurate.
No matter how careful we are, there is always a chance that an OSHA official will conduct an inspection of the facility or jobsite. OSHA may carry out an inspection for any of the following five reasons, in order of priority:
1. Imminent Danger – If there is a report of a condition with a high probability of causing death or serious physical harm, an inspection will be initiated.
2. A catastrophe or fatality - If an employment-related fatality or an accident that results in the hospitalization of three or more of your employees occurs, you must report it to OSHA within 8 hours. In this case, OSHA is required to make an inspection.
3. An employee complaint - Generally, OSHA will limit its inspection to the condition(s) alleged in the complaint. At your request, OSHA must provide you with a copy of this complaint, although the employee's name will not be included.
4. Targeted Industry Program investigation - Each year, OSHA selects several industries with high rates of injuries and targets them for increased levels of inspections.
5. General Inspections - Area OSHA offices randomly inspect employers within their jurisdictions.
By preparing the required documentation and training employees in the safe execution of their tasks, you can elevate safety, reduce injury, and increase the chance of a favorable outcome to an OSHA inspection.
Jason
Monday, February 21, 2011
Wednesday, February 2, 2011
Untangling Extension Cord Usage
Extension cords are a common sight on both Construction and General Industry jobsites. When used properly, they provide convenience and flexibility. Improperly used, they pose serious health and physical hazards to the work.
When using extension cords, the first step is to ensure that the cord chosen is appropriate for the task. Both the General Industry and the Construction standards require that only ‘hard service’ or ‘junior hard-service’ cords may be used on the jobsite. In practical terms, this means the cord type should be SO or SJ. The type will be embossed on the outside cable jacket, so make sure it contains those letters. Flat-style extension cords, like the ones commonly used to connect decorative, holiday lighting are not approved for use at work.
The next step is to make sure that the cord has the appropriate current-carrying capacity to safely connect the load. Check the tool or appliance for its amperage-rating, then select a cord that has conductors large enough for the application. Consult the manufacturer, or consult with a qualified person if there is any question about the appropriate size.
The cord must be inspected before use to determine that it is safe to put in operation. Some examples of inspection points are the strain relief, making sure the prongs are in good condition, and checking the cable jacket for any burns, cuts, or abrasions that could affect the integrity of the insulation. Employees must receive training from the employer regarding the safe use of extension cords on the jobsite, and regarding the inspection process that is required. It is never a bad idea to document the inspections. If the cord is in any way deficient, then it must be removed from service and replaced or repaired by a qualified worker.
Lastly, the cord must be used in a safe manner. This includes making sure the cord is not damaged while in use. Employers should take care to see that cords are not subject to physical hazards on the jobsite such as sharp corners, having doors and windows closed on them, and heat damage from welding, cutting, or brazing operations on the jobsite. Cords should also be routed in such a way as to reduce the trip hazard they can cause. When the work is finished, the cord should be rolled up and stored safely.
Cords may not be used as a substitute for the fixed wiring of a structure, so make sure that extension cords are only used in a temporary fashion. Choose the right cord for the task, inspect them before use, and repair or replace any damaged cords. These steps will help reduce shock and physical hazards associated with extension cord use on the jobsite.
-Jason
When using extension cords, the first step is to ensure that the cord chosen is appropriate for the task. Both the General Industry and the Construction standards require that only ‘hard service’ or ‘junior hard-service’ cords may be used on the jobsite. In practical terms, this means the cord type should be SO or SJ. The type will be embossed on the outside cable jacket, so make sure it contains those letters. Flat-style extension cords, like the ones commonly used to connect decorative, holiday lighting are not approved for use at work.
The next step is to make sure that the cord has the appropriate current-carrying capacity to safely connect the load. Check the tool or appliance for its amperage-rating, then select a cord that has conductors large enough for the application. Consult the manufacturer, or consult with a qualified person if there is any question about the appropriate size.
The cord must be inspected before use to determine that it is safe to put in operation. Some examples of inspection points are the strain relief, making sure the prongs are in good condition, and checking the cable jacket for any burns, cuts, or abrasions that could affect the integrity of the insulation. Employees must receive training from the employer regarding the safe use of extension cords on the jobsite, and regarding the inspection process that is required. It is never a bad idea to document the inspections. If the cord is in any way deficient, then it must be removed from service and replaced or repaired by a qualified worker.
Lastly, the cord must be used in a safe manner. This includes making sure the cord is not damaged while in use. Employers should take care to see that cords are not subject to physical hazards on the jobsite such as sharp corners, having doors and windows closed on them, and heat damage from welding, cutting, or brazing operations on the jobsite. Cords should also be routed in such a way as to reduce the trip hazard they can cause. When the work is finished, the cord should be rolled up and stored safely.
Cords may not be used as a substitute for the fixed wiring of a structure, so make sure that extension cords are only used in a temporary fashion. Choose the right cord for the task, inspect them before use, and repair or replace any damaged cords. These steps will help reduce shock and physical hazards associated with extension cord use on the jobsite.
-Jason
Monday, January 17, 2011
Deconstructing OSHA Crane Standards, Pt. 3 1926.1400
A few weeks ago, I posted a couple of articles about the Construction Crane Standards that went into effect in November of 2010. I would like to address one more important change that is included in the update; the new requirements for working around power lines.
The basic requirement before the change was that workers had to stay at least ten feet away from energized overhead electrical lines. This proved over the years to not always be sufficient, so the new standard has some different requirements. First, the competent person has to evaluate the jobsite and determine if any part of the equipment, load line, or load can come within 20 feet of a power line. If so, then there are three options for controlling the hazard that may be exercised.
Option one is the simplest where practical, and provides the most protection. The employer simply confirms with the utility owner or operator that the conductors have been deenergized, and visibly grounded at the jobsite. Requirements for uninterrupted electricity may preclude this solution.
Option two is to ensure that no part of the assembly comes within 20 feet of the line. This will also require ‘encroachment prevention procedures’ outlined in the standard. These procedures will require a planning meeting with all employees on the jobsite, nonconductive tag lines, and at least one other prevention measure. The additional measure may include spotters, proximity alarms, or elevated warning lines. Consult the OSHA Standards for clarification, and a Safety Consultant or industry organization if you still have questions.
Option three allows the employer to determine the voltage the power lines are operating at, then consult a table published in the standard to determine the appropriate clearance to maintain from the equipment. Voltages over 350kV will require more than 20 feet of clearance. Option three also requires the additional encroachment prevention procedures as option two.
The standard also requires training for all employees that may be exposed to these hazards, and like most of the training required by OSHA, it must be provided by the employer at no charge, and before the work actually commences. Documentation of the training is a good idea, too.
Ensuring that equipment stays clear of energized power lines on any jobsite should, obviously, be a priority, and complying with the new requirements in the OSHA Construction Crane Standard is one more tool employers have to protect worker safety.
-Jason
The basic requirement before the change was that workers had to stay at least ten feet away from energized overhead electrical lines. This proved over the years to not always be sufficient, so the new standard has some different requirements. First, the competent person has to evaluate the jobsite and determine if any part of the equipment, load line, or load can come within 20 feet of a power line. If so, then there are three options for controlling the hazard that may be exercised.
Option one is the simplest where practical, and provides the most protection. The employer simply confirms with the utility owner or operator that the conductors have been deenergized, and visibly grounded at the jobsite. Requirements for uninterrupted electricity may preclude this solution.
Option two is to ensure that no part of the assembly comes within 20 feet of the line. This will also require ‘encroachment prevention procedures’ outlined in the standard. These procedures will require a planning meeting with all employees on the jobsite, nonconductive tag lines, and at least one other prevention measure. The additional measure may include spotters, proximity alarms, or elevated warning lines. Consult the OSHA Standards for clarification, and a Safety Consultant or industry organization if you still have questions.
Option three allows the employer to determine the voltage the power lines are operating at, then consult a table published in the standard to determine the appropriate clearance to maintain from the equipment. Voltages over 350kV will require more than 20 feet of clearance. Option three also requires the additional encroachment prevention procedures as option two.
The standard also requires training for all employees that may be exposed to these hazards, and like most of the training required by OSHA, it must be provided by the employer at no charge, and before the work actually commences. Documentation of the training is a good idea, too.
Ensuring that equipment stays clear of energized power lines on any jobsite should, obviously, be a priority, and complying with the new requirements in the OSHA Construction Crane Standard is one more tool employers have to protect worker safety.
-Jason
Friday, December 31, 2010
Happy New Year!
All of us at Comprehensive Safety Resource wish you a prosperous and safe New Year. (Now, go check those smoke detectors since you forgot to do it in October.)
-Jason
-Jason
Monday, December 20, 2010
Training Options for Safety
Employee training is a key component of any successful safety program, and OSHA requires employers in the United States to furnish it. The question then is, what is the best way to deliver it?
The traditional classroom setting, with a live instructor, is probably the most flexible method. A knowledgeable instructor can evaluate the makeup of the class and tailor the content to the specific needs of the attendees. But, work schedules, travel arrangements, and other factors may make this type impractical.
Correspondence courses are also available, where the student receives instructional material in the mail, completes it, then mails it back to the instructor for grading. I have personally never taken a correspondence course, but I imagine that the greatest drawback would be the tendency to forget about the material until it was too late to send it in. In any case, this method would require considerable self-discipline to gain any knowledge from the material. Correspondence courses are no longer widely requested.
The most common type of distance-based training now, utilizes the computer. Many different types of training are available, even OSHA 10- and 30- Hour courses in both General Industry and Construction. The availability of internet training has never been so great, and in many instances, this type of training offers several benefits over other types of instruction.
The first one, in many minds, is cost. If a company only has a few employees that need training, internet-based training may be substantially cheaper. For the traditional classroom setting, the cost of the instructor is usually about the same whether there is one student, or twenty-five. Not only does the instructor incur costs, but if the employees have to travel to attend training, the company will incur costs as well that add on to the overall expense o the training. For online training, the fee is set, usually per person, no matter where the employees are located, for larger groups, it may be possible to negotiate a reduced rate with the online training provider.
Another benefit of internet-based training is the convenience. Often work schedules, product shipments, employee vacation days, and the like conspire to make centralized classroom training difficult to accomplish. Online training, however, allows employees to progress as they have time, making the scheduling problem almost disappear. This helps insure that deadlines are still met, that projects are completed on time, and that product gets out the door. Many courses will have a time limit, but they are usually measured in weeks or months, not hours.
Location is also sometimes a factor in training. For online training, employees only need a computer with internet access. The do not have to travel to meet at a central location. This can be a huge benefit for employers that have several offices, or employees that work at remote locations. The travel costs to get all employees at the same location can be huge. Online training eliminates that.
Employers have the duty to furnish relevant training to employees, but deciding how to accomplish it can be a challenge. Online, internet-based training adds one more solution that more and more companies choose as they weigh cost with benefit.
-Jason
The traditional classroom setting, with a live instructor, is probably the most flexible method. A knowledgeable instructor can evaluate the makeup of the class and tailor the content to the specific needs of the attendees. But, work schedules, travel arrangements, and other factors may make this type impractical.
Correspondence courses are also available, where the student receives instructional material in the mail, completes it, then mails it back to the instructor for grading. I have personally never taken a correspondence course, but I imagine that the greatest drawback would be the tendency to forget about the material until it was too late to send it in. In any case, this method would require considerable self-discipline to gain any knowledge from the material. Correspondence courses are no longer widely requested.
The most common type of distance-based training now, utilizes the computer. Many different types of training are available, even OSHA 10- and 30- Hour courses in both General Industry and Construction. The availability of internet training has never been so great, and in many instances, this type of training offers several benefits over other types of instruction.
The first one, in many minds, is cost. If a company only has a few employees that need training, internet-based training may be substantially cheaper. For the traditional classroom setting, the cost of the instructor is usually about the same whether there is one student, or twenty-five. Not only does the instructor incur costs, but if the employees have to travel to attend training, the company will incur costs as well that add on to the overall expense o the training. For online training, the fee is set, usually per person, no matter where the employees are located, for larger groups, it may be possible to negotiate a reduced rate with the online training provider.
Another benefit of internet-based training is the convenience. Often work schedules, product shipments, employee vacation days, and the like conspire to make centralized classroom training difficult to accomplish. Online training, however, allows employees to progress as they have time, making the scheduling problem almost disappear. This helps insure that deadlines are still met, that projects are completed on time, and that product gets out the door. Many courses will have a time limit, but they are usually measured in weeks or months, not hours.
Location is also sometimes a factor in training. For online training, employees only need a computer with internet access. The do not have to travel to meet at a central location. This can be a huge benefit for employers that have several offices, or employees that work at remote locations. The travel costs to get all employees at the same location can be huge. Online training eliminates that.
Employers have the duty to furnish relevant training to employees, but deciding how to accomplish it can be a challenge. Online, internet-based training adds one more solution that more and more companies choose as they weigh cost with benefit.
-Jason
Monday, November 29, 2010
Deconstructing OSHA Crane Standards, Pt. 2 1926.1400
In the last post, I discussed some of the changes imposed by the new OSHA Construction Crane Standards. Operator Certification was the focus there, but there are new requirements for other employees, too.
Effective immediately with the new standards (as in, it’s already happened,) is a new requirement for signal persons. The rule now requires signalers for affected crane operations to be qualified for that operation. Signal person qualification must be documented either on paper or electronically, and be available on the jobsite. The documentation must specify the type of signaling for which the employee is qualified. (i.e. hand signals, radio signals, smoke signals, etc.)
To be considered “qualified” under the new standards, the employee must understand the types of signals in use on the jobsite, demonstrate competency in using those signals, understand the operation of the particular cranes in use, and understand the requirements of the OSHA Standard relevant to signal person qualification. Additionally, the signal person must pass both a written and a practical exam dealing with the subject. This training can be performed by a qualified third-party evaluator, or by a company’s in-house qualified evaluator. There is no accreditation required for the evaluator, they just need to be able to demonstrate that they are capable of assessing whether or not a signal person is qualified in accordance with the standard.
A signal person is required on any jobsite where the point of operation is not completely visible to the crane operator, or if the operators view is obstructed in the direction the equipment is traveling. A signal person is also required if the operator or the person handling the load deems one necessary due to site-specific safety concerns.
Riggers also need to be qualified under the new standard, but the requirements for documentation are a little less strenuous. A qualified rigger is defined as a "qualified person" who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve/resolve problems relating to rigging.
A qualified rigger is required whenever assembly or disassembly of the crane is being performed. A qualified rigger is also needed whenever employees are engaged in hooking/unhooking the load, guiding the load, or otherwise manipulating loads, and are within the fall zone of the material.
In the next post, we’ll examine some additional requirements for crane operations, especially operations near power lines. In the mean time, if you have specific questions, consult OSHA directly, or contact a private safety consultant to address your specific needs.
Jason
Effective immediately with the new standards (as in, it’s already happened,) is a new requirement for signal persons. The rule now requires signalers for affected crane operations to be qualified for that operation. Signal person qualification must be documented either on paper or electronically, and be available on the jobsite. The documentation must specify the type of signaling for which the employee is qualified. (i.e. hand signals, radio signals, smoke signals, etc.)
To be considered “qualified” under the new standards, the employee must understand the types of signals in use on the jobsite, demonstrate competency in using those signals, understand the operation of the particular cranes in use, and understand the requirements of the OSHA Standard relevant to signal person qualification. Additionally, the signal person must pass both a written and a practical exam dealing with the subject. This training can be performed by a qualified third-party evaluator, or by a company’s in-house qualified evaluator. There is no accreditation required for the evaluator, they just need to be able to demonstrate that they are capable of assessing whether or not a signal person is qualified in accordance with the standard.
A signal person is required on any jobsite where the point of operation is not completely visible to the crane operator, or if the operators view is obstructed in the direction the equipment is traveling. A signal person is also required if the operator or the person handling the load deems one necessary due to site-specific safety concerns.
Riggers also need to be qualified under the new standard, but the requirements for documentation are a little less strenuous. A qualified rigger is defined as a "qualified person" who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated the ability to solve/resolve problems relating to rigging.
A qualified rigger is required whenever assembly or disassembly of the crane is being performed. A qualified rigger is also needed whenever employees are engaged in hooking/unhooking the load, guiding the load, or otherwise manipulating loads, and are within the fall zone of the material.
In the next post, we’ll examine some additional requirements for crane operations, especially operations near power lines. In the mean time, if you have specific questions, consult OSHA directly, or contact a private safety consultant to address your specific needs.
Jason
Monday, November 8, 2010
Deconstructing Construction Crane Standards, Pt. 1
Well, it’s November 08, 2010, and if you are covered under OSHA’s 1926 standards for Construction, and you operate just about any sort of crane, then your world has probably changed a little. After almost forty years, the Overhead Crane standards have been dramatically revised, with major changes in the training requirements for both operators and for ground personnel. Those changes went into effect this morning. We’ll explore these changes over the course of the next couple of updates.
First off, who is affected by these changes? Well, the easy part is, if you fall under OSHA’s 1910, General Industry standards, you can relax; this isn’t aimed at you. Only Construction is involved with this round of changes. The standard defines a crane for the purposes of this section as "power-operated equipment that, when used in construction, can hoist, lower and horizontally move a suspended load" [1926.1400]. That’s pretty broad, so these changes are obviously meant to have pretty sweeping impact. Some, but not all, equipment included are mobile cranes, tower cranes, crawler cranes, boom trucks, knuckleboom cranes, and cranes on barges. Also included are service trucks with a lifting device, pile drivers, and multipurpose equipment that is outfitted to hoist and lower, and horizontally move a suspended load.
Now, before everyone gets too upset, there are some exclusions. First off, there is a general exclusion for equipment with a manufacturer’s rated lifting capacity of less than 2000 pounds. Also, several types of equipment are mostly excluded; excavators, backhoes (even when used to lift suspended loads), concrete pumps, aerial lifts, tow trucks, digger derricks, gantry systems, and forklifts among them. Be sure and check 29 CFR 1926.1400(c) for detailed information on the exclusions.
Probably the biggest change involved in the new revision is the requirement for training of personnel involved in crane operations. Today, we will look at the most prominent: the operator. Beginning today, all operators of affected equipment must be certified to operate the specific equipment under their control. However, there is a four-year grace period to have the training completed, giving a real deadline of November 10, 2014. There are a few ways to comply with this standard. The first is to send operators to a nationally-accredited training program that includes practical and written tests specific to the equipment type and rating for their certification. This option may be the easiest to implement, if not necessarily the least expensive. A quick internet search for ‘crane certification’ should pull up several options, just make sure they are nationally accredited to insure compliance with the standard.
Another option is an audited employer training program. The employer may hire an independent auditor (certified by an accredited crane operator testing organization) to oversee training programs developed by the company. This option results in a certification that is not portable, so employees certified under this rule may only operate equipment while employed by that company. This option requires the employer to take an active role in training, and may be a good option if company resources permit.
There are also options to be certified by a government entity, or by the US military. In any case, certifications are valid for a maximum of five years.
We’re over 500 words into this, and we have barely scratched the surface. In the next installment, we will look at the changes that affect signalers and riggers. In the mean time, if you need additional assistance, the crane standard can be found in 29 CFR 1926.1400, and an independent safety consultant can be contacted to help determine what particular exposures your company has, and what approach would be most effective in ensuring your compliance.
-Jason
First off, who is affected by these changes? Well, the easy part is, if you fall under OSHA’s 1910, General Industry standards, you can relax; this isn’t aimed at you. Only Construction is involved with this round of changes. The standard defines a crane for the purposes of this section as "power-operated equipment that, when used in construction, can hoist, lower and horizontally move a suspended load" [1926.1400]. That’s pretty broad, so these changes are obviously meant to have pretty sweeping impact. Some, but not all, equipment included are mobile cranes, tower cranes, crawler cranes, boom trucks, knuckleboom cranes, and cranes on barges. Also included are service trucks with a lifting device, pile drivers, and multipurpose equipment that is outfitted to hoist and lower, and horizontally move a suspended load.
Now, before everyone gets too upset, there are some exclusions. First off, there is a general exclusion for equipment with a manufacturer’s rated lifting capacity of less than 2000 pounds. Also, several types of equipment are mostly excluded; excavators, backhoes (even when used to lift suspended loads), concrete pumps, aerial lifts, tow trucks, digger derricks, gantry systems, and forklifts among them. Be sure and check 29 CFR 1926.1400(c) for detailed information on the exclusions.
Probably the biggest change involved in the new revision is the requirement for training of personnel involved in crane operations. Today, we will look at the most prominent: the operator. Beginning today, all operators of affected equipment must be certified to operate the specific equipment under their control. However, there is a four-year grace period to have the training completed, giving a real deadline of November 10, 2014. There are a few ways to comply with this standard. The first is to send operators to a nationally-accredited training program that includes practical and written tests specific to the equipment type and rating for their certification. This option may be the easiest to implement, if not necessarily the least expensive. A quick internet search for ‘crane certification’ should pull up several options, just make sure they are nationally accredited to insure compliance with the standard.
Another option is an audited employer training program. The employer may hire an independent auditor (certified by an accredited crane operator testing organization) to oversee training programs developed by the company. This option results in a certification that is not portable, so employees certified under this rule may only operate equipment while employed by that company. This option requires the employer to take an active role in training, and may be a good option if company resources permit.
There are also options to be certified by a government entity, or by the US military. In any case, certifications are valid for a maximum of five years.
We’re over 500 words into this, and we have barely scratched the surface. In the next installment, we will look at the changes that affect signalers and riggers. In the mean time, if you need additional assistance, the crane standard can be found in 29 CFR 1926.1400, and an independent safety consultant can be contacted to help determine what particular exposures your company has, and what approach would be most effective in ensuring your compliance.
-Jason
Subscribe to:
Posts (Atom)