Let’s talk Safety Audits. 

Specifically, how often to conduct them. A common question we get from our clients is, How often should I be conducting safety audits? Frankly, the answer to that is that there is no exact timeframe. Because every job site and management team has different rules and factors to consider before scheduling an audit, there is not just one answer. However, the following are some of those factors and suggestions for what the audit rate should be. 

To begin, here are some factors should be considered in safety audit scheduling:

• First, has the job site changed?

• Second, are there new risks to the work environments, operations, and equipment used?

• Next, Have the number of trades or workers on the site increased?

• Finally, have there been at-risk activities or near-miss reports that would spark the need for an audit?

Any of these factors can change the frequency of safety audits. Now, the only way to know how often they are needed is by thoroughly reviewing the job site, operations, and knowledge of the crews involved. Basic company established written safety procedures serve as a great place to start. The fact is, however, that most effective safety programs are always changing according to the job environment, crew changes or trades working on the site. 

So, what is a reasonable answer to audit frequency?  OSHA, under requirements listed in its Voluntary Protection Program, has issued recommendations that employers can follow to improve their health and safety programs. Their conclusion – audits should normally be done WEEKLY. In the case of multi-employer worksites all subcontractors on-site should be inspected.  Due to the different nature of the various construction trades and the hazards they face, audits may be more frequent and focus on separate areas or equipment for each.

Additionally, OSHA states that regularly scheduled safety audits should have the following factors included in the audit process:

1. A list of all items and operations to be reviewed.

2. Clear and recurring audit schedules.

3. Completion and findings should be recorded and be available for management and crew to review following the audit.

4. Responsibility should be assigned to specific crew members to reduce or eliminate risks found, including when they are corrected.

5. A record of that correction should be kept and added to the audit.

Contact us for help with this process. 

DEVEOLPING A WORLD CLASS SAFETY PROGRAM

Let’s talk safety programs – specifically how they are developed and what needs to be done to improve them.  You might be surprised to learn, as I was, that many smaller companies “appropriate” the plans of one or more of their vendors or friends as their own.  After all, why go through the trouble and expense to reinvent the wheel?   Let’s examine that idea a little closer and put it in a more familiar context. 

Suppose you wanted to build a new home for your business – a warehouse and/or manufacturing space complete with offices.  Perhaps you were particularly struck by a building you recently visited, or one owned by a colleague.  Maybe that colleague even offered to give you their plans to use as your own.  Would you do it? I doubt it.  First, you would want a facility that reflected your business and would put your own personal stamp on it.  Perhaps the building codes in your area would not permit that specific building from being built in your area.   But the bigger question becomes, would someone else’s system meet your needs?  Probably not.

So why would you want to copy and paste a safety program that was designed for another company and appropriate it as your own?  You wouldn’t.   Simply, OSHA requires that a company’s safety program reflect the hazards that company faces and that each company has the responsibility to protect its workers from harm.  (Read the General Duty Clause if you need to see why).   Of course, every safety program should have similar headings, but that’s where the comparison ends.

In subsequent posts, I will address the areas that I think are common to a world class safety program.  But remember – your safety program has to reflect what you actually do!  Keep you eyes on this space for more info to come.

New ANSI Standard

STANDARDS BLUES

Let’s take a few minutes to talk standards – specifically the recent ANSI standard changes for Aerial Lifts. The first question most people ask me is “Why worry about an ANSI standard change?  Isn’t it OSHA that we have to be wary of??”  My answer is simple – standards evolve.  Changes in the EU eventually find their way here.  Changes in ANSI will almost certainly be incorporated into the OSHA standard at some point.  Need proof?  Just look at ANSI 359 (fall protection).  It ushered in any number of changes and interpretations to Subpart M once it was introduced.  I expect the same with this change. 

So, what are some of the differences?  ANSI A92 is designed to bring the aerial lift industry closer to a worldwide consensus (can you say Globally Harmonized System??) and really affects two main areas – design and training – and applies to owners, manufacturers and users.  However, because it applies to manufacturers you will see it in their literature and on their machines soon.

The changes start with the nomenclature.  We will now NOT be talking about scissors lifts, JLGs or articulating boom lifts.  The new name is Mobile Elevated Work Platforms (MEWPS) and will now be placed into two groups, amazingly called Group A and Group B.  In Group A, the center of the work platform does not extend beyond the edge of the chassis at any time (think scissors lifts).   In Group B, the center of the work platform can extend beyond the chassis (think boom lifts).  To add to the confusion, each group can be further broken down into three sub-categories:

• Lifts that can travel only in the stowed position. These must be moved manually.

• Lifts that are controlled from the chassis. These can be driven while the platform is in the air.

• Lifts that have controls on the work platform. These can also be driven while the platform is in the air.

The new standard goes on to offer examples of each, but I am sure the above will properly identify the types for you.

The substantive standard changes are in three areas – equipment changes, safety plans and training.  Lets briefly look at them. 

1). Equipment changes: New aerial lifts must be equipped with two types of sensors. One sounds an alarm and prevents the machine from operating when the load exceeds safety limits. The other is a tilt sensor that triggers an alarm when the slope level gets too steep. It also prevents movement of the chassis or work platform in the event of an alarm.  In addition, units cannot use chains to close off entrances as in the past, they must have gates that include toe boards.  Outdoor units must also have wind indicators that will allow them to be safely used in windy conditions and if used in rough terrain conditions they must have solid tires to aid stability.  The final equipment change is that the railings will be higher (43.5”) rather than the 39” previously.

2). Safety Plans:  Going forward, every business using a MEWP will be required to have a written safe use plan.  That plan should include a site risk assessment; a rescue plan understandable by all employees (multiple languages if necessary); a trained supervisor to monitor worker use and compliance while using the equipment; and finally steps to prevent authorized use and to protect workers NOT using the equipment.  Obviously, this is a major change for users.

3). Training: This is perhaps the biggest potential hurdle for users.  ANSI A92 has rules for both supervisors and operators.  The new standard requires that all supervisors of MEWP workers, in addition to being able to select the best device for the job, must ensure that they know the safe operating rules for that specific piece of equipment and the hazards related to its use and how to protect against them. They also must see to it that a copy of the operator’s manual is in each piece of equipment.  That would require that the leasing or renting company, if that is the case, must include the manual with the rental.  If its not there, technically the lift may not be used.  Operators must provide training to any other workers using the lift with them.

The using company must also now have a SITE-SPECIFIC rescue plan which details how workers get down if the lift stops or malfunctions while they are in the air.  It is also the employer’s responsibility to make sure that users know how to operate the lift being used and that they read the manual and familiarize themselves with the operation of the lift and safety precautions before use.

 So, as you can see, this new ANSI standard could easily become a minefield for users of this equipment.  Even though ANSI standards are voluntary, remember, it is always possible to cite employers under OSHA’s General Duty Clause, where the fines can reach nearly 130,000.00.

If you have questions or need training on this new standard, which goes into full effect in December 2019, keep in mind that The Safetyguys are ready to help.  You can contact us directly or through our website.

Worker deaths during elevator construction due to falls increase!!

A recent article in Safety & Health Magazine from February, 2019 quoted a recent report from the Center for Construction Research and Training which detailed that a total of 145 construction workers were killed in elevator-related incidents from 2011 through 2016 – more than twice the combined total for all other industries,

Falls to a lower level were the leading cause of elevator-related construction deaths, accounting for 53.5 percent of the fatalities. Nearly half of the fatal falls – 47.9 percent – were from heights of 30 feet or more.

Other findings:

• Workers installing or repairing elevators had the highest fatality rate, at 14.9 per 100,000 full-time equivalent workers. Laborers experienced the most fatalities, with 31.

• Workers in organizations with 10 or fewer employees comprised 33.8 percent of the fatalities.

• 35.2 percent of the fatally injured workers were younger than 35.

• Annual elevator-related fatality totals trended upward between 2003 (14) and 2016 (28), peaking at 37 in 2015.

The report includes injury prevention strategy recommendations from CPWR, OSHA and NIOSH, including guidance for fall protection systems, personal protective equipment, and safety training and management..

Of particular interest in these statistics was the number of deaths in smaller companies and among younger workers. We can help you not to become a statistic!!

Examine our four step process to achieve best safety practices and reduce costs!!

Step #1. We analyse existing data regarding work practices, injuries, accidents, OSHA inspections and citations. We then perform as detailed evaluation of your currentSafety policies and procedures.

Step #2. Using the information from Step 1, we design a new comprehensive safety program to deal with the type of work you perform and any issues we find.

Step #3. We then set up a training schedule that takes into account the NEW safety program - and we do it without interfering with current work schedules.

Step #4, We conduct regular (at least weekly) safety audits to determine the level of compliance with the new program. During those audits we instruct employees about any deviations from procedure.

All Site Audits are sent electronically to all managers immediately for their review.. The audits will include detailed inspection observations including pictures and corrections made. These PDF reports could then easily become part of the relevant job files for future references or to provide to OSHA in the event of any issues.

Protecting skylights

When the Walking and Working Surfaces standard changed last year, I focused on the changes that primarily affected my main business - mainly competent person issues, ladders and rope descent systems. Recently, I read an article which pointed out something I had glossed over, namely a major difference in the wording regarding force loads on covers for skylights, which started me thinking. The prior standard said "Skylight screens shall be of such construction and mounting that they are capable of withstanding a load of at least 200 pounds applied perpendicularly at any one area on the screen. They shall also be of such construction and mounting that under ordinary loads or impacts, they will not deflect downward sufficiently to break the glass below them…" - 1910.23 (e)(8) .

That compares to the revised standard which states "Is capable of supporting without failure, at least twice the maximum intended load that may be imposed on the cover at any one time…" - 1810.29(e)(1).

Since Maximum intended load means the total load (weight and force) of all employees, equipment, vehicles, tools, materials, and other loads the employer reasonably anticipates to be applied to a walking-working surface at any one time it appears that systems that rely on static, rather than dynamic testing will not meet the revised standard.

In looking at the fall protection standard we see references to force loads not exceeding 900 pounds. Given the twice the intended maximum load referenced in the revised standard, does that mean that covers need to withstand 1800 pounds if someone were to fall on them? I can only speculate on the answer until OSHA provides a clarification. I am open for suggestions.