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Five Fall Protection Myths to Counteract

Monday, January 30, 2012

Falls are the leading cause of worker fatalities. According to OSHA, each year more than 100 workers die and thousands are injured as a result of falls at construction sites. The fall protection standard, at 29 CFR 1926 Subpart M, details training and equipment requirements that employers must use to protect workers from falls.

This story is excerpted from an article by Mark Stromme, ISHN. He offers valuable suggestions for increasing safety for workers, and avoiding OSHA fines.


Employers need to:

    •    Select systems and equipment appropriate for the situation;
    •    Properly construct and install safety systems; and

    •    Train workers in the proper selection, use and maintenance of fall protection systems.

Train employees so they don’t fall for these five common myths and misconceptions about fall protection requirements in the construction industry. (Note: The citation amounts listed are related to the specific standard violated.)

Myth #1-“Residential construction has an exemption from the fall protection rules.”

This used to be true. However, in December 2010, OSHA rescinded the directive that allowed for that exception and as of September 15, 2011, all residential construction companies must comply with 1926.501(b)(13). The employer still has the option to develop and implement a fall protection plan that meets the requirements of paragraph (k) of 1926.502 if the employer can demonstrate that fall protection is infeasible or creates a greater hazard.

The new directive STD 03-00-002, Compliance Guidance for Residential Construction, rescinds STD 03-00-001, Interim Fall Protection Compliance Guidelines for Residential Construction, and provides that OSHA will be enforcing 1926.501(b)(13) for all residential construction work.

According to OSHA:

“Prior to the issuance of this new directive, STD 03-00-001 allowed employers engaged in certain residential construction activities to use specified alternative methods of fall protection (e.g., slide guards or safety monitor systems) rather than the conventional fall protection (guardrails, safety nets, or personal fall arrest systems) required by the residential construction fall protection standard (29 CFR 1926.501(b)(13)). Employers could use the alternative measures described in STD 03-00-001 without first proving that the use of conventional fall protection was infeasible or created a greater hazard and without a written fall protection plan. With the issuance of the new directive, all residential construction employers must comply with 29 CFR 1926.501(b)(13).”

When employees say there isn’t a need for fall protection during residential construction work, point out that OSHA says differently. As of September 15, 2011, OSHA compliance officers can enforce STD 03-00-002 for residential construction sites.

Myth #2-“I don’t need any fall protection; it’s only going to take me a couple minutes to install that equipment.”

Fall protection must be provided when employees are performing construction work on a walking/working surface with an unprotected side or edge that is six feet or more above a lower level. (Note: Construction work is “work for construction, alteration, and/or repair, including painting and decorating.”)
The length of time needed to perform that construction work has no bearing on the employer’s duty to provide fall protection. Be it one minute or one hour, OSHA requires fall protection per 1926.501(b)(1).

There is an exception: when employees are making an inspection, investigation or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed, no fall protection is needed.

The following is from an OSHA Letter of Interpretation dated March 2, 2010:

“OSHA has set this exception because employees engaged in inspecting, investigating and assessing workplace conditions before the actual work begins or after work has been completed are exposed to fall hazards for very short durations, if at all, since they most likely would be able to accomplish their work without going near the danger zone... [R]equiring the installation of fall protection systems under such circumstances would expose the employee who installs those systems to falling hazards for a longer time than the person performing an inspection or similar work.”

When employees say they don’t need any fall protection — because the task is going to take them only a few minutes — tell them that in 2010 this misunderstanding cost employers $1,344,612 in OSHA citations.

Myth #3-“Training programs for fall protection aren’t really needed.”

OSHA is clear about requiring training for each employee who might be exposed to fall hazards. For example, employees may be familiar with specific types of fall protection and have had proper training. However, if a different type of fall protection is to be used, employees using it must be trained by a competent person qualified in this area of expertise.
This training must include the following:
  •     •    The nature of fall hazards in the work area;
  •     •    The correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used;
  •     •    The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be
  •     •    The role of each employee in the safety monitoring system when this system is used;
  •     •    The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs;
  •     •    The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection;
  •     •    The role of employees in fall protection plans; and
  •     •    The standards contained in Subpart M.
To prove this training was done, employers need to have a written certification of training that contains the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer.
If workers scoff and say they don’t need to be specifically trained in fall protection, tell them the OSHA regulations state otherwise. Failure to provide the required fall protection training in 1926.503(a)(1) resulted in $649,006 in OSHA citations in 2010.

Myth #4-“I’m doing roofing on a low-sloped roof so I don’t need any fall protection.”

OSHA requires (per 1926.5010(b)(10)) each employee engaged in roofing activities on low-sloped roofs, with unprotected sides and edges six feet or more above lower levels be protected from falling by:

    •    Guardrail systems,
    •    Safety net systems, or
    •    Personal fall arrest systems

Other options include a combination of:

    •    Warning line system and guardrail system,
    •    Warning line system and safety net system,
    •    Warning line system and personal fall arrest system, or
    •    Warning line system and safety monitoring system.

On roofs 50 feet or less in width, the use of a safety monitoring system alone (i.e., without the warning line system) is permitted.
There is an exception. When the employer is doing leading edge work, precast concrete erection work or residential construction work, and can demonstrate that it is infeasible or creates a greater hazard to use these systems, they must develop and implement a fall protection plan that meets the requirements of 1926.502(k).

Contrary to what workers may think, OSHA does require fall protection on low-sloped roofs. In 2010 they issued $909,442 in citations to enforce that requirement.

Myth #5-“A warning line is all I need for fall protection when working on a steep roof.”

According to 1926.501(b)(11), a warning line is not allowed as a form of fall protection when working on a steeply pitched roof. OSHA requires that each employee on a steep roof with unprotected sides and edges six feet or more above lower levels be protected from falling by guardrail systems with toeboards, safety net systems or personal fall arrest systems.

Training employees on these requirements would have saved employers $447,828 in citations in 2010.

Counteract these myths... Training employees to avoid these five fall protection myths and misconceptions can prevent injuries and fatalities and save your company money.
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NOTICE: Statement on special use of the Petzl Shunt

Friday, January 20, 2012

Petzl has published a statement addressing special use of the Petzl Shunt as a back-up device for industrial rope access.  For any users of the Petzl Shunt as a self-belay device such as tower rescuers, the same information applies.

For Roco Tower Work and Rescue students who were taught the use of the Shunt as a self-belay device and have not attended Roco’s Tower Work and Rescue refresher training in the past two years, please read this information.  For recent initial and refresher students of Roco’s Tower Work and Rescue class, students were taught to use the Petzl ASAP as their self-belay device.  Roco still encourages all prior Roco Tower students to review the Petzl statement to become familiar with their concerns regarding the use of the Shunt as a back-up device.

To request a NEW Roco Training & Equipment Catalog or our 2012 Course Schedule, call us at 800.647.7626.
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INVISIBLE HAZARD KILLS AGAIN

Wednesday, January 18, 2012

Roco Director of Training/Chief Instructor, Dennis O’Connell reviews the importance of following OSHA safety standards for confined space entry, no matter how many times workers have entered the space. The take away? With confined spaces…It’s NEVER old hat! The importance of preplanning confined space entries and identifying “potential hazards ”should be old hat by now. Yet every year we are still killing entrants and rescuers in confined spaces.

In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

Atmospheric Hazards Continue to Claim Lives in Confined Space Entry Scenarios

The importance of preplanning confined space entries and identifying “potential hazards” should be old hat by now. Yet every year we are still killing entrants and rescuers inconfined spaces.  In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

It’s always important to remember that each entry stands alone. Each and every time a space is entered, we need to:

(a) identify potential hazards;

(b) eliminate or control them, when possible;

(c) use proper PPE; and,

(d) have an EFFECTIVE Rescue Plan.

Otherwise, as in this story, we will lose or injure workers as well as those attempting the rescue.

Start from scratch and treat each entry like it’s the first time you’re entering the space – it could save your life.

Keep in mind, the history of a space really has nothing to do with the current entry. We’ve all heard people say, “We do this all the time, and we’ve never had a problem!” Or, “We’ve entered this space a thousand times and the air is always good!” Remember this… IT DOES NOT MATTER!! This entry has nothing to do with the last.

As you read of yet another unfortunate incident, let it be a reminder to those of us who make entries or do rescues from confined spaces – do not let your guard down, do not get complacent…it could be deadly. Atmospheric hazards are still one of the leading ways that people are dying in confined spaces. Because humans are visually oriented by nature, if we can see a hazard, we’ll protect ourselves from it. However, if we can’t see it, we tend to assume it’s safe. OSHA’s 1910.146 PRCS standard and others were developed for a reason… people were making tragic mistakes and dying in confined spaces. These standards and guidelines are written so we don’t make the same mistakes.

OSHA FINES UTILITY FIRM $118,580 FOLLOWING WORKER’S DEATH

OSHA has cited a contracting and utilities company for two willful and two serious safety and health violations following the death of a worker at the company’s Texas facility. Proposed penalties total $118,580. An inspection was initiated by OSHA on June 28 in response to a report that employees working on a new sewer line were exposed to inhalation of a hazardous chemical. One employee who entered a manhole to remove a plug in order to flush out accumulated debris became overwhelmed by toxic fumes and died. Another employee was hospitalized after attempting to rescue his co-worker.

The willful violations are for failing to test for atmospheric conditions and provide adequate ventilation and emergency retrieval equipment prior to entry into a manhole.

The serious violations are failing to provide or require the use of respirators as well as conduct an assessment to determine the potential for a hazardous atmosphere where oxygen deficiency, methane, and/or hydrogen sulfide were present or likely to be present.

“The company failed to ensure that proper confined space entry procedures were followed,” said Jack Rector, OSHA’s area director in Fort Worth. “If it had followed OSHA’s safety standards, it is possible that this tragic incident could have been prevented.”
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OSHA Violation Penalties on the Rise

Friday, January 13, 2012

According to statistics recently reported by OSHA, the number of workplace inspections conducted by federal OSHA in Fiscal Year 2011 fell to a total of 40,215, down 778 from 2010.  The agency attributes this slight decline in the number of inspections to the fact that many inspections, particularly those focused on health hazards and record keeping compliance, require more time per inspection.

Double the Penalties from OSHA Last Year

“Every day in America, 12 people go to work and never come home. Every year in America, 3.3 million people suffer a workplace injury from which they may never recover. These are preventable tragedies that disable our workers, devastate our families, and damage our economy.”
– Secretary of Labor Hilda Solis


According to statistics recently reported by OSHA, the number of workplace inspections conducted by federal OSHA in Fiscal Year 2011 fell to a total of 40,215, down 778 from 2010.  The agency attributes this slight decline in the number of inspections to the fact that many inspections, particularly those focused on health hazards and record keeping compliance, require more time per inspection.

OSHA Doubles Violation Penalties in 2011

Despite the fewer number of inspections, the size of enforcement actions (penalties) is increasing.  The average OSHA penalty per Serious violation in 2011 increased to $2,132, more than doubling from 2010’s average of $1,053.  In the last year of the Bush administration, 2008, that average was $998.

OSHA’s increase in the size of penalties and the number of Significant Cases can be traced back to key changes that OSHA made to its Field Operations Manual in October 2010.  For instance, OSHA doubled the minimum penalty for Serious violations, limited the Area Offices’ freedom to reduce penalties during settlement conferences, and reduced allowable penalty reductions for clean OSHA history (and required more years without past violations to be eligible for a clean history penalty reduction).

Roco Rescue Preplans can help detect confined space safety violations before OSHA visits your site. Find out more by calling 800-647-7626.
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On-Duty Firefighter Fatalities Down from 2010: USFA

Tuesday, January 10, 2012

The United States Fire Administration (USFA) recently announced there were 81 on-duty firefighter fatalities in the United States as a result of incidents that occurred in 2011. This represents an almost seven percent decrease from the 87 fatalities reported for 2010. The 81 fatalities occurred in 33 states, one U.S. territory, and one overseas U.S.military facility. Texas experienced the highest number of fatalities (seven).

North Carolina experienced six firefighter deaths and was the only other state with five or more firefighter fatalities.Heart attacks were responsible for the deaths of 48 firefighters (59 percent) in 2011, nearly the same proportion of firefighter deaths from heart attack or stroke (60 percent) in 2010.

The United States Fire Administration (USFA) recently announced there were 81 on-duty firefighter fatalities in the United States as a result of incidents that occurred in 2011. This represents an almost seven percent decrease from the 87 fatalities reported for 2010. The 81 fatalities occurred in 33 states, one U.S. territory, and one overseas U.S. military facility. Texas experienced the highest number of fatalities (seven). North Carolina experienced six firefighter deaths and was the only other state with five or more firefighter fatalities.

“In 2004 at the initial Life Safety Summit, a number of fire service leaders did not believe we would complete a calendar year with less than 100 firefighter on-duty deaths,” U.S. Fire Administrator Ernest Mitchell said. “We broke through that perceived barrier in 2009, 2010, and now in 2011. We salute and congratulate our fire service family and pledge to continue working closely with the entire fire service community and its partners to maintain and even accelerate this downward trend in on-duty firefighter deaths.”

Heart attacks were responsible for the deaths of 48 firefighters (59 percent) in 2011, nearly the same proportion of firefighter deaths from heart attack or stroke (60 percent) in 2010. Ten on-duty firefighters died in association with wildland fires, the lowest number of annual firefighter deaths associated with wildland fires since 1996. Fifty-four percent of all firefighter fatalities occurred while performing emergency duties. Three firefighters were killed in vehicle collisions.
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