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Atmospheric Monitors May NOT Detect All Dangers

Tuesday, February 09, 2016

By Dennis O’Connell, Roco Director of Training with contributing author Spencer Pizzani of Weston Solutions

Readings are 20.9/0/0/0…so it must be safe for entry, right? Not necessarily! 

After completing an interesting confined space standby job for Roco, I wanted to caution rescuers about the possibilities of atmospheric hazards within a confined space – despite what the atmospheric monitor says!

For this particular job, the atmosphere in the workspace never varied on the 4-gas monitor readings. The readings were consistently 20.9% for O2; 0 for LEL; 0 for H2S; and 0 for CO. However, this entry required the use of air-purifying respirators even though there were no visible signs of anything unusual – no odor, no product warning signs, no indication that there may be an inhalation hazard in the space.

This particular space was located at a public water facility. It was a 70-ft. deep concrete metering pit with six consecutive 12-ft x10-ft levels. It had concrete floors and walls with a vertical ladder that accessed each level. Although the space was not designed to store any product, in this case, we still had an atmospheric hazard.

The purpose of the entry was for remediation of mercury contamination on the concrete surface. The gross cleanup of liquid mercury had been performed years prior, but further action was required to eliminate vapor hazards still present in the lower chambers.

During the first phases of the entry, vapor levels that exceeded 40,000 ng/m3 (nano-grams per cubic meter) were detected. The more frequently updated ACGIH Threshold Limit Value is only 25,000 ng/m3. The work environment in this space routinely approached twice this level, even though there were no visible signs of liquid mercury. The source of the toxic atmospheric hazard was invisible and odorless – mercury vaporizing from the concrete surfaces.

Mercury is only one example of a toxicant that can produce a hazardous atmosphere in confined spaces that will not be indicated on a typical 4-gas meter or atmospheric monitor. Many rescuers assume that their 4-gas meter will detect all atmospheric conditions that may present a risk to their health or safety, but this is just not true. There are a wide variety of agents or toxicants besides mercury that will not be detected and whose presence may require other controls or the use of respiratory protection. This mistake could be deadly, or leave rescuers with chronic health issues.

In this scenario, for example, if you were an off-site rescuer responding to the above described space in an emergency situation. Without someone on site to inform you of the possible hazard, you would have no indication that any hazards were present. Many times as municipal rescuers we respond to, shall we say, shady locations where unauthorized storage or illegal dumping of hazardous products has taken place; there are no SDS, placards, or signage. Personnel on scene may not know, or may not want to relay vital information about a space of any products within the space.

Rescuers Beware: It's important to play the role of “detective” when planning or preparing to make a confined space entry.

Oftentimes, there are placards or signs on tanks or storage containers to start the investigation into what hazards may be present – and SDS for additional information. However, as rescuers we often fall into a state of “false security” with our 4-gas meter readings.

While much of our training may include “Go/No Go” scenarios for rescue teams, the use of respiratory protection is usually based on one of the “Big 4” readings on our atmospheric monitors. Unfortunately, this may only serve to reinforce the notion that a 4-gas monitor will always provide the “complete” information of what may be going on inside a confined space. We get dependent on these monitors to tell us if it’s safe to enter without respiratory protection – and there may be much more to the story!

OSHA’s Respiratory Standard [1910.134 (d)(1)(III)] specifies "Where the employer cannot identify or reasonably estimate the employee exposure, the employer shall consider the atmosphere to be IDLH.” 

In the above statement, if you substitute Team Leader for “employer” and “Rescue Team” for employee, you may find that you cannot “identify or reasonably estimate the employee exposure.” Therefore, rescuers would need to use SCBA/SAR and other PPE until you can completely identify what hazards are in the space even though typical monitoring devices are telling us that all is well.

While your standard 4-gas meter is an important screening tool – it is NOT a "catch all" for every atmospheric hazard.

Remember that NIOSH statistics indicate that 40%-60% of confined space entry fatalities are (would-be) rescuers, including both dedicated on-site standby teams and off-site professional rescuers (municipalities) who attempt to perform a confined space rescues.

But let’s take this a step further. If you ask most rescuers at what O2 level does an atmosphere become dangerous, they will say below 19.5%. I know from my initial hazmat/confined space training on 4-gas monitors included oxygen displacement. It was so elegantly described to me as “if your monitor shows a decrease in oxygen, it is telling you that something else has pushed out that percentage of oxygen and replaced it with some other agent.” Now, it would be up to you to figure out what else is in the air.

For example, normal breathing air is 20.9%. To get a reading of 19.5% means that about 1.4% of “something else” has displaced the oxygen. Then, depending on what that “something else” is, could require the use of respiratory protection. Hey, wait, the good news keeps coming, and I am getting in way over my head on this science stuff, but my high school chemistry teacher should still be proud. Ambient air is made up of about 79% nitrogen and other gases and 21% oxygen. So, using fingers and toes mathematics, that equals about a 4:1 ratio of nitrogen to oxygen.

In other words, if we have a 1% displacement of oxygen from the breathing air, it will be accompanied by about a 4% displacement of nitrogen (both gases displace at about the same rate). Therefore, instead of it being about a 1.4% percent of an unknown product in our breathing air, it could be as much as 5.6% or more! And, depending on what that product is, it could already be at its IDLH level.


Project Scientist Spencer Pizzani of Weston Solutions provides this insight.

"While many rescuers are habituated to only watch oxygen (O2) percent composition, this can be deceptive. The OSHA standard for O2 concentration is based on standard temperatures and pressures at sea level. When an environment presents lower pressure (such as at higher altitudes or in chambers subject to continuous air evacuation), the partial pressure of O2 is decreased as described by the Ideal Gas Law. This can lead to 'normal’ concentrations, but with less oxygen available for respiration.

A widely used example demonstrates that the partial pressure of oxygen in a confined space at high altitudes such as in mountainous areas would be the equivalent partial pressure of 14-15% oxygen at sea level. This can be low enough for the leading effects of asphyxiation to manifest – a problem exacerbated by the high oxygen demand of strenuous rescue work.

Gases that displace oxygen can have a similar effect. A typical 4-gas meter will only read oxygen concentration. This neglects the largest component of ambient air – nitrogen. The portion of air normally occupied by nitrogen is also replaced by another gas. When taken as a whole, the contaminant gasses may exceed levels and require the use of respiratory protection, with no indication from the typical 4-gas meter. Many toxic gases are odorless and colorless. Radiation can be a similar risk. While some types of radiation can be filtered or excluded with the use of respiratory protection, exposure to other types are simply a function of time, distance and shielding. Rescuers entering confined spaces may have a strict time limit for operations as established by a health physicist. In such cases, a 4-gas meter would be entirely unresponsive even in the presence of an instantly lethal radiation exposure vector.”

Pizzani advises,

“Rescuers responding to an emergency always need to look at the big picture and be part detective in identifying potential hazards that may impact both initial and rescue entry. Identification of past residues in storage containers, examination of process system SDS, and any information/knowledge provided by workers familiar with the space or process is invaluable. Warning signs such as odors, visible dust, or any variability on oxygen concentration should be met with a thorough set of instrument diagnostics and further investigation.”

Summary

A standard 4-gas meter is an important screening tool for atmospheric acceptability. However, it is "not a catch all" for every atmospheric hazard. Developing a detailed preplan; identifying possible hazards; and proper PPE should be the top priority of anyone planning a rescue entry. The use of supplied air systems (SAR/SCBA) should be considered “minimum protection” for rescuers until an atmosphere is completely characterized or in the event of an unknown agent or condition. Remember, a standard 4-gas meter may not be telling the whole story.

Special thanks to contributing author, Spencer Pizzani, who is an Industrial Hygienist and Project Scientist for Weston Solutions, Inc. Weston is a global environmental consulting firm specializing in environmental solutions, specialty construction and green development.

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Service Life Guidelines for Rescue Equipment

Wednesday, January 20, 2016
Regardless of the stated service life, the condition of equipment–as determined through inspection by a qualified party – is a key factor in determining whether or not a piece of equipment is fit for service.

THIS INSPECTION PROCESS OFFERS GUIDELINES FOR KEEPING EQUIPMENT IN SERVICE OR RETIRING IT.

Depending on the manufacturer, you will find varying specifications for service life of rescue equipment. For example, Petzl specifically defines the “potential” service life of plastic or textile products to be no longer than 10 years. It states indefinite for metallic products. CMC, on the other hand, does not give specified times for their equipment stating, “The service life of equipment used for rescue depends greatly on the type of use and the environment of use. Because these factors vary greatly, a precise service life of the equipment cannot be provided.” However, in reference to harnesses, CMC’s cites ASTM F1740-96 as the industry standard for service life. SMC follows along the lines of CMC when stating the amount of time a product can stay in service.

Although the definition of “equipment lifespan” is very broad depending on the manufacturer, each will provide specific instructions on proper inspection of equipment and detailed explanations on when to the retire service item.

Most manufacturers follow the same general guidelines for removing equipment from service. Several general identifiers that pertain to all equipment are shown below. 

Download Roco's Quick Checklist for your convenience. →

REASONS FOR EQUIPMENT RETIREMENT INCLUDE:

  •   Item fails to pass any pre/post use or competent person inspection.
  •   Item has been subjected to a major fall or load.
  •   Item is constructed of plastic or textile material and is older than 10 years.
  •   You cannot determine the complete full-use history of item.
  •   You are not certain or have lost confidence in the equipment.

Most manufacturers will provide service for equipment items that are repairable. However, most caution against this because the cost of repair typically exceeds the cost of replacement. Any repairs attempted outside of the manufacturer may void any warranty and will release the manufacturer from any liability or responsibility. In addition, all manufacturers recommend destroying equipment once it has been retired from service to prevent items from inadvertently being recycled back into active service gear.

Manufacturers also provide indicators for different types of equipment that require it to be retired from service. These are not only capturing the general conditions mentioned above, but also bring in conditions that are specific to each category of equipment. It is important to identify these specific conditions as they are vital to the dependability and functionality of each component.

Harnesses:

Harnesses are one of the most vital components of life safety equipment. Without a certified harness in serviceable condition, the best life safety rope and hardware in pristine condition will do little to protect the user. All individuals who are required to wear harnesses to perform duties should be trained and authorized in the inspection process. Harnesses should be inspected before and after use as well as once annually by an individual deemed a competent person by the facility or department.

Since harnesses are a nylon product, they fall under the guidelines set forth by ASTM consensus standard F1740-96 and have a service life of 10 years. Manufacturers also state that hard or excessive use – as well as the conditions when a harness is used – may significantly reduce its service life. It is important to conduct routine inspections as well as keep records of harness use. This “usage” history could indicate signs that would require the equipment to be retired early.

Here are some conditions to help identify when it’s time to retire your life safety harness:

  •   The harness has surpassed 10 years since the manufacture date.
  •   Webbing shows signs of cuts, significantly worn or frayed areas, soft or hard spots.
  •   Webbing shows signs of discolored or melted fibers.
  •   Stitching shows signs of pulled threads, abrasion or breaks.
  •   Hardware shows signs of damage, sharp edges, excessive wear or improper function.
  •   If the harness has been subjected to shock loads, fall loads, or abuse.
  •   If there is any doubt about the integrity of the harness.
  • If the harness demonstrates any of these conditions, it should be removed from service and destroyed.

  • Life Safety Rope, Webbing, Anchor Straps, Accessory Cord:
       

Since these products are nylon or textile based as well, they fall under the same inspection process as harnesses. A complete inspection of life safety rope and associated products includes not only a visual inspection but a tactile (or touch) inspection as well. The tactile inspection should be done with tension on the rope, webbing or strap. 

The inspector is looking to identify any of the following conditions:

  •   Chafed, glazed or discolored surfaces (these areas should receive a more thorough inspection).
  •   Abrasions or cuts in the sheath where the core is exposed.
  •   Variation of diameter of the rope that could indicate potential damage to the core fibers.
  •   Soft or hard spots that could indicate core damage or that the fibers have been over stressed.
  •   If the rope has been subjected to shock loads, fall loads or abuse.

If any of these conditions are noted, then the item should be retired and destroyed immediately. It is important to remember that an accurate history should be maintained for all life safety rope products. The date of manufacture should be identified and recorded as products are being put into service. Equipment inspectors or users should ensure that these products do not exceed their service life. As with harnesses, the amount, type and conditions of use can drastically reduce the service life of these products.

Carabiners:

Since carabiners are metallic, they do not fall under the ASTM service life recommendation of 10 years. As long as these products are in serviceable condition and properly maintained, they have an infinite service life. Even though they do not have a dedicated service life term, it is still important to conduct the same pre/post use and annual inspections. 

Some conditions that would require the equipment, such as carabiners, to be retired from service include:

  •   Carabiner has been dropped a significant distance.
  •   Exposed to heat sufficient enough to alter the surface appearance.
  •   Cracks, distortion or deep gouges.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Gate does not line up when closed.
  •   Gate action does not return to closed position when opened and released.
  •   Locking mechanism does not fully engage.
  •   Complete history of use cannot be determined.
  • If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items even though the service life of the product is infinite.
Pulleys:

Pulleys, as with carabiners, are metallic in construction and do not have a service life recommendation. They will also have an infinite service life as long as they are in serviceable condition and are properly maintained. Pulleys fall under the same inspection requirements as carabiners. 

Below are some conditions that would require such equipment to be removed from service:

  •   Pulley has been dropped a significant distance.
  •   Exposed to heat sufficient enough to alter the surface appearance.
  •   Cracks, dents or elongation at the carabiner hole on side plates.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Deep scratches or gouges to side plates or sheave(s).
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Side plates that do not line up at the carabiner hole.
  •   Elongation of the side plates at the sheave pin.
  •   Side plates that do not move freely.
  •   Sheave does not turn freely or significantly rubs against side plate.
  •   If the item has been subjected to shock loads, fall loads or abuse.
  •   If the history of use or manufacture date cannot be determined.

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items even though the service life of the product is infinite.

DeScent control devices:

Descent control devices, if metallic, do not have a service life recommendation. If the device is constructed of plastic or other textile material, it will have a service life not to exceed 10 years. 

Below are some conditions that would require this equipment to be removed from service:

  •   Cracks, deformations or elongation to any portion of the device.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Deep scratches or gouges to any portion of the device.
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Excessive wear to friction surfaces or cam (see wear indicator on some devices).
  •   If the device has been subjected to shock loads, fall loads or abuse.
  •   If the history of use or manufacture date cannot be determined.

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items throughout their service life.

Ascenders:

As with previously mentioned equipment, the same inspection procedures apply to ascenders. 

Below are some of the conditions that would require ascenders to be removed from service:

  •   Cracks, deformations or elongation to any portion of the device.
  •   Corrosion or deep pitted rust. (Note: Surface rust may be removed with a fine abrasive cloth and coated with a preservative such as LPS #1.)
  •   Deep scratches or gouges to any portion of the device.
  •   Sharp edges that could cause damage to life safety rope (minor edges may be smoothed with the same process as rust removal).
  •   Fouled teeth on cam (handled type ascenders).
  •   Excessive wear to surface of cam.
  •   Damage to rivets (if applicable).

If any of these conditions exist, the equipment should be removed from service and destroyed. Records of use and inspection should be kept on these items throughout their service life.

Service history is an extremely important part of ensuring life safety equipment is properly maintained and that service life is not exceeded. Not only does this help rescue teams control inventory and operational capability of equipment by documenting each use and inspection, it also assists the teams in forecasting budget costs for the replacement of items that are nearing the end of their service life.

Maintaining records of the manufacturer’s information received when purchasing new equipment is vital to identifying and keeping track of the manufacture date. It is also important to keep this information on file for the exact procedures for inspecting and removing equipment from service. If the manufacture date of equipment, such as life safety rope and harnesses, cannot be identified; it poses extreme liability for agencies or facilities whose teams may potentially be operating with equipment that has passed its service life. It could also create a compromise in the safe operation of the equipment. Also, if record-keeping of equipment inspection and use is not a primary focus, it could potentially expose team members to operating with unsafe equipment due to abuse or excessive/extreme conditions that go undetected.

All team members should be qualified and knowledgeable enough to perform pre- and post-use inspections of equipment. It is crucial that all members document each use of equipment, denote any deficiencies, and report to the proper person. One person should be designated to perform the competent person annual inspection. This person should have complete knowledge of the equipment and inspection procedures as well as the authority to keep or remove equipment from service as they see fit. If team members are unable to fill this role, a qualified third party with applicable manufacturer certifications in competent person inspection should be brought in to assist in determining the condition and estimated service life of rescue equipment. For assistance from our rescue equipment professionals, call us at 800-647-7626.

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Worth the Wait...OSHA’s Confined Space Standard for Construction

Tuesday, December 15, 2015

In our opinion, the new OSHA regulation for Confined Spaces in Construction (Subpart AA of 1926) was worth the wait! This new standard is well thought out and includes some significant as well as subtle differences from the General Industry Permit Required Confined Space Standard 1910.146.

In this article, we will point out additional requirements for compliance for construction activities involving confined spaces. With the exception of residential construction, the final rule became fully enforceable as of October 2, 2015.   

These additional requirements instituted by OSHA are due to the dynamic nature of the construction environment. Dynamic in terms of the continuously evolving configuration of the workplace, and also in the diverse and ever-changing makeup of employers and employees depending on the phase of construction. We feel the most significant differences are not complete shifts in an administrative or operational approach to conducting safe permit required confined space operations, but more of an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.

“We believe the new standard offers an increased emphasis and clarification of the requirements that were already in place in the General Industry regulations.”

Please pay particular attention and review 1926 Subpart AA for requirements to ensure clear communication and coordination between the varied entities that work in or adjacent to the construction areas that have confined spaces. The lack of accurate communication and coordination continues to be a cause of confined space fatalities.

The need to communicate with the controlling contractor and entry employers regarding any operations that may have introduced a hazard into a confined space is of paramount importance. The failure to do so has repeatedly led to disaster for unsuspecting follow-on entrants into those confined spaces. Likewise, understanding and communicating the types of operations adjacent to, or in the proximity of confined spaces that may negatively affect that entry operation, must be coordinated and communicated.

Also, several new roles and responsibilities have been added to the confined space regulations. One of the most important new roles is that of the “competent person” for confined spaces.

Having a dedicated individual (Competent Person) who has the expertise and background to perform this critical function will undoubtedly result in lives saved.

OSHA has also added clarification to the need to ensure that the designated confined space rescue service is not only available at the time entry operations commence, but also that rescue service must now agree to notify the entry employer if a situation arises that renders them unable to respond to an emergency.


So let’s take a look at some of the particulars of these new requirements and clarifications.

1. Allows an Entry Permit to be suspended, instead of cancelled in the event of changes from the entry conditions list. Ref: 1926.1205(e)(2)

This differs from 1910.146(e)(5) which requires an employer to terminate entry and cancel the entry permit. This change has specific requirements and limits. Suspending a permit is only allowed when a condition that is not allowed under the entry permit arises in or near the permit space and that condition is: (a) temporary in nature; (b) does not change the configuration of the space; and/or, (c) does not create any new hazards within it.

The first action of the entry supervisor must be to terminate entry and ensure all authorized entrants have safely evacuated the space. At that point, the entry supervisor can suspend or cancel the entry permit. Prior to authorizing reentry, the entry supervisor must fully reassess the space before allowing reentry.

2. Includes more detailed provisions requiring coordinated activities when there are multiple employers at the worksite.

This is an important difference compared to the General Industry regulation. It is required due to the ever-changing makeup of the construction workforce and most especially when the need for workers from multiple employers must enter permit spaces at the same time, or perform work activities in the vicinity of the permit space – thus, the potential to introduce new hazards to the space that all employers on site must be aware of and prepare for.

This final provision differs from 1910.146(d)(11) by specifically addressing the need to coordinate work activities through the controlling contractor, as well as with employers working outside the permit space when their work could foreseeably affect conditions within a confined space. The new construction industry standard goes far beyond by outlining the need for coordinated activities between multiple employers by identifying specific roles – host employer, controlling contractor and the entry employer. (Refer to Chart.)

OSHA 1926.1203 General Requirements paragraph (h) includes specific communication and coordination requirements between the various employers and contractors. The host employer must provide certain information they may have about confined spaces to the controlling contractor.

Required information includes items such as:
(a) The location of known permit spaces;
(b) The nature of hazards in those identified permit spaces;
(c) The reason for classifying the space as permit required; and,
(d) Any additional precautions that the host employer, any other controlling contractor, or entry employer have previously employed to protect their employees must be provided.

It is also incumbent upon the controlling contractor to obtain information from the host employer regarding the hazards associated with the permit spaces and any information on previous entry operations into that permit space.

The controlling contractor is responsible for passing information to any entry employer that may authorize entry into that permit space as well to any other entity at the worksite that could foreseeably create a hazard that may affect that confined space.

The entry employer must obtain from the controlling contractor all the information regarding the particular permit space hazards and entry operation information. Additionally, the entry employer must inform the controlling contractor of the provisions of their permit required confined space program and any hazards they expect to confront or create during their entry operations.

It is also very important that the controlling contractor and all entry employers coordinate their activities when multiple entry employers have entrants in the same space, or when other activities around the permit space may create a hazard that affects the confined space entry operation.

At the completion of entry operations, it is equally important that all entities including entry employers and controlling contractors communicate information regarding the particulars of any given entry. This information must include the permit space program followed during the entry operation as well as any hazards confronted or created during entry. Of particular importance is to communicate any hazards created within the confined space that may still be in place. The controlling contractor in turn communicates all of this information to the host employer.

3. Requires a Competent Person to evaluate the work site and identify confined spaces, including permit spaces.

Along with the increased need for strong communications and coordination, the addition of the role of competent person for confined spaces may be one of the most important differences between the general industry standard and the construction standard.

It may seem to be a subtle difference in the two standards’ requirements, but now there is a specific role, or an identified position for conducting an evaluation of the worksite to determine the presence of confined spaces, a determination of the known or potential hazards associated with those confined spaces, and that has the authority to eliminate the identified hazards.

The competent person for confined spaces must have a high degree of expertise in identifying confined spaces and to make an accurate determination of the nature of any known or potential hazards associated with the confined space that would trigger it to be classified a permit space. In the event that the configuration or use of a non-permit required confined space changes, or a new hazard is introduced, the entry employer must have the competent person reevaluate that space to determine if it has become a permit required confined space. This is also true for any confined space that may not have initially been adequately evaluated to identify any known or potential hazards that would require that space to be classified a permit required confined space.

4. Designated rescue service must agree to notify the entry employer immediately if it becomes unavailable.

Although it has always been implied in the general industry standard that the entry supervisor would ensure the designated rescue service is available during entry operations, 1926.1211 explicitly requires an employer to designate a rescue service – in turn, the rescue service agrees to notify the entry employer immediately if they become unavailable to respond.

5. Provide an early warning system for non-isolated engulfment hazards.

This is primarily for sanitary and storm drain entry operations, but is equally important for any entry operations of a similar nature. The type of early warning systems can be as simple as posting an individual as an “upstream watch” to more complex systems such as electronic sensors or camera systems. Whatever system is used to detect an impending engulfment hazard, it must include a means of communications to provide advanced warning to the downstream entrants in time to safely evacuate the space.

We encourage our readers to spend time studying the new regulation, and in particular understanding the points we have highlighted in this article as well as in our downloadable Confined Spaces in Construction Safety Poster. If you have questions, or if we may be of service, please contact us at 800-647-7626.

 

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Two New York contractors indicted for manslaughter after worker is killed in trench collapse

Monday, October 19, 2015

OSHA reports that two workers are killed every month in trench collapses. Just recently, OSHA cited two contractors following a trench collapse that buried 22-year-old laborer Carlos Moncayo beneath tons of soil and debris at a Manhattan construction site. OSHA found that Moncayo's death could have been prevented if the general contractor and subcontractor had provided cave-in protection for the trench or braced an adjacent section of undermined and unsupported sidewalk. In connection with Moncayo's death, officials from both companies were indicted for manslaughter and other charges in the New York State Supreme Court on Aug. 5.

"Managers from these companies were aware of these deadly hazards and did not remove employees from the trench, even after warnings from project safety officials." 

OSHA issued each employer two citations for willful violations of workplace safety standards on Oct. 5. Proposed fines total $280,000 – $140,000 for each company – the maximum allowable fines under the Occupational Safety and Health Act. A willful violation is committed with intentional, knowing or voluntary disregard for the law's requirements, or with plain indifference to worker safety and health. 

"Carlos Moncayo was a person, not a statistic. His death was completely avoidable. Had the trench been guarded properly against collapse, he would not have died in the cave-in. This unconscionable behavior needlessly and shamefully cost a man his life."
Quotes by Kay Gee, OSHA Area Director-Manhattan

Updated OSHA guide on Trenching and Excavation Safety

Trench and excavation work are among the most hazardous operations in construction. Because one cubic yard of soil can weigh as much as a car, an unprotected trench can be an early grave. OSHA's updated guide to Trenching and Excavation Safety highlights key elements of the applicable workplace standards and describes safe practices that employers can follow to protect workers from cave-ins and other hazards. A new section in the updated guide addresses safety factors that an employer should consider when bidding on a job. Expanded sections describe maintaining materials and equipment used for worker protection systems as well as additional hazards associated with excavations.

Remember, an unprotected trench can become an early grave. Learn how to keep workers safe. Download these OSHA Guides for details.

OSHA Guide to Trenching and Excavation Safety
Trenching and Excavation Safety Fact Sheet

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