“Reminder: Are You In Compliance With OSHA’s New Construction Confined Space Standard?”

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Most employers in the construction industry already know that OSHA issued a new confined space standard for construction that became effective on August 3, 2015. Companies with employees who enter confined spaces at construction sites must be sure to understand the new regulation and adjust their processes in order to remain in compliance. Although the new standard has been in effect for six months, this blog provides a reminder on some of the key provisions of which employers should be aware.

As background, OSHA used to just have a confined space standard for general industry employers (29 CFR 1910.146). However, in recognition that construction sites often host multiple employers and are continually changing, with the number and nature of confined spaces changing as work progresses, OSHA promulgated a new standard, available at 29 CFR Subpart AA 1926.1200, tailored to the unique characteristics of construction sites.

While the general industry standard and the construction standard have many similarities, some key differences are:

The construction standard requires coordination when there are multiple employers at the worksite. Specifically, the construction standard imposes duties on three types of employers because of the recognition that different workers may perform different activities in the same space, which can result in hidden dangers:

Entry employers. This is defined as an employer who decides that an employee it directs will enter a permit space. Entry employers have a duty to inform controlling contractors (defined below) of any hazards encountered in a permit space. Entry employers also have to develop safe entry procedures.

Host employers. This is defined as the employer who owns or manages the property where the construction work is taking place. If the host employer has information about permit space hazards, it must share that information with the controlling contractor (defined below) and then the controlling contractor is responsible for sharing that information with the entry employers.

Controlling contractor. This is defined as the employer with overall responsibility for construction at the worksite. The controlling contractor is responsible for coordinating entry operations when there is more than one entry employer. Controlling contractors must provide any information they have about any permit space hazards to all entry employers.

The controlling contractor is also responsible for coordinating work in and around confined spaces so that no contractor working at the site will create a hazard inside the confined space. After the entry employer performs entry operations, the controlling contractor must debrief the entry employer to gather information that the controlling contractor then must share with the host employer and other contractors who enter the space later.

Continuous atmospheric monitoring is required under the construction standard “whenever possible.” In contrast, the general industry standard merely encourages continuous atmospheric monitoring where possible and only requires periodic monitoring as necessary.

The construction standard requires that a “competent person” evaluate the work site and identify confined spaces including permit-required confined spaces.

Notably, the general industry standard does not require that a “competent person” complete this task. A “competent person” is defined under the new standard as someone who is capable of identifying existing and predictable hazards associated with working conditions, including, of course, whether a workspace is permit-required.

Employers who perform construction-related activities need to make sure they understand the requirements of the new confined space construction standard. For more information, download : Confined Space in Construction: OSHA 29 CFR Subpart AA 1926.1200 here: https://www.osha.gov/confinedspaces/1926_subpart_aa.pdf or consult with your Seyfarth attorney.

Source: Seyfarth, Shaw : Evironmental Safety Update / Law Blog

http://www.environmentalsafetyupdate.com/osha-compliance/are-you-in-compliance-with-oshas-new-confined-space-standard-for-the-construction-industry/

 

 

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“Excavation & Trenching Safety” #ConstructionSafety @StopThinkPrevnt

Trenching and Excavation Safety

Excavation and trenching are among the most hazardous construction operations. OSHA defines an excavation as any man-made cut, cavity, trench, or depression in the earth’s surface formed by earth removal. A trench is defined as a narrow underground excavation that is deeper than it is wide, and is no wider than 15 feet (4.5 meters).

Dangers of Trenching and Excavation
Cave-ins pose the greatest risk and are much more likely than other excavation-related accidents to result in worker fatalities. Other potential hazards include falls, falling loads, hazardous atmospheres, and incidents involving mobile equipment. Trench collapses cause dozens of fatalities and hundreds of injuries each year.

Protect Yourself
Do not enter an unprotected trench! Trenches 5 feet (1.5 meters) deep or greater require a protective system unless the excavation is made entirely in stable rock. Trenches 20 feet (6.1 meters) deep or greater require that the protective system be de-signed by a registered professional engineer or be based on tabulated data prepared and/ or approved by a registered professional engineer.

Protective Systems
There are different types of protective systems. Sloping involves cutting back the trench wall at an angle inclined away from the excavation. Shoring requires installing aluminum hydraulic or other types of supports to prevent soil movement and cave ins. Shielding protects workers by using trench boxes or other types of supports to prevent soil cave-ins. Designing a protective system can be complex because you must consider many factors: soil classification, depth of cut, water content of soil, changes due to weather or climate, surcharge loads (eg., spoil, other materials to be used in the trench) and other operations in the vicinity.

Competent Person

OSHA standards require that trenches be inspected daily and as conditions change by a competent person prior to worker entry to ensure elimination of excavation hazards. A competent person is an individual who is capable of identifying existing and predictable hazards or working conditions that are hazardous, unsanitary, or dangerous to employees and who is authorized to take prompt corrective measures to eliminate or control these hazards and conditions.

Access and Egress
OSHA requires safe access and egress to all excavations, including ladders, steps, ramps, or other safe means of exit for employees working in trench excavations 4 feet (1.22 meters) or deeper. These devices must be located within 25 feet (7.6 meters) of all workers.

General Trenching and Excavation Rules

  • Keep heavy equipment away from trench edges.
  • Keep surcharge loads at least 2 feet (0.6 meters) from trench edges.
  • Know where underground utilities are located.
  • Test for low oxygen, hazardous fumes and toxic gases.
  • Inspect trenches at the start of each shift.
  • Inspect trenches following a rainstorm.
  • Do not work under raised loads.

Additional Information
Visit OSHA’s Safety and Health Topics web page on trenching and excavation at http://www.osha.gov/SLTC/trenchingexcavation/ index.html

Highlights

“National Trench Safety Releases Mobile App for the Excavation Industry”

National Trench Safety announced its new NTS Mobile App for the Excavation Construction Industry.

National Trench Safety, LLC (NTS), a Houston-based company specializing in the rental and sales of trench and traffic safety equipment, trench and traffic safety engineering, and OSHA-compliant training classes, officially announced the release of the NTS Mobile App designed specifically for anyone working with Trench and Traffic Safety equipment.

“We’re really pleased to be announcing the rollout of the new NTS Mobile App,” commented Ron Chilton, President of NTS. “We believe we have created a tool with a lot of unique functionality built into this app that will make it a must have item for contractors and their crews. This app is a total handheld resource that contractors should find highly valuable. Our app is not an advertising tool, but rather this app puts all of the specific tools a contractor needs and is required to have on any job site in the palm of his or her hand. One of the features we’re most excited about is the app’s ability to allow a contractor’s Competent Person to complete an electronic excavation daily checklist, to log that checklist for future reference and the ability to print, text and or email those logs.” The NTS Mobile app will also provide real-time access to and the ability to print, text and or email manufacturer’s tabulated data, product depth ratings and weights, OSHA sloping and benching tables, and all relevant OSHA excavation, confined space, and fall protection standards.

“As technology has permeated our industry and culture, it’s made some really unique things possible that weren’t feasible as little as a decade ago,” remarked Chilton. “The NTS Mobile app is the first of a series of technology related services we’ll be introducing over the next year. We also remained committed to bringing new products to the market and have a couple planned product launches for later in the year.”

The NTS Mobile App is currently available on the AppleTM Store for both the iPad and iPhone and will be available for download for Android phones on the GoogleTM Play Store in late February. The app is offered free of charge to users. NTS has several updates planned for the app over the next few months to further enhance the functionality of the app and will be actively seeking feedback from the app’s user community to enhance its value to the construction industry. To learn more about the NTS Mobile App, its features and how to download it please visit us at http://www.ntsafety.com/ntsmobileapp.

National Trench Safety currently has 30 branch locations within the United States. This large national foot print allows NTS to provide its national, regional and local market customers a fully integrated, national branch network delivering unique engineered solutions, the highest level of customer service and the most cost-effective shoring solutions in the industry.

In maintaining its objective of building a nationwide network of trench and traffic safety branches, NTS plans to open several additional branch locations in 2017. For more information about NTS, visit the National Trench Safety website at http://www.ntsafety.com.

“Confined Spaces – Supervisor Safety Tip Series” #ConfinedSpace #Safety

Developed by Vivid’s Chief Safety Officer Jill James, a former OSHA inspector, this series examines real hazards in real work environments. This safety tip video explains ways to stay safe while working with Confined Spaces.

Confined spaces are enclosed or partially enclosed spaces of a size such that a worker can squeeze entry for performing assigned work through a narrow opening—they’re tough to get in and out of, tight spaces. These spaces are normally only entered to perform specific tasks and then barricaded to prevent unauthorized access.

As an example, think of a large tank used for holding liquid. Sometimes, these storage units or big containers need to be cleaned out, so you send a worker to get inside and they’re completely surrounded by walls of the structure, with only a small entry/exit hatch for escape if things go awry. Confined spaces create the ideal conditions for the onset of claustrophobia. Confined spaces can be large or small and above or below ground.

This video covers:

Source: Vivid Learning Systems

“Confined Spaces – “What To Do Before You Enter” #ConfinedSpace #StayAlive

80% of fatalities happened in locations that had been previously entered by the same person who later died.

Each year, an average of 92 fatalities occurs from confined spaces locations due to asphyxiation, acute or chronic poisoning, or impairment.

But, what is a “confined space?”

A confined space is a space that:

  1. Is large enough and so arranged that an employee can bodily enter it;
  2. Has limited or restricted means for entry and exit;
  3. Is not designed for continuous employee occupancy.

Examples of confined spaces include:

  • Sewers
  • Storm drains
  • Water mains
  • Pits
  • And many more

Permit-required confined spaces include:

  • Contains or has the potential to contain a hazardous atmosphere
  • Contains a material with the potential to engulf someone who enters the space
  • Has an internal configuration that might cause an entrant to be trapped or asphyxiated
  • Contains any other recognized serious safety or health hazards

Here are some steps you can take to help ensure the safety of your workers.

1. Is This a Confined Space?

2. Is the Atmosphere Safe?

Testing must be done in several levels of the space because specific hazardous gases react differently to the rest of the atmosphere. Why? Hydrogen Sulfide is slightly heavier than air, while other dangerous gases such as methane may be lighter than air and rise to the top. Only by testing all levels of the tank you are about to enter can you be reasonably sure the atmosphere is acceptable for breathing.

3. How Do I Exit Safely?

Before you start thinking about entering, first make sure you can get back out. Meaning you have a rescue plan and are working with someone else who can provide for rescue.

If you don’t have a rescue plan, don’t enter.

4. How Do I Enter Safely?

Does the job or project require special equipment to get in and out of the space, such as a body harness?

5. Will The Atmosphere Stay Safe?

Once you’ve established that the atmosphere is safe to enter, you next have to know that it will stay that way. Which leads us to our next point.

6. Does the Space Need Ventilating?

If the air is found to be unsafe within the confined space because of existing fumes or gas, or if the work being done will contribute to a degradation of the breathable atmosphere, the space needs to be ventilated and you need to be using an air monitoring device.

7. Equipment Check

It’s important to check your equipment before beginning any sort of confined space entry work. Has your gas detector been bump-tested or recently calibrated? Have all lanyards and lifelines been checked for wear? Have harnesses been properly stored?

8. Lighting

Confined spaces are often cramped, dark and awkwardly shaped. A well-lit worksite helps workers avoid injury.

9. Communication

Radios are a great way to stay connected with workers, but also keep in mind that, nothing can replace having a standby worker positioned at the exit when workers are in a confined space. This tried and true system allows the outside person not only to communicate with workers within the space but also to call for help if it is needed.

10. Are you and your crew up to the task?

Can each team member be relied upon in a life-threatening situation?

This list is not meant to be comprehensive, check the OSHA Standards for that.

Stop to consider the dangers before you enter, and be mindful that confined spaces can become dangerous after you have entered.

Source: Vivid Learning Systems – Safety Toolbox

“Miller Fall Protection Safety Webinar” & “Fall Clearance Calculator App”

Miller Fall Protection Webinar

When working at height, it is important to know your fall clearance and swing fall, whether using a shock-absorbing lanyard or self-retracting lifeline. Calculating your fall clearance and swing fall is critical to your safety. The Miller Fall Clearance Calculator App gives workers who work at heights, the ability to quickly calculate the required fall clearance for Shock Absorbing Lanyards and Self-Retracting Lifelines, including swing fall.

Download the New Miller Fall Clearance Calculator App by Honeywell : Download link – https://itunes.apple.com/us/app/miller-fall-clearance-calculator/id971198656?mt=8

Miller Fall App

“N95 Day: A NIOSH-Approved Holiday”

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Today is the 5th annual N95 Day, which focuses on respiratory protection awareness and proper use of N95 respirators. Here are some ways you can participate:

  • Social media. Look for N95-related information on Twitter (@NIOSH, @NPPTL, #N95Day) Facebook, Instagram and Pinterest as well as the annual N95 Day NIOSH Science Blog. Share NIOSH’s infographics, and be sure to follow ASSE (@ASSE_Safety) and other campaign partners to find free training, resources, and safety tips.
  • Hospital respiratory protection program resources. NIOSH has launched a web page of resources dedicated to hospital respiratory protection programs.
  • Webinars. NIOSH is presenting two webinars this year: 1) The Science Behind Respirator Fit Testing in the Workplace: Past, Present and Future; and 2)  Why Do We Have to Fit Test? And Why Every Year? Although registration is now closed, the agency will post the webinar videos and slides after the event. Check the campaign page for updates.
  • ASSE materials. Check out ASSE’s Tech Brief on ANSI/ASSE Z88.2-2015, Practices for Respiratory Protection and visit our respiratory protection standards page.

Source: ASSE, NIOSH, CDC

3M “DB​I-SALA® Lad-Saf™ (Tower Ladder Safety) Sleeve – Stop Use and Voluntary Recall / Replacement”

DBI SALA® Lad Saf™ Sleeve – Stop Use and Voluntary Recall   Replacement

After more than 30 years of use in the fall protection industry, the original Lad-Saf™ sleeve has been replaced by a completely redesigned next generation Lad-Saf sleeve. Capital Safety/3M recently reviewed the performance of the original Lad-Saf sleeve in the field, including a limited number of incidents involving a serious injury or death in the United States while using the sleeve.

Although our review did not reveal product hazard or risk scenarios that would arise in the ordinary and proper use of the product, it did reveal potential misuse scenarios that could result in serious injury or death.

The potential misuse scenarios include interference with the braking mechanism (such as entanglement with cords, lanyards, clothing or other materials, or grasping the sleeve prior to or during a fall), or result from the user attaching the sleeve upside down (user inversion). No safety regulator has made a finding that the design of the original Lad-Saf sleeve is defective. At 3M, customer safety and confidence are high priorities. In light of the reported incidents and potential misuse scenarios, we have discontinued sale of the original Lad-Saf sleeve, and are voluntarily initiating a full recall of all original Lad-Saf sleeves.

At 3M, customer safety and confidence are high priorities. In light of reported incidents and potential misuse scenarios involving the original Lad-Saf sleeve, 3M has discontinued sale of the original sleeve, and is voluntarily recalling all original Lad-Saf sleeves.

Please click on the link to take you to the Stop Use and Recall/Replacement Notice (English) (Spanish).

 

 

“Safety Photo of the Day” – “Who Should Be Tied Off In This Photo?”

Who Should Be Wearing Fall Protection &  Tied Off In This Photo?

wrigley-reno

OSHA issued a letter of interpretation that addresses the requirements for use of a body-restraint system on aerial lifts (body restraint is required) versus scissor-lifts (body restraint not required as long as standard guardrails are in place). One last thing about scissor-lifts to keep in mind; in some cases, the manufacturer of a scissor-lift may install a tie-off point(s) in the work platform. In those cases, you should consult their instructions for recommendations as to when it might be necessary to tie-off while using their equipment.
Why is fall protection important?

Falls are among the most common causes of serious work related injuries and deaths. Employers must set up the work place to prevent employees from falling off of overhead platforms, elevated work stations or into holes in the floor and walls.

What can be done to reduce falls?

Employers must set up the work place to prevent employees from falling off of overhead platforms, elevated work stations or into holes in the floor and walls. OSHA requires that fall protection be provided at elevations of four feet in general industry workplaces, five feet in shipyards, six feet in the construction industry and eight feet in longshoring operations. In addition, OSHA requires that fall protection be provided when working over dangerous equipment and machinery, regardless of the fall distance.

To prevent employees from being injured from falls, employers must:

  • Guard every floor hole into which a worker can accidentally walk (using a railing and toe-board or a floor hole cover).
  • Provide a guard rail and toe-board around every elevated open sided platform, floor or runway.
  • Regardless of height, if a worker can fall into or onto dangerous machines or equipment (such as a vat of acid or a conveyor belt) employers must provide guardrails and toe-boards to prevent workers from falling and getting injured.
  • Other means of fall protection that may be required on certain jobs include safety harness and line, safety nets, stair railings and hand rails.

OSHA requires employers to:

  • Provide working conditions that are free of known dangers.
  • Keep floors in work areas in a clean and, so far as possible, a dry condition.
  • Select and provide required personal protective equipment at no cost to workers.
  • Train workers about job hazards in a language that they can understand.
Additional Fall Protection Resources

“Are You In Compliance?”-“June 1, 2016 – HAZCOM And GHS, The Final Deadline”

HazCom and GHS: The Final Deadline

HazCom and GHS: The Final Deadline by Safety.BLR.com

June 1, 2016, is the final deadline in the 4-year phase-in period for OSHA’s 2012 revisions to the hazard communication standard that aligned with the Globally Harmonized System for the Classification and Labelling of Chemicals, or GHS. Check out the infographic for an overview of what the final deadline requires and tips to make sure your facility is prepared.

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