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“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

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“Fall Protection – What’s Required Where?” – “Scissor Lifts”

scissor-lifts-and-harnesses-fall-protection-or-no-protection

First, I want to start off with the “scissor lift” dilemma and confusion. If you talk to two different people, you’ll get two differing opinions. Here are my thoughts on this:

I have watched while the battle has raged over whether the use of personal fall arrest harnesses by scissor lift operators is appropriate. The rationale on each side of the issue; pro and con, is intelligent, compelling, and complete with opinions from well informed, knowledgeable people.

The core argument from the pro-harness side stems from the assertion that scissor lift operators are more or less subject to the same falling hazards as anyone else working at height, so why not wear a harness?

On the con-harness side of things, some of the many the arguments follow the logic that if a scissor lift operator who is tethered to the unit goes over the guardrail, the resulting force(s) exerted on the machine when his/her weight jerks to a stop at the end of the lanyard’s travel could be enough to cause the unit to topple, sending it and the operator down. In addition, so I’m told, as the unit plummets down with the operator in tow, the lanyard serves to worsen things by “slingshotting” the operator into the ground and possibly under the machine, resulting in even greater injury than if he/she were able to free fall or jump clear.

If that’s not enough, neither OSHA regulations or ANSI/SIA standards require the use of personal fall protection harnesses for operators of scissor lifts. In fact, in many cases manufacturers do not provide an anchor point to connect the snap hook of a lanyard to and, OSHA prohibits tying off to a guard rail as per 29CFR 1926.502(d)(23)); “Personal fall arrest systems shall not be attached to guardrail systems.”

Some other issues that I have heard from the con side have to do with things like how wearing a harness restricts the movement of the operator or that wearing a harness may actually lull the operator into a false sense of security. I could go on, but I won’t.

I am going to go on record here and state that I believe scissor lift operators should be required to wear a personal fall restraint system (PFRS) consisting of a full body harness and non-shock absorbing lanyard provided there is an approved anchor point to connect it to. (In fact, if you dig into the OSHA regulations, you’ll find that “If the scissor lift manufacturer provides tie off anchor points at the base of the guardrail system, and the manufacturer’s user instructions require them to be used, then you need to be tied off with a PFRS”.)

Allow me approach each point of the “con” argument and, for what it’s worth, chip in my two cents.

First of all, take note of the suggestion for using a fall restraint harness rather than a fall arrest harness. Fall arrest systems are designed to stop a fall in progress while fall restraint systems prevent a fall from occurring… big difference. No fall means no excessive force on the unit, therefore no tip-over. The operator stays on the platform and the lift stays upright. Granted, a fall restraint harness may restrict the operator’s motion depending on the type of anchor point and how much mobility is actually required, but this is a fair trade in exchange for preventing a fall and possible fatality.

As for the “slingshot” effect, well, the laws of physics do not support that theory. A few centuries ago, Galileo discovered something we know today as, the law of falling bodies. Without going into great detail here, it basically states that everything that falls accelerates toward the earth at a rate of 32 feet per second/per second, until reaching peak terminal velocity (top speed), which is about 120 mph. So, if a scissor lift tips over, the operator and the platform are going to travel toward the ground at approximately the same speed; there will be no “slingshot” effect and certainly no need to jump from the platform. In addition, an operator wearing a PFRS will not sustain further injury because of multiple impacts with the ground from bouncing after the initial impact with the ground.

On the topic of jumping clear of the unit, there are serious concerns about the practicality of that notion. Even a conditioned athlete that is prepared and ready for the unit to tip would have difficulty picking the right moment to leap clear. When an aerial lift goes over it typically happens unexpectedly and quickly. The average operator is unlikely to have the physical prowess or presence of mind to do the right thing at the right time and even if he/she did, they would still have the actual fall to the ground with which to contend.

That brings us to OSHA regulations which, after all, are the law and the law says you don’t have to wear a harness to operate a scissor lift. I am going to avoid getting wrapped up in reg’s here the same way I do when I train operators, suffice to say that we are not attempting to determine if we have to wear it, but whether we should. Allow me to share a bit of wisdom that I usually impart to operators when they get a bit carried away with the law, which is; when you operate aerial lift devices, the only law you need to concern yourself with is the law of gravity. Respect for occupational safety and health laws will affect your relationship with OSHA while respect for gravity will affect your relationship with the ground!

As far as harnesses giving operators a false sense of security, it shouldn’t. It should give them a real sense of security. It is a simple fact that an operator wearing a PFRS is less likely to be killed by falling from the platform, which in itself is reassuring. It is also a fact that more scissor lift operators are killed by falling from the platform than by tipping the unit over and besides, if the unit goes over for any reason, the effect on the operator will be ugly with or without a PFRS.

The bottom line here is that every situation, or in this case, each use of the scissor lift has to be looked at from a different approach, so good judgment and the use of best practices are imperative.

9-23-2016 – Here is a link to a Scissor Lift Manufacturers letter, requiring the use of Fall Protection while using their product. https://goo.gl/hi2mvw

“Does Your Facility Have An Effective Safety Culture? Is Safety Truly A Priority?

lead lag 2

One way to improve the effectiveness of your safety process is to change the way it is measured.

Measurement is an important part of any management process and forms the basis for continuous improvement. Measuring safety performance is no different and effectively doing so will compound the success of your improvement efforts.

Finding the perfect measure of safety is a difficult task. What you want is to measure both the bottom-line results of safety as well as how well your facility is doing at preventing accidents and incidents. To do this, you will use a combination of lagging and leading indicators of safety performance.

Lagging indicators of safety performance

What is a lagging indicator?

Lagging indicators measure a company’s incidents in the form of past accident statistics.

Examples include:

  • Injury frequency and severity
  • OSHA recordable injuries
  • Lost workdays
  • Worker’s compensation costs

Why use lagging indicators?

Lagging indicators are the traditional safety metrics used to indicate progress toward compliance with safety rules. These are the bottom-line numbers that evaluate the overall effectiveness of safety at your facility. They tell you how many people got hurt and how badly.

The drawbacks of lagging indicators.

The major drawback to only using lagging indicators of safety performance is that they tell you how many people got hurt and how badly, but not how well your company is doing at preventing incidents and accidents.

The reactionary nature of lagging indicators makes them a poor gauge of prevention. For example, when managers see a low injury rate, they may become complacent and put safety on the bottom of their to-do list, when in fact, there are numerous risk factors present in the workplace that will contribute to future injuries.

Leading indicators of safety performance

What is a leading indicator?

A leading indicator is a measure preceding or indicating a future event used to drive and measure activities carried out to prevent and control injury.

Examples include:

  • Safety training
  • Ergonomic opportunities identified and corrected
  • Reduction of MSD risk factors
  • Employee perception surveys
  • Safety audits

Why use leading indicators?

Leading indicators are focused on future safety performance and continuous improvement. These measures are proactive in nature and report what employees are doing on a regular basis to prevent injuries.

Best practices for using leading indicators

Companies dedicated to safety excellence are shifting their focus to using leading indicators to drive continuous improvement. Lagging indicators measure failure; leading indicators measure performance, and that’s what we’re after!

According to workplace safety thought leader Aubrey Daniels, leading indicators should:

  1. Allow you to see small improvements in performance
  2. Measure the positive: what people are doing versus failing to do
  3. Enable frequent feedback to all stakeholders
  4. Be credible to performers
  5. Be predictive
  6. Increase constructive problem solving around safety
  7. Make it clear what needs to be done to get better
  8. Track Impact versus Intention

While there is no perfect or “one size fits all” measure for safety, following these criteria will help you track impactful leading indicators.

How Caterpillar used leading indicators to create world-class safety

An article on EHS Today titled, “Caterpillar: Using Leading Indicators to Create World-Class Safety” recaps an interview with two Caterpillar executives who explained how they were able to successfully transition to a culture that utilizes leading indicators for safety.

According to the execs at Caterpillar, “… traditional metrics can help companies tell the score at the end of the game, but they don’t help employers understand the strengths and weaknesses of their safety efforts and cannot help managers predict future success.”

By utilizing a Safety Strategic Improvement Process (SIP) that emphasized leading indicators of safety, they saw an 85% reduction of injuries and $450 million in direct/indirect cost savings.

According to the article, the critical elements of the SIP included:

  • Enterprise-wide statement of safety culture.
  • Global process, tools and metrics.
  • Top-down leadership of and engagement with the process.
  • Clearly defined and linked roles and responsibilities.
  • Clearly defined accountability.
  • Consistent methods establishing targets and reporting performance.
  • Consistent criteria for prioritizing issues and aligning resources.
  • Recognition for positive behavior and performance.
Conclusion

To improve the safety performance of your facility, you should use a combination of leading and lagging indicators.

When using leading indicators, it’s important to make your metrics based on impact. For example, don’t just track the number and attendance of safety meetings and training sessions – measure the impact of the safety meeting by determining the number of people who met the key learning objectives of the meeting / training.

What metrics do you use to measure your facility’s safety performance? Do you use a combination of leading and lagging indicators?

“Infographic: OSHA’s Multiemployer Citation Policy”

Do you work on a multiemployer worksite? If so, do you understand your safety responsibilities?

When OSHA inspects multiemployer workplaces, inspectors determine who should be cited for violations based on whether employers are “creating employers,” “exposing employers,” “correcting employers,” or “controlling employers.”

This infographic will give you an overview of what these terms mean and help you understand your safety responsibilities depending on your role on a worksite.

OSHA's Multiemployer Citation Policy

OSHA’s Multiemployer Citation Policy by Safety.BLR.com

“NFPA 70E – 2017” – “LOTO & Arc Flash Proposed Changes From Second Draft Meeting “

NFPA-70E-2015

The second draft meeting for NFPA 70E was held in Salt Lake City on July 18th through July 21st. There were 173 public comments acted on at the meeting. There are a few proposed changes to the standard that were acted upon that may garner the most attention.

NOTE:  The official position of the committee has not been given through the formal ballot. This blog only addresses preliminary revisions proposed by the public and committee.

The first is that the layout of Article 120 Establishing an Electrically Safe Work Condition has been reorganized to better address the logical sequence of events. The steps, principles, and program for lockout/tagout have been moved to be the first sections of Article 120 since these are necessary before verifying the condition.  The verification steps have been moved to the end of Article 120 since these are the last steps for establishing the electrically safe work condition.

A second change is to place further emphasis on the risk assessment and put the hierarchy of controls into mandatory language.  The use of personal protective equipment (PPE) has always been and remains to be the last method selected when providing protection for the worker exposed to hazards when conducting justified energized work. The revised text clarifies this principle.

The third changes clarifies how the standard should have always been used when justified energized work is to be conducted. It essentially is not adding new requirements but will assist in preventing the misuse of the standard. The change is that Table 130.7(C)(15)(A)(a) [that many call the task table] has become a new table applicable to both the PPE category method or the incident energy analysis method. It no longer determines whether PPE is required but whether or not there is a likelihood of an arc flash occurrence. The user conducts a risk assessment and determines the protection scheme to be employed to protect the worker using the hierarchy of controls (same as in the past editions).

The last big change is that the references to PPE equipment standards have been changed to informational notes. The equipment must still meet the applicable standards but the verification process has been changed to one of a conformity assessment where the PPE manufacturer should be able to provide assurance that the applicable standard has been met by one of three methods. The previous edition of the standard did not require any verification method. The three methods are; self-declaration with a Supplier’s Declaration of Conformity, self-declaration under a registered Quality  Management System and product testing by an accredited laboratory and a Supplier’s Declaration of Conformity, or a certification by an accredited independent third-party certification organization.

The committee’s official position will be taken by ballot in early September.  If you want to keep up on the process visit the NFPA 70E web page at www.nfpa.org/70E. The next edition tab will carry all the current information throughout the process. NFPA 70E – 2017 is slated to be voted on at the association meeting in Boston, MA in June 2017.

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