“Employer In Fatal Boston Trench Collapse Did Not Provide Safety Training & Basic Safeguards For Employees, OSHA Finds”

Atlantic Drain Service Co. Inc. cited for 18 violations

BOSTON – Robert Higgins and Kelvin Mattocks died on Oct. 21, 2016, in Boston, when the approximately 12-foot deep trench in which they were working collapsed, breaking an adjacent fire hydrant supply line and filling the trench with water in a matter of seconds.

An investigation by the U.S. Department of Labor’s Occupational Safety and Health Administration found that their employer, Atlantic Drain Service Co. Inc., failed to provide basic safeguards against collapse and did not train its employees – including Higgins and Mattocks – to recognize and avoid cave-in and other hazards.

“The deaths of these two men could have and should have been prevented. Their employer, which previously had been cited by OSHA for the same hazardous conditions, knew what safeguards were needed to protect its employees but chose to ignore that responsibility,” said Galen Blanton, OSHA’s New England regional administrator.

OSHA’s inspection determined that Atlantic Drain and owner Kevin Otto, who oversaw the work on the day of the fatalities, did not:

–       Install a support system to protect employees in an approximately 12-foot deep trench from a cave-in and prevent the adjacent fire hydrant from collapsing.

–       Remove employees from the hazardous conditions in the trench.

–       Train the workers in how to identify and address hazards associated with trenching and excavation work.

–       Provide a ladder at all times so employees could exit the trench.

–       Support structures next to the trench that posed overhead hazards.

–       Provide employees with hardhats and eye protection.

As a result, OSHA has cited Atlantic Drain for a total of 18 willful, repeat, serious and other-than-serious violations of workplace safety standards and is proposing $1,475,813 in penalties for those violations. OSHA cited Atlantic Drain trenching worksites for similar hazards in 2007 and 2012. The full citations can be viewed here.

In February, a Suffolk County grand jury indicted Atlantic Drain and company owner, Kevin Otto, on two counts each of manslaughter and other charges in connection with the deaths. OSHA and the department’s Regional Office of the Solicitor worked with the department’s Office of the Inspector General, the Boston Police Department’s Homicide Unit and the Suffolk County District Attorney’s Office during the course of this investigation.

Atlantic Drain has 15 working days from receipt of the citations and proposed penalties to meet with OSHA’s area director, and to contest the citations before the independent Occupational Safety and Health Review Commission, if it chooses to do so.

The walls of an unprotected trench can collapse suddenly and with great force, trapping and engulfing workers before they have a chance to react or escape. Protection against cave-in hazards may be provided through shoring of the trench walls, sloping the soil, or by using a protective trench box. Employers must ensure that workers enter trenches only after adequate protections are in place to address cave-in hazards. More information about protecting employees in trenches and excavations can be found here and here.

“We want to emphasize to all employers that trenching hazards can have catastrophic consequences if they are not addressed effectively before employees enter a trench,” said Blanton.

To ask questions, obtain compliance assistance, file a complaint, or report amputations, eye loss, workplace hospitalizations, fatalities or situations posing imminent danger to workers, call OSHA’s toll-free hotline at 800-321-OSHA (6742) or the nearest OSHA Area Office.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful working conditions for their employees. OSHA’s role is to ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. For more information, visit http://www.osha.gov.

# # #

Media Contacts:

Ted Fitzgerald, 617-565-2075, fitzgerald.edmund@dol.gov
James C. Lally, 617-565-2074, lally.james.c@dol.gov

Release Number:  17-413-BOS

Here Is WHY Trenching Safety Training IS Required!

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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

“OSHA Walking-Working Surfaces & Fall Protection Final Rule Requirement Implementation Dates “

On November 18, 2016, OSHA finally published a final rule updating the walking-working surfaces and fall protection standards for general industry. Percolating since 1990 (55 FR 13360), reopened in 2003 (68 FR 23528) and again in 2010 (75 FR 28862), revisions to the walking-working surfaces and fall protection standards were long overdue. OSHA’s 500+ final rule gives employers new options to combat slip, trip and fall hazards (Subpart D) while adding employer requirements to ensure those new options provide for enhanced safety.

It adds a new section under the general industry Personal Protective Equipment standard (Subpart I) that specifies employer requirements for using personal fall protection systems and clarifies obligations for several specific industries, including telecommunications, pulp, paper and paperboard mills, electrical power generation, transmission and distribution, textiles and sawmills.

The final rule addresses fall protection options (including personal fall protection systems), codifies guidance on rope descent systems, revises requirements for fixed and portable ladders, prohibits the use of body belts as part of a personal fall arrest system, and establishes training requirements on fall hazards and fall protection equipment. OSHA Administrator Dr. David Michaels stated, “The final rule will increase workplace protection from those hazards, especially fall hazards, which are a leading cause of worker deaths and injuries.” OSHA notes the final rule also increases consistency between general and construction industries, which it believes will help employers and workers that work in both industries.

The rule is effective January 17, 2017, but some of the requirements are phased in over time. Phased-in or delayed compliance dates include:

• May 17, 2017

  • Training exposed workers on fall and equipment hazards

• November 20, 2017

  • Inspecting and certifying permanent anchorages

• November 19, 2018

  • Installing personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders/ladder sections, including fixed ladders on outdoor advertising structure
  • Equipping existing fixed ladders over 24 feet, including those on outdoor advertising structures, with a cage, ell, personal fall arrest system, or ladder safety system

• November 18, 2036

  • Replacing cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet

OSHA estimates the rule will affect 112 million workers at nearly 7 million worksites and will prevent 29 fatalities and over 5800 injuries annually.

Many employers that have been operating under the cover of OSHA interpretive letters and statements in the preambles of the proposed rules because the standards in place were so outdated and/or ill-suited to particular work environments. For them, the final rule offers an opportunity to confirm that their policies are compliant. However, those employers should scrutinize the final rule to ensure the interpretations they were relying on were incorporated and that no additional actions are required.

Some have suggested that Congress may seek to overrule these changes using the Congressional Review Act (“CRA”) (5 U.S.C. §§801-808), but that action is risky because the CRA is such a blunt instrument. The CRA can only be used to repeal a regulatory act in its entirety; it cannot be used to amend the regulation. Moreover, repudiation by Congress of a final rule prohibits the agency from issuing a substantially similar rule in the future.

Congress has only used the CRA once—to overrule the ergonomics regulation OSHA adopted at the end of the Clinton Administration. Congress should recognize that the provisions of this final rule are too important to too many employers for it to act reflexively by disapproving the entire rule and prohibiting further action on these issues.

A copy of the final rule is found here. More on the final rule, including OSHA’s Fact Sheet, can be found on OSHA’s website here.

“Behavior-Based Safety: Myth or Magic?”

Behavior-Based Safety: Myth or Magic?

Behavior-based safety is a broad term used to describe everything from basic employee behavior audits and feedback to a comprehensive safety management system designed to change a company’s safety culture.

When it was introduced, behavior-based safety (BBS) was seen as a magic panacea for everything that ailed safety programs. “It was the Swiss Army Knife of safety programs. It could take care of everything,” says Ron Bowles, director of operations for Portland, Ore.-based Strategic Safety Associates. “Now people realize that it is just one tool and more are needed.”

Decades after the initial launch of BBS programs, the process has lost favor with many safety managers, who claim the cost – such programs can be expensive – and the long-term results are not what they expected.

Some experts argue that expectations for BBS were unrealistic from the start, while others believe the process has been corrupted at some companies, transformed into an auditing program that assumes a “blame the employee” attitude about safety failures. “Behavior-based safety makes the assumption you know what behaviors you should be doing,” says Robert Pater, managing director of Strategic Safety Associates. “It assumes you know what to do and need to be reminded to do it.”

Not surprisingly, that approach failed at many companies, says Larry Hansen, CSP, ARM, author and principal of L2H Speaking of Safety Inc.

“My intro to behavior-based safety was being asked by my employer at the time to go to an Indiana food distribution company to analyze the safety program,” remembers Hansen. “At 9 a.m., I walked in the door and the general manager said, ‘Stop right there. I just bought a gun, and the next SOB who mentions behavioral safety…’”

Hansen said the company had spent hundreds of thousands of dollars on a behavior-based safety program and it had failed miserably. “It never had a chance,” he says. “There was a poor manager and a sick organization. They bought into it because they thought it said what they wanted to hear about the cause of incidents, what I call PDDT: people doing dumb things. In other words, employees are the problem and a BBS program can ‘fix’ them. It’s a core misconception that leads to failure.”

The Myth

Jim Spigener, vice president of BST Inc., a global safety consulting and solutions firm that was one of the pioneers in the concept of BBS, says BBS caught fire because “for years and years and years, there wasn’t much new in safety. Then someone seized on the fact that management might want to pay attention to employees. But very few companies were ready to embrace the whole movement.”

Even without a total commitment to changing the safety culture with BBS as a part of that process, BBS caught on “because it was getting results and it seemed to make sense,” says Spigener.

BBS was meant to be part of a bigger safety system, he adds, mentioning what he calls the “fatal error” of assuming that BBS in some form or another works as the only approach necessary to improve safety and reduce incidents.

“BBS, the way people talk about it now, is really a myth,” says Spigener. “A lot of companies jumped on the bandwagon, grabbed a BBS program off the shelf and now are disappointed with the results. And unions have a very good case for going after traditional BBS programs [that ‘blame’ the worker]. Traditional BBS programs don’t examine what drives employees to be in a hazardous situation.”

Hansen offers a perfect example to illustrate Spigener’s point. Hansen says he visited a facility that incurred repetitive losses from injuries employees suffered running up the lunchroom stairwell. Finally, an employee fell and broke his leg, at which point management adopted a BBS program, installing monitors in the hallway leading to the stairwell to remind employees to walk up the steps and to reiterate the company policy, which called for no running. Despite the focus on employee behavior, employees continued running up the stairs until a second major incident occurred, leaving an employee paralyzed. Finally, someone got smart and began to examine systemic causes for employee behavior that ran contrary to company policy and, even, common sense.

“They weren’t asking the most basic question of employees: ‘Why are you running up the stairs?’” says Hansen. “The answer was, ‘There aren’t enough chairs in the lunchroom.’” Employees knew, says Hansen, that if they were late entering the lunchroom, they had to stand to eat their lunches.

“Behavior-based safety done right can be very effective at helping you discover what’s wrong with an organization, find the core organizational causes of risk,” Hansen adds. “Done wrong, it can be used to mask organizational and management failures.”

It’s the Culture, Stupid

E. Scott Geller, Ph.D., talks of attending a session at a safety conference where the presenter asked audience members if they had been injured in a workplace incident and then asked, “How many [incidents] were caused by another person? An equipment failure? Your behavior?”

“When the majority raised their hands when he asked if their behavior caused the incident, he said, ‘I rest my case,’” Geller, alumni distinguished professor at Virginia Tech and director of the Center for Applied Behavior Systems in the Department of Psychology, remembers. “But he didn’t go to the next step and ask the next question: ‘What influences behavior?’ It all happens as part of the culture.”

BBS has its virtues, says Donald Eckenfelder, CSP, P.E., the principal consultant with Profit Protection Consultants and a past president of the American Society of Safety Engineers, but it also has its faults, one of which is the lack of focus on the overall safety culture and environment at a facility. To its credit, Eckenfelder says BBS:

  • Focuses on the human side of safety;
  • Defines safe and unsafe behaviors;
  • Encourages safe behavior and discourages unsafe or destructive behaviors;
  • Involves employees in safety;
  • Requires management to put its money where its mouth is; and
  • Engenders commitment and passion, especially in the early phases.

“There are clearly good things about behavior-based safety,” says Eckenfelder. “But there is more negative than positive” in many of the BBS programs companies have adopted, he adds.

For example, many BBS programs, as packaged by the provider or used by the customer, don’t deal with the causes of safety failures; they deal with the symptoms. “Behaviors of employees are a long way from the root cause,” says Eckenfelder.

If corporate management supports and encourages safe behavior by eliminating root causes – such as engineering, process, communication or training failures – then employees are more likely to want to adopt safe behaviors. Employers, managers and supervisors who actively and vocally support safe production and put money and resources behind that support are less likely to get pushback from employees regarding safe behavior.

“Safety isn’t primarily a technical problem or a behavioral problem,” Eckenfelder points out. “It’s a cultural problem. If the culture’s wrong, nothing else works.”

He notes that when we walk into clothing stores or restaurants, we know if the culture is good or bad. “Can’t you feel the culture?” Eckenfelder asks. “If they’ve got the culture ‘right,’ you say to yourself, ‘Wow! I’d really like to come back here.’”
And the quickest way to ensure safety culture failure, experts agree, is to try to “force” safe behavior on employees.

Experts equate such pressure to a parent telling a teenager how to behave … and say it gets about the same response. As Robert Pater, managing director of Strategic Safety Associates, says, “You can’t mandate people to monitor themselves. You can invite them to do it. Forcing change creates pushback.”

If you really want behavioral change, says Pater, “employees have to see the value of change. They have to believe they can change. They have to know how to change. They have to practice, because behavioral change doesn’t happen from one exposure. And the new actions have to be reinforced through acknowledgment, celebration and external monitoring.”

The key to true, positive behavior change, adds Bowles, “is to create an environment where, rather than have safety as something that is being done to me or for me, it’s something that’s being done with me or by me. Once I begin to own it, I can have incredible success.”

“Real change happens inside out,” Eckenfelder adds. “People get better because they change their attitudes, not because there is pressure placed on them from the outside.

Read the remainder of the story here: http://ehstoday.com/safety/ehs_imp_75429

Source EHS Today®

 

“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

“Conducting An Effective Job Hazard Analysis” – Infographic” #JHA #Safety

JHA_InfographicJob hazard analysis is an essential component of a successful safety program. This BLR infographic details the 6 steps of a JHA so you can assess the hazards at your facility and implement corrective actions.

“JHA Downloads”

JHA Checklist: http://bit.ly/20crSNM

OSHA JHA Powerpoint: http://bit.ly/1K1ebiT

“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

“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

“Why Lock-Out, Tag-Out Is Vitally Important” #LOTO #WorkplaceSafety

Why LOTO is Vitally Important 3

Why LOTO is Vitally Important

Note: The photos above are not intended for page views or shock value as I don’t believe that those methods truly teach you anything in and of themselves. I don’t know the particulars of the above accident, but I do know that the lack of a proper lock out – tag out (control of hazardous energy) policy and procedure contributed to the accident.

This is always on OSHA’s Top 10 Violations list on a yearly basis, typically coming in at number 2 each year in the total number of times cited. Please use the training information below to keep your employees safe and involved in this process at your workplace.

Remember to AUDIT your procedures more than once per year. LOTO can be a difficult procedure especially when your job or facility has large manufacturing equipment such as a multi-employee operated mile long paper mill versus many single employee operated machines.

Hopefully, the Temp Worker Without LOTO Training who lost his life on the first day of his new job and the LOTO Webinar below, as well as the other resources further down the page will help you to put together an appropriate LOTO policy and procedure for your company.

Ninety minutes into his first day on the first job of his life, Day Davis was called over to help at Palletizer No. 4 at the Bacardi bottling plant in Jacksonville, Fla. What happened next is an all-too-common story for temp workers working in blue-collar industries. Read the investigation: http://www.propublica.org/article/tem..

The Control of Hazardous Energy (Lockout/Tagout) Full Webinar 2016

What is hazardous energy?

Energy sources including electrical, mechanical, hydraulic, pneumatic, chemical, thermal, or other sources in machines and equipment can be hazardous to workers. During the servicing and maintenance of machines and equipment, the unexpected startup or release of stored energy can result in serious injury or death to workers.

What are the harmful effects of hazardous energy?

Workers servicing or maintaining machines or equipment may be seriously injured or killed if hazardous energy is not properly controlled. Injuries resulting from the failure to control hazardous energy during maintenance activities can be serious or fatal! Injuries may include electrocution, burns, crushing, cutting, lacerating, amputating, or fracturing body parts, and others.

  • A steam valve is automatically turned on burning workers who are repairing a downstream connection in the piping.
  • A jammed conveyor system suddenly releases, crushing a worker who is trying to clear the jam.
  • Internal wiring on a piece of factory equipment electrically shorts, shocking worker who is repairing the equipment.

Craft workers, electricians, machine operators, and laborers are among the 3 million workers who service equipment routinely and face the greatest risk of injury. Workers injured on the job from exposure to hazardous energy lose an average of 24 workdays for recuperation.

What can be done to control hazardous energy?

Failure to control hazardous energy accounts for nearly 10 percent of the serious accidents in many industries. Proper lockout/tagout (LOTO) practices and procedures safeguard workers from hazardous energy releases. OSHA’s Lockout/Tagout Fact Sheet* describes the practices and procedures necessary to disable machinery or equipment to prevent hazardous energy release. The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry outlines measures for controlling different types of hazardous energy. The LOTO standard establishes the employer’s responsibility to protect workers from hazardous energy. Employers are also required to train each worker to ensure that they know, understand, and are able to follow the applicable provisions of the hazardous energy control procedures:

  • Proper lockout/tagout (LOTO) practices and procedures safeguard workers from the release of hazardous energy. The OSHA standard for The Control of Hazardous Energy (Lockout/Tagout) (29 CFR 1910.147) for general industry, outlines specific action and procedures for addressing and controlling hazardous energy during servicing and maintenance of machines and equipment. Employers are also required to train each worker to ensure that they know, understand, and are able to follow the applicable provisions of the hazardous energy control procedures. Workers must be trained in the purpose and function of the energy control program and have the knowledge and skills required for the safe application, usage and removal of the energy control devices.
  • All employees who work in an area where energy control procedure(s) are utilized need to be instructed in the purpose and use of the energy control procedure(s), especially prohibition against attempting to restart or reenergize machines or other equipment that are locked or tagged out.
  • All employees who are authorized to lockout machines or equipment and perform the service and maintenance operations need to be trained in recognition of applicable hazardous energy sources in the workplace, the type and magnitude of energy found in the workplace, and the means and methods of isolating and/or controlling the energy.
  • Specific procedures and limitations relating to tagout systems where they are allowed.
  • Retraining of all employees to maintain proficiency or introduce new or changed control methods.

OSHA’s Lockout/Tagout Fact Sheet* describes the practices and procedures necessary to disable machinery or equipment to prevent the release of hazardous energy.

The control of hazardous energy is also addressed in a number of other OSHA standards, including Marine Terminals (1917 Subpart C), Safety and Health Regulations for Longshoring (1918 Subpart G), Safety and Health Regulations for Construction; Electrical (1926 Subpart K), Concrete and Masonry Construction (1926 Subpart Q), Electric Power Transmission and Distribution (1926 Subpart V), and General Industry; Electrical (1910 Subpart S), Special Industries (1910 Subpart R), and Electric Power Generation, Transmission and Distribution (1910.269).

Highlights
  • Lockout-Tagout Interactive Training Program. OSHA eTool. Interactive tool to provide the user with an in-depth understanding of the LOTO standard, with three components: Tutorial, Hot Topics, and Case Studies.
  • Construction. OSHA eTool. Helps workers identify and control the hazards, including electrical hazards, that commonly cause the most serious construction injuries.
    • Electrical Incidents. Landing page for Electrical Incidents subpage of the Construction eTool, which identifies electrical hazards and recommends preventive measures.
  • Electric Power Generation, Transmission, and Distribution. OSHA eTool, (January, 2010). Assists workers in identifying and controlling workplace hazards.
Lockout/Tagout Concepts
Lockout/Tagout Program

Example elements of a lockout/tagout (LOTO) program are described in the OSHA standard for the control of hazardous energy (29 CFR 1910.147), along with these additional references.

Other Resources
Training
  • Lockout-Tagout Interactive Training Program. OSHA eTool. Interactive tool to provide the user with an in-depth understanding of the LOTO standard, with three components: Tutorial, Hot Topics, and Case Studies.
    • Case Studies. Presents a series of case studies for review, followed by related questions. Each of the case studies is based on descriptions of LOTO inspections derived from compliance interpretations, court decisions, Review Commission decisions, and inspection files.
  • Small Business Handbook (PDF). OSHA Publication 2209, (2005). Handbook is provided to owners, proprietors and managers of small businesses to assure the safety and health of workers.
  • Lockout/Tagout. National Ag Safety Database (NASD) Research Publications-11. Brief publication providing an overview of lockout/tagout, California laws and regulations, and training materials.
Additional Information
  • Fatality and Catastrophe Investigation Summaries. OSHA. Enables the user to search the text of Accident Investigation Summaries (OSHA-170 form) for words that may be contained in the text of the abstract or accident description.
  • Z244 Committee Information. American Society of Safety Engineers (ASSE).
  • Safety Alert: Control of Hazardous Energy – Lockout/Tagout (LO/TO) Procedures in Shipyard Employment*. OSHA and Shipbuilders Council of America, National Shipbuilding Research Program, and American Shipbuilding Association Alliances (now the Shipbuilding Group Alliance) and the American Industrial Hygiene Association and American Society of Safety Engineers Alliances, (February 2009). Safety Alert Fact Sheet that provides information on how to protect employees from hazardous energy. Also available in Spanish*.
  • Safety Alert: Electrocution and Shock Hazards in Shipyard Employment*. OSHA and Shipbuilders Council of America, National Shipbuilding Research Program, and American Shipbuilding Association Alliances (now the Shipbuilding Group Alliance) and the American Industrial Hygiene Association and American Society of Safety Engineers Alliances, (February 2008). Safety Alert Fact Sheet that provides information on how to protect employees from electrocution and shock hazards. Also available in Spanish*.
Related Safety and Health Topics

Note: These photos are the property of Jack Benton, and may not be used without written consent.

“How Would Nick Saban Handle An OSHA Inspection?”

nick-saban-alabama

Lessons for Employers from the Crimson Tide’s Championship Football Coach

September has arrived. That can only mean one thing: it’s time for college football!

Labor Day weekend offered several high-profile games for our viewing pleasure. Number-one ranked Alabama won one of those contests, with the Crimson Tide overwhelming Southern California by the score of 52-6. Alabama looked well-prepared and disciplined in its lopsided victory over a ranked opponent, showing once again why its coach Nick Saban is likely the best in college football.

Coach Saban’s unprecedented success – having won five career national championships, including four out of the last seven – is the result of his unparalleled work ethic and a commitment to excellence even the CEO of a Fortune 500 company would envy. Indeed, his processes transfer well to the corporate world and some companies attempt to mimic what Saban has developed at Alabama. His attention to detail could create a successful environment at any business.

Employers can learn from Saban’s methodical determination to succeed. His model provides employers an example on how to, among many other things, institute programs to handle adversity and challenges that arise in the workplace.

Following Saban’s routine of working hard, staying focused, teaching discipline, and developing character could help any employer prepare for unexpected events like a workplace accident or visit by a government compliance agency, such as the Occupational Safety and Health Administration (OSHA).

Given what we know about the habits that led to his success as a football coach, here’s how Saban – if employed as a safety supervisor – might handle the difficult tasks of developing a culture of workplace safety and responding to an OSHA inspection:

Pre-Game Preparation- Before OSHA Arrives

1. Be Prepared. No coach prepares like Nick Saban. Saban rarely loses a game for which he had additional time to prepare. In fact, he has never lost a national championship game, which generally does not take place until several weeks after the end of the regular season. Safety Supervisor Saban would have his company extremely prepared for any government agency visit, including an OSHA inspection. He would take the proactive approach of creating robust safety programs, rigorous training techniques, and a culture of accountability.He would not wait until after OSHA arrived to take these steps.

2. Challenge the (Safety) Program. Coach Saban loves for his team to play top-notch opponents, especially early in the season. Stiff competition challenges his team and only makes it better. He currently employs 21 consultants – in addition to his coaching staff – to analyze the quality of his program at Alabama. Safety Supervisor Saban would have consultants from top safety companies and safety professionals from competitor companies review his safety program and give feedback on how to make it better. He would listen to and learn from these consultants in an effort to develop new techniques and continuously improve safety in his workplace.

First Half – The Opening Conference with OSHA

3. Take Charge and Speak for the (Safety) Team. Coach Saban prohibits his assistant coaches from speaking to the media on behalf of the program. If you have a question about the Alabama football team, you ask Coach Saban. If OSHA arrived for an inspection, Safety Supervisor Saban would instruct his employees not to speak to any OSHA representative until he arrived. OSHA could only meet with the head of the safety program prior to beginning its inspection. This would ensure proper, and knowledgeable communication is delivered on behalf of the company.

4. Know the (OSHA) Rules. Coach Saban understands the rules of college football. In fact, he often questions why other coaches aren’t following them, or why certain rules should be changed. He is a student of the game. Safety Supervisor Saban would know not only the OSHA safety regulations but the procedures OSHA must follow when conducting an inspection. He would understand, for instance, that regardless of the reason OSHA appears at your door, if you consent to the inspection without limiting the review to the stated reason OSHA is there (e.g., hazard alleged in a complaint), most arguments relating to the scope of the inspection are lost. Saban would know what OSHA can and cannot do, and require the agency to follow its procedures.

Second Half – OSHA’s Walk-Through and Interviews

5. (Make OSHA) Focus on the Task at Hand. Coach Saban refuses to allow certain team personnel to speak on the headsets worn by coaches during the game. He believes any additional conversation is unnecessary and a waste of time. He also requires his players to focus on each individual play and attempt to execute it without error. Saban generally prohibits players and coaches from discussing the score at any point during the game. He believes that if you take care of each play, the score will take care of itself. While walking through his facility with OSHA during an inspection, Saban would require OSHA to focus solely on the reason why it is there. If OSHA is there for a complaint on a press machine, OSHA would inspect the press machine- nothing else. There would be no discussion of any other matters.

6. Tell the Truth and Don’t Make Excuses. Coach Saban doesn’t like excuses. Win or lose; he generally gives the other team credit for their excellent play; he doesn’t blame the referees.He also requires his players, to be honest. Saban believes honesty is a crucial character trait. Safety Supervisor Saban would require his employees, to tell the truth, if interviewed by OSHA. If there is a safety issue, he would instruct them to not hide it or make excuses. Honesty is the only policy.

Post-Game – After the Penalties

7. Learn from Mistakes. Saban doesn’t always win. When he loses, however, he allows that experience to be an opportunity to learn. Rarely does Saban lose to the same team twice in one season, or more than one year in a row. If Safety Supervisor Saban received a citation, he may contest it if plausible defenses existed. More importantly, however, he would learn from the experience and rigorously reassess and evaluate his safety program with respect to the alleged hazard in order to improve.

8. Above All, Be Professional. Coach Saban is a professional. He generally refrains from yelling or swearing on the sidelines, and treats others with respect in both victory and defeat. Safety Supervisor Saban would understand that employers and OSHA are on the same page from a mission standpoint. They want to keep employees safe. Being abrasive or unprofessional is not the demeanor that will help accomplish this goal. Saban would realize the importance of remaining cordial throughout the inspection process.

Coach Saban’s success is the product of habits that could produce results on and off the football field. Employers can learn from accomplished leaders like him.

When determining how to improve your safety program, consider what has led to success for others, even if that success occurred outside your industry. Think outside the box. This innovation and critical evaluation will lead to results.

By Travis Vance of Fisher Phillips

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