“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

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

“OSHA – DOL News Release” – “Worker Falls 22 Feet to Death, 4 Months After OSHA Cites Employer for Failing to Protect Workers on the Same Job Site”

Worker falls 22 feet to death  4 months after OSHA cites employer for failing to protect workers on the same job site

Louisville employer faces $320K in fines for serial disregard of fall protection

ADDISON, Ill. ‒ Four months after federal safety investigators cited his employer for failing to provide workers with fall protection at a United Parcel Service facility in Addison, a 42-year-old employee of Material Handling Systems/MHS Technical Services, fell 22 feet to his death at the same site.

On July 29, 2016, the U.S. Department of Labor’s Occupational Safety and Health Administration cited the employer for three egregious willful violations for exposing workers to falls over 6 feet, after its investigation of the Feb. 9, 2016, fatality. OSHA also cited three repeated and three serious safety violations.

“A man is dead because this employer decided to break the law over and over again. Before this tragedy, OSHA cited this contractor twice for exposing workers to fall hazards, including at the same site just four months earlier,” said Dr. David Michaels, assistant secretary of labor of Occupational Safety and Health. “OSHA is asking companies contracting with Material Handling Systems to take strong steps to ensure that this employer protects its employees, and terminate its contracts if this employer continues to violate OSHA regulations. Material Handling Systems employer must demonstrate it can work safely and stop injuring its employees.”

OSHA also found Material Handling Systems/MHS Technical:

–       Exposed other workers to falls of up to 22 feet as they hoisted conveyor equipment while working on raised surfaces with unprotected sides. Failed to determine whether walking and working surfaces could structurally support employees.

–       Allowed workers to use a combustible polyethylene tarp as a welding curtain, which created a serious fire hazard.

OSHA cited Material Handling Systems most recently for fall protection violations in October 2015 at the same jobsite. In 2014, OSHA cited the company for similar violations after an employee suffered serious injuries in a fall in Keasby, New Jersey. The employer also received fall protection citations in 2009 in Oregon and 2012 in Florida. The company’s workers’ compensation carrier is Old Republic Insurance Company of Greensburg, Pennsylvania.

Material Handling Systems/MHS Technical Services removes and installs high-speed conveyor systems. In this case, the company was working under a multi-million contract with United Parcel Service to dismantle existing conveyor systems and install new, high-speed conveyors at UPS’s Addison facility.

Based in Louisville, Kentucky, Material Handling Systems/MHS Technical Services faces total proposed penalties of $320,400. View current citations here.

Preventable falls account for nearly 40 percent of all deaths in the construction industry. Federal safety and health officials are determined to reduce the number of preventable, fall-related deaths in the construction industry. OSHA offers a Stop Falls online resource with detailed information in English and Spanish on fall protection standards. The page provides fact sheets, posters, and videos that illustrate various fall hazards and appropriate preventive measures. OSHA standards require that an effective form of fall protection be in use when workers perform construction activities 6 feet or more above the next lower level.

OSHA’s ongoing Fall Prevention Campaign was developed in partnership with the National Institute for Occupational Safety and Health and NIOSH’s National Occupational Research Agenda program. Begun in 2012, the campaign provides employers with lifesaving information and educational materials on how to prevent falls, provide the right equipment for workers and train employees to use fall protection equipment properly.

Material Handling Systems/MHS Technical Services has 15 business days from receipt of its citations and penalties to comply, request an informal conference with OSHA’s area director, or contest the findings before the independent Occupational Safety and Health Review Commission.

To ask questions, obtain compliance assistance, file a complaint, or report amputations, eye loss, workplace hospitalizations, fatalities or situations posing imminent danger to workers, the public should call OSHA’s toll-free hotline at 800-321-OSHA (6742) or the agency’s North Aurora office at 630-896-8700.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces 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:

Scott Allen, 312-353-6976, allen.scott@dol.gov
Rhonda Burke, 312-353-6976, burke.rhonda@dol.gov

Release Number: 16-1572-CHI

Fall Protection Training – Miller Fall Protection

“Workplace Injuries By The Numbers – Every 7 Seconds A Worker Is Injured On The Job”

Nearly 13,000 American workers are injured each day. These numbers are staggering, and the worst part is that each one is preventable. Taking preventative action can spare workers needless pain and suffering.

Journey to Safety Excellence
Provided by the National Safety Council

“The “Vert Alert” Lanyard Attachment Warning System Saves Lives”

VertAlertSCA_full

The VertAlert verbally warns the lift operator if the safety harness lanyard has not been properly attached to the lift anchor point. The VertAlert will not allow the lift to proceed UP until it has verified this proper attachment.

It will also collect and store data on lift activity including safety violations and if any attempts were made by the operator to circumvent this safety system. See more information about this unique and excellent system at: http://millennialplatform.com/ or email Paul Baillergian at  paul@suncook-intl.com 

“Heat, Lightning Hazards are Focus of Federal Safety Campaigns”

With the arrival of summer, the Occupational Safety and Health Administration has launched initiatives to alert employers and workers to heat and lightning hazards and the steps to take to prevent injury or illness from them.

The official hashtag of OSHA’s annual heat safety campaign is #WaterRestShade, which is designed to encourage employers to provide their workers with drinking water, ample breaks, and a shaded area while working outdoors.

In a May 26 webinar, OSHA identified four vulnerable populations ‒ the elderly, athletes, emergency responders, and outdoor workers ‒ as being at special risk from extreme heat. In addition, the agency identified time on the job as a risk factor, since the most recent heat-related deaths OSHA investigated involved workers on the job for three days or less. The finding highlights the need for employers to ensure new workers become heat-acclimated before starting or returning to work, the agency stated. In 2014, 2,630 workers suffered from heat illness and 18 died from heat stroke and related causes on the job, according to the agency.

OSHA has provided a host of heat safety tips, which can be found in blog and Twitter posts. An updated webpage also includes illustrations of heat exhaustion and heat stroke, an animated video, training resources, and links to an updated heat safety phone app. OSHA partnered with the National Oceanic and Atmospheric Administration (NOAA) to raise awareness on the dangers of working in the heat through NOAA’s Weather-Ready Nation campaign.

NOAA is also a partner with OSHA in a joint fact sheet on lightning. It urges supervisors and employees working outdoors to consider lightning to be an occupational hazard and to take lightning safety seriously. More than 300 people are struck by lightning every year in the U.S. and, on average, over the past 30 years, about 50 people have died annually. Many others have suffered permanent disabilities.

According to the fact sheet, lightning is unpredictable. It can strike outside the heaviest rainfall areas or even up to 10 miles from any rainfall. When the threat arises, the most important thing to do is move quickly to a safe place and remain there for at least 30 minutes after hearing the last sound of thunder. “When thunder roars, go indoors,” the agencies advise, as nowhere outside is safe when thunderstorms are in the area.

Employers are advised to monitor weather reports, such as at weather.gov, before scheduling outdoor work and throughout the workday. Darkening clouds and increasing wind speeds can indicate thunderstorms are developing. Workers should know in advance where to seek shelter. NOAA recommends seeking fully enclosed buildings with electrical wiring and plumbing, which can serve as grounds for lightning charges. Additional advice includes avoiding the use of corded phones, as they conduct electricity. If caught outdoors, seek safety inside a hard-topped metal vehicle. No place outdoors is safe during a thunderstorm, but workers can reduce the risk of harm by avoiding isolated tall structures or objects, water, open spaces, and metal objects, the agencies said.

OSHA advises employers to include a written lightning safety protocol in their Emergency Action Plans (EAPs). Written EAPs, as outlined in 29 CFR 1910.38 or 29 CFR 1926.35, are required by certain OSHA standards, and are a best practice even when not required. OSHA said it will use its general duty clause as a basis for enforcement, but also reminded employers that during storms or high winds, OSHA prohibits work on or from scaffolds under 29 CFR 1926.451(f)(12); use of crane hoists, 29 CFR 1926.1431(k)(8); and work on top of walls, 29 CFR 1926.854(c). During these weather conditions, crane hoists and scaffold work may continue only if a qualified person determines it is safe. In addition, for scaffold work, personal fall protection or wind screens must be provided.

“New Traveler’s Insurance Report – 170 Billion In Cost & 3.7 Million Workers Injured Per Year”

worker-with-head-injuryOf all public sector and private US businesses, roughly 3.7 million workers are injured per year. Businesses spend $170 billion per year on costs associated with occupational injuries and illnesses (according to OSHA) – and these findings provide critical insight on how the numbers add up.

The nature of employee injuries in the modern workplace is changing in a variety of ways. Improved workplace safety management efforts over the past 25 years have led to a decrease in the frequency of workers compensation claims. During this time, Travelers has seen an increase in the severity of those claims.1 Preventing even a single injury, or managing the injured worker’s return to work as soon as medically appropriate, can have a significant impact on the health of your workforce and on your company’s bottom line.

The Travelers Injury Impact Report, an analysis of workplace injuries based on Travelers Claim data collected between 2010-2015, identifies the most frequent injuries, those with the greatest severity and the top causes of workplace accidents, both by industry and by business size. This information can be helpful for employers to understand how to manage their exposures and tailor training programs for their workforce in their particular market and industry.

According to the Travelers Claim data, strains and sprains topped all lists for most frequent types of injuries, except for small businesses, which experienced cuts and punctures most frequently, followed by strains and sprains. Contusions, fractures and inflammation rounded out the list of the top five most frequent injuries.

Chart of Top 5 Most Frequent Injuries, by claim count

The report also explores the top five most frequent accident causes, with material handling topping the lists of most frequent causes of injury, followed by slips, trips and falls, struck by/striking against injuries, tool handling and cumulative trauma, according to claim count across all industries and all claims. “The injury type only tells part of the story,” explains Woody Dwyer, a Travelers Risk Control safety professional. “Identifying that root cause helps us determine the best strategies to help prevent future accidents and reduce their severity.”

As part of Travelers Workforce Advantage, Travelers Risk Control professionals can help businesses develop their strategies to attract, hire, onboard, train, support and engage their existing workforce. At its core, it focuses on the importance of elevating the company’s safety message, beginning with the recruiting process and continuing throughout the employee’s career at the company. The safety best practices, from safe lifting to getting adequate nightly sleep, can also offer health benefits beyond the workday for employees.

“A significant part of developing an effective risk management process involves understanding your unique workforce,” Dwyer said. This includes a shift in the state of health of the U.S. workforce, with more than half of workers experiencing at least one chronic health condition, such as heart disease, diabetes and arthritis. This can add cost and complexity to treating workplace injuries, which has led to rising medical costs for workers compensation claims.

If an employee does get injured, conducting an accident analysis can help discover the root cause of an accident, develop corrective action that can help prevent a similar accident in the future and continuously improve safety management practices.

Managing the employee’s injury so he or she returns to work as soon as medically appropriate can also help manage costs and improve employee morale. A Functional Capacity Evaluation (FCE) is one tool that can measure an employee’s current functional status and ability to meet the physical demands of a job, especially after a workplace injury.

In 2015, medical cost inflation topped the list of risk concerns for businesses, according to the Travelers Business Risk Index. Promoting the overall health and safety of your employees can help control costs while retaining an engaged workforce. Learn about how you can create a culture of safety and develop an injury management strategy at your business.

Injuries can happen at any time, anywhere, regardless of industry or business size. Knowing what those injuries are and their root causes can help companies develop workplace safety practices. To learn more about the most frequent workplace injuries, those with the greatest severity and the top causes of accidents by business size, industry and region, view The Travelers Injury Impact Report.

Source:
1 The 2014 National Council on Compensation Insurance (NCCI).
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