Pat Furr reviews the importance of following OSHA safety standards for fall protection, and the steps an employer can take to ensure a safe work environment by providing high quality training. In the recent article by Mark Stromme, published in ISHN and on this blog, he addresses several myths regarding compliance with OSHA Fall Protection in the construction industry. Fact is, this wisdom applies to industry across the board.

OSHA Fall Protection Standards for Industry

It does not take long for an employer to realize that understanding the OSHA 29 CFR 1926 Subpart M standard is no quick and easy task. Fully adhering to this standard requires employers to complete a number of assessments, including the following:

    •    Evaluating areas that workers are exposed to fall hazards
    •    Developing work practices that eliminate or reduce the exposure to those fall hazards
    •    Selecting and installing suitable fall protection equipment
    •    Training employees on proper use of the equipment
    •    Inspecting and maintaining the equipment
    •    Developing rescue plans
    •    Re-evaluating the entire program on a regular basis

There’s no doubt, this can be a very daunting task – especially with all the other safety responsibilities we must deal with on a daily basis. But, I wanted to demonstrate that there is much more to providing a safe work environment for employees than handing them a harness and an energy absorbing lanyard.

Fall Protection Competent Person Essentials

One of the most important steps an employer can take towards developing an effective comprehensive fall protection program is to provide top quality training to their selected fall protection competent persons. By selecting the right person(s) for this position, the employer is assigning a degree of authority and expectations that the competent person will be very well versed in all there is to know about fall protection.

A common question we get from our former Competent Person students has to do with proper use of fall protection equipment. This is a critical function of the Competent Person, to provide the authorized persons training on the proper use of the selected fall protection equipment. As good as the equipment has become with modern materials, increased strength requirements, and functionality, we still are seeing equipment failures when subjected to forces they were not designed to see. If the authorized user is using the equipment outside the manufacturers’ instructions for use, that means the training has fallen short. No pun intended.

Roco's Fall Protection protocol challenges employers and current competent persons to ratchet up their diligence in providing high quality training to the folks that are counting on them. Employers must seek out truly effective Competent Person training programs and avoid programs that are more interested in selling product than delivering the instruction that the students need. Once the employer is satisfied that the competent person has the appropriate level of knowledge and experience, they complete written documentation attesting to such as described in the following article.

Now the ball is in the Competent Person’s court. With support from the employer, it is of paramount importance that the competent person continues educating themselves on everything “Fall Protection.”  Divide time between the OSHA and ANSI standards, new product information, fall protection “Walkabouts” at your facility, to include rescue provisions, and continuous monitoring of the work practices of the authorized persons.

There is always the need for continued fall protection training at every level. Make sure your team is properly trained and equipped to avoid injuries, fatalities, penalties or both. Check out Roco courses for Fall Protection/Competent Person by clicking here.

As an employer with permit-required confined spaces, you’ll need to determine if your rescue team or selected rescue service can truly “walk-the-walk” when it comes to confined space rescue. OSHA’s Permit Required Confined Space Standard (1910.146) is “performance-based” – meaning it’s all about capabilities when the stakes are high.Conducting a performance evaluation of your rescue service is a vital component in determining their true capabilities as well as fully meeting the performance requirements of 1910.146.

The Dilemma

Determining the adequacy of the team’s rescue capability can present a dilemma for many employers. That is, does the employer have the depth of understanding in technical rescue required to administer an accurate, meaningful performance evaluation? Do they know what to look for in terms of proper equipment use, efficiency, compliance with industry standards, and required safety systems – just to name a few. If not, is it then possible that the team may not be able to affect rescue when the need arises?

As we know, it’s quite easy to demonstrate a rescue capability for a very “straight forward” situation. This is what we call a “Dog and Pony Show.” They tend to be very controlled and scripted to ensure that everything goes smoothly. Unfortunately, when there’s an actual emergency, it seems the victims never get a copy of the script. Unless the rescue team or service is prepared for the “other than straight forward” rescue, the operation has little chance of going smoothly. There are still way too many incidents involving injury or death to would-be rescuers that can be directly attributed to lack of proficiency in the type of rescue being attempted.

The Guidance

Fortunately, Appendix F (Non-Mandatory) of 1910.146 provides guidance for employers in choosing an appropriate rescue service. It contains criteria that may be used to evaluate the capabilities both of prospective and current rescue teams. For all rescue teams or services, the evaluation should consist of two components:

An initial evaluation, in which employers decide whether a potential rescue service or team is adequately trained and equipped to perform permit space rescues of the kind needed at the facility and whether such rescuers can respond in a timely manner.

A performance evaluation, in which employers measure the performance of the team or service during an actual or practice rescue.

Another way to break down these two evaluation components is something like this… 
(1) The initial evaluation is to determine if the rescue service can “talk-the-talk”; and, (2) the performance evaluation is to determine if the rescue service can “walk-the-walk.”

During the initial evaluation the employer should interview the prospective rescue service or team to determine response times, availability, a means to summons in the event of an emergency, reciprocal communications should the service/team become unavailable, whether they meet the requirements 1910.146 paragraph (k)(2), and whether they are willing to perform rescue at the employer’s workplace.

Additionally during the initial evaluation the employer should determine if the rescue service/team has the necessary equipment to perform rescues. This includes both technical rescue equipment and if a space may pose a significant atmospheric hazard which requires entry rescue, does the team/service have adequate supplies of SCBA [or SAR].

ROCO NOTE:  Another aspect often overlooked is HazMat capabilities… does the team have the proper training and PPE to protect themselves from the particular hazards they may face? Can they deal with de-con issues that may result from exposure? Or, as the employer, will you provide the appropriate PPE and decon?

Finally, the employer should evaluate if the rescue team/service has the technical knowledge for vertical rescues in excess of five feet, the knowledge of rope work or elevated rescue, if needed, and the necessary skills for medical evaluation and patient packaging. Other than the visual and/or physical review of the rescue equipment; and, if necessary, emergency breathing air, the initial evaluation of the team/service is primarily completed through interviews and a review of training documents. In other words, can the team or service “talk-the-talk”?

Therefore, it is simply not enough for an employer to rely on the initial evaluation. While it’s a good start in narrowing the field of prospective rescue team/services, it is incumbent on the employer to determine if the rescue service can indeed walk-the-walk.  And the only way to ensure that is to complete a performance evaluation during an actual or practice rescue from the actual or representative types of spaces that they may be summoned to.

The Third Party Advantage

Performance evaluations can be administered to a prospective rescue service, or as a periodic evaluation of current rescue services. As an option, an employer may choose to use a third party that has extensive experience in this type of rescue.

This is especially beneficial when employers may not have the in-house expertise necessary to administer an accurate evaluation, or for employers who are more comfortable with having a third party evaluation as a documented, independent, and unbiased record of the rescue service/team’s capabilities.

As an independent evaluator, Roco has conducted these team (TPE) and individual (IPE) performance evaluations for many years using specific grading criteria. It is a valuable tool for the employer to ensure and document that the selected rescue team/service (whether an outside service or in-plant team) has the required proficiencies for rescue at their facility. These TPE/IPEs also provide a degree of refresher training that will help bring the team/individual up to the level they need to be.

In rare instances, our recommendation may be that the team requires more than spot training in order to meet an acceptable level of proficiency. Another benefit of third party TPE/IPEs is that it may be an opportunity for the evaluator to recommend minor changes in equipment or techniques that would enhance the capability of the team. In fact, Section B of Appendix F states,

“As part of each practice session, the service should perform a critique of the practice rescue, or have another qualified party perform the critique, so that deficiencies in procedures, equipment, training, or number of personnel can be identified and corrected.”

Another area where third party evaluations are beneficial is when contractors will be providing their own rescue capability. Some host employers mistakenly believe that theyare relieved of all responsibility when the contractor’s employees are performing the entries. But 1910.146(c)(8) and (9) place reciprocal responsibilities on both employers to each other. This includes the host employer informing the contractor that permit space entry is allowed only through compliance with a permit space program meeting the requirements of 1910.146, and the contractor informing the host employer of the permit program it will be following.

Although this paragraph of the standard lacks specific direction, it certainly contemplates that the host employer cannot turn a “blind-eye” to deficiencies in the program presented by the contractor – including insufficient rescue capabilities. A team performance evaluation would be helpful in determining the contractor’s ability to provide rescue services for their employees. While some host employers may be qualified to evaluate contractor’s technical rescue capabilities, that is usually not the case.

Keeping Skills Fresh

Employers must also realize that technical rescue skills are very perishable. While a team or individual can successfully complete rescue training and attain a high degree of proficiency, regular practice is crucial to maintaining these skills. Unfortunately, all too often, the time and resources required to maintain this level of proficiency are not provided. How quickly these skills erode will vary. However, even with the most experienced rescuers, they will eventually lose their edge if practice time is not provided. For newer rescuers that complete their training but don’t the chance to practice fairly soon, their skills can erode at an incredibly fast rate.

The degree of difficulty for the anticipated rescues must also be considered. When more complex rescues are involved, teams may require even more training and practicetime to maintain their level of expertise. And, while a training certificate is good to have, the only way an employer can truly know if the rescue team/service meets the OSHA performance requirement for confined space rescue is by completing a properly administered performance evaluation.

For all those employers who have workers entering confined spaces to work, we hope that you will carefully consider this rescue evaluation process – it could save a life or even prevent multiple fatalities. For you rescuers out there, we hope that you will do everything you can to maintain and increase your proficiencies – so when the time comes, you can walk-the-walk with pride in a job well done.

If you would like additional information on a documented Team Performance Evaluation for your rescue service, please contact Roco at 800-647-7626.

Falls are the leading cause of worker fatalities. According to OSHA, each year more than 100 workers die and thousands are injured as a result of falls at construction sites. The fall protection standard, at 29 CFR 1926 Subpart M, details training and equipment requirements that employers must use to protect workers from falls.

This story is excerpted from an article by Mark Stromme, ISHN. He offers valuable suggestions for increasing safety for workers, and avoiding OSHA fines.

 

Employers need to:

    •    Select systems and equipment appropriate for the situation;
    •    Properly construct and install safety systems; and

    •    Train workers in the proper selection, use and maintenance of fall protection systems.

Train employees so they don’t fall for these five common myths and misconceptions about fall protection requirements in the construction industry. (Note: The citation amounts listed are related to the specific standard violated.)

Myth #1-“Residential construction has an exemption from the fall protection rules.”

This used to be true. However, in December 2010, OSHA rescinded the directive that allowed for that exception and as of September 15, 2011, all residential construction companies must comply with 1926.501(b)(13). The employer still has the option to develop and implement a fall protection plan that meets the requirements of paragraph (k) of 1926.502 if the employer can demonstrate that fall protection is infeasible or creates a greater hazard.

The new directive STD 03-00-002, Compliance Guidance for Residential Construction, rescinds STD 03-00-001, Interim Fall Protection Compliance Guidelines for Residential Construction, and provides that OSHA will be enforcing 1926.501(b)(13) for all residential construction work.

According to OSHA:

“Prior to the issuance of this new directive, STD 03-00-001 allowed employers engaged in certain residential construction activities to use specified alternative methods of fall protection (e.g., slide guards or safety monitor systems) rather than the conventional fall protection (guardrails, safety nets, or personal fall arrest systems) required by the residential construction fall protection standard (29 CFR 1926.501(b)(13)). Employers could use the alternative measures described in STD 03-00-001 without first proving that the use of conventional fall protection was infeasible or created a greater hazard and without a written fall protection plan. With the issuance of the new directive, all residential construction employers must comply with 29 CFR 1926.501(b)(13).”

When employees say there isn’t a need for fall protection during residential construction work, point out that OSHA says differently. As of September 15, 2011, OSHA compliance officers can enforce STD 03-00-002 for residential construction sites.

Myth #2-“I don’t need any fall protection; it’s only going to take me a couple minutes to install that equipment.”

Fall protection must be provided when employees are performing construction work on a walking/working surface with an unprotected side or edge that is six feet or more above a lower level. (Note: Construction work is “work for construction, alteration, and/or repair, including painting and decorating.”)
The length of time needed to perform that construction work has no bearing on the employer’s duty to provide fall protection. Be it one minute or one hour, OSHA requires fall protection per 1926.501(b)(1).

There is an exception: when employees are making an inspection, investigation or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed, no fall protection is needed.

The following is from an OSHA Letter of Interpretation dated March 2, 2010:

“OSHA has set this exception because employees engaged in inspecting, investigating and assessing workplace conditions before the actual work begins or after work has been completed are exposed to fall hazards for very short durations, if at all, since they most likely would be able to accomplish their work without going near the danger zone... [R]equiring the installation of fall protection systems under such circumstances would expose the employee who installs those systems to falling hazards for a longer time than the person performing an inspection or similar work.”

When employees say they don’t need any fall protection — because the task is going to take them only a few minutes — tell them that in 2010 this misunderstanding cost employers $1,344,612 in OSHA citations.

Myth #3-“Training programs for fall protection aren’t really needed.”

OSHA is clear about requiring training for each employee who might be exposed to fall hazards. For example, employees may be familiar with specific types of fall protection and have had proper training. However, if a different type of fall protection is to be used, employees using it must be trained by a competent person qualified in this area of expertise.
This training must include the following:

•     •    The nature of fall hazards in the work area;
•     •    The correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used;
•     •    The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be
•     •    The role of each employee in the safety monitoring system when this system is used;
•     •    The limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs;
•     •    The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection;
•     •    The role of employees in fall protection plans; and
•     •    The standards contained in Subpart M.

To prove this training was done, employers need to have a written certification of training that contains the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer.
If workers scoff and say they don’t need to be specifically trained in fall protection, tell them the OSHA regulations state otherwise. Failure to provide the required fall protection training in 1926.503(a)(1) resulted in $649,006 in OSHA citations in 2010.

Myth #4-“I’m doing roofing on a low-sloped roof so I don’t need any fall protection.”

OSHA requires (per 1926.5010(b)(10)) each employee engaged in roofing activities on low-sloped roofs, with unprotected sides and edges six feet or more above lower levels be protected from falling by:

    •    Guardrail systems,
    •    Safety net systems, or
    •    Personal fall arrest systems

Other options include a combination of:

    •    Warning line system and guardrail system,
    •    Warning line system and safety net system,
    •    Warning line system and personal fall arrest system, or
    •    Warning line system and safety monitoring system.

On roofs 50 feet or less in width, the use of a safety monitoring system alone (i.e., without the warning line system) is permitted.
There is an exception. When the employer is doing leading edge work, precast concrete erection work or residential construction work, and can demonstrate that it is infeasible or creates a greater hazard to use these systems, they must develop and implement a fall protection plan that meets the requirements of 1926.502(k).

Contrary to what workers may think, OSHA does require fall protection on low-sloped roofs. In 2010 they issued $909,442 in citations to enforce that requirement.

Myth #5-“A warning line is all I need for fall protection when working on a steep roof.”

According to 1926.501(b)(11), a warning line is not allowed as a form of fall protection when working on a steeply pitched roof. OSHA requires that each employee on a steep roof with unprotected sides and edges six feet or more above lower levels be protected from falling by guardrail systems with toeboards, safety net systems or personal fall arrest systems.

Training employees on these requirements would have saved employers $447,828 in citations in 2010.

Counteract these myths... Training employees to avoid these five fall protection myths and misconceptions can prevent injuries and fatalities and save your company money.

Petzl has published a statement addressing special use of the Petzl Shunt as a back-up device for industrial rope access.  For any users of the Petzl Shunt as a self-belay device such as tower rescuers, the same information applies.

For Roco Tower Work and Rescue students who were taught the use of the Shunt as a self-belay device and have not attended Roco’s Tower Work and Rescue refresher training in the past two years, please read this information.  For recent initial and refresher students of Roco’s Tower Work and Rescue class, students were taught to use the Petzl ASAP as their self-belay device.  Roco still encourages all prior Roco Tower students to review the Petzl statement to become familiar with their concerns regarding the use of the Shunt as a back-up device.

To request a NEW Roco Training & Equipment Catalog or our 2012 Course Schedule, call us at 800.647.7626.

Roco Director of Training/Chief Instructor, Dennis O’Connell reviews the importance of following OSHA safety standards for confined space entry, no matter how many times workers have entered the space. The take away? With confined spaces…It’s NEVER old hat! The importance of preplanning confined space entries and identifying “potential hazards ”should be old hat by now. Yet every year we are still killing entrants and rescuers in confined spaces.

In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

Atmospheric Hazards Continue to Claim Lives in Confined Space Entry Scenarios

The importance of preplanning confined space entries and identifying “potential hazards” should be old hat by now. Yet every year we are still killing entrants and rescuers inconfined spaces.  In the story below, we have one very lucky rescuer, but this very easily could have been a multi-fatality event.

It’s always important to remember that each entry stands alone. Each and every time a space is entered, we need to:

(a) identify potential hazards;

(b) eliminate or control them, when possible;

(c) use proper PPE; and,

(d) have an EFFECTIVE Rescue Plan.

Otherwise, as in this story, we will lose or injure workers as well as those attempting the rescue.

Start from scratch and treat each entry like it’s the first time you’re entering the space – it could save your life.

Keep in mind, the history of a space really has nothing to do with the current entry. We’ve all heard people say, “We do this all the time, and we’ve never had a problem!” Or, “We’ve entered this space a thousand times and the air is always good!” Remember this… IT DOES NOT MATTER!! This entry has nothing to do with the last.

As you read of yet another unfortunate incident, let it be a reminder to those of us who make entries or do rescues from confined spaces – do not let your guard down, do not get complacent…it could be deadly. Atmospheric hazards are still one of the leading ways that people are dying in confined spaces. Because humans are visually oriented by nature, if we can see a hazard, we’ll protect ourselves from it. However, if we can’t see it, we tend to assume it’s safe. OSHA’s 1910.146 PRCS standard and others were developed for a reason… people were making tragic mistakes and dying in confined spaces. These standards and guidelines are written so we don’t make the same mistakes.

OSHA FINES UTILITY FIRM $118,580 FOLLOWING WORKER’S DEATH

OSHA has cited a contracting and utilities company for two willful and two serious safety and health violations following the death of a worker at the company’s Texas facility. Proposed penalties total $118,580. An inspection was initiated by OSHA on June 28 in response to a report that employees working on a new sewer line were exposed to inhalation of a hazardous chemical. One employee who entered a manhole to remove a plug in order to flush out accumulated debris became overwhelmed by toxic fumes and died. Another employee was hospitalized after attempting to rescue his co-worker.

The willful violations are for failing to test for atmospheric conditions and provide adequate ventilation and emergency retrieval equipment prior to entry into a manhole.

The serious violations are failing to provide or require the use of respirators as well as conduct an assessment to determine the potential for a hazardous atmosphere where oxygen deficiency, methane, and/or hydrogen sulfide were present or likely to be present.

“The company failed to ensure that proper confined space entry procedures were followed,” said Jack Rector, OSHA’s area director in Fort Worth. “If it had followed OSHA’s safety standards, it is possible that this tragic incident could have been prevented.”