What are the high-level changes that ANSI Z359.14-2021 addresses?
 
On June 17, 2021, ANSI approved the new 2021 revision of Z359.14, Safety Requirements for Self-Retracting Devices (SRDs) for Personal Fall Arrest and Rescue Systems. This revision supersedes the 2014 version and goes into effect on August 1, 2023, which is an important date for ANSI compliance while using self-retracting devices.
 
In the previous 2014 revision of Z359.14, SRDs were organized by type (SRL, SRL-R for devices with rescue/retrieval functions, or SRL-LE for leading edge capability) and class (Class A or Class B). The intent was to organize SRDs by features in "Type" and then by their overhead performance capability by "Class." 
 
At a high level, the 2021 changes to the ANSI Z359.14 standard are designed to:

1. Simplify types and classes of SRDs so end users can quickly identify a compliant product's capabilities.
2. Increase factors of safety on multiple components and tests.
3. Introduce a new testing regime for personal SRDs or SRL-P's (those worn on the back, connected to the full body harness), including specific tests to address product issues that led to a manufacturer recall.
4. Further standardize labels and markings to make clear an ANSI compliant product's capabilities.

 
What will be the new ANSI Z359.14-2021 SRD types and classes?
 
Both types and classes were overhauled in 2021: "types" are SRL, SRL-P for personal devices meant to be installed on the user's full body harness, or SRL-R for devices with rescue/retrieval functions, and "classes" are Class 1 or Class 2. 
 
The SRD class is now applied to acceptable anchorage locations. Class 1 devices are suitable for at or above dorsal D-ring anchorage locations. Class 2 devices are suitable for above, at, or up to 5 feet below the dorsal D-ring anchorage locations AND must be leading edge rated. So, if your jobsite has edge exposures and you need a leading edge SRL or SRL-LE, you will be looking for a Class 2 device in compliance with ANSI/ASSP Z359.14-2021.

Mobile elevating work platforms (MEWPs) are indispensable tools when it comes to allowing workers to work safely at height. However, there are specific hazards associated with their operation that operators must be aware of. These hazards have been identified by the manufacturers, can be found in the operator's manual for each model, and are to be observed in conjunction with all other workplace safety rules and regulations.

One of the hazards that operators must always be on the alert for is windy conditions. Per ANSI1, outdoor-rated MEWPs must be designed to be stable in winds up to 28 mph if all other factors are taken into consideration, which I will discuss further in a moment. Any wind above 28 mph will place the machine, and the occupants, in serious jeopardy. 

One unfortunate example of that is described on the OSHA Scissor Lift Fact Sheet 2:

“Caution: Wind Can Make Extended Scissor Lifts Unstable. 
During the Fall 2010 college football season, a student who was also an employee of the University of Notre Dame was killed while filming the school’s football team practice from a scissor lift. Reportedly, the untrained worker raised the lift over 39 feet to film the practice. The wind gusts that day were more than 50 miles per hour. The high winds blew the lift over, killing the worker.”

Please note that this example from the OSHA Scissor Lift Fact Sheet stresses that the individual was untrained. One comment that I often hear from untrained operators is, “I thought it would be safe or it wouldn’t let me go up.” The fact is that MEWPs are only machines, and even with all the safety devices that are designed into them, they are only truly safe in the hands of well trained, well supervised operators.

Best Practices 

In the latest round of ANSI A92 design standards3, there are provisions for both outdoor rated and indoor-only rated machines. Indoor-only machines can only be used in areas that are not exposed to any wind whatsoever. This even includes warehouses or other structures with open bay doors.

All MEWPs that were manufactured to the previous standards are unaffected by that change. However, it is important to note that some manufacturers released indoor-only machines before the standards changed, so it’s important to be aware of the limitations on the MEWP being used. Indoor-only MEWPs must be clearly marked to that effect in a durable manner in an easily visible place.

Many new scissor lifts provide an option to switch between indoor and outdoor modes. Operators should never use a machine in indoor mode while working outside, or in areas where the air is moving (such as around large shop fans).

When using outdoor-rated MEWPs, in outdoor mode, the best rule of thumb is if you are not comfortable with the situation, don’t go up. If you are elevated and wind speeds do exceed 28 mph, immediately lower the MEWP and do not continue to operate the machine. There are tools that can be used to estimate wind speed, such as the Beaufort Wind Chart4, and if you are unsure, small handheld wind meters (anemometers) are available online for less than $30. 

There are other factors concerning wind that need to be taken into consideration as well. The combined weight of the occupants, materials, tools, and any options or accessories must never exceed the rated platform capacity of the MEWP. Care must be taken when handling building materials, sheet materials, panels and other such materials that can act as sails. No modifications or additions to the MEWP that affect its wind loading — and consequently its stability — should be made without the manufacturer’s approval. Certain manufacturer-approved options and accessories, such as panel cradles and material holders (when installed) can impose a reduced maximum wind speed rating. 

The shielding and funneling effects of certain structures can cause high wind speeds and turbulence on days when the wind speed in open areas is low, so caution should always be taken when working between buildings, in alleyways or other confined spaces. Other potential sources of local high wind speed that must be taken into considered in relation to safety at worksites are at airports and along roadways. 
 

1ANSI A92.20-2021.4.2.2.4.1.1
2 Working Safely with Scissor Lifts
3 ANSI A92.20-2021.6.4.7
4 Beaufort Wind Chart — Estimating Wind Speeds

This Safety Flash was contributed by Scott Owyen, Genie Director of Training in cooperation with SEAA’s Safety Committee. It is designed to keep members informed about ongoing safety issues and to provide suggestions for reducing risk. Best practices are gathered from a variety of sources. They may be more or less stringent than individual corporate policies and are not intended to be an official recommendation from SEAA. Always get approval and direction from your company officers on any new practice or procedure as these best practices may not work for all situations.   

Everyone benefits when a worker avoids injury. Submit your ideas for Safety Flash to admin@seaa.net.

Did you know that hand and arm injuries are the most frequent and preventable injury in the workplace, accounting for more than 23 percent of injuries, according to an article by Safety + Health magazine? 

On that same note, an article from Occupational Health & Safety magazine reported that more than one million workers are sent to the emergency room each year due to serious hand, arm, and finger injuries. 

Training, communication, and planning are often all that’s needed to reduce risk of pinch points on the job.  

On a recent reinforcing steel project, the task was to adjust a pier cap filled with #11 bar.  Shelby Erectors, a reinforcing steel and metal decking and member of SEAA, experienced a minor incident where an employee pinched his arm when the pier cap shifted.

Here is what we discovered when we reviewed the incident. 

The pinch point risk was identified and addressed in the daily pre-task meeting, however, the injured employee showed up late and did not go through the original pre-task meeting. The foreman allowed the worker to get right to work rather than reviewing the pre-task information with him individually.

Although the hurt employee was trying to do the right thing by jumping to work after being late, he was not fully aware of how the task was being approached to avoid risk. This resulted in the employee putting his arm in an area that was not fully protected.  

Training on identifying pinch points and proper planning to avoid the hazard are key to incident prevention.

What are potential pinch points? 
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These examples are just a few of the possible pinch points Shelby Erectors comes across in the course of typical work days.

1. Pinned between moving and stationary machine parts.
2. Pinned Between moving parts and materials being processed or manufactured.
3. Catching fingers, hands, toes, or feet under or between heavy crates or equipment while moving them.
4. Catching fingers in nipping tools like pliers, shears, etc.
5. Getting clothing or harness tangled in a pinch point.
6. Pinched between tools and a fixed object, pipe and fittings and a fixed object.
7. Crushed by an object. 

Best Practices to avoid pinch points:

1. Ensure all heavy equipment has proper guards.
2. Lockout/tagout heavy equipment before servicing.
3. Identify possible pinch points prior to starting a task.
4. Wear the proper PPE to protect your hands, eyes, and head. 
5. Lift, carry, and place equipment carefully.
6. Even the smallest tasks require your full attention.  
7. Ask yourself “what will happen if XXX moves? Will I be in the path of movement?”
8. Be on guard. Drowsiness, being distracted or in a hurry, leads to inattentive work habits and shortcuts.

And finally:

1. Train, identify, plan, and act on the plan. This mentality is critical in avoiding an accident involving pinch points. As we here at Shelby Erectors like to say, “Don’t be in such a hurry.” 

Resources: 
Occupational Health & Safety: Understanding Hand Injuries in the Workplace
Safety + Health: Hand Safety Programs
OSHA Cranes & Derricks in Construction 1926.1430(e)
Michigan Occupational Safety and Health Act, Fact Sheet on Pinch Points
Bureau of Labor Statistics, Employer-Reported Workplace Injuries and Illnesses Report 2020

This Safety Flash was contributed by Jason Zyla, Safety Manager, Shelby Erectors, in cooperation with SEAA’s Safety Committee. It is designed to keep members informed about ongoing safety issues and to provide suggestions for reducing risk. Best practices are gathered from a variety of sources. They may be more or less stringent than individual corporate policies and are not intended to be an official recommendation from SEAA. Always get approval and direction from your company officers on any new practice or procedure as these best practices may not work for all situations.   

Everyone benefits when a worker avoids injury. Submit your ideas for Safety Flash to admin@seaa.net. ​

Jobsite Info
It’s important to include jobsite information in your plan. This will consist of general information about the project; company name, the pre-identified competent person, jobsite address, and scope of work. Also make sure to include phone numbers for first responders in the event of an emergency.  

Make sure to identify the fall hazards on site. Do this prior to starting work and remember that no two jobs are the same. Evaluate all of the potential hazards on the project and ensure that you understand how the work is to be completed. Make note of where will employees be working, and the known fall hazards. Including, leading edge work, floor holes, connecting operations, ladders, and use of mobile elevating work platforms (MEWPs), such as boom lifts or scissor lifts.

Types of Equipment and Inspections
There are many options for a fall protection system. Determine the equipment and methods prior to beginning work.  When deciding the method of protection, you should use the hierarchy of controls. These controls (from most preferred to least) are as follows - Elimination, Passive Fall Protection, Fall Restraint, Fall Arrest, Administrative Controls.
​

• Restraint vs Arrest
• Horizontal Lifeline
• Anchor points
• Body harness and connector

Next, outline proper equipment assembly and installation requirements. Include inspection criteria as well as proper storage of equipment. Employees need to fully understand how the equipment works, the frequency of inspections that will be required, and what to do with equipment if they identify any damaged or defective equipment. Additionally, improper storage of equipment can cause premature damage or deterioration. Be sure to refer to manufacturer manuals and inspection criteria.

Falling Objects
The plan should also include best practices for protecting workers from falling objects. This can include controlled or limited access zones. If this route is taken, ensure the proper tape, signage and spotters are in position. 

Rescues
In the event of a fall, time is critical and having a rescue plan is essential to minimize any potential injury.  Ensure the workforce is aware of the plan and has been properly trained on the equipment and its location. 

In your fall protection plan, identifying a method of communication (via phone, radio, etc.) is key in the event of an emergency. Then, outline the rescue plan by type. Did the employee fall off of a ladder, MEWP, ascent or descent device, or scaffold? Make sure there is a rescue plan for each one. 

Founding father, inventor, and publisher Benjamin Franklin is credited with the saying: “If you fail to plan, you are planning to fail!”  In safety, if you do not have a plan then you can almost guarantee you will fail.  Every project is different and presents a unique set of challenges when setting up your Fall Protection Plan but following these steps should help make planning easier. 
​
Resources: 
OSHA Fall Protection Plan 
OSHA Fall Protection Page 
USACE Fall Protection Guide 
3M Fall Protection Rescue Plan

This Safety Flash was contributed by Dax Biederman, Senior Safety Consultant, Trivent Safety Consulting, in cooperation with SEAA’s Safety Committee. It is designed to keep members informed about ongoing safety issues and to provide suggestions for reducing risk. Best practices are gathered from a variety of sources. They may be more or less stringent than individual corporate policies and are not intended to be an official recommendation from SEAA. Always get approval and direction from your company officers on any new practice or procedure as these best practices may not work for all situations.    

Everyone benefits when a worker avoids injury. Submit your ideas for Safety Flash to admin@seaa.net ​

Dropped Object Prevention

​When it comes to steel erection, usually a simple fence on the ground isn’t enough protection. Dropped objects accounted for over 240 deaths in 2019, according to the Bureau of Labor Statistics. The goal is to prevent falling objects in the first place. The use of tool lanyards and catch nets are the best ways we can protect the public from dropped objects.
​
When guard rails are used, they must have sufficient toe boards at least 3½ inches in height from top edge to floor level, and no more than a ¼ inch gap at the bottom. It must be capable of withstanding a force of 50 pounds applied in any direction.  It’s always best practice to add mesh fencing from the top guard rail to the toe board for extra dropped object protection.

What It All Comes Down To

​The most effective way to keep the public safe starts with in depth planning, detailed pre-construction meetings, and keeping our employees’ training up to date. Employees need to have a clear understanding of the hierarchy and be made aware of the procedures, materials, tools, and equipment available to them to support their efforts in creating a safer job site for the public and other workers. Great safety cultures have foundations built from both directions, top down and bottom up all connecting in a common goal.  
​
Resources: 
​
Guidelines for Establishing the Components of a Site-specific Erection Plan
Protection of Pedestrians (ICC) Section 3306
Dropped Object Prevention ​

The Roman philosopher Seneca once said, “Luck is what happens when preparation meets opportunity.” When companies approach compliance preparedness with this thought process, they are overwhelmingly successful in their interactions with OSHA.
​
Here are three tips to not only survive but thrive when OSHA visits your site.

1. Define who is your competent person onsite for hazardous activities.
2. Provide formal and ongoing training for employees on hazardous activities.
3. Train employees on what to expect from OSHA visits and their rights under the law.

Get more details about implementing these three tips and additional details.

1.  Define who is your competent person onsite for hazardous activities. 
When an OSHA compliance safety and health officer arrives onsite for a scheduled visit, employee complaint or accident, they will want to know who the company’s competent person for those hazardous activities is. An OSHA "competent person" is defined as "one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them" [29 CFR 1926.32(f)]. 

The two key words to this definition are “capable” and “authorization.” 

Companies will be able to demonstrate capability by the training the employee has had and work history. 
​
Authorization is demonstrated by companies defining who these competent persons are during the preconstruction process.

2.  Provide formal and ongoing training for employees on hazardous activities.
OSHA will request employee training records for hazardous activities during an investigation. Companies will be well served to provide formal training for all employees prior to putting them to work. For Steel Erectors, the must have training prior to starting work will probably involve:

• Employee safety orientation 
• Fall Protection
• MEWPS (Aerial Lifts)
• GHS/Hazcom
• Silica
• Subpart R and Connector Hazard training for connectors

In addition to formal training, all employees should attend weekly toolbox talks on specific relevant safety topics. OSHA will recognize this training if sign in sheets with the topics are kept by the company.

3.  Train employees on what to expect from OSHA visits and their rights under the law. When employees know what to expect they will be less apt to make compounding mistakes when dealing with OSHA.  The rights of workers during an inspection are:
​​

• ​Have a representative of employees, such as the safety steward of a labor organization, go along on the inspection.
• Talk privately with the inspector; and
• Take part in meetings with the inspector before and after the inspection

A full list of workers’ rights published by OSHA can be found here. 
​
While this list doesn’t encompass everything a company needs to do to prepare for an OSHA visit, by being proactive on the front end of projects, companies will save time, money, and their reputation if OSHA ever does visit. 

Resources:
OSHA Worker Rights and Protections

Worker Rights Under the Occupational Safety and Health Act of 1970

OSHA Workers Rights Pamphlet

1960.26 - Conduct of inspections

This Safety Flash was contributed by Bryan McClure, Senior Safety Consultant, Trivent Safety Consulting, in cooperation with SEAA’s Safety Committee. It is designed to keep members informed about ongoing safety issues and to provide suggestions for reducing risk. Best practices are gathered from a variety of sources. They may be more or less stringent than individual corporate policies and are not intended to be an official recommendation from SEAA. Always get approval and direction from your company officers on any new practice or procedure as these best practices may not work for all situations.   

Everyone benefits when a worker avoids injury. Submit your ideas for Safety Flash   
to admin@seaa.net 

Forklifts (telehandlers or industrial trucks) are vital workhorses in the construction industry. Routine inspections and maintenance are required to ensure that forklifts are reliable and safe to operate. In the steel erection industry, forklifts are constantly moving heavy loads, which leads to wear and tear. It’s important that operators not become complacent when conducting routine inspections, which can lead to discovery of critical warning signs. Completing regular maintenance and correcting damage or deficiencies is essential to safety and prevention of operational hazards. ​