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Tips to Survive an OSHA Inspection

4/14/2022

 
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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:
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  • ​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 

Forklift Boom Failure Emphasizes Importance of Inspections and Maintenance

2/11/2022

 
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. ​

Read More

Safety Onboarding of New Employees

12/10/2021

 
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In the past when new employees were hired, they often went straight to the job site and it was weeks before they received safety orientation. But establishing an onboarding procedure that introduces new hires to your company’s safety culture is a critical first step in reducing risk.

According to a 
2016 article by Safety + Health magazine and research from Toronto-based Institute for Work & Health, “Employees in their first month on the job have more than three times the risk for a lost-time injury than workers who have been at their job for more than a year.”



Read More

Ladder Safety Tips

10/18/2021

 
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No matter how low or high you are off the ground, a tumble from a ladder can have serious consequences. 
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The National Institute for Occupational Safety & Health (NIOSH) reports that more than 500,000 people in the United States are treated for ladder injuries every year. What’s more, about 300 fatalities occur each year from ladder-related injuries. Ladder safety is something that should be taken seriously.

OSHA Standard 1910.23(b)(9) states that the employer must ensure that ladders are inspected before initial use each work shift, and more frequently as necessary, to identify any visible defects that could cause employee injury. Not to be taken for granted, if ladders are used regularly by employees, it’s a good idea to include ladder safety in daily safety meetings. And even if your workers only use them occasionally, then at least an annual safety meeting on ladder safety is a must.

Best Practices
  • Never use one side of a disassembled step ladder as an extension ladder.
  • Always read the warning labels and follow the manufacturer recommendations for use.
  • Only use a ladder that is rated to support the weight of your body and your tools/equipment.
  • Use the right ladder for the job. Even if it is inconvenient to get it, use the correct type of ladder.
  • Never attempt to repair a ladder that does not pass inspection. Remove it from service.
  • Never stand on the top rung or step of the step ladder. This makes the ladder unstable.
  • Plan to raise awareness during National Ladder Safety month in March.​

True or False: An employer is not required to have a training program for each employee using ladders?

FALSE – Per OSHA 1926.1060(a), the employer shall provide a training program for each employee using ladders and stairways, as necessary. The program shall enable each employee to recognize hazards related to ladders and stairways, and shall train each employee in the procedures to be followed to minimize these hazards. 
​

Ladder safety training is often overlooked. Why? It’s simple. Anyone can climb a ladder. Right? Remember when you climb a ladder you are placing yourself at height. Height is a hazard and a hazard should be controlled or eliminated. 
​

References:
OSHA Standard 1910.23(b)(9)
American Ladder Institute 
National Ladder Safety Month
Ladders: From Research to Smart, Safe Practices

This Safety Flash was contributed by  Kevin Muldoon, Project Manager at Mazzella/FHS Engineered Lifelines & Fall Protection, 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  

Preventing and Treating Heat-related Illness

8/16/2021

 
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Millions of U.S. construction workers are exposed to extreme heat in their workplace, especially when working outdoors. Of those millions, thousands of workers get sick from heat exposure each year, and some cases are fatal. The General Duty Clause (Section 5[a][1] of the Occupational Safety and Health Act of 1970), requires employers to provide a place of employment that is “free from recognized hazards that are causing or are likely to cause death or serious physical harm to employees.” 

Heat-related illness can take on five forms.  

1) Heat rash is caused by clogged skin pores that hold in sweat. This prevents the body from cooling down and causing skin rash. 

2) Next are heat cramps, which are painful muscle spasms caused by dehydration. 

3) The third form is heat syncope, a condition causing an employee to become light-headed and sometimes faint. It is caused by dehydration resulting in decreased blood flow to the brain.  

4) Even more severe is heat exhaustion, which sets in when the body loses too much water creating an electrolyte imbalance. Signs include weakness, dizziness, nausea, headache, heavy sweating, and clammy skin.  

5) Finally, heatstroke is an extremely serious condition and can lead to brain damage or even death if not treated promptly and properly. Signs of a heatstroke include a rapid pulse, hot, dry skin, mental confusion, and temporary vision/hearing impairments. 

The first line of defense in all forms of heat related illness is to immediately get the employee out of the heat so they can cool down and hydrate. All employees should learn how to recognize a victim of heat-related illness. Evaluate the symptoms, then follow the recommended first aid actions. 
  • For Heat Cramps, move employee to a cool, shaded area. Encourage water or a sports drink. Gently stretch and massage cramped muscles and ice afterward. 
  • For Heat Syncope, move employee to a cool, shaded area. Lay the employee flat on back and elevate legs to restore central blood flow. Encourage water or sports drink (if able to swallow) and monitor symptoms.
  • For Heat Exhaustion, move employee to a cool, shaded area. Remove excessive layers of clothing. Encourage water or sports drink, but do not give anything to drink if employee vomits. Decrease employee’s body temperature with cool water or wet cloths/towel and monitor symptoms.
  • For Heatstroke, call 911 immediately. While waiting for EMS, move the employee to a cool, shaded place and remove any unnecessary clothing. If possible, submerge the employee in cool water, up to neck, to lower body temperature. Alternatively, apply ice packs at the neck, armpits, and groin, and cover with wet towels or spray with cool water. Fan employee to quickly evaporate dampness on the skin.

Hazardous heat exposure can be prevented by employers.  Supervisors should watch for warning signs of heat-related illness in their crews and should never push employees beyond their limits. Many companies offer first aid training to educate, prevent, and treat heat-related illnesses. Some preventative strategies include establishing a shaded break area, providing ice, water/sports drinks, and issuing protective clothing/cooling towels. Companies can also limit employee heat exposure through well planned work and rest schedules. Although most healthy employees will be able to acclimate to heat over a period of time, some staff may be heat intolerant.

Employees can take their own preventative measures to combat heat. Drinking plenty of fluids throughout the day and staying away from alcohol and caffeine is essential. Remember to eat lighter meals while working because the more calories you consume, the more body heat you produce. Wear protective lightweight clothing and use sunblock on exposed skin. Employees should know their limits and notify a supervisor immediately if having heat illness symptoms. Occupations requiring heat exposure do not have to be dangerous. If everyone works together to take preemptive measures and watch for warning signs, heat-related illnesses can be prevented.

Resources:

Nation Safety Council, 2016, Heat-related Illness

Occupational Safety and Health Administration, Heat​

American Red Cross Heat Wave Safety

Multiple Lift Rigging, what can you tree?

6/15/2021

 
OSHA’s Final Rule for Safety Standards for Steel Erection was published in 2001, and paragraph (e), Multiple Lift Rigging Procedure, outlines OSHA’s standard for lifting multiple pieces of steel at one time. 

Multiple Lift Rigging (Christmas-Treeing), is allowed only for steel erectors and should only be done when the outlined criteria are met. Recently, I have seen erection companies perform multiple lifts with items not approved under OSHA’s final rule. For example, bundles of decking, pallets of CMU blocks and portable toilets are not permitted for multiple lift rigging because it unnecessarily exposes employees to overhead loads.

Multiple lifts should only be performed if the following criteria are met: 
  1. A multiple lift rigging assembly is used;
  2. No more than five members are hoisted per lift;
  3. Only beams and similar structural members are lifted.
​
It is important to understand the Steel Erection Negotiated Rulemaking Advisory Committees (SENRAC) original argument captured in the Federal Register persuaded OSHA to allow steel erection employees to work under the load by using multiple lift rigging. This is because multiple lift rigging, when done properly, is a safe and effective method for decreasing the number of total crane swings and employee exposure on the steel while connecting. To be in compliance with OSHA, steel erectors may “tree” steel beams, bar joists, and girders. 
​

Other benefits of multiple lift rigging are:
  • A reduction in the time connectors must spend out on the iron because tandem loading allows them to complete their tasks more quickly.
  • Reduced stress on the crane operator because fewer mechanical operations are required.
  • Further, the practice reduces the total number of swings the crane makes in each project, thus reducing the risk of exposing the workers located in the vicinity of the crane or in the path of travel of the load.​

Best Practices:
​
  • The total load must not exceed the rated capacity of the hoisting equipment specified in the load charts or the rigging capacity specified in the rigging rating chart.
  • Bundles of decking are not permitted for multiple lift rigging. The best practice for lifting bundles of decking is one at a time. 
  • Only structural members may be lifted during a multiple lift.
  • A typical multiple lift member would be a wide flange beam section between 10 and 30 feet long, typically weighing less than 1,800 pounds.
  • All employees engaged in the multiple lift have been trained in these procedures in accordance with § 1926.761(c)(1).
  • No crane is permitted to be used for a multiple lift where such use is contrary to the manufacturer's specifications and limitations.
  • Members must be attached at their center of gravity and maintained reasonably level
  • Members must be rigged at least 7 ft apart
  • The members on the multiple lift rigging assembly shall be set from the bottom up.​
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Resources: 

OSHA’s Final Rule for Safety Standards for Steel Erection

OSHA’s Safety and Health Regulations for Construction Subpart R

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  
​

The No. 1 Rigging Mistake Taking Place on Construction Sites

2/16/2021

 
Pop Quiz: What’s the total sling capacity of two ½” EIPS/IWRC wire rope slings that are used in a double wrap choke at 45 degrees? The answer may surprise you.

Failure to properly account for sling tension is the most common rigging mistake I’ve seen construction professionals make over the years. Sling tension occurs when the slings are rigged at an angle; this directly affects capacity.

The same misunderstanding of sling angle on capacity often happens when basket hitches are rigged to a single attachment point, whether the sling is vertical or at an angle from the center gravity. Many riggers simply believe that the lifting capacity is doubled because of the assigned multiplier of 2.00.

Keep reading to find solutions to these scenarios and to learn about handy references every rigger
should have.

Read More

What You Need to Know About Crane Operator Evaluations

12/14/2020

 
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In April 2019, the final piece of the OSHA Cranes & Derricks Standard 29CFR 1926.1400 came into effect. This requires employers to conduct evaluations of crane operators to ensure that they are certified and qualified. If an employer is not conducting evaluations of their crane operators, they are not in compliance with OSHA.

Once the operator has been successfully evaluated for the necessary skills and knowledge for the size and configuration of the crane they plan to operate, they may operate similar equipment. In order to do so, it must be determined that it does not require considerably different skills, knowledge, or ability to recognize and avert risk.

Operators must demonstrate their skills and knowledge, which includes understanding of crane
configuration, counterweight setup, use of safety devices and operational aids, and other items.

The OSHA Crane & Derricks standard 29CFR 1926.1400 took almost 10 years to fully come into effect. Rigger & Signal persons had to be qualified by November 2010 and crane operators had to be certified by November 2017. The final piece, the requirement to evaluate operators, is now also in force.

Best Practices
  • 1926.1427(f) requires that employers conduct an evaluation of each crane operator to ensure he/she is qualified.
  • Items to be evaluated include: skills and knowledge of safety devices, operational aids and software; understanding the size and configuration of the crane to be operated, including lifting capacity, boom length, attachments and counterweight set-up. The evaluation must also cover the operator’s ability to perform the hoisting activities required to perform their tasks, and if applicable, blind lifts, personnel platforms and multi-crane lifts.
  • Evaluations must be conducted by someone who has the “knowledge, training, and experience necessary” to assess the operators.
  • The documented evaluation must be available at the worksite and include the name of the operator and evaluator, the date of the evaluation, make, model and configuration of the crane used in the evaluation.
  • To be in compliance with OSHA, all operators must be certified and evaluated.

Resources:
OSHA Enforcement Memo
Free Operator Evaluation Form
Operator Qualification final rule
https://www.osha.gov/laws-regs/regulations/standardnumber/1926/1926.1427

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 executivedirector@seaa.net

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Steel Erectors Association of America 
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Phone: (336) 294-8880
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