Hazard Prevention Strategies & Controls - The Safety & Numbers work safety blog

Know the Standards: OSHA Fall Protection Compliance

Most informed industry professionals are aware that OSHA has emphasized the importance of awareness and compliance to fall protection safety standards that are designed to reduce injury risk and fatalities from falls from heights. What may be less clear to business owners in both construction and general industry is OSHA’s dedication to proactively prosecute violations to the letter of the law. Several recent examples of OSHA’s commitment to fall protection injury prevention have shed light on risk areas for small business owners to be aware of.

OSHA Fall Protection Policy Enforcement

In February this year, OSHA drafted and delivered a warning to the communication tower industry of the increasing fatality rate in that industry, it’s relationship to fall protection, and how strictly OSHA will be enforcing fall protection standards as a result. Another example of OSHA’s firmness on fall protection is in their willingness to prosecute compliance gaps even when a business has taken significant precautions to protect employees. OSHA attempted to prosecute Ryder Transportation Services for an injury to a subcontractor at their site for a fall fatality through a roof skylight that was safely inaccessible to employees.

OSHA Fall Protection Standards

The most important point for concerned business owners in light of OSHA’s increased emphasis on fall protection compliance is their strictness and strategy for standard enforcement. OSHA may potentially cite your business not only for injuries resulting from a failure to provide fall protection, but also in cases where the business did not conduct an appropriate hazard assessment, even at seemingly low-risk heights of 4′. This result is effectively a double whammy effect for a single employee fall incident.

As a result, while it’s important to provide proper fall protection, it’s even more critical to conduct and document the proper precautionary procedures for any potential risk area, to save money and administrative battles in the case that a fall injury does occur. Here’s a brief summary of OSHA’s fall protection standards policy, with this in mind. Of course, anyone subject to OSHA violations should fully research the topic on their own with OSHA or a certified compliance consultant.

Construction Industry Fall Protection Compliance

Found in Section 1926.501, these can generally be summed up to require businesses to provide fall protection (guardrail systems, safety net systems, personal fall arrest systems) on walking or working surfaces with an ‘unprotected side or edge which is six feet or more above the lower‘.

General Industry Fall Protection Compliance

General industry standards are also stringent, with Section 1910.23 stated to include ‘every wall opening from which there is a drop of more than four feet‘, with that also applying to open-side floor or platforms. This requirement stipulates that risk areas be guarded by a standard railing or other means of fall protection.

And remember, the typical fall protection standards citations could be coupled with a citation for Section 1910.132 for failing to conduct a hazard assessment.

Fall Protect Your Business for Compliance

The application of these OSHA standards and enforcement policy strategies can thus be applied to a variety of settings, ranging from loading docks and flatbed truck beds to onsite or offsite machinery and equipment. Business owner/operators should be aware that even for fall hazards of 4′ or less, a hazard assessment must be conducted and fall protection compliance equipment provided.

Trucker® & IAS Custom Access Fall Protection Products

Of course, we at Innovative Access Solutions are well-prepared to help with your flatbed truck and loading dock fall protection, starting with safety engineered Trucker trailer access ladders and working platforms. In addition, IAS has a great deal of experience providing custom fall protection access equipment to machinery/equipment and multi-level walking or working surfaces at manufacturing facilities, dockyards, construction and mining sites, and public/retail settings.

To learn how IAS can design a fall protection access solution for your business, call our engineering team at (800) 388-6884 or submit our Contact form on IAScustom.com.

Fall Prevention Through Design: A Case Study from ASSE

Putting safety first applies not only in day to day operations, but also in the planning stages of new projects, investments and expansions. In 2012 ANSI/ASSE created a consensus standard to promote this mentality. Prevention Through Design as a concept in work safety began in the 1940’s and today has gained enough momentum and regulatory support to provide several models that prove its effectiveness. A recent article at ASSE.org charts the effectiveness of engineering safety controls in the design process while considering the defeatability of safety hazard risk.

The most effective controls include elimination, substitution and engineering solutions, each ideally suited to be planned in the design phase of new projects. Doing so will provide safety, productivity, and cost benefits. In fact, the cost of implementing fall prevention through design can be thousands of times less expensive than the same solution integrated post completion. Compromised solutions are often less effective, leaving hazard risks and associated costs.

Fall Prevention Design Case Study

The ASSE article provides a case study from a petrochemical organization building a new offshore platform. The company had experienced the challenges of implementing fall prevention after the design stage and instead chose to hire a fall protection consultant early on to assist the engineering design team. The combined expertise resulted in fall prevention safety measures that focused on productivity and risk abatement. The process consisted of the following steps.

Kickoff Meeting with Design team
Virtual Fall Hazard Risk Assessment
Design Team Workshops
Specification Binder for Hazard Abatements
Follow-Through During Construction Process

The benefits of foreseeing and engineering fall prevention through design are long term: safety advantages, productivity gains, and ultimately lower costs. The case study resulted in hazard risk controls addressing elevated platforms, floor openings, ladders, and stair guardrails, helping to prevent the need for PPE and optimize processes, equipment placement and usage. Indirect long term benefits included ‘less equipment purchases, less training and fewer elements to manage.’

Innovative Access Fall Prevention Design

Contacting a consultant while engineering an offshore platform was effective for the company from the ASSE case study. The consultant costs were compared favorably to erecting scaffolding, the cost of which would have been required to address just one of the safety risks post-completion. Innovative Access Solutions is available to contribute similarly during the design or redesign stages at your organization. IAS has worked with Fortune 500 companies as well as SMB businesses to design solutions that provide long term cost and productivity benefits and accomplish your safety goals. IAS designs ladders, platforms and fall prevention equipment and has provided solutions for a range of industries. For a brief review of our access solutions, visit us at IAScustom.com. Or call (800) 388-6884 to schedule an appointment with our team.

Shipyard Work Safety

Shipyard work safety programs for private sector businesses are generally under the jurisdiction of Federal OSHA regulations. The shipyard workplace environment presents a wide range of injury hazards including confined spaces, scaffolds and ladders, rigging, and equipment associated with painting, welding, and material handling. To help reduce the risks affiliated with these environments, Personal Protective Equipment is frequently recommended. OSHA has published a complete guide to Shipyard Industry Safety Standards with recommendations for small, medium, or large businesses.

Of particular interest to this blog are the shipyard safety standards provided for Scaffolds, Ladders, and Other Working Surfaces. In this post we will take a look at the training recommendations for work safety Hazard Identification, Assessment and Control, and also provide information about access products to meet OSHA requirements at shipyards.

Hazard Identification and Controls

We have discussed the importance of work hazard assessments on this blog. The published OSHA standards cover the basic policies of inspecting the workplace, evaluating the level of risk, and working with employees and management to identify and determine solutions to work hazards. In addition, OSHA provides valuable recommendations regarding how to manage risk associated with identified hazards in the short term while longer term solutions are being developed. Placing priority on hazard abatement timeframe is important, and interim solutions should be considered.

OSHA also emphasizes the importance of systematic processes, from checking injury logs in support of hazard identification, to using checklists during inspections and breaking down jobs into tasks to determine root causes of accidents or hazards. The Shipyard Standards document additionally provides a hierarchy of hazard prevention controls, starting with engineering and work practice improvements. These involve ‘physical changes to jobs’ and are the top level priority. When engineering controls are not feasible, or in support of engineering controls, administrative controls and personal protective equipment are to be considered next in the hazard prevention hierarchy.

Custom Shipyard Access Products from IAS

OSHA provides detailed requirements for scaffolds, ladders, deck openings and edges, and access to vessels, dry docks/marine railways, and cargo spaces. Innovative Access Solutions has provided shipyard work safety access products for each of these applications. A few of the OSHA-referenced access solutions include portable metal ladders, gangways, guardrails, platforms, access to lower levels, and ladders for accessing cargo areas or confined spaces. IAS is experienced, knowledgeable and available to help meet your shipyard access needs. Contact IAS at (800) 388-6884 to inquire about shipyard access products.

Fall Protection PPE Equipment

Personal Protective Equipment (PPE) covers a wide range of industries and safety objectives, from law enforcement to sports, industrial settings, contractors and even casual retail environments. The various functions of PPE are designed to protect hazards in support of work safety policies and controls. These can range from bodily injury, exposure to environmental threats, breathing mechanisms, and much more.

With OSHA having a renewed focus on Fall Protection and having imposed new rules for Fall Protection PPE, businesses in a range of industries are investing heavily in fall protection equipment. Consider the following review of Fall Protection PPE equipment and how it can help to reduce injuries at your workplace.

Personal Protective Equipment Options for Workplace Fall Protection Safety

Personal Protective Equipment is required by OSHA when positive fall protection such as guardrails, access platforms, gangways, catwalks, and stairways are unavailable.

When guardrails and other positive fall protection are not available to protect from falls, workers must use personal fall protection systems (such as harnesses, lanyards, lifelines). [29 CFR 1910.67, 29 CFR 1915.71, 29 CFR 1915.73, and 29 CFR 1915.77]

Harnesses & Lanyards

Harnesses and lanyards are considered personal protective equipment since each individual worker must be fitted with the equipment for fall protection safety, as opposed to an all encompassing solution. A lanyard is the rope or other length of connection between a single point anchor source and a safety harness, worn by an employee. Snap hooks, D-rings and caribiners are utilized to ensure a safe connection. Anchors must be secured and can be affixed to a variety of stable structures. The complete fall protection system must be able to adequately support the weight of the employee. Fall protection PPE systems are typically categorized as a fall restraint system, which prevents falls similar to a car seat belt, and a fall arrest system, which catches a falling worker prior to contact with the ground or other solid structure.

Fall Restraint Systems

The advantage of fall restraint systems is the prevention of the need to absorb the shock and otherwise prevent further injury in the event of a fall. Further, in cases where the environment requires rescue efforts in the case of a fall, a fall arrest system is preferred. Generally speaking, fall arrest systems are more safe and less expensive, while more limiting and often less efficient in a workplace.

Fall Arrest Systems

Fall arrest systems often require shock absorbing lanyards and must be carefully considered to avoid further injuring the employee when a fall occurs. These systems are often used in work environments such as roofing, construction, and shipyards. In these work environments, a fall is more permissible compared to a mining operation or manufacturing plant with heavy machinery.

Horizontal and Vertical Lifelines

Lifelines are a broad range of fall protection equipment that can be applied for horizontal applications such as roofs or ship decks, as well as vertical applications such as enclosed spaces or ladder systems. As opposed to a single point anchor, lifelines provide more freedom of movement as they are typically connected to a cable, pipe, or other continuous structure. Horizontal systems can be designed to provide ultimate movement flexibility via pass through systems, overhead connections, and other similarly unobtrusive mechanisms. Vertical lifelines can be track based or climb assist systems on ladders at heights, or pulley operated systems for confined spaces and similar applications. In each case, lifelines generally differ from harness and lanyard systems in so much that they are less mobile and more of a direct method for cases where fall protection risk is consistent and eminent.

Work Hazard Analysis

Identifying Workplace Hazards is an integral component of an effective work safety program. As a required element of OSHA VPP Program participation, following an organized hazard assessment process can be the backbone of a company’s safety policy. Identifying hazards provides the ability to mitigate risk and evaluate safety effectiveness.

The work hazard assessment process consists of five main components:

Identify Hazardous Condition
Hazards that can lead to injury or illness range from physical injury risk to chemicals, temperature, radiation, noise, and electrical. Employees need to be involved in hazard analysis from the beginning to assist with acceptance and recognition of benefit.
Determine Root Cause
Potential root causes can include lack of knowledge, lack of physical ability, improper training, or unidentified hazards. Managers should reassess hazards when new equipment is installed or new work processes developed.
Eliminate Hazards
Mitigate risks via controls based on level of injury risk, frequency of exposure, and potential harm. Evaluate the level of overall risk to prioritize controls and implement. Identify PPE (Personal Protective Equipment) such as gloves, safety glasses, etc.
Control Measures
Risk management efforts can include engineering controls to manage exposure, layout, and access; administrative controls to to manage employees, tasks, and training; and work practices for safety, hygiene, and work area cleanliness.
Evaluation of Effectiveness
Hazard assessment programs should be evealuated on injury prevention effectiveness. Evaluation tactics include routine inspections; documentation for injury reports and near misses; requesting, researching and responding to employee feedback.

Source: Marine Corp Community Services

Initiating a Work Hazard Analysis

When commencing hazard assessment, plan to document responsible team members, tasks, and step sequence for processes with injury risk. A Hazard Assessment checklist similar to this sample provided by the California Department of Industrial Relations may be helpful. Next, determine and document preventative measures, equipment, and Personal Protective Equipment, and train employees accordingly. Finally, consider residual risk – any risk that remains after controls have been implemented – for future evaluation and improvement.

Creating Safety Culture as a Brand

Safety culture compared to safety policy is similar to the difference between creating a brand and pitching a service. Putting in place a safety and health program can and will be effective, but motivational factors can seem like a burden to managers and employees.

Creating safety culture will align executive initiatives with employee investment and organizational commitment to create value across operational activities. As a result, effective safety culture not only reduces hazards, injuries, and related costs, it can also provide reputation advantages that improve employee recruiting, generate sales opportunities, and build morale-based quality and efficiency.

Core Elements of Safety Culture

Culture is a small word with a large connotation. Just how to implement culture is a concept that is a challenge to grasp when managing business objectives. The first step in implementing safety culture is to understand and build upon cultural principles.

Commit to Safety as a Value

Management staff as a rule is subject to shifting priorities and objectives. To build culture, safety should be considered as a value throughout the decision making process: considering new initiatives, managing day to day activities, reviewing performance, and everywhere in between. As employees hear safety consistently discussed as a value, they will understand it is not a shifting objective and more actively support initiatives.

Employee Involvement in Decision Making

Culture is the driving force for decision making in business, from leadership to management, operational employees, sales and support staff. Well known cultural values include quality, service, and efficiency. As values effect each member of an organization on a continual basis, each employee should be involved in planning cultural systems that affect them. By providing employees with objectives and focus areas, management will understand key factors and produce safety systems that employees support.

Cross-Departmental Investment

Values such as quality, service, and efficiency are often driven by incentives across the organization, from executives to managers and staff. Safety as a value can be rewarded in the same way. Safety culture should encourage communication across departments, reward performance at all levels, and include cross departmental activities.

To Support Culture, Create Systems

Once you begin to embrace safety as a culture, you will soon identify the need to create systems for consistency, management, and performance review. Effective systems will build trust and focus on correcting unsafe practices, generally improving the environment for safety discussions. Systems will also provide management with a process for hazard identification, injury prevention training, incident reporting, and continuing improvement.

The importance of safety to businesses of all sizes is proven to reduce work injuries and related costs, but implementing safety initiatives at optimal benefit is not always easy. Integrating safety as a cultural value will build motivation across the organization and encourage cooperative discussion. For more on safety culture, visit OSHA.gov.