On January 5, 2010 the ASSE announced that it had completed a voluntary consensus standard dubbed “Work Zone Safety For Highway Construction.”  The ASSE has been in existence for almost 100 years, and has grown in size and stature to represent one of the most respected national safety organizations in the country.  The standard is set to be published by the American National Standards Institute (identifier A10.47-2009) and go into effect February 24, 2009.

Highway work provides many challenges to risk managers due to how exposed workers are to a wide variety of different hazards.  Most obvious is the presence of speeding cars, many of whose drivers pay little or no attention to signage warning them to slow down before entering a work zone.  This is compounded by the low visibility associated with certain outdoor work scenarios (night time, precipitation, fog) as well as the frequent use of heavy equipment which can itself seriously restrict the field of vision of both operators and workers on foot. Obviously, both day and night PPE supplies should be available.

A10.47-2009 has been designed to cover a wide range of different employment scenarios associated with highway work, and deal not just with typical construction activities such as paving, maintenance or repair, but also the often overlooked utilities activities that take place on public roadways.  Given that roughly twenty percent of all workplace fatalities in 2008 occurred on highways, and a third of those involved someone being struck by a vehicle, it is clear that highway work ranks as one of the most dangerous types of employment in the United States.

The fact that individual states often have their own policies in this area only adds to the confusion for foremen and risk managers attempting to satisfy conflicting legal requirements while still offering their workers the highest possible degree of injury protection.  The federal government’s involvement in roadwork safety balances the convenience of motorists (through the reduction of delays and the scheduling of major work to occur at night, for example) with the safety of workers, which is not always an equation that works out in favor of hazard mitigation.

Although the ASSE standard is voluntary in nature, its adoption across the country by private contractors may spur OSHA into taking longer look at whether highway work requires its own section of the federal regulatory code.

To be fair, the current standard dates back to the early 70s and there have been numerous advances in technology and industry practices since then.  Designed to take aim at the leading causes of crane and derrick related fatalities and injuries related to equipment malfunctions. Two studies were used to as a basis for aspects of the proposal “Crane-Related Fatalities in the Construction Industry,” by J.E. Beavers, et al, and “Crane-Related Deaths in the U.S. Construction Industry,” by A. Suruda, et al.  According to Suruda, the top 5 causes of fatalities from crane related incidents are electrocution, crane assembly or disassembly, boom buckling or collapse, crane overturn, and rigging failure.

Here are a few of the ways in which the Oct. 08 proposal would combat the major hazards outlined in both the Beavers and Suruda studies.

• Unless ground conditions are firm, drained, and sufficiently graded, equipment would be prohibited from being assembled or used.
• The “controlling entity,” normally either the employer owning the property or primary contractor would be responsible for prepping ground conditions before cranes could be assembled or used.
• Employees would be prohibited from standing under an equipment (crane, boom, etc) while pins are being removed unless employer could demonstrate a restraint that would prohibit equipment from falling on an employee.
• The proposal also covers electrocution hazards, overhead protective covers to be attached to guardrails; care to be taken, and the need for a signal person to relay signals of hazards.

It should be noted that these are just a few of the proposed in changes in the Oct. 08 final register for the cranes and derricks standard.  OSHA will still be taking into consideration the comments from these proposed changes and any new data that may impact the safety and health of workers.  At the time that the proposal was issued, the cost of complying with the changes represented less than 1% of revenues for each of the industries affected.

The agenda released pointed to a final rule date being issued around July of 2010.  If you use cranes and derricks, now is the time to review the Oct. 08 proposed standard and any new industry changes that have occurred since then.  The new standard is coming be ready.

References

Proposed Rule: Cranes and Derricks in Construction; http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=FEDERAL_REGISTER&p_id=21169;

Accessed November 7, 2009.

Several hazardous materials – specifically, how they are handled in the workplace and how to control employee exposure to them – will fall under more intense scrutiny.  Crystalline silica, which is essentially the dust produced by a wide variety of different industrial, manufacturing and construction operations will be subject to a new rulemaking that will change current exposure limits.  It will also institute additional regulations concerning worker protections from exposure to the dust.  OSHA hopes to make their intentions known with a Notice of Proposed Rulemaking to be issued in July, 2010.

Two other substances will also be dealt with in the spring and fall of that same year.  In March, the metal beryllium will be the focus of a peer review its health effects and overall risk with regards to permissible exposure limits and worker protections.  The dust or fumes emitted by this metal can in some cases result in an immune disease that eventually brings forth a host of unpleasant and debilitating symptoms that may take as long as 30 years post-exposure to develop.  Then, in October diacetyl will take its turn undergoing the same analysis.  A food additive most commonly found in butter-flavored microwave popcorn, there have been several concerns regarding its possible respiratory impact on workers when inhaled over a long period of time.  Specifically, OSHA will examine a disease called bronchiolitis obliterans linked to the chemical.

Combustible dust, which has grabbed headlines over the past few years due to several spectacular and fatal explosions at a number of facilities in the United States, is set to gain its own standard from the Administration.  The process is already well underway, and the goal is for OSHA to gather what regulations they currently have on the books related to combustible dust hazards and combine them with additional research and information in order to complete a general standard and prevent future tragedies.  Crane and derrick safety will also see similarly sweeping standards changes in the summer of 2010 when a new final rule is issued.  In an industry where almost 100 lives are lost each year in workplace accidents, OSHA is working quickly to update safety regulations which were first implemented in 1971 and rarely altered since.

The final component of the Fall 2009 agenda addresses infectious diseases which have an airborne vector, otherwise known as the H1N1 initiative.  OSHA is looking to expand the epidemic response guidelines that were heavily publicized in August and September of 2009 through a Request for Information that will focus on how healthcare workers can better protect themselves from not just influenza but all other types of illness which can be easily transmitted through the air.  The formal Request will take place in March of next year, and it is hoped that the effort will be able to head off an increasingly large number of reported sick workers on the front lines of American’s healthcare industry.

The ‘loudness’ or intensity of sound is measured using decibels (dBa), with a figure of around 45 dBa representing what most individuals would consider a quiet level of background noise.  On a worksite where heavy machinery or even hand tools are in frequent use, it is not inconceivable for noise levels to start at around 90 dBa.  Given that decibels are a logarithmic unit, this indicates far more than a doubling of ambient sound levels – it in fact represents a much, much louder environment.

To demonstrate just how quickly a decibel increase can result in hearing damage, it is helpful to look at the permissible exposure lengths to specific levels of sound provided by the Occupational Safety and Health Administration (OSHA).  Workers can tolerate a constant 90 dBa of noise for up to 8 hours before there is any danger of permanent hearing loss.  However, increase that value by merely 2 dBa and the safe exposure length drops to 6 hours.  At 95 dBa, the time before injury occurs is halved to four hours.

Just as continual exposure to high levels of noise can cause permanent injury to an employee’s ears, a brief transient spike of loud sound can be equally scarring.  Exposure to sounds as loud as 139 dBa for more than just .11 seconds can cause significant damage.  To put that volume of sound into perspective, 139 dBa is approximately the auditory equivalent of a jet taking off or a gunshot.  There are plenty of chemical and other transformative processes that can produce this level of audio energy.  Those working in construction can also be exposed to sudden noise spikes caused by blasting and other explosives use.

It is clear that a simple and inexpensive investment in hearing protection can go a long way towards protecting the health of workers across a broad range of industries.  Hearing protection is generally divided into over-ear and in-ear categories, with the former providing up to 29 dBa of noise reduction (Optime 105 Series Earmuff) and the latter coming very close to that level (26 dBa for Moldex ear plugs).  It is even possible to purchase custom-molded earplugs that can block up to 40 dBa of sound.

Of course, some jobs require hearing protection that doesn’t interfere with communications between workers.  Products like the Peltor Push Earmuffs feature the ability to momentarily disable sound attenuation to the point where a conversation is possible.  It is important that any type of hearing protection that can be easily defeated always be accompanied by training that indicates when it is appropriate to do so without increasing the risk of permanent hearing damage.

This is one of the reasons why the Occupational Safety and Health Administration (OSHA) publishes their yearly list of the 10 most often-cited safety violations from the past 12 months.  The list represents the sections of federal workplace safety code that have been the focus of the greatest number of citations on the part of OSHA inspectors.

Naturally, the specific violations listed by OSHA tend to gather around industries which are on average more dangerous towards worker health than others.  In the top five are scaffolding violations and fall protection violations (construction industry), citations for respiratory protection (chemical and mechanical industries), and lockout/tagout citations (heavy industry, mechanical industries).  However, sitting at number three on the list is hazard communication, a section of the standard which applies to every single workplace across the country.  The fact that over the past year there were 6,378 violations of the hazard communication sections of the safety code indicates that risk managers and employers are still not doing all that they can when it comes to training and preparing their workers for the dangers that are present on a job site.

Also alarming from OSHA’s perspective was the revelation that 81 percent of the citations stemmed from willful violations or violations of a serious nature.  This has lead the agency to draw the conclusion that many of the accidents that occur in workplaces across the country are completely preventable, and are often the result of companies attempting to save a few dollars by gambling with the health of their employees.

The full list of the top 10 OSHA standard violations is as follows:

1. Scaffolding, General – 9,093 violations
2. Fall Protection – 6,771 violations
3. Hazard Communication – 6,378 violations
4. Respiratory Protection – 3,803 violations
5. Lockout/Tagout – 3,321 violations
6. Electrical, Wiring – 3,079 violations
7. Ladders – 3,072 violations
8. Powered Industrial Trucks – 2,993 violations
9. Electrical, General – 2,556 violations
10. Machine Guarding – 2,364 violations

The list of the standards cited most often by OSHA break down along similar lines:

1. Scaffolding, general requirements, construction (29 CFR 1926.451)
2. Fall protection, construction (29 CFR 1926.501)
3. Hazard communication standard, general industry (29 CFR 1910.1200)
4. Respiratory protection, general industry (29 CFR 1910.134)
5. Control of hazardous energy (lockout/tagout), general industry
6. Ladders, construction (29 CFR 1926.1053)
7. Powered industrial trucks, general industry (29 CFR 1910.178)
8. Electrical, wiring methods, components and equipment, general industry (29 CFR 1910.305)
9. Electrical systems design, general requirements, general industry (29 CFR 1910.303)
10. Fall protection, training requirements (29 CFR 1926.503)

The most comprehensive type of fall protection available is known as a fall arrest system.  Designed to use a system of harnesses and ropes or cables to limit the distance which a worker can fall before they are caught and suspended, this type of fall protection requires careful training and proper maintenance to use.

A full harness, such as the Miller Revolution or the Miller Duraflex is meant to strap around the shoulders and the upper legs of an employee, in order to spread out the forces associated with sudden deceleration that are involved in falls.  This specific harness also helps to a fall victim to maintain greater control over their orientation while hanging from a support cable, which can simplify recovery efforts.  Some harnesses also provide a large back plate which further dissipates the shock of a fall, and can protect against impacts should the victim swing into a hard surface on the way down.  Tool belts and other attachments can usually be added to these harnesses in order to give them a practical edge.

Anchoring systems are an important complement to any fall protection harness and cable strategy.  While it is possible to anchor to a raw beam, this is not recommended as sharp edges can cut into a cable or rope while the anchoring point moves along with the worker during the performance of their task.  Instead, a beam anchor like that offered by Miller offers a secure attachment point that can slide along a beam without exposing a tether to any additional wear.  This type of anchor is strong yet lightweight, which makes it easy to carry while moving from one area of the job site to another.  For sites where a beam anchor cannot be safely attached to a building’s frame, cross-arm straps can be used as a less mobile but safer alternative to direct tethering.

Lifelines themselves should be regularly inspected in order to ensure that they have not begun to fray or display any other indications of weakness or damage.  Depending upon the environment in which they are used, a standard webbing lifeline from AOSafety SafeWaze or a galvanized steel Mightylite retractable lifeline are among the best options.  The Mightylite unit offers the further protection of an automatic brake that engages to gradually slow a worker’s descent during a fall, lessening any jerking at the end of the line that could result in musculoskeletal injury.  For areas where limited movement is acceptable, 6-foot shock absorbing webbed lanyards can provide OSHA-compliant fall protection without the added expense or complexity of a retractable lifeline.

• In every task, wet methods, such as wet cutting, wet grinding, manual spraying, and freezing are considered the most effective in each area.  The idea is that by wetting dust; it becomes too heavy to achieve the airborne state that can cause life threatening injuries.
• Vacuum Dust Collection systems or VDCs were next on the list.  Although the jury is still out on this method.  The guide described two conflicting studies on VDC systems.  Still for certain task, such as using a handheld saw OSHA gave tips on what to look for in the a good VDC kit.
• Ventilation Booths were also mentioned, but not as emphasized as the other methods. As OSHA acknowledged that you would need to play around with the different elements of your booth to achieve maximum protection.
• It is unanimous, that using a fan as a primary method for controlling dust is ineffective method.  Although, it can be used as a supplement to another more primary.

OSHA also noted that simpler things, such as employee repositioning or using a smaller grinder wheel can aid in controlling dust.  The guide goes further to stress the importance of distinguishing the difference between visible dusts versus the respiratory dust; stating that visible dust should not be a gauge of how well silica and respiratory dust is being controlled.

Although specific tasks such as using handsaws, jackhammers, and similar tools were detailed, OSHA detailed the various common construction duties or “housekeeping,” activities could easily stir up dust at a worksite.  Please note that this is not a complete list, but dust can become airborne due to things such as:

• Dry sweeping
• Dumping bags of raw material
• Emptying vacuums
• Using blowers or compressed air for cleaning
• Driving over debris

The guide focused on controlling silica exposure by reducing the dust in a construction worksite.  Yet, OSHA acknowledged the fact that some employees and some jobs will require the use of respirators.  Employers need to be providing either half-piece or full-faced NIOSH approved respirators that are properly fit for specific employees; or, disposable respirators that are designed with an N, R. or P 95 filter.  On worksites where respirators are required or used, a written respiratory protection program should be implemented.

For more information the guide is available for print at the OSHA website, www.OSHA.gov

References:

Controlling Silica Exposures in Construction; http://www.osha.gov/Publications/3362silica-exposures.pdf; Accessed September 23, 2009.

Risk managers have long known that one of the keys to keeping employees from becoming victims of a tragic highway construction accident is to ensure that they are as visible as possible.  There are a number of ways to go about meeting this crucial requirement.  Night construction, where sight lines are the most compromised, often uses enormous floodlights which are designed to provide near daylight conditions in the site itself.  In addition, many state construction sites employ marked police cruisers with a full light package in order to draw attention to the areas where workers are present.

However, these methods have their drawbacks.  For example, bright lights contrasted against the dark night can often create glare that can actually increase the chance of an accident.  Also, at the municipal level, police vehicles are often too valuable of a resource to expend on local road construction.  This means that risk managers must turn to alternate and complementary means of making their workers obvious to drivers.

The Occupational Safety and Health Administration (OSHA) has long considered the issue of highway construction worker safety, and has recently released a new letter of interpretation concerning the issue.  Specifically, OSHA has clarified their earlier position concerning the wearing of high visibility reflective vests.  While in the past official interpretations of OSHA regulations concerning this personal reflective gear restricted the requirement of its use to very specific situations outlined in the Federal Highway Administration’s Manual on Uniform Traffic Control Devices, the latest letter expands the scope considerably.

Whereas previously only those working as flaggers or who were exposed to vehicle traffic were called upon by regulations to wear reflective safety vests, OSHA now demands that any worker who is actually working construction on a job site with a right of way to a federal highway meet the same standards.  This blanket interpretation is back in line with OSHA’s original intent for the rule itself, and serves to provide a consistent level of visibility to all site workers.  Reflective vests such as those manufactured by Ergodyne, Glowear and Occulux, and which come in a variety of bright and eye-catching colors fully meet the new OSHA interpretation.

Construction risk managers are responsible for ensuring that those in their charge are provided with high visibility apparel.  Not only that, but they must also ensure that such clothing is both care for and worn properly.  For example, reflective apparel which has become dirtied through continual use is significantly less safe than that which is regularly washed and cleaned.  Likewise, workers must be shown how to go about their tasks without concealing the reflective portions of their clothing, as well as how to properly wear each item in order to maximize visibility.  Simple training and common sense can go a long way towards preventing unnecessary injury on a highway construction work site.

Colder temperatures can have an impact on employees in ways that may not be immediately obvious.  Limbs, muscles and nerves which have been dulled by the cold do not react nearly as quickly as they do at room temperature, and manual dexterity is also lower.  This can increase the chances of an accident involving power tools, electrical wiring or any other task that requires delicate and precise hand movements.  Exposure to the cold can also affect skin in a way that is not noticeable until it is too late to take steps to reverse the damage. Specialty cold-weather gloves are a must.

There are a number of different options that risk managers can employ to augment the personal protection equipment of their outdoor workers during the winter season.  Portable work tents are a good solution for individual workers performing maintenance tasks or inspection work in a specific area for an extended period of time.  Allegro manufactures several different work tents that are designed to protect employees from strong winds, snow and rain while on the job.  Using a flame retardant material framed by metal poles, these tents can be set up from the inside and also offer a blower duct tube.  Heaters for these tents are also available, which can greatly extend the period of time a worker can spend on task.

For jobs which require more mobility than a tent allows, such as a site walk-through or more rapid inspection process, risk managers should focus on providing their employees with thermal gear that complements and works with their personal protective equipment.  Liners that fit under hard hats without compromising their safety are particularly helpful, and can be purchased in designs that wrap around the full face, neck or just the top of the head.  Insulating gloves that can be worn inside of protective work gloves are another excellent option for dealing with the cold, as in general wearing different layers is a good strategy for keeping out the cold.

Even though it can be tempting to pile on as many different jackets, vests and other types of field gear as possible in an effort to stave off the winter chill, risk managers must be vigilant that workers are not impeding their mobility through the use of too many layers.  Not only can too many layers make for clumsy movement, but extra clothing can easily snag on scaffolding or other sharp and protruding surfaces, potentially leading to a fall or other type of injury.

The Occupational Safety and Health Administration (OSHA) maintains a Steel Erection Standard aimed at codifying the safety regulations surrounding the use of steel structures when constructing a number of different types of buildings and other structures, such as bridges.  Recently, some important changes have been made to several sections of the Standard in order to improve worker protections.  Specifically, the decision to no longer consider certain safety infractions as de minimis has had definite implications for construction industry risk managers.

Construction sites will now be required to improve their current fall protection with regards to steel erection in structures.  Section 1926.754(b)(3) of the Standard now specifies that a full panel floor or a net must be installed within two stories or 30 feet, depending upon which is achieved first.  The goal of such a regulation is to limit the distance over which a fall can take place, which in turn diminishes the level of injury that can occur.  An installed floor also provides a better platform for mounting any rescue attempts should a fall take place, or should any other workplace injuries that require outside intervention happen on-site.  OSHA also notes that the building of a floor or net provides protection for workers from falling objects, should construction activities be occurring over their heads – thus taking care of two regulatory issues at once.

The Standard has additionally been updated to provide greater protection against trips, which often lead to falls on construction sites.  Shear connectors, used to secure concrete to steel, must be installed so that they do not project out and pose a tripping hazard.  Not only can horizontal or vertical projecting studs catch feet while walking, but they can also cause serious injury if landed on while falling.  Projecting studs are only permissible if a floor or deck has been built so as to reduce falling distance.

None of these regulations can be considered new – however, the consequences of not following through with their implementation have been changed.  Prior to the issuance of the revised Standard, OSHA considered non-compliance to the above-mentioned safety regulations to be a minor infraction as long as personal protective equipment was worn at the worksite.  However, this is no longer the case, and as of September 30, 2009 the new regulations will go into effect on a wide range of structures.  OSHA instruction documentation provides an in-depth explanation of how the new Standard will be implemented.