OSHA’s Focus Four

I’m a safety professional. It’s what I do. When I drive around my neighborhood, I observe the practices of roofers who are working. Rarely—if ever—do I see them using proper fall protection. It is upsetting to me because hundreds of roofers fall to their deaths in the U.S. every year, and fall-related standards are consistently in OSHA’s most cited standards.

The Washington, D.C.-based Occupational Safety and Health Administration’s Focus Four are the four most common causes of death and serious injury in the construction industry. OSHA’s title, Focus Four, is basically a warning in and of itself: These are the four hazards to which OSHA officials pay the most attention. It is not surprising, then, that the Focus Four are always among OSHA’s most cited standards.

The Focus Four Are:

  • Falls
  • Struck by object
  • Electrocutions
  • Caught in/between

The Focus Four with statistics from construction in 2013 are:

  • 1) Falls: 302 out of 828 total construction deaths (36.5 percent)
  • 2) Struck by object: 84 deaths (10.1 percent)
  • 3) Electrocutions: 71 deaths (8.6 percent)
  • 4) Caught in/between: 21 deaths (2.5 percent)

Now do you see why these hazards are titled the Focus Four?

Falls from height are the primary cause of fatalities in the roofing industry. Between 2012-14, there were more than 1,300 roofer fatalities from falls. Year after year, falls are No. 1 on OSHA’s Focus Four. In addition, fall-related topics are heavily represented in the top 10 most-cited OSHA standards (see list below).

Struck-by incidents, while not as common as falls, can also cause death and serious injuries in the roofing trade. Employees throwing scrap material off a roof without a chute or in a controlled landing area combined with employees not wearing proper personal-protective equipment can lead to serious struck-by incidents.

Electricity also poses a safety risk for roofers. It can kill in three ways: falls, burns and electrocution. Working too closely to electrical lines, using aluminum ladders and working with metallic conductive gutters, as well as using conductive roofing and flashing materials, can lead to death from electrocution. In addition, a lack of ground-fault protections while using damaged, non-construction-rated electrical cords with missing ground plugs can lead to fatalities.

Caught-in/crushed-by incidents are less prevalent in the roofing industry. However, there have been occasions where employees are caught in ladders and killed. It happens.

The Focus Four are, of course, not the only hazards. Particularly in hot weather, heat syncope, heat exhaustion and heat stroke are all prevalent in the roofing industry.

Construction inspections account for 60 percent of OSHA’s total inspections. In 2009, preliminary data from the U.S. Bureau of Labor Statistics, Washington, suggest there were 816 fatal on-the-job injuries involving construction workers—more than in any other single industry sector and nearly one out of every five work-related deaths in the U.S. In the same year, private-industry construction workers had a fatal occupational injury rate nearly three times that of all workers in the U.S.: 9.7 per 100,000 full-time equivalent construction workers versus 3.3 per 100,000 for all workers. (Learn more from the Construction Focus Four: Outreach Training Packet.) Therefore, it seems to me it’s a good idea to follow OSHA’s fall-protection standards—as well as its other standards. It just might save lives.

THE 10 MOST FREQUENTLY CITED OSHA STANDARDS IN 2014

  • Fall Protection, Construction (29 CFR 1926.501)
  • Hazard Communication Standard, General Industry (29 CFR 1910.1200)
  • Scaffolding, General Requirements, Construction (29 CFR 1926.451)
  • Respiratory Protection, General Industry (29 CFR 1910.134)
  • Powered Industrial Trucks, General Industry (29 CFR 1910.178)
  • Control of Hazardous Energy(lockout/tagout), General Industry (29 CFR 1910.147)
  • Ladders, Construction (29 CFR 1926.1053)
  • Electrical, Wiring Methods, Components and Equipment, General Industry (29 CFR 1910.305)
  • Machinery and Machine Guarding, General Industry (29 CFR 1910.212)
  • Electrical Systems Design, General Requirements, General Industry (29 CFR 1910.303)

The Aftermath of Construction Accidents

According to a 2014 Washington, D.C.-based Bureau of Labor Statistics press release, the construction industry has the highest fatality rate of any industry in the U.S. In 2013, the construction industry saw a total of 796 fatal injuries with more than 100 more deaths than the next highest industry fatality rate in transportation and warehousing. Within the construction industry, general construction laborers are the most at risk for injury or death on the job.

These statistics are frightening, and the reality is that most construction accidents could have been prevented. Washington-based OSHA standards are in place to prevent most construction workplace accidents. Many of the primary causes of injury, including the fatal four—falls, struck by an object, electrocution, and caught-in/between—can be prevented if proper care is taken and OSHA standards are followed.

DEALING WITH A CONSTRUCTION-SITE INJURY

When someone is injured or killed at a construction site, the ramifications can extend to family members and last a lifetime. Work-related injuries can cause loss of income, chronic pain, extensive medical expenses, a decrease in quality of life and psychological suffering. Legal advice and workers’ compensation insurance can remedy the loss of income and medical expenses, but a worker can never get back his health and/or quality of life after a serious job-site injury.

Liability becomes an important legal issue after a construction-site injury and is generally determined by the following factors:

  • The responsibility of the general contractor to provide a safe work environment.
  • The responsibility of other subcontractors to act in a responsible and safe manner.
  • The responsibility of the worker to act in a responsible and safe manner.

Other parties that may be held liable in workplace injury claims include the employer, architects, engineers and equipment manufacturers. In some cases, fault lies with more than one party and navigating a construction injury claim without the aid of a knowledgeable attorney is nearly impossible.

A personal injury or workers’ compensation attorney working on a construction case generally does the majority of casework before a case is ever presented in court. The attorney must carefully investigate every detail of the accident independent of the insurance investigation and the injured worker’s employer investigation. The evidence presented in construction-accident cases often determines a worker’s or worker’s family’s ability to be made whole for medical expenses, lost income, legal fees and more.

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Causes of Workplace Accidents

In Safety Pioneer W.H. Heinrich’s Industrial Accident Prevention, A Scientific Approach, first published in 1931, Heinrich states 88 percent of all accidents are caused by unsafe acts. Unsafe conditions cause only about 10 percent of workplace accidents, and 2 percent are caused by “acts of God”. Although, there was no research behind these statements whatsoever, Heinrich essentially says accidents rarely just happen. They almost always have causes and can be prevented.

The two primary causes of accidents—unsafe conditions and unsafe acts—need to be understood to keep our employees and ourselves safe in the workplace.

Unsafe conditions are physical conditions of the workplace that render the workplace unsafe. These conditions may include unguarded leading edges, slippery walking/working surfaces, and precariously stacked material

The good news is it is relatively easy for employers to protect their workers from unsafe conditions. All it requires is knowledge of what causes the workplace to be unsafe and the willingness to address these issues. Regular inspections and training will prevent most, if not all, unsafe conditions.

Unsafe acts, put simply, are practices human beings perform that are hazardous. Some of the most common unsafe acts include rushing, taking shortcuts, horseplay, and drinking or drug abuse. Other unsafe acts include disabling safety devices and not using or improperly using personal protective equipment. Safety education and training and enforcement are the most effective ways to keep employees from committing unsafe acts.

Although unsafe conditions and acts are the immediate causes of accidents and incidents, it is important to remember every accident may have started long before the immediate causes. In other words, every accident is the culmination of a series or chain of events that may have begun several months before the job even started, even at the bidding process. If the chain is broken, the incident or accident could be avoided.

For example, consider an incident that recently happened to me at home. I am a diabetic. Because I am a diabetic, I drink a great deal of water. Most nights I sleep with a glass of water on my bedside table. One night, I placed the glass on the corner of the table, close to the edge. My wife said, in her sweet voice, “That glass is too close to the edge of the table.” Me being me—tired and having been married almost 30 years—heard, “Blah, blah, blah.” During the night, I woke up to use the bathroom. As I was climbing back into bed, I knocked the glass over and spilled water all over the bed. My wife woke up angry. I got angry. We needed to change the bed sheets, so by the time I got back to sleep, it was 3:30 a.m., almost time to get up for the day. My alarm goes off at 4:30. I drove to work feeling like a plane on autopilot. Walking up the stairs to the office I missed the top step and smashed my knee. All day long, I was walking around the site wincing in pain. My accident started the night before when I didn’t listen to my wife. If you think about it, if I took better care of myself, I would have not come down with diabetes. And then I wouldn’t need to drink so much water.

Think about any accident or incident you may have had in your life or career. Think about when that incident began. What was the situation? Were there any unsafe conditions? Were you or anyone else involved in any unsafe acts? What was your frame of mind? Think about each accident as a chain. What links in that chain could you have broken to prevent that accident?

The Hidden Costs of Workplace Accidents

Asking an employee why he or she wants to be safe is like asking them why they work. Overwhelmingly, every roofer I ask this question to tells me he or she wants to go home at the end of the day. He doesn’t want to lose any time because losing time is losing money. And, believe it or not, money can buy happiness. A New York City carpenter once told me he fell 35 feet and broke multiple bones. He was out of work for two years, during which he collected $57,000 from workers’ compensation insurance. If he worked, he would have made more than $100,000 per year. In his words, “I almost lost my big house on Long Island and my high-maintenance wife.”

In addition to how accidents impact workers’ finances, they can seriously affect a company’s bottom line. A good Health and Safety Program can save a company money by cutting workers’ compensation insurance premiums; heading off needless, expensive and embarrassing OSHA citations; avoiding expensive and embarrassing lawsuits; increasing the efficiency of the workforce; and boosting workers’ morale, which consequently will improve their productivity. A good Health and Safety Program also will give a business owner peace of mind by knowing all his or her employees are working safely.

In my experience, project managers, job-site superintendents and crew foremen are the people who are reluctant to want job-site safety. They believe following safety standards slows the job down. Management is responsible for making money in a business that regularly grapples with close bids, tight schedules and limited job budgets. However, these factors do not take into account the “hidden” costs of workplace accidents. Oftentimes, accidents are more expensive than people realize because of these hidden costs.

Examples of Hidden Costs

Some costs created by accidents are obvious; for example, workers’ compensation claims cover medical costs and indemnity payments for an injured or ill worker. What people often don’t think about are the hidden costs, like the costs to train and compensate a replacement worker, repair damaged property, investigate the accident and implement corrective action, as well as maintain insurance coverage. Even less apparent are the costs related to schedule delays, added administrative time, lower morale, increased absenteeism and poorer customer relations.

Washington, D.C.-based OSHA’s Safety Pays Program states the lower the direct costs of an accident, the higher the ratio of indirect to direct costs. The more accidents that occur in a workplace, the higher the costs in increased insurance premiums and greater indirect costs. According to the Boca Raton, Fla.-based National Council on Compensation Insurance Inc., these include the following kinds of indirect costs:

  • Any wages paid to injured workers for absences not covered by workers’ compensation.
  • The wage costs related to time lost through work stoppage associated with the worker injury.
  • The overtime costs necessitated by the injury.
  • Administrative time spent by supervisors, safety personnel and clerical workers after an injury.
  • Training costs for a replacement worker.
  • Lost productivity related to work rescheduling, new employee learning curves and accommodation of injured employees.
  • Clean-up, repair, and replacement costs of damaged material, machinery and property.

Some of the possible indirect costs not included in these estimates are:

  • The costs of OSHA fines and any associated legal action.
  • Third-party liability and legal costs.
  • Worker pain and suffering.
  • Loss of good will from bad publicity.

The Human Factor

Direct and indirect costs certainly are motivation for preventing workplace accidents. In fact, when I ask roofing company owners why they want their employees to work safely, many automatically default to the money answer. However, in most cases, business owners are generous, caring members of their communities. I once sat across the desk of an owner of a large construction company after his team experienced a fatality. He asked me, “How do I look at myself in the mirror every morning, knowing one on MY guys didn’t go home today?” Even though he did not know this employee personally, he considered this worker one of his guys. Ultimately, it’s the human factor that is the most important reason to ensure safe working conditions on job sites.

My favorite phrase is “To protect my employer, I protect his employees.” I think they’re words to live by.

Software Improves Safety and Makes the Roofing Process Transparent for Clients

Safety is always a major concern and, at Castro Roofing, Dallas, it’s one of our core values. In fact, we have a full-time safety manager and a third-party safety consultant who evaluate every one of our jobs from a safety perspective. On top of that, we also have monthly safety meetings with the whole crew where we discuss best practices and train on new equipment. Safety should be a top priority for everyone in our line of work. I’m sure most contractors are pretty familiar with this routine.

So is there anything new to say about safety? Well, we’ve found a secret weapon! This past year we implemented an Online Project Management (OPM) software system. It has been a game changer for us.

How the OPM Works

The OPM streamlines communication with our clients and workers by archiving photos and information for every single project we have—every day. It notifies the client, via email, five days before the start of his or her job to ensure the client is prepared. We can personalize this email if we choose.

Once the job begins, each client receives daily reports, which include 12 to 16 photos from the job site covering the entire workday. Of course, someone on your team has to take the photos, but the software is linked to your smartphone and an app makes the process pretty simple. Through the OPM, everyone involved is made aware of the entire construction process.

The truth is, our clients really only have three questions for us:

    1. When are you starting my project?
    2. What have you done so far?
    3. When will you be finished with the work?

Ok, maybe there’s one more:

    4. How much is this going to cost me?

None of these questions take into consideration the personnel involved. Maybe this is a no-brainer, but if we are losing workers because of safety issues, our customers’ jobs are not going to be completed on time. Implementing this OPM addresses all those client questions and so much more.

OPM and Safety

The OPM allows quick response times by allowing us to fix anything we see that might become a hazardous issue before the next workday. Increased communication is literally available at the click of a button. Plus, the OPM makes it possible to go back and review any day of a project for different factors, like weather, safety and material delivery—not just work progress.

For example, while looking through the photos of a job’s progress as it was getting started, we noticed that if we unloaded and set up the scaffolding in a slightly different way, the unloading would be much smoother. We are constantly adjusting our approach to each job.

A New Outlook

While the OPM has made our work available in a much more transparent way—allowing our clients an all-access pass—it has also given us a new way to evaluate the ways we are utilizing our resources and our human capital.

When we know that others are able to keep such close tabs on the work we do, it changes the way we run our business. Our communication with clients should be as open and honest as possible. And the work that we do should be safe for everyone involved.

It’s pretty easy to pay lip service to safety in a monthly meeting and check it off the agenda. It’s altogether different when we are able to evaluate our daily routines from a different perspective. Our clients love it because our process no longer feels like a mystery to them. We love it because we can take our attention to detail to a whole new level—a bird’s eye view, if you will.

Before the OPM, it was nearly impossible to include our clients in our workflow. It was even harder to quickly evaluate and make changes that make work safer and more efficient for our employees. Now, we really can’t remember how we got along without it. Isn’t technology amazing? The OPM has genuinely helped us work smarter, not harder.

Online Project Management Software

Castro Roofing, Dallas, uses LookOut Software.

Our Company Culture: Safety Is Priceless All Year Long

Safety is Tualatin, Ore.-based Columbia Roofing & Sheet Metal’s No. 1 core value and a year-round commitment that streams through our entire operation. Just one very small diversion from the rules can cost someone his or her home, business or life. I sleep easy knowing everyone is home safely at the end of the workday.

Employees in the field perform a “Stretch and Flex” activity every morning, led by the foreman, to help prevent injuries.

Employees in the field perform a “Stretch and Flex” activity every morning, led by the foreman, to help prevent injuries. PHOTO: Columbia Roofing & Sheet Metal

There are key processes we follow at Columbia Roofing & Sheet Metal to ensure job safety:

Every two weeks our employees train with a paid outside safety training consultant, Integrity Safety of Vancouver, Wash. OSHA comes to our facility and our job sites if we have any questions. We keep up on the safety regulations and strive for perfection through staff member Pete Perrin and our safety consultant. In addition to all the safety rules that state and federal OSHA requires, we go beyond in many areas that just make sense, such as tagging all safety equipment, including ladders,
fall-protection equipment, first-aid kits and fire extinguishers, each quarter. Our employees, in the field and in the office, are held to a very high level of responsibility.

Each quarter we have a mandatory “stand down”, much like a military operation. This is when everyone stops all activities and inspects all job-site gear. We examine electrical tools, cords and equipment for proper function and wear and tear. Gear is tagged according to the color of the season as required by OSHA. Additionally, all ladders are inspected and tagged for acceptance. We exchange all our personal fall-protection equipment with each other and have it inspected in accordance with OSHA requirements. It is then tagged with the proper-color tape and worn; damaged equipment is replaced.

In addition, Columbia Roofing & Sheet Metal holds a mandatory “Save A Back” training every two years. Everyone, including me, attends a half-day of training on a Saturday. Save A Back is a program that began in New Zealand more than 30 years ago. It explains how to properly lift and focuses on workplace movement design, not just lifting with your legs. This makes it very different from many techniques taught in the U.S. Our employees in the field also conduct a “Stretch and Flex” activity every morning, led by the foreman, to help prevent injuries. Our foremen have been trained via Save A Back, and all the activities we engage in with our employees are moves taught by Save A Back.

All these efforts not only have helped us at work, but also benefit us in our daily lives.

In fact, our employees are encouraged to take safe practices home with them. We encourage personal-protective equipment and processes even when off the clock doing household chores. It is easy to skip following work-safety practices when off the clock, but we explain that everything we teach is for our employees and their friends to take home; it is the Columbia way!

I believe these rigorous safety standards have helped our company achieve a great insurance program and better customers who require low insurance modification rates (mod rates) on workers’ compensation. It also shows our customers we are serious about their safety, as well as ours. We have had two OSHA fines in 18 years in the roofing business. I believe this shows we are “walking the talk”!

We have found being safety conscious is also profitable. You are never “money ahead” making sacrifices related to safety. We spend less time processing claims, talking with lawyers and families, doing light-duty work, dealing with OSHA and losing customers over safety issues. The value of sending home employees and customers to their families in a healthy way—every day—is priceless.

How Is Your Fall-protection Plan?

Citing “record numbers” of unsafe roofing complaints in the Denver area during the first half of 2014, OSHA began its own outreach efforts and partnered with organizations, like the Colorado Roofing Association (CRA) and the Better Business Bureau (BBB), to make fall protection a priority among roofers and encourage consumers to hire roofing companies who do.

“In the past six months, we have received 63 complaints related to unsafe work practices, and this is the beginning of roofing season,” said David Nelson, OSHA’s area director in Englewood, Colo.

This emphasis contains two messages: the first to get consumers to hire contractors with a safety plan and good record; the second to prompt roofers to develop and follow safe work practices.

FOR CONSUMERS

Among its efforts, OSHA emphasized that home and business owners should use the OSHA website, CRA and BBB to hire reputable roofing companies with a safe work record without safety violations. OSHA advises consumers ask probing questions of roofing contractor’s safety plans, such as:

    ▪▪ Are the installers your employees or subcontractors?
    ▪▪ Are they insured?
    ▪▪ What is their past work history?
    ▪▪ How will the project be managed?
    ▪▪ What kind of fall protection will be used?

FOR ROOFING CONTRACTORS

For roofing contracting companies, OSHA hosted a 2014 National Safety Stand-Down week on June 2-6 that encouraged employers to stop work for one week to discuss fall hazards and safety measures.

At the end of June, the same OSHA Region 8 (Colorado, Montana, North Dakota and South Dakota) announced it was going to spend extra energy enforcing safety in roofing following increased construction after a hailstorm.

“Falls from roofs, ladders and scaffolds can be prevented by planning ahead, providing the right equipment for the job and by training everyone working on a project to use the equipment safely,” said Jeff Funke, OSHA’s area director in Billings, Mont.

These efforts demonstrate that roofing companies need to be prepared and committed to an effective fall-protection safety plan and be able to answer questions about it to prevent injuries and protect the company if an accident happens, as well as help win jobs if customers ask about the safety plan.

REVIEW YOUR FALL-PROTECTION PLAN

Considering the reasons for adhering to a comprehensive plan, take a moment and review your fall-protection procedures. This should be done annually, anyway.

Ideally, all potential hazards that could be encountered are eliminated or addressed through proper protection, work practices and training. Often, expertise, past experience or industry standards will point out these potential work hazards that need to be rectified.

According to information provided by OSHA’s outreach, a comprehensive fall-protection plan should include at least preventing falls from roofs, ladders and scaffolding. OSHA stresses the need to plan for safety, provide the correct equipment and ensure everyone is trained in safe work practices. Consider the following:

FALLS FROM ROOFS
Employees need to know when to wear a harness and how to ensure it fits. The proper guardrails and lifelines need to be implemented and used. Employees need to inspect all fall-protection equipment before using it and be able to determine when it is no longer safe. Holes, open stairwells, openings and skylights must be securely covered or guarded.

FALLS FROM LADDERS
Employees must know how to select the correct ladder and the proper way to safely use all ladders. Regardless of the type of ladder, users must maintain three points of contact; always face the ladder; and, without overreaching, secure the ladder on level footing; as well as never stand on the top step.

Extension ladders are not self-supporting and, therefore, need a stable structure and foundation to withstand the load. In addition, the area around the bottom and top of the ladder must have sufficient unobstructed space.

Plan to have an extension ladder that can hold at least four times the weight you intend to put on it. That includes any people and equipment and materials.

Also have a “competent person” visually inspect the ladder and secure the top of the ladder to a solid support. (A competent person is a technical term for someone who has the training and experience to know how to act safely and the authority to make a decision.)

Other safe work practices that should be followed include:

    ▪▪ Check the location of power lines before placing the ladder.
    ▪▪ Stay near the middle of the rungs while going up or down.
    ▪▪ Use barriers while on the ladder to keep traffic away, especially near doors and entryways.
    ▪▪ Only use the ladder for the purpose it was designed.

FALLS FROM SCAFFOLDS
Basic scaffold safety incorporates using fully planked scaffolds and ensuring they are sturdy, plumb and level with all guardrails completed and with stable footing. The scaffold must be used properly and accessed through a properly provided route; users should not climb on cross braces or stand on guardrails. Ladders also can’t be used on top of a scaffold.

A competent person—someone with the experience to recognize hazards and the authority to fix them—must inspect the scaffold before use.

STAY AHEAD OF OSHA

OSHA’s outreach is another example of it using incidents and complaints to focus attention on an industry. But it’s not just roofing contractors who are receiving increased attention.

In February, OSHA contacted communication-tower employers to remind them of their responsibility to train and monitor employee fall protection following 13 deaths in 2013 and four in the first weeks of 2014—a total higher than in the previous two years combined.

Ultimately, OSHA has reason to focus on particular industries, so it’s imperative you ensure your fall-protection program is effective.

OSHA’s Fall Protection Clarifications for Roofers

OSHA’s fall-protection regulations are easy to find (see OSHA 29 CFR, Subpart M, 1926.500 – 1926.503 and four appendixes). Understanding them is a bit more difficult because they apply to a variety of occupations, including roofing.

The following clarifications are OSHA’s responses to questions regarding fall-protection requirements and work practices affect roofers:

ROOF OPENINGS

The “Holes” section of the regulation requires the use of fall protection— personal fall-arrest systems (PFAS), guardrails, safety nets, covers, etc.—when there is a hole in a work/walking surface. Because a roof is a work/walking surface, employees must be protected from falling through. OSHA concluded that immediately securing a cover over a cut hole is sufficient because the cover eliminates the fall hazard requiring fall protection. The rest of the environment may still require fall protection.

SUPPLYING MATERIAL TO THE ROOF

A supplier who delivers roofing material onto a roof must use all available fall protection, meaning a sufficient ladder or other means with a sturdy handhold. A supplier also must wear personal fall-protection equipment and connect to existing anchorage points when receiving and delivering materials on a roof.

If anchorage points do not exist for workers at the site, suppliers are not required to install anchorage points because they spend so little time at the job site. Anchorage points are the primary contractor’s responsibility, and it’s the supplier’s responsibility to use available fall protection.

CONTROLLED ACCESS ZONES

A controlled access zone (CAZ) is a designated work area marked by a warning line that only authorized employees can cross to work next to an unprotected edge. This less-safe approach is explicitly reserved for leading-edge work (the changing unprotected side of a roof or floor as it is installed) and overhand brickwork.

Except for steep roofs (slopes greater than 4-inches vertical to 12-inches horizontal) and non-residential roofing, CAZs are an option if you can prove traditional fall protection is not possible or too dangerous. Just be prepared to justify in writing why other fall protection isn’t effective; identify all authorized employees; and investigate all accidents and near accidents.

Some examples where traditional fall protection fails:

    ▪▪ Safe anchors cannot be provided.
    ▪▪ Lifelines may entangle or mire in grout.
    ▪▪ Fall protection prevents completion of the work.
    ▪▪ Work-area configuration causes ineffective fall-arrest systems.

At the very least, the CAZ must include a safety monitoring system.

USING SAFETY MONITORS ON LOW-SLOPE ROOFS

A safety monitor is a competent person responsible for recognizing and warning employees they are in danger of falling. The monitor counts as part of the fall-protection solution on low-slope roofs.

The following are fall-protection options on low-slope roofs:

    ▪▪ Guardrails
    ▪▪ Safety nets
    ▪▪ PFAS
    ▪▪ Warning lines and guardrails
    ▪▪ Warning lines and safety nets
    ▪▪ Warning lines and PFAS
    ▪▪ Warning lines and safety monitors
    ▪▪ Safety monitors on roofs 50-feet wide or less

The safety monitor must:

    ▪▪ Be competent to recognize fall hazards.
    ▪▪ Warn employees when it appears they are unaware of a fall hazard or are acting unsafely.
    ▪▪ Be on the same work/walking surface as monitored employees and be able to see them.
    ▪▪ Be close enough to talk to the employees.
    ▪▪ Not have any other responsibilities.
    ▪▪ Ensure employees follow warnings and directions.

Also, mechanical equipment can’t be in safety monitoring areas. Because these feasibility exceptions are only listed in specific categories (low-slope roof work, leading-edge work, precast concrete erection and residential construction), if a worker doesn’t fit those categories, such as HVAC installation, the worker must follow conventional fall protection. Alternative plans are generally for situations in which there isn’t a completed structure to attach anchor points; once anchor points are available, OSHA favors regular fall protection.

WARNING LINE FOR NON-ROOFERS

OSHA’s stance on fall protection is that there is no safe working distance away from an unprotected edge. But in an interpretation of workers on a low-slope roof, having just a warning line at least 15 feet from the edge of a roof for non-roofers (HVAC installers) would be considered a “de minimis” violation if non-roofers are prohibited from crossing the warning line. A de minimis violation violates regulations without making the workplace less safe and doesn’t result in a citation.

ASSEMBLING AND INSTALLING ROOFS

OSHA assumes traditional fall protection is safer than creating an alternative plan and has described some industry approaches to assembling and installing roofs without foregoing fall-protection precautions just because an anchor isn’t convenient:

    ▪▪ Assemble the roof on the ground and use a crane to place it.
    ▪▪ Use permanent and reusable roof anchors and reusable truss braces while working from ladders or platforms at both ends to brace the trusses without needing to be on them.
    ▪▪ Once trusses are braced, begin initial sheathing at the eaves with workers on platforms inside the structure, removing braces one at a time. Sheath the last course while tied off to existing wood anchors.

When OSHA regulations meet the real world, they can leave you wondering how they should be interpreted, and roofing is no exception. Hopefully this summary of how OSHA has interpreted fall protection for roofing situations clarifies some of the questions.

Upgrade to a Learning Management System

The first stone tools were made and used by early humans nearly 2.5 million years ago. As man evolved, so did the tools, transforming from blunt objects to precision equipment capable of greater rates of productivity and improved craftsmanship.

These days, tools aren’t the only advancements helping us do our jobs. During the past 10 years, safety training and compliance have evolved into a Learning Management System (LMS). An LMS is a software application for the administration, documentation, tracking, reporting and delivery of training programs.

BENEFITS

Learning Management System

Click to view larger.


To better demonstrate the strategic value of an LMS, let’s look at the competitive profile comparing instructor-led training to LMS training. In the figure, the horizontal axis of the competitive profile captures the range of factors on which LMS and instructor-led training solutions compete. There are six principle factors:

    ▪▪ PRICE: The cost to set up and deliver an employee training solution.
    ▪▪ PERFORMANCE: Training that goes beyond introducing knowledge and generates behavior change, driving improved individual, team and organizational performance.
    ▪▪ ENGAGEMENT: Instructionally sound, visually appealing and interactive training programs that engage individuals throughout the learning.
    ▪▪ EASE OF USE: Easy set up and maintenance of the training and delivery system.
    ▪▪ CONVENIENCE: Easy employee access to the training, anytime and anywhere. This includes the office, the job site or even at home. Management can access records from mobile workstations without having to be in the office.
    ▪▪ MEASUREMENT: Easy and cost-effective learner tracking, measurement and reporting.

The figure shows LMS and instructor-led training score high for Performance, Engagement and Ease of Use. However, instructor-led training, relatively speaking and largely due to its inherent lack of convenience, is expensive (in addition to paying the training company, think travel and/or time away from the job for the trainees) and, therefore, it gets a low score on Convenience and Price.

In addition, LMS allows the employer the opportunity to automate the training process, deliver offline training and ensure continued compliance. To automate training, the employer creates a list of trainings needed by job description. These lists are then used to create a learning plan. When the employer puts a new employee into the system, the LMS will automatically assign the training content via the job description. The employer then monitors the system to ensure the employee is completing his or her training.

If the employer chooses not to use automation to assign training inside of the LMS, he or she can manually assign training courses one at a time through the system. This may be done to reissue a training course because of a workplace incident.

DID YOU KNOW?

More than 40 percent of global
Fortune 500 companies are
using some form of a Learning
Management System.

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Keys to an Effective Accident Investigation

The nature of a workplace accident will determine the extent of the investigation, the resources that will be needed, what types of investigative processes will be required and who will need to be interviewed. The following basic steps should be taken to complete a formal investigation:

  • Gather information
  • Interview witnesses
  • Review existing documentation
  • Organize and analyze the facts
  • Develop the sequence of events
  • Determine and report the cause(s)
  • Make recommendations
  • Implement solution(s)
  • Write the report

Gather Information

Your primary goal in this step is to gather accident information that can give critical clues into the causes of the accident. To achieve this goal, you must first secure the accident scene. An accident scene can be secured with cones, caution tape, or by locking a door or stationing a person to watch the scene. Once the accident scene is secure, you can collect information by photographing or sketching the scene; recording video; or reviewing recorded information, such as security videos.

Interview Witnesses

Witnesses are the best resource for gaining an understanding of how the accident occurred and the conditions that led to the accident. Witnesses include people who saw the accident, the injured person(s) and others who may have contributed to the accident. This can include supervisors and trainers, maintenance personnel and anyone else tied to the investigation.

When interviewing these people, it is important to remember emotions can run high in the wake of an accident, especially a catastrophic one. Try to put the witnesses at ease by:

  • Explaining your purpose and role.
  • Sincerely expressing concern regarding the accident and desire to prevent a similar occurrence.
  • Listening with a calm, attentive and unhurried demeanor.
  • Keeping an open mind.

Review Existing Documentation

When searching for information, investigations should not stop at the scene of the accident, physical evidence or the individuals involved. Documents related to the incident can provide insight into the causes of an accident, especially root causes. Some examples of useful documents are:

  • Technical data sheets
  • Health and Safety Committee minutes (in situations where a Safety Committee exists)
  • Inspection reports
  • Company policies/procedures
  • Maintenance reports
  • Injury and illness logs
  • Past accident reports
  • Job-hazard analyses and safe-work procedures
  • Training records and reports
  • Work schedules
  • Other documents that may substantiate safety-related systems in the area of the accident

Organize and Analyze the Facts

When all the evidence is collected and interviews are complete, a timeline of the accident should emerge. Each event on the timeline describes an actor and action. The actor effects change through action or inaction. Actors do not have to be employees; equipment or processes can impact the system to precipitate an accident.

It may take a great deal of time to determine any weaknesses in management systems or other root causes that contributed to the conditions and practices associated with the accident. [Read more…]