U.S. Department of Labor’s OSHA Issues Rule to Revise Requirements in Safety and Health Standards

The Occupational Safety and Health Administration (OSHA) has issued a final rule that revises 14 provisions in the recordkeeping, general industry, maritime, and construction standards that may be confusing, outdated, or unnecessary. The revisions are expected to increase understanding and compliance with the provisions, improve employee safety and health, and save employers an estimated $6.1 million per year.

OSHA proposed the changes in October 2016. This is the fourth final rule under OSHA’s Standards Improvement Project, which began in 1995 in response to a Presidential memorandum to improve government regulations. Other revisions were issued in 1998, 2005, and 2011.

For more information, visit www.osha.gov.

MRCA Safety Directors Meeting Live Seminar/Webinar Set for May 31

Gary Auman of Auman, Mahan & Furry concentrates his practice in OSHA defense nationally. He has 40 years of experience in OSHA compliance and litigation matters. Gary serves as General Counsel for many State, Regional and National Associations. During this Safety Directors Meeting, Gary will speak on the following topics:

  • Important updates to the Rules of Practice that impact all employers
  • Current OSHA enforcement activities
  • Emergency Action Plans

Live Seminar/Webinar

Friday May 31, 2019

11:30 am – 1:00 pm EST Lunch Buffet

The Engineers Club of Dayton

110 E. Monument Ave., Dayton, OH

You can attend this session live or participate via webinar, instructions will be emailed after receipt of registration. Register here to attend the webinar.

For more information, visit www.mrca.org.

National Fall Prevention Safety Stand-Down Scheduled for May 6-10

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) is joining with occupational safety organizations for the 6th annual National Fall Prevention Safety Stand-Down, May 6-10, 2019. The week-long event will focus attention on preventing falls in construction, the leading cause of fatalities in the industry.

The national stand-down encourages employers and workers to pause voluntarily during the workday for safety demonstrations, training in hazard recognition and fall prevention, and talks about hazards, protective methods, and the company’s safety policies, goals and expectations.

“Falls can be prevented when employers train and educate workers about these hazards properly and provide appropriate protection,” said Acting Assistant Secretary of Labor for Occupational Safety and Health Loren Sweatt. “This should be a priority during the first week of May and must be a priority every day. OSHA has tools readily available for employers and workers to address the prevention of fall hazards.”

OSHA anticipates thousands of work sites and millions of workers to observe the stand down worldwide in 2019. To help guide their efforts, the Agency’s fall prevention webpage provides information on how to conduct a successful event, and educational resources in English and Spanish, including:

  • A series of fall safety videos that demonstrate how to prevent fall hazards from floor openings, skylights, fixed scaffolds, bridge decking, reroofing, and leading edge work.
  • OSHA’s Fall Prevention Training Guide that provides a lesson plan for employers, including several Toolbox Talks.
  • Fact sheets on ladders and scaffolding that describe the safe use of these types of equipment while performing construction activities.
  • A brief video, 5 Ways to Prevent Workplace Falls, encourages employers to develop a fall prevention plan, and to provide workers with fall protection and training.

Employers are encouraged to provide feedback after their events, and to obtain a personalized certificate of participation. The national safety stand-down is part of OSHA’s fall prevention campaign, and was developed in partnership with the National Institute for Occupational Safety and Health, National Occupational Research Agenda, and The Center for Construction Research and Training (CPWR). To learn more about preventing falls in construction, visit OSHA’s Fall Prevention Campaign page.

For more information, visit www.osha.gov.

Understanding the New OSHA Regulations for Fixed Ladders

As of November 19,2018, the U.S. Department of Labor’s Occupational Health and Safety Administration (OSHA) implemented new requirements for fixed ladders on buildings. Understanding these new ladder regulations can be confusing, and you can spend a great deal of time referencing the standard interpretations pages on the OSHA website and still not find the answers you need. 

In this article, we will be referencing the OSHA fixed ladder rules found under Occupational Health and Safety Standards, Subpart D, Standard 1910.28, “Duty to Have Fall Protection and Falling Object Protection.” We will address some of the most frequently asked questions about the regulations for fixed ladders and include some tips and links to other resources for more information. 

What has OSHA changed?

The first and primary change is the phasing out of cages on fixed ladders. Many see this as a step forward for ladder safety. The reality is that cages offer little in the way of fall protection. In fact, they can increasethe risk of injury during a fall. 

Should we order our new ladder with a cage or not?

Under the new rules, cages are not required or recommended for any new ladder installation. We will get deeper into what this means for existing ladders later in this article.

The next question is if OSHA takes away cages, how are they planning to protect people from falls? This is accomplished using a personal fall arrest system (PFAS) or ladder safety system. These come in wide variety of designs. 

Three primary types are:

1. Bolt-on cable systems (with a cable grab fall arrester)

2. Track systems (with a climbing trolley)

3. Top-mounted self-retracting lifelines

Of course, each type has its advantages and disadvantages. The key is that each must meet the minimum OSHA requirements outlined in section 1926.502(d) of the OSHA codes. 

When is a PFAS Required?

Under the new regulations, a ladder over 24 feet high will require a personal fall arrest system or ladder safety system. You can choose any PFAS provided it meets the OSHA requirements in section 1926.502(d).

Please note: A ladder that is less than 24 feet high does not require a fall arrest system of any sort. 

What about landing platforms?

Multi-section ladders with a climb of 24 feet or more require rest points. These are meant to protect climbers as they ascend. Previously, a fixed ladder with a cage required a landing platform at a maximum interval of 30 feet.

The new regulations change this requirement dramatically. Fixed ladders without cages must now have a landing platform at maximum intervals of 150 feet. Ladders with cages must now have a landing platform at maximum intervals of 50 feet. 

How do the new rules affect existing ladders?

Under the new rules, the modification of an existing ladder or replacement of a ladder section requires that the modified or replaced section be equipped with a fall arrest system. 

By November 18, 2036, allladders 24 feet or higher must be retrofitted with a PFAS or ladder safety system.

Here’s the confusing part: Will all existing ladders with cages have to be replaced, or at least have the cages removed? No.The existing caged ladder can stay. But as outlined above, a fall arrest system of some type will have to be retrofitted. 

In such cases, the cage must not interfere with whatever fall arrest system is installed. Choosing the right type fall arrest is critical in these retrofit situations.

What questions should I ask then choosing a fall arrest system?

While the fall arrest systems themselves are not that complicated, the burden often falls on the purchaser to try to figure out all the parts and pieces needed to make their ladder OSHA compliant. 

It’s not uncommon to select a fall arrest system, only to find out the product or that the accessories needed to make it compliant might be discontinued or out of stock. This leads to a list of questions that you need to ask prior to picking a fall arrest system:

· Will this system work with my ladder and the height of my climb?

· What is the system’s load capacity? 

· Will the system allow for only one or for multiple climbers? How many?

· What is the true product cost? You need to gather information on the cost of not only the base components, but any accessories needed to make the system OSHA compliant, such as harnesses, cable grabs, trolleys, carabiners, etc. 

· Is the system, and all its accessories, readily available?

· Will replacement parts be available in the future?

Where can I turn for more information about ladder regulations? 

Reputable manufacturers and suppliers of ladders and fall protection equipment should have experienced personnel on hand that can help you navigate the new OSHA regulations. The OSHA website includes the regulations cited above, as well as a Q and A section that covers fixed ladders (https://www.osha.gov/walking-working-surfaces/faq.html). Contractors can also contact their area OSHA representative for assistance. 

Other OSHA ladder resources available online include:  https://www.osha.gov/stopfalls/trainingresources.html  and https://www.osha.gov/dcsp/alliances/alliance_products.html#Ladder.

The American Ladder Safety Institute also provides an online ladder safety training resource: https://www.laddersafetytraining.org/

About the author: Chris Lafferty is a sales and marketing associate with Design Components Inc., a full-service provider of fixed ladders and fall protection accessories. For more information, visit www.designcomponents.com

Rooftop Walkway System Features Integrated Safety Railing

Kee Safety Inc. introduces Kee Walk with Guardrail, an OSHA-compliant rooftop walkway system with integrated safety railing. Designed to provide a secure, anti-slip walking surface on all roof types including metal profile and standing seam roofs, Kee Walk with Guardrail accommodates steps, traverses, and sloped roofs with pitches up to 35 degrees, according to the company.

Serving as a “collective fall protection” system by OSHA criteria, Kee Walk with Guardrail helps to eliminate potential fall hazards by presenting a clear demarcation route for personnel accessing the roof. It can be used in conjunction with Kee Safety crossover platforms to provide safe access across roof-mounted pipework, over low-level walls, and to service plant equipment. The corrosion-resistant walkway-railing system is also compatible with other Kee Safety fall protection products to deliver a complete rooftop safety solution, according to the company.

Kee Walk with Guardrail is available with aluminum or nylon modules that feature anti-slip treads. These are supplied in 5-foot and 10-foot pre-assembled sections that are easy to install and do not require onsite fabrication. The guardrail uses Kee Klamp fittings and can be set up as either a single or dual-sided handrail system. The durable, corrosion-resistant system also installs without penetrating the roof. With its modular design, Kee Walk with Guardrail can be customized for layouts of new buildings or retrofitted onto existing structures. The walkway and guardrails combine to enhance worker safety even in wet and windy conditions, noted Kee Safety.

Established in 1934, Kee Safety is a global manufacturer of safety equipment and fall protection systems. Kee Safety products are designed for new-build and renovated or upgraded commercial, institutional, industrial, and municipal buildings and facilities.

To download a free brochure, visit: https://www.keesafety.com/products/kee-walk-with-guardrail

For more information, visit www.keesafety.com.  

https://www.keesafety.com

OSHA Issues Final Rule to Protect the Privacy of Workers

To protect worker privacy, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has issued a final rule that eliminates the requirement for establishments with 250 or more employees to electronically submit information from OSHA Form 300 (Log of Work-Related Injuries and Illnesses) and OSHA Form 301 (Injury and Illness Incident Report) to OSHA each year. These establishments are still required to electronically submit information from OSHA Form 300A (Summary of Work-Related Injuries and Illnesses).

By preventing routine government collection of information that may be quite sensitive, including descriptions of workers’ injuries and body parts affected, OSHA is avoiding the risk that such information might be publicly disclosed under the Freedom of Information Act (FOIA). This rule will better protect personally identifiable information or data that could be re-identified with a particular worker by removing the requirement for covered employers to submit their information from Forms 300 and 301. The final rule does not alter an employer’s duty to maintain OSHA Forms 300 and 301 on-site, and OSHA will continue to obtain these forms as needed through inspections and enforcement actions. 

In addition, this rule will allow OSHA to focus its resources on initiatives that its past experience has shown to be useful—including continued use of information from severe injury reports that helps target areas of concern, and seeking to fully utilize a large volume of data from Form 300A—rather than on collecting and processing information from Forms 300 and 301 with uncertain value for OSHA enforcement and compliance assistance.

The agency is also amending the recordkeeping regulation to require covered employers to electronically submit their Employer Identification Number with their information from Form 300A. The final rule’s requirement for employers to submit their EIN to OSHA electronically along with their information from OSHA Form 300A will make the data more useful for OSHA and BLS, and could reduce duplicative reporting burdens on employers in the future.

OSHA has determined that this final rule will allow OSHA to improve enforcement targeting and compliance assistance, protect worker privacy and safety, and decrease burden on employers.

Collection of Calendar Year 2018 information from the OSHA Form 300A began on January 2, 2019. The deadline for electronic submissions is March 2, 2019. 

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance. 

For more information, visit www.osha.gov.

Safety Tips and Best Practices for Roofing in Frosty Temperatures

Installing a roof in cold weather is nothing to sneeze at. While roofing contractors in the deep South may not have to worry about business slowing down in the winter, the majority of contractors must contend with cold temperatures, snow, ice and sleet. And even when these extreme weather conditions allow work to be done, they can still create many product and safety issues on the job. 

No matter how well you’ve honed your craft, roofing in cold weather is a challenge for any seasoned contractor. In addition to thinking about the safety of your workers, you must also consider the usability of supplies and equipment, which may be susceptible to the elements. 

For instance, in lower temperatures, certain types of asphalt shingles can become less flexible and equipment may freeze. Also, you should ask yourself: Can I keep my workers motivated and focused on the quality I expect? When roofers are uncomfortable or can’t work safely, they begin to worry about themselves more than the work they’re doing — and justifiably so. 

Before proceeding with your next cold-weather roofing job, consider the following precautions and recommendations. 

Product Considerations

The first rule of cold-weather roofing is to follow all manufacturers’ cold-weather installation guidelines. Different manufacturers specify different minimum temperatures for their products. If the temperature is below that minimum, you will need to take extra precautions to ensure the roof shingles are handled correctly and the product seals properly. 

For example, while asphalt shingles have been successfully used in cold climates for more than a century, they become less flexible at temperatures below 40 degrees Fahrenheit. 

When asphalt shingles lose their pliability, they become prone to cracking and other problems, including failing to lie flat and not holding their shape, which can result in granule loss, humping and other damage. Lower temperatures will also keep the shingle sealant lines from achieving proper thermal activation. 

Because of the increased risk of shingle damage and the shingle not sealing correctly in cold temperatures, workers should keep the following things in mind:

  • Never throw or drop shingles. 
  • Give shingles time to warm up before installation if they have been stored in freezing temperatures. Cold shingles — especially fiberglass shingles — may crack on the back when nailed to the deck, which can cause roof leaks. Best practice: When installing shingles in low temperatures, nail them by hand to avoid the “blow through” that a high-powered nail gun can cause.

Remember that most sealants won’t thermally activate at temperatures below 40 degrees. Instead, seal strips must be hand sealed with an approved asphalt roofing cement or other manufacturer-approved adhesive. 

The Asphalt Roofing Manufacturers Association (ARMA) recommends that shingles be pressed into the asphalt cement so that the adhesive reaches almost to the shingle edges, but is not exposed. For laminated shingles, ARMA says at least three spots of sealant may be used. If not sealed properly, eaves and rakes can be extremely susceptible to wind blow-off. 

The association also suggests the use of open metal valleys in cold weather because installing closed and woven valleys require shingles to be bent, which could result in damage. 

To prevent ice dams — the frozen water that can build up at the eaves of a roof — be sure to install proper roof and attic ventilation in addition to a premium ice and water roof underlayment, which provides a second layer of protection in cold-weather conditions. Ice and water underlayment can be used along eaves, valleys, flashings, hips, ridges, dormers, rakes, skylights and chimneys. Properly ventilating a roof will help ensure maximum protection against ice dams.

Before installing roofing underlayment, be sure that the deck is completely dry so the moisture doesn’t cause wrinkling or buckling of the underlayment. This wrinkling can telegraph through the shingles, creating cosmetic and performance concerns. In addition, trapped moisture can contribute to shingle blistering. 

Overall, when roofing during cold-weather months, check the forecast and plan for potential delays. Better yet, try to work on bright, clear days, when the sun can bear some of the burden and help warm up the roof deck. 

Safety Concerns

Near-freezing temperatures not only create issues with supplies, they can also pose safety risks to workers.

To avoid frostbite, roofers should layer up in clothing such as ClimaWarm and Hyperwarm, which provide warmth, breathability and protection from wintery weather. Even with the proper attire, workers should beware of the signs and symptoms of frostbite, which include prickling skin, numbness and — worst of all — clumsiness caused by stiff joints and muscles. 

In addition to following the Occupational Safety and Health Administration’s (OSHA’s) safety regulations for harnesses and fall-protection systems, roofers should always wear shoes with good traction — but especially in cold weather, when surfaces can become slippery. 

Also, encourage everyone to take regular warm-up breaks throughout the day, limit work schedules during extreme weather conditions and consider investing in on-site heating equipment, such as portable foot warmers.

To best prepare yourself and your crew for winter jobs:

  • Plan work around the shorter daylight hours, as well as weather conditions that may prevent roofers from safely being able to put in the necessary hours. 
  • Expect work performance to slow down due to dexterity issues and other natural body-responsive reactions caused by cold temperatures. 
  • Anticipate the extra time that will be required to clear snow from roofs and protect the surface from the elements while work is being performed. 
  • Remember that even a thin layer of snow can camouflage skylights, other materials and debris, which could pose a tripping or falling hazard. 
  • Because working in cold weather takes just as much, if not more, physical exertion as working in warm weather, roofers should be sure to drink plenty of fluids to prevent dehydration. 

Ultimately, the best advice is to be prepared. Take a cold hard look at the weather forecast and plan accordingly, taking into consideration worker safety, product usability and equipment functionality. Being flexible and ready to adjust work as needed can keep winter business from freezing up altogether.

About the author: Paul Casseri is the product manager of the Roofing Shingles and Underlayment Division for Atlas Roofing Corporation. For more information, visit www.atlasroofing.com.

U.S. Department of Labor Provides Compliance Assistance Resources to Protect Workers from Falls

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) has developed a collection of compliance assistance resources to address falls in the workplace, the leading cause of worker fatality in the construction industry. OSHA’s goal is to promote awareness about common fall hazards in construction, educate job creators and workers on fall prevention, and reduce the number of fall-related injuries and fatalities. These resources, which continue the goals of the Department’s Office of Compliance Initiatives (OCI), encourage and facilitate compliance evaluations.

Falls can be prevented if employers plan ahead to ensure the job is done safely; provide the right equipment; and train workers to use the equipment safely. OSHA is working with industry stakeholders to provide informative compliance assistance resources.

The sixth annual National Safety Stand-Down to Prevent Falls in Construction will be held May 6-10, 2019. The weeklong outreach event encourages employers and workers to pause during the workday to discuss fall hazards and how to prevent them. 

A series of fall safety videos show how to prevent construction-related fall hazards from floor openings, skylights, fixed scaffolds, bridge decking, reroofing, and leading edge work.

OSHA’s Fall Prevention Training Guide provides a lesson plan for employers including several Toolbox Talks.

Fact sheets on ladders and scaffolding provide guidance on the safe use of these types of equipment while performing construction activities.

A brief video, 5 Ways to Prevent Workplace Falls, encourages employers to develop a fall prevention plan, and to provide workers with fall protection and training.

OSHA’s On-Site Consultation Program provides valuable services for job creators that are separate from enforcement. OSHA recently published an analysis demonstrating how the agency’s On-Site Consultation Program contributes $1.3 billion to the national economy each year. Job creators who implement workplace improvements can reduce lost time due to injuries and illnesses, improve employee morale, increase productivity, and lower workers’ compensation insurance premiums.

Under the Occupational Safety and Health Act of 1970, employers are responsible for providing safe and healthful workplaces for their employees. OSHA’s role is to help ensure these conditions for America’s working men and women by setting and enforcing standards, and providing training, education and assistance.

 For more information, visit www.osha.gov.

U.S. Department of Labor Issues Final Rule on Crane Operator Certification Requirements

The U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) published a final rule that clarifies certification requirements for crane operators, and maintains the employer’s duty to ensure that crane operators can safely operate the equipment. The final rule will maintain safety and health protections for workers while reducing compliance burdens.

Under the final rule, employers are required to train operators as needed to perform assigned crane activities, evaluate them, and document successful completion of the evaluations. Employers who have evaluated operators prior to December 9, 2018, will not have to conduct those evaluations again, but will only have to document when those evaluations were completed.

The rule also requires crane operators to be certified or licensed, and receive ongoing training as necessary to operate new equipment. Operators can be certified based on the crane’s type and capacity, or type only, which ensures that more accredited testing organizations are eligible to meet OSHA’s certification program requirements. The final rule revises a 2010 requirement that crane operator certification must specify the rated lifting capacity of cranes for which the operator is certified. Compliant certifications that were already issued by type and capacity are still acceptable under this final rule.

The final rule, with the exception of the evaluation and documentation requirements, will become effective on Dec. 9, 2018. The evaluation and documentation requirements will become effective on February 7, 2019.

For more information, visit www.osha.gov.

 

Kee Safety Introduces Partnership Program for Installers of Fall Protection Systems and Products

Kee Safety, Inc. announces the launch of its “Partnership Program” for installers of the company’s extensive range of fall protection systems and other safety products and systems. Examples include OSHA-compliant KeeGuard rooftop railing systems and related safety products such as the enhanced new KeeLine®retractable lifeline and the company’s traditional ground-based railing systems built from Kee Klamp steel and Kee Lite aluminum fittings.

According to Kee Safety, the program offers comprehensive support from project concept to completion with free training, marketing and advertising support, experienced design capability, expert customer service, fast turnaround on quotes, and timely product delivery.

“The Kee Safety team is fully trained in OSHA fall protection standards and other important safety guidelines,” said Mike Mumau, President of Kee Safety, Inc. “We know how our product and fall protection system capabilities will meet or exceed regulatory requirements. We strive to help solve safety concerns for architects and engineers planning projects, and for the building owners and facility or safety managers.”

Training for Kee Safety installers can be provided at the installer’s facility or the company’s North American headquarters and training center in Buffalo, New York. It includes: Product Introductions; On-site Demonstrations; and Comprehensive Installation Training.

“We are committed to the success of our partners and their clients,” Mumau added.

Established in 1934, Kee Safety is a global manufacturer of safety and fall protection systems. Kee Safety products and systems are designed for new-build and renovated or upgraded commercial, institutional, industrial, and municipal buildings and facilities.

For more information, visit www.KeeSafety.com.