#1 of Top 10 – 10/21/13
Earlier this month, at the National Safety Council (NSC) Congress and Expo, OSHA announced their top 10 violations for 2013. If you’d like to see the full list, here’s a link to the announcement on the NSC’s website: OSHA Top 10 Violations http://news.yahoo.com/oshas-top-10-violations-2013-announced-national-safety-161300619.html. Because the goal of this weekly tip is to bring you information to stay safe, which in turn may reduce your likelihood for OSHA Violations, we are going to focus on some of these violations, what they are, and of course, some safety information.
As you look at the list, once again, Fall Protection Systems, Construction, (29 CFR 1926.501) heads the list. If you want to see what that means, click on the regulation, it’s a link for your convenience. The first sentence in the regulation is: “ (a)(1) This section sets forth requirements for employers to provide fall protection systems.” This is more than just providing safe ladders, PPE, or training your workers to look for a green tag before climbing up a scaffold. The key word we want you to see is “system.”
The first definition on dictionary.com of a system is “an assemblage (assembly) or combination of things or parts forming a complex or unitary whole.” In other words, yes, safe ladders, PPE and scaffolding are parts of fall protection systems. But they are just parts.
If you look at the next subparagraph in the regulation, (a)(2), it says “The employer shall determine if the walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely.”
What if we change the way we talk about fall protection? What if, instead, we use the phrase “Safe Walking/Working Surfaces?” It does not matter what the height of the walking or working surface is – it matters how safe it is.
What is “safe”? The International Organization for Standardization (ISO) defines safety as “freedom from unacceptable risk.” (For a discussion on this, see our blog “What is Safety?” linked here: http://scmsafety.blogspot.com/2013/08/what-is-safety.html). How do you take away the risks when working at heights? If you are 6 or more feet off the ground, there’s risk. It’s hard to get around that. But, there’s also a risk walking at ground level. Have you ever tripped while walking on a sidewalk? I have. So risks of falling may exist whether height is involved or not. The unacceptable risk is the lack of safety on the walking/working surface.
One way to make a risk more “acceptable” is to control it. We recently posted a blog about the hierarchy of controls. Here’s a link to that blog, if you need to catch up: http://scmsafety.blogspot.com/2013/10/taming-tiger-hierarchy-of-controls.html. In the hierarchy of controls, the first and most successful control is to eliminate the hazard. You can’t eliminate the need to work at heights. But you can eliminate or at least partially eliminate the risk while at heights. The regulation we are reviewing today gives you some ways to do that. Covering openings, using guard rails and toe boards, having hand rails on stairs are just a few examples. OSHA has a Safety and Health Topic page on Fall Protection with videos, information in Spanish. Here’s a link if you would like to check it out: https://www.osha.gov/SLTC/fallprotection/index.html.
What we’d like to offer as our safety tip of the week is for you to walk around your site, whether that’s your main facility, or a jobsite at a client’s place. Take a look at what is going on. Ask yourself if the work is being performed on a safe walking and/or working surface. Don’t look at how high the work is off the ground or what the height is from the working surface to the next level below. Just look at how safe the work surface is.
Next week, we are going to look at another of OSHA’s top 10 Violations that has been on this list for years – Hazard Communication.