INSPECTION! INSPECTION! INSPECTION!
From the IWEA Ironworker Employers Association comes a story of near miss with a fiberglass extension. While we speak often about inspecting your safety equipment, this reminds everyone just how important it is to inspect your tools and equipment!
Prepare for Cold Weather
Needless accidents rob people of their sight every day whether your job is in a laboratory, on a jobsite, in a factory — you don't have to be next. Safety goggles and glasses can withstand a terrific blow -- your eyes can't. And don't forget to protect your eyes from radiation. The intense light from work like arc welding and lasers can damage your eyes too!
It is paramount that safety professionals NOT fall into the trap which suggests that the manufacturer or OSHA be the deciding factor on when to retire a company’s harness or lanyard.. There are way too many variables for anyone, including OSHA, ANSI, the manufacturer, or a distributor of these goods, to tell you when to discard your safety equipment.
OSHA has at times, opportunistically, used (and abused) the 'manufacturer' as a rule maker. They cannot abrogate their duty to make rules to a private industry with selfish interests, and you should not allow them to imply they can. They cannot. They do use manufacturer's guidelines as a tool to help determine whether there is a violation. For instance, if a 'Competent Person' does NOT take into consideration the manufacturer's guidelines, they could say that he did not comply with the rules to properly inspect the equipment, which would imply that he SHOULD take into account the manufacturer's guidelines. But saying that doesn't make it so.
The Competent Person could have taken into consideration a more comprehensive set of guidelines put out by the webbing and fabric industry, or a more rigid instruction for another manufacturer that makes almost the same item. He could have conducted testing or gotten specific information from a source that is better than the manufacturer’s. This is readily seen, (sort of in reverse) if you look at all manufacturer's guidelines and notice they all tell you to avoid knots... or to NOT use the device with any knots more commonly. In appendix C inspection and design criteria for safety systems OSHA themselves tell you to take into consideration the manufacturer's advisories. But they also tell you to account for and deduct for the use of knots in any safety system. Clearly, they allow that YOU, the Competent and Qualified Person can decide how and when to determine right from wrong, and a distant CSHO, or a manufacturer cannot. Another example is the assumption that the manufacturer will tell you when its time to throw it out, or if you can keep it.
Specific instructions for use, inspection, and cleaning that must be understood and followed accompany the goods. However, regarding the 5-year “expiration” date that is general in the industry, this life expectancy is a general guideline. From the moment you open the bag the harness starts to deteriorate. The manufacturer cannot tell you how many tiny little spatters of slag it takes to discard the harness, nor how many whiffs of chlorine at how much concentration in PPM it would take to degrade the material to a given percentage. The manufacturer cannot tell you (except generally and qualitatively) how many rays of sunshine at what elevation (that matters) it takes to degrade the item to a point it is worn out (or too weakened) to use. The manufacturer cannot tell you the effects of your sweat components (acid, alkalinity, salts), or of the amount of grit in your air, or the pollution in your work locations. Acid rain has what? Acid in it. You are supposed to avoid acids. Rest assured the best and most qualified person to tell an employer when to retire equipment is the Competent and a Qualified Person on site.
Rest assured the equipment has tremendous excess capacity, and the degradation that is common (not normal...) in a 3-5 year period does not render the device worthless on the 1st day of the 6th year. The manufacturer knows that a harness worn every day will likely not make the 5 year mark, not by a long shot. A heavy form carpenter or an iron worker can wear out a harness in less than a year. On the other hand, a harness that is properly stored and worn only for inspections and riding in boom lifts and on roofs, that is used once a week or once a month, may last a lifetime. The Competent Person is the deciding factor. Also note, lanyards have a recommended 3 year use limit.
Manufacturers can't tell you about strength or loss of strength. They can in fact take your lanyard or harness back and test it, but that destroys it, and it’s a moot point whether it should be retired after that. Therefore, they could only provide more recommendations (still requiring the Competent Person to make the final decisions).
If you have 25 lanyards and really can't decide what to do, you ask for a test. The manufacturer can test the material of three lanyards that YOU decide are the worst, because YOU agree that getting some data will help YOU make up YOUR mind. The webbing of all three lanyards are tested and it tells you that the break test shows that the webbing is about 25% diminished from when it was new. So the 10,000 break strength is now 7,500 lbs. Well, that is substantially more than the minimum 5,000 lbs. YOU decide to keep using the remaining 22 lanyards, using the data as ONE of your considerations for that decision.
The manufacturer can't tell you to use the three that were tested, but it cannot tell you to use the other 23 either, since it’s not their decision. Most importantly, the assumption that all 25 have similar exposures, similar amounts of sun time, chemical time, sweat components, acid rain baths, storage similarities, ages in services (the label doesn't tell us that), wear on parts (one is used every day on the same exact grommet in the leg straps by one user, and the others are used on different settings since different users have them each day). The test is probably useful if the controlled experiment was indeed controlled, or even an experiment. It is a piece of data the Competent Person can use, but again, in the end, the 23 units going back into service are doing so on the decision of the Competent Person.
Safety people, don't turn your responsibility to train and make decisions and help others make rightful decisions over to a salesman or technician at some manufacturer. They will always default to 'read the warnings and instructions, and advice and take our recommendations', as if their attorney was speaking directly to you.
OSHA realizes, when they are honest about it, that manufacturers have one overall interest and that is making a good product and getting paid, and protecting themselves from injurious lawsuits and claims that imply and allege they have some duty they do not. They do not have a duty to inspect and approve equipment for use by your clients or employers. That is the domain of a safety professional and a Competent or Qualified Person, properly trained by such professionals.
A Competent Person, as defined by OSHA, uses manufacturer's recommendations and OSHA and ANSI rules as guidelines. Appendix C has a lot of helpful indicators and reminders to check for, too. At the end of the day, you make the decision. It would be prudent to all concerned to default on the side of taking it out if there is doubt. By the same token, if there is no doubt it’s fine, then the safety professionals and Competent and/or Qualified Persons should be confident enough of their knowledge and observations and all things taken into consideration, and allow it to stay in service. And document your choices and decisions whether on the little tags, (really not the best), or on a separate record tied to the unit number of each piece.
Expanding our product information to include Frequently Asked Questions will be a great resource for our product users. Just like many of our best selling products that have been developed with input from users in the field, we welcome input from you to develop the FAQ into a resource that will be useful for new users and seasoned hands.
One last important thing: don’t mistake our growth for distance. Our goal has always been to be a company that serves people with people. The internet is just another tool that should be easy, informative, and a resource for you just like the fax, voice mail, or email. So, rest assured we are always ready to take your call, help you with safety problems, compare your options, and offer decades of experience that we will share with you!
We are excited to be growing our internet presence with online purchasing, FAQs, blogging, and other communications about OSHA compliance and new products! So, check in frequently and also check out our sister company, Cole-Preferred Safety Consulting for additional information. We look forward to your feedback on both sites. And remember, we have more than what's on our website, so if you don’t see what you need while you’re browsing, contact us! We’re happy to take your call!
]]>The number of Americans who died on the job fell to the lowest level since 1992 last year, dropping 17 per cent to 4,340 across the country in 2009.
The Bureau of Labor Statistics said economic factors played a role in the decrease.
The recession, during much of the year, caused the total number of hours worked to decline by six per cent in 2009. "And some industries that have historically accounted for a significant share of fatal work injuries, such as construction, experienced even larger declines in employment or hours worked," which could explain the large drop, the agency said in a release.
Fatal work injuries in the construction sector declined by 16 per cent, the agency said. That's a similar decline to the economic activity in the sector overall, as U.S construction spending fell 15 per cent in 2009 to its worst showing on record.
Transportation-related deaths were the most frequent, responsible for 1,682 deaths in 2009, down from 2,130 in 2008.
Canadian data is not yet available, but figures compiled by the Association of Workers Compensation Boards of Canada count 1,036 workplace fatalities in Canada in 2008, just below the 1,055 figure for 2007.
The U.S. report noted that workplace homicides decreased by one per cent in 2009, far less than the 17 per cent average across all sub-sectors.
Workplace suicides declined 10 per cent from a previous high of 263 cases in 2008 to 237 cases in 2009.
The number of U.S. workplace fatalities declined across all ages and sexes, except for workers under 16, where the death rate increased. Thirty-seven out of 50 states overall reported declining fatalities.
]]>Do you think those words are “Safety First”? No, that would put safety on a higher plane than the rest of the factors that you must manage to run your business. While it is important to consider safety early on in planning your work, there are two other words that you must understand if safety is to succeed in your company.
Two words paint the big picture, and they are possibly the most meaningful of all the concepts in safety management. These two words have been ringing loudly in the construction safety movement for decades: “Management Commitment.”
So, if it’s that easy and has been said for so long, why isn’t everybody doing it successfully? The problem is that no one has explained to most managers what Management Commitment means in terms of actions, goals and expectations, and measurement. Therefore, we have many company executives and owners that say, “I am committed to my employees’ safety,” “ I don’t want anyone hurt on this job,” or “I have developed (or purchased) a safety program to show my commitment.” By saying they have commitment, or doing a few things that are required for safety, they feel they have arrived at a good or acceptable safety level.
The paradox is that virtually everyone is committed to safety, because the opposite of this would be “I don’t care if someone gets hurt”--and we know this is not true of any decent human. So, the dilemma is that we need to go beyond the word “commitment,” and beyond simply saying we are “committed,” and assure that our desire to have top safety performance is translated into actions in our company--actions that actually result in safety improvements and a long-lasting culture shift in our company. We must address safety the same way we would go after an improvement in quality, or introduce a new technique or a new product/installation technique to our supervisors and workers, or take on a new product line, or change our marketing style to attract new customers.
Successful company executives know that Management Commitment must be translated into actions that are definable, measurable, are part of a corporate business plan, and are on par with their other commitments. This last point is likely the most compelling. It seems that we are all committed to the routine-, day-to-day-, and production-oriented parts of our company. We are committed to profits, quality, customer service, productivity, marketing, sales, risk management/risk avoidance, and other aspects. We spend time, money, and management resources getting information and training on installation techniques, new product knowledge, cost and scheduling systems, and methods to improve productivity. We invest in training and cultivating our supervision that oversees our production to insure profitability and customer satisfaction. We take days at a time to go to seminars and trade shows and conferences to learn about new products and new marketing opportunities. We buy the best tools and devices to enhance production. We have trained buyers and estimators and accountants, insurance specialists, and lawyers that we pay good money to insure that we can manage costs, and legal and contractual risk. We know it takes training and skill development and a serious investment in time to get workers up to speed on techniques to insure quality and productivity and customer satisfaction. Even though they cost money and effort, we desire to do these things, because we know it yields results.
Now ask yourself these questions:
If you can’t answer “yes” to each of the above questions, then your Management Commitment is not as strong in the safety area as it is in all other areas. Safety is likely an afterthought, or an expense that is necessary but not desirable, and the message is not crystal clear in your company that safety matters as much as every other aspect of a professionally run, profitable company.
If you didn’t answer “yes” to all the questions, don’t feel bad. Most companies can’t answer “yes” to most of the questions. We treat safety as a second-class management function, and allow the confusing language of OSHA, and unknowing safety products salesmen and unsophisticated safety persons to sway us and draw us off the real issues of Management Commitment, and investment in your personnel’s safety aptitude and skills.
An amazing thing to me is this: Safety management is the purest form of management, because the majority of safety is not very technical (the confusing part). Most safety performance is human behavior modification (the harder to do, but simpler part). If you can motivate people to adhere to quality, productivity, customer service, profitability, and other management disciplines, then you can manage safety, too. If you can manage safety, the rest of your management functions will be easy. Good safety programs actually enhance the rest of the factors you want to manage-- including productivity and profitability.
Define your goals and measure your actions and efforts and investment for productive safety improvements against the time, resources and money spent on other aspects of your business-- by you and your other leaders. Is your Management Commitment and the actions required to make it work what it needs to be? You can start by showing support and providing human and financial resources to safety, providing training and professional help to your leaders and workers alike, and investing your own time and effort in it as well, which shows the staff that it is important to you. Only when the business executives place safety on the same plane as every other important discipline in their company, will they arrive at a point where safety is integrated into their company culture.
Barry A. Cole
Note: This article by Barry A. Cole, President of Preferred Safety Products and Cole-Preferred Safety Consulting, was recently published by the Steel Erectors Association of America (SEAA).
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