
Make sure everyone is on the same page. The adage applies to safe operations of contractors as surely as it does to hymnals.
If anyone skips ahead or falls behind, confusion can ensue. Policies and procedures exist so that no one needs to guess what comes next.
A day-to-day fundamental to ensure safe operations is the clarity that derives from a written reference. (Yes, “written” includes in digital format.)
“An operations manual should be in place so that the technicians of the business know what is expected of them,” says Mike Dingler, owner of Firehouse Power Washing in Peachtree City, GA. That operations manual includes prescriptive information about safety. [We should mention that Dingler is an Enterprise Member of the PWNA as well as a PWNA certified instructor.]
“A safety policy within the operations manual is paramount as it outlines how to perform the work in a safe manner, often using systems that have been put in place due to injuries in the past,” says Dingler. “These systems, when followed by the technicians, can help avoid injuries in the future.”
To be sure, contractors must develop ways to keep employees from succumbing to complacency. “In any company a training program needs to be in place, and this is especially true in high safety-risk operations,” says Dingler.
“Morning muster meetings should be conducted in which the day’s objectives and jobs are discussed, and at least one safety protocol should be reviewed at each meeting,” says Dingler. “This keeps safety top of mind for all employees.”
Knowledge and tools are inextricably linked. Contractor operations proceed safely when team members follow best practices and can do so because they have proper equipment and ancillaries.
“Proper equipment and proper maintenance of the equipment can contribute to a safer operation overall,” explains Dingler. “Assuring bolts stay tightened and plumbing stays leak free can minimize equipment breakdown and possible technician injury in the future.”
Scrupulous adherence to use and storage of chemicals is a must for safe operations. “Chemicals used in soft washing are hypersensitive to being stored with other chemicals, and improper mixing could lead to an exothermic reaction in which a chemical explosion could take place,” says Dingler.
Consider chemicals. “Assure the proper safety data sheets (SDS) are in place on your mobile units in case of a motor vehicle accident. DOT and the local authorities require the identification and handling instructions of any chemicals you may be transporting,” says Dingler.
Ready SDS access does much more than keep a contractor compliant with regulations. “Having these materials on hand can not only get you out of a fine but also provide important information to first responders or others who may be exposed to chemicals on your truck,” explains Dingler.
Keeping employees (and passersby) safe (and healthy) is the primary reason contractors commit to safe operations. A secondary reason is to remain fully aligned with regulations from federal, state, and local entities and avoid fines.
There’s a third reason, though, that contractors ought to keep in mind. Not only do responses to requests for proposals (RFPs) and bids on work require documentation of one’s safety record, but the public and private entities inviting proposals or bids increasingly require prequalification.
That is, a contractor must demonstrate policies and procedures are in place and followed precisely. A small, growing contractor in our industry might not envision a time when prequalification or bidding will be necessary; but as the size of jobs increases, that could change.
Many industry organizations offer advice to those hiring contractors regarding how to assess the safety record of a prospective contractor. Among the organizations is the familiar ANSI [American National Standards Institute]. CURT [Construction Users Roundtable] and Industrial Hygiene Association [AIHA] are two others.
The guidelines provided to those prequalifying or hiring contractors include assessment of staff qualifications, accident history, and the type of safety program in place. Here, the operations manual, which includes safety program details, becomes significant.
Working as contractor without a tie to an industry association is possible. But such a contractor forfeits valuable assistance in keeping up to date with safety regulations (as they are modified or added to) and easy access to training and discussions.
For instance, PWNA [Power Washers of North America], UAMCC [United Association of Mobile Contract Cleaners] and IWCA [International Window Cleaners Association] put contractor safe practices as well as training and certification high on their agendas.
A contractor may assess his or her company and feel confident that the policies and procedures in place will result in safe operations. If so, there will be no surprises in the realm of regulatory violations (and fines), at least in theory.
Because regulators modify and expand regulations frequently, the “no surprises” assumption is faulty. Contractors can sign up for alerts from OSHA [Occupational Safety and Health Administration]—see OSHA.gov—to avoid missing new requirements.
In addition to regulators, contractors may encounter investigators should an incident occur. For example, the Chemical Safety Board (CSB.gov) is a nonregulatory body that dates to 1998. Its members are appointed by the Senate and the White House.
CSB undertakes root cause analyses concerning safety events involving chemicals. It has no punitive authority but aims to use analyses to reduce injuries and deaths by preventing the same type of incident from occurring again. In short, there are watchful eyes on contractors from all directions.
A contractor can gain some assurance that nothing has been missed in meeting requirements of OSHA by using the administration’s On-site Consultation Program, which provides free, confidential advice to small and medium-sized businesses. (The program gives priority to high-hazard worksites.)
An on-site consultation can highlight potential risks a contractor may not recognize. The consultation does not result in citations or penalties, but the contractor must correct any deficiencies. (Learn more at the https://www.osha.gov/consultation.)
Although an employer must have more than 10 employees before OSHA reporting requirements take effect, it’s best to be prepared. Employers covered by the OSHA record-keeping regulation must report all fatalities and all work-related illnesses and injuries that require time away from work, as well as work-related illnesses or injuries diagnosed by a physician even if they require no time away from work.
“OSHA’s Frequently Asked Questions” (https://www.osha.gov/faq) is a good starting point for a small contractor who wants a quick grounding in OSHA, even though the number on the employee roster is fewer than 10.
Power washing contractors are covered by general industry standard 1910, but the nature of their work may also place them under the prescriptions of standard 1926 for the construction industry. (An on-site consultation can help a contractor determine which regulations apply.)
Two subparts of 29 CFR 1926—subpart E and subpart D—should get the attention of contractors in our industry. (That is attention in addition to 29 CFR 1910.)
According to subpart E, employers must provide and require their employees to use protective equipment “wherever necessary to prevent injury or impairment.” The safety equipment must meet standards established by ANSI or by NIOSH [National Institute of Occupational Safey and Health]. Head protection, hearing protection, eye and face protection, and respiratory protection may be required.
Subpart E also includes rules for use of safety belts, lifelines and lanyards, safety nets, and buoyant jackets or vests when working over water. It can be complicated. For example, turning an employee’s safety belt on or off depends on what the employee is doing. Just wearing the belt constantly may result in a violation.
There’s another good example of the vexing nature of the regulations in the context of buoyant safety devices. Contractors who work on bridges over water must wear the devices, but that’s just step two. All such devices must be free of defects and checked before and after each use.
It’s almost a given that a contractor with a safe operation will be surprised by some rule that’s been overlooked. And that takes us to subpart D of 29 CFR 1926 – Occupational Health and Environmental Controls.
Subpart D includes rules for sanitation (e.g. adequate drinking water and cups, toilets), hearing protection, protection from ionizing radiation, protection from airborne contaminants, amount of illumination, hazard communication, and many more considerations. There are plenty of things a contractor can be surprised by when trying to follow this subpart.
Take toilets. Mobile crews who have transportation available to get to toilets nearby do not need to be supplied with toilets. But the determination of “nearby” is ambiguous, which becomes irrelevant in municipalities that mandate on-site toilets.
Toilet use frequency is also spelled out by OSHA. No “unreasonable restrictions” can be placed on use of restrooms by employees.
OSHA regulations can surprise. And remember that many of them (e.g., the nearness of toilet facilities) can be open to interpretation. That’s why the free, on-site consultation is invaluable.
Associations and other similar stakeholders can also take advantage of meetings with OSHA compliance assistance specialists. Like contractors with safe operations, OSHA’s compliance assistance specialists want to be sure everyone is on the same page.