By Terri Perrin / Published August 2015
While researching and writing ‘Taking Protection to New Heights’ for the April 2015 issue of Cleaner Times|Industrial Water Application (CT|IWA), I discovered that the federal Occupational Health and Safety (OSHA) website provided a wealth of information on creating safe workplaces. I also learned that, if you are strapped for time, it can be a challenge to find specific, industry-related information quickly. Don’t get me wrong! The website is well organized and relatively simple to navigate, but there is just so much there!
CT | IWA: Does OSHA offer a training and certification program specifically for workers using equipment to work on ladders, etc.? If not, where should contractors go for training and certification for their staff?
OSHA: Our organization does not offer training and certification in the construction industry. However, OSHA has developed many publications, such as those listed above, and has issued training guides, including the Fall Prevention Training Guide. These are intended to help employers prevent worker injuries and deaths from falls. (www.osha.gov/Publications/OSHA3666.pdf)
OSHA staff can also provide assistance. Small contractors can call OSHA’s free consultation program that can provide education and outreach on ladder safety. Visit OSHA’s On-Site Consultation page to find the local consultation office in your state. (www.osha.gov/dcsp/smallbusiness/consult.html)
Additionally, the OSHA Training Institute (OTI) Education Centers offer course #3115 Fall Protection. OSHA does not fund OTI Education Centers and the centers do charge tuition.
A schedule of OTI Education Centers can be accessed at www.osha.gov/dte/ecd/course_otiec_search_public.html.
To help our readers access specialty material related to fall prevention and any areas that may apply to the power washing and waterjetting industries, we decided to go right to the source. The following interview with OSHA representatives provides insight as to what you need to know to be OSHA compliant and, more importantly, to ensure your place of employment is a safe place for all.
We trust that this information will be of value to you and thank OSHA for their cooperation in answering our questions.
CT|IWA: The OSHA website has a wealth of information about safety standards and protecting workers. Are there specific, written standards for proper safety equipment and protocols for people working at heights? Where on the website can our industry contractors and manufacturers quickly access this information?
OSHA: Falls are the leading cause of death in the construction industry. Here are key pages on OSHA’s website that explain how employers can protect worker safety and health:
• Construction Industry: www.osha.gov/doc/index.html
• Fall Prevention: www.osha.gov/stopfalls/index.html
• Fall Protection in ResidentialConstruction: www.osha.gov/doc/topics/residentialprotection/index.html
• Fall Protection in General Industry: www.osha.gov/SLTC/fallprotection/standards.html
CT | IWA: Are there penalties for not properly maintaining equipment or not having the right equipment to work at heights?
OSHA: Working at high elevation is a leading cause of worker fatalities. Failure to properly use and maintain fall protection equipment would likely be considered violations of the serious, high gravity nature. Knowingly using improperly maintained or the wrong equipment for the application could constitute willful violations. Serious, high gravity violations can result in $7,000 penalties, and willful violations can be as much as $70,000.
CT|IWA: In the OSHA guidelines, are there specific steps to keeping a proper maintenance/evaluation schedule of equipment used to work at heights, or are they generic for all types of safety equipment?
OSHA: Requirements for inspection and maintenance vary by the type of equipment being used. However, in all cases, OSHA expects the employer to maintain and inspect equipment in a way that protects employees working at heights from the hazards of damaged or defective equipment.
CT|IWA: When working at heights, fall prevention should always be of utmost importance but, when accidents do happen, how should workers handle it?
OSHA: Employees have the right to a safe workplace. They are entitled to working conditions that do not pose a risk of serious harm. Most injuries are due to unsafe conditions, and employers must provide workers with the required equipment and training. Workers have the right to file a complaint and ask OSHA to inspect their workplace without fear of retaliation.
The Occupational Safety and Health Act requires that employers provide a workplace free from serious hazards. It is the employer’s responsibility to keep accurate records of injuries, illnesses, and fatalities. Employers must also report to OSHA all work-related fatalities, hospitalizations, amputations, and losses of an eye.
Furthermore, once an injury happens, employers should initiate an incident investigation to find the root cause(s)—and implement preventative measures to prevent any further injuries. The root cause(s) are the underlying reasons the incident occurred—and are the factors that need to be addressed to prevent future incidents. If safety procedures were not followed, why were they not being followed? If a machine was faulty or a safety device failed, why did it fail? Additional resources are available on OSHA’s Incident Investigation Web page. (www.osha.gov/dcsp/products/topics/incidentinvestigation/index.html)
CT | IWA: How do you recommend employers establish emergency response plans before any incidents occur? Is there a step-by-step guide available?
OSHA: We have a number of resources to help employers meet their responsibilities to provide safe workplaces. OSHA’s On-site Consultation Program offers free and confidential advice to small- and medium-sized businesses in all states across the country, with priority given to high-hazard worksites. Responding to requests from small employers looking to create or improve their safety and health management programs, OSHA’s On-site Consultation Program conducts more than 29,000 visits to small business worksites annually. This covers more than 1.5 million workers across the nation. On-site consultation services are separate from enforcement and do not result in penalties or citations.
Additionally, employers can develop and implement an injury and illness prevention program, an effective tool for reducing workplace injuries, illnesses, and fatalities. This entails:
• Establishing clear safety and health goals
• Consulting with workers when developing the program and encouraging them to report hazards, injuries, and illnesses
• Identifying and assessing hazards by asking for input from workers
• Implementing a plan to prioritize and control workplace hazards; and
• Training workers in a language they understand.
More information is available in OSHA’s Injury and Illness Prevention Programs fact sheet. OSHA is available to provide assistance to employers interested in developing and applying this program within their workplaces. Visit OSHA’s On-Site Consultation Web page to find a local consultation office. (www.osha.gov/dcsp/smallbusiness/consult.html)
CT|IWA: Tell us about OSHA safety inspections. Are they random? Pre-scheduled? What is involved?
OSHA: On-site inspections are initiated without notice and are performed by highly-trained compliance officers. They are scheduled based on the following priorities:
• Imminent danger
• Catastrophes—fatalities, hospitalizations, amputations, or losses of an eye
• Worker complaints and referrals
• Targeted inspections—particular hazards, high injury rates
• Follow-up inspections.
Workers or their representatives may file a written complaint and ask OSHA to inspect their workplace if they believe there is a serious hazard or that their employer is not following OSHA standards. More details on OSHA inspection priorities are published in the All About OSHA booklet. (www.osha.gov/Publications/all_about_OSHA.pdf)
OSHA also conducts targeted (programmed) inspections through national, regional, and local emphasis programs. These programmed inspections focus on high-hazard industries and worksites. The establishments are selected based on injury, illness, and fatality rates; previous history of citations; worker exposure to toxic substances; or random selection. Lastly, OSHA conducts follow-up inspections to determine if an employer has corrected previously cited violations.
CT | IWA: How can business owners keep proper records for an OSHA safety inspection?
OSHA: Our regulations require certain employers to keep records of serious employee injuries and illnesses. Please see Updates to OSHA’s Record-keeping Rule Web page for more information. (www.osha.gov/recordkeeping2014/index.html)
As of Jan. 1, 2015, all employers under federal OSHA’s jurisdiction must report all work-related fatalities within eight hours and all work-related inpatient hospitalizations, amputations, and losses of an eye within 24 hours. Establishments in a state with a state-run OSHA program should contact their state plan for the implementation date. More information is available on OSHA’s recordkeeping and reporting requirements Web page (www.osha.gov/recordkeeping2014/index.html).