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Among the more welcome pieces of safety equipment to be broadly adopted by employer and worker alike is the back brace. Most often seen over the smock of your friendly neighborhood Home Improvement Store associate, the girdle-like garment has been the savior of many hard working people. However, even a back brace can not be a cure all for back related pains at the work site.
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OSHA recently issued a Hazard Information Bulletin to its compliance officers (inspectors) to be “on the lookout for unsafe use of LP-gas containers.” OSHA distributes Hazard Information Bulletins to all area offices and state plan offices, in addition to labor and industry associations.
The bulletin is notifying readers that propane tanks commonly found on construction sites may have regulators that extend outside the protective collars designed to prevent damage to valves. Extending regulators beyond the protective collar causes the regulator and attached equipment to be vulnerable if the tank falls, is dropped, are struck by a heavy object.
OSHA reported a case where a worker entered a confined space to clear ice from a manhole using a blowtorch with a regulator that was attached outside the collar of a 20-pound propane cylinder. The cylinder fell, the exposed regulator broke off, and gas and liquid propane released into the manhole. The propane caught fire inside the space and the worker burned to death.
The bulletin is likely to cause compliance officers to specifically look for this hazard during an OSHA inspection.
According to OSHA, workers using gas cylinders with unguarded regulators “appears” to be a common practice found on construction sites. OSHA standard 1926.153 addresses the use of liquefied petroleum (LP) gas containers. It requires you to protect normal 20-pound LP-gas containers from damage while in use or in storage. OSHA also reminds readers that LP-gas cylinders are covered by the National Fire Protection Association’s (NFPA) “Standard for the Storage and Handling of Liquefied Petroleum Gases,” 58-1995, section 2-2.4.1.
OSHA warns construction workers and employees of the hazards associated with unguarded regulators on propane cylinders, and that the standards require employees to receive training on how to do their jobs safely. The NFPA which sets voluntary safety standards also has recommendations covering protection for valves and connections such as regulators.
In short, make sure that your cylinders do not have attached regulators extending outside the confines of the protective collar, and that all critical parts of the equipment are protected from danger/damage. Supervisors should be familiar with the OSHA standard, safe use of the equipment, and most importantly – assure that all workers using/handling cylinders are properly trained.
Some of the most dangerous devices may be found on your jobsites and in your shop. Compressed gas cylinders of all types have a tremendous capacity for injury from mistreatment or mishandling.
The sheer energy storage that is contained in a cylinder (especially Oxygen) makes this equivalent to storing and handling a bomb. Oxygen cylinders are typically pressurized to 2,000 P.S.I, and acetylene cylinders are typically pressurized to 250 P.S.I. The following will cover the common high-pressure oxygen/ acetylene cylinder regulations outlined by OSHA in Subpart J “Welding & Cutting”, and should be a part of your safety program. Most of the handling techniques addressed here will apply to CO2, LP, and other similar gas cylinders.
All high pressure gas cylinders need to comply with certain regulations. The following are highlights of the more common requirements for storage.
Outside storage areas selected should be dry, well-ventilated, protected, and not subject to continuous exposure to sunlight, moisture, salts, corrosives, or extreme weather. The areas should have a definitive designation for cylinder storage, and not be subject to damage, falling, or from tampering. Outside storage areas require a minimum of a 20-B fire extinguisher located from 25 ft. to 75 ft. away from the storage area.
Inside storage areas selected should be dry, well-ventilated, protected, and away from high traffic areas such as gangways, elevators, and stairs. The areas should have a definitive designation for cylinder storage, and not be subject to damage, falling, or from tampering. Areas should be located away from salts, corrosives, or sources of heat. Inside storage rooms with more than 60 gallons of flammable or combustible liquids shall have a minimum of a 20-B fire extinguisher located within 10 ft. of the storage room door. Inside storage areas are limited to 2,000 cubic ft. gas capacities, or 300 lbs. of LPG. Larger amounts would require a separate storage room.
When cylinders are stored, or transported, the protective caps are required to be screwed on. Caps may be screwed on hand tight. Caps should be removed only when the cylinders are in use- which is when the regulators are installed. Cylinders may be moved without protective caps (and with regulators installed) only in carts designed for the purpose, with the cylinders secured. Protective caps cannot be used to hook onto for hoisting. When removing caps, do not apply leverage to the valves. According to OSHA, when caps are frozen, warm water may be used to thaw cap threads.
Cylinder valves shall be closed at all times, except when in use. Empty cylinders are also required to have valves closed. Cylinders should not be emptied completely, but retain approximately 30 P.S.I. to prevent contamination. Oxygen cylinders not in use are required to be separated from fuel-gas cylinders, oils, grease, and other combustibles by at least 20 ft. In lieu of this requirement, you may store oxygen cylinders closer (adjacent) if separated by at least a 5 ft. high 1/2 hr. fire-rated partition.
Cylinders shall always be stored upright in a vertical position. In the case of acetylene, if a cylinder is found lying down, it must be set upright for at least one half hour before use to allow the acetone component in the cylinder to settle.
All high pressure gas cylinders need to comply with certain regulations. The following are highlights of the more common requirements for usage and handling.
Gas cylinders are made to be slightly tilted and rolled along their base. However, they shall not be dropped, dragged, or allowed to strike each other, or surrounding surfaces.
Moving cylinders may also be done by hand trucks, or cylinder hand carts. Lifting by hand typically takes two people. When lifting by cranes, hoists or forklifts a metal cradle or skid box shall be used- no rope or chain slings. When moving cylinders, always assume they are pressurized.
Gas cylinders are required to be secured in a vertical position when transported, or used. Cylinders in use shall be placed to avoid sparks, slag, or flames from reaching the tanks. Cylinders shall be placed where they cannot become part of an electrical circuit, or in the case of arc welding, be far enough away to prevent an arc from striking the cylinder. Cylinders shall not be placed, or used in any confined space. Cylinders (even empty ones) can never be used as rollers, or supports for any equipment or materials.
Fuel-gas valves shall be opened slightly, then closed (called cracking) before connecting the regulator to clear the valve of any dirt or dust first. The valve should be clear of any source of ignition, and the worker cracking the valve should stand to one side. When a regulator is placed on a gas valve, the valve should be turned open slowly to prevent regulator damage, and not opened more than 1-1/2 turns to permit quick closing. If a special wrench is used to operate the valve, it shall be left in place to permit quick closing of the valve. Any gases must be released from the regulator before disconnecting a regulator from the gas valve. Cylinders shall not become greasy or oily through use. Any grease or oil can become a fire hazard if oxygen is accidentally released. Clean off any grease or oils frequently.
Forklifts Multi-Employer Sites- Joint Liabilities
Most jobsites encountered have more than one contractor involved. If you’re the only contractor on a particular jobsite, and a CSHO [Compliance and Health Safety Officer] discovers violations, you would receive any citations and fines- simple.
However the way OSHA treats jobsites with more than one contractor may surprise you. For instance general contractors who disregard hazards created by other subcontractors onsite may find themselves with the same citation as well! In most cases, immediate [written if necessary] notification of any violations to the controlling contractor onsite to quickly eliminate the hazard will not only limit possible worker injury, but also prevent widespread citations passed out to all contractors onsite regardless of their perceived involvement.
Lets take a look at a hypothetical situation that could occur on a jobsite. Say a construction project has a construction manager and a general contractor. An excavation subcontractor opens up for an 8′ deep foundation, which is then poured. Before backfill is placed however, the plumbing contractor places a 2×10 board across the 8′ deep excavation for a walkway. Various subcontractors then walk across the board to gain access to the building interior to perform work. A CSHO observes the various trades crossing the makeshift ramp, contacts the construction manager, and conducts an inspection resulting in the citation of this single violation.
Question: Which contractors could be cited?
Answer: Every contractor onsite could be cited!
OSHA has defined who on a multiple-contractor jobsite can be cited for a single violation. This comes from the 29 CFR Part 1926.16 (a) through (d) titled “Rules of Construction”. The following applicable statements illustrate OSHA’s position with regard to each contractor’s responsibility concerning safety hazards.
(a) “…the prime contractor and his subcontractors may…make an agreement…thus relieving the subcontractors from the actual but not any legal, responsibility…”
(a) “…In no case shall the prime contractor be relieved of the overall responsibility for compliance with the requirements of the part [the OSHA Act] for all work to be performed under the contract.”
(b) “…the prime contractor assumes all obligations under the [OSHA Act] …, whether or not he subcontracts any part of the work.”
(c) “…[the subcontractor] also assumes responsibility for complying with the [the OSHA Act] with respect to [his portion of work]. Thus, the prime contractor assumes the entire responsibility under the contract and the subcontractor assumes responsibility with respect to his portion of the work. With respect to subcontracted work, the prime contractor and any subcontractor…shall be deemed to have joint responsibility.”
(d) “Where joint responsibility exists, both the prime contractor and his subcontractor[s] regardless of tier, shall be … subject to [the OSHA Act].”
OSHA has interpreted the above statements to define classes of contractors which can be cited for a violation. There are four types:
The “Exposing Employer”
This is defined as the contractor who by action or inaction allows his workers to be exposed to a hazard. In the hypothetical case described before, any workers crossing the makeshift ramp would allow OSHA to cite [and fine!] their employers- even if their employer had no knowledge of this happening!
The “Creating Employer”
This is defined as the contractor who actually created the hazard. In this case, the plumbing contractor or perhaps the excavation contractor would be determined as having created the hazard by not backfilling, or at least providing a walkway with handrails.
The “Controlling Employer”
This is defined as the contractor who has the authority to ensure that hazardous conditions are corrected. In this case the construction manager would have that role and could be cited for not having the hazard corrected.
The “Correcting Employer”
This is defined as the contractor who has the responsibility to actually correct the hazardous conditions. In this case the general contractor would likely have had that role and could be cited for not correcting the hazard..
As you can see in this example, many contractors can be cited and fined for each violation, depending on a contractor’s involvement- even if peripheral.
Now, what can you do to protect yourself from getting caught “in the net” with other contractors when violations are discovered? Again OSHA has developed a list of items as a defense to a citation- however, ALL ITEMS MUST APPLY:
The contractor did not create the hazard.
The contractor did not have the responsibility or authority to have the hazard corrected.
The contractor did not have the ability to correct or remove the hazard.
The contractor notified other contractors in control of the specific hazards to which it’s workers were being exposed to.
The contractor has instructed it’s workers to:
Recognize the hazard.
How to avoid it.
Where feasible- use protection from it.
Remove themselves from the jobsite.
From a review of the above items it would seem that each contractor onsite in effect has to make their own safety inspection of the jobsite prior to, and during the duration of work.
While this may seem impractical, safety is indeed everyone’s concern. Contractors who show written evidence of a practice of notifying other contractors of their potential safety hazards may go a long way in a favorable finding from a CSHO when handing out citations.
Another way to help your position whether you’re a general or subcontractor is to have safety as a regular topic of discussion. Almost every construction project has either weekly or monthly progress meetings. This is an excellent time for you to place jobsite safety on the agenda as an item to be discussed. This is where new hazards seen by any contractor can be brought out, and a plan to quickly eliminate it accomplished. Any new hazardous materials can be determined, the jobsite MSDS sheets updated, and all contractors brought up to speed as to what hazardous materials are onsite [another OSHA requirement].
All contractors onsite should work together to promote safety. At times any contractor can “slip up”, and a word from the general or construction manager can keep everyone onsite not only safe- but safe from possible collateral citations. Looking out for each other should be part of any construction project.
Are your workers storing materials correctly?
An OSHA safety course and safety training for your construction site can help keep you from having to deal with these issues. Contact us today for a materials safety manual for your jobsite.
A large part of the construction industry consists of simply moving, handling and storing various materials and equipment. From accepting shipments, loading and transporting tools and materials from the shop to the jobsite, moving materials around a jobsite, to loading and bringing tools and materials back to the shop. Thus, construction workers are usually involved in a constant state of material movement.
This is perhaps why material handling is a major factor in workplace injuries. Improper storage and handling methods can cause costly injuries. While it is discussed frequently, improper lifting is still a leading cause of workplace injury. Bending, and especially bending and lifting with a twisting motion can sometimes cause severe back injury. In fact, according to the National Safety Council, more than 20% of all occupational illnesses are the result of back injuries.
In addition to injury caused by lifting, workers can also be injured by falling or collapsing materials improperly stacked, or by the lifting or moving of equipment. The common actions that result in injury can be grouped into three categories:
Carrying or lifting loads that are too large and awkward, or too heavy can cause muscle or ligament tears, strains or sprains.
Being struck by, or caught between materials or lifting or moving equipment can cause fractures, bruising, or in extreme cases, even fatalities.
Falling materials, or improperly cutting ties, or straps can cause cuts, bruises and fractures to the worker or bystanders.
In most of the above cases, using personal protective equipment can prevent or limit injury from materials handling. Hardhats, gloves, safety shoes, eye, ear and face protection, and sometimes clothing can all contribute to protecting the worker.
Employers need to assess their storage areas and jobsites in an effort to minimize or eliminate causes of injury from material movement. The following are some of OSHA’s regulations regarding this subject.
When storing materials, it needs to be done in a manner that will not cause or contribute to fire propagation or explosion, overgrowth of weeds or vegetation, or to the harboring of rats and other pests. Naturally when storing flammable or combustible materials more stringent requirements apply. For instance, flammable liquids need to be separated from other materials by a fire wall. Also, combustible materials are required to be in an area where smoking and open flames or sparks are prohibited.
Another consideration is to provide sufficient aisle space around materials to allow for loading, unloading, and turning to prevent a worker from accidentally getting pinned between materials or equipment. Aisles should also be looked at for any trip hazards that may be present due to improper material storage. Overhead clearance shall also be assessed since materials striking an obstruction can fall onto workers.
When stacking materials, it’s important to be aware of the condition of the boxes or containers, accessibility, and the materials weight and size.
Materials bound together need to be blocked, or stacked in a manner that will prevent sliding, falling, or collapsing of material piles. Aisles need to be kept clear, especially any aisles that serve as a fire exit. If storing on a building or structure’s floor, care needs to be taken to ensure the floor loading is not exceeded.
When stacking lumber, OSHA will allow stack heights to 16 ft. when the materials are moved manually. If forklifts, or other similar equipment is used for material handling, lumber may be stored up to 20FT. If used lumber is stored, OSHA does require all nails to be removed before stacking.
When stacking brick or block, OSHA has height and stacking requirements also. Stacks of loose brick shall not be more than 7 ft. high, however any brick layers above 4 ft. shall be placed on a 1:6 taper (see diagram). Masonry blocks are allowed to be stacked higher, but any block layers higher than 6 ft. shall be placed on a 1:2 taper (see diagram).
When stacking bagged or bundled materials, they shall be stacked in interlocking rows for stability. Bagged materials shall be stacked by stepping back the layers and cross-keying the bags at least every ten layers.
When stacking drums or barrels, they need to be stacked symmetrically. If stored on their sides, the bottom layer of drums need to be blocked at the sides to prevent movement. When stacked on end, each layer of drums or barrels shall have planks, plywood, pallets, or other similar articles placed on each layer to provide a flat stacking surface for the next layer. In addition, the bottom layer of drums would be required to be blocked on the sides to prevent movement.
Finally, some materials may be more suitable for storage by placing in other containers, or racks. Also pipe and bars should not be stored in racks that face main aisle as it could cause a hazard to others when loading or unloading
This is part one of a two part series on material storage and handling.
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An OSHA safety course and safety training for your construction site can help keep you from having to deal with these safety violations. Contact us today for a custom written safety manual for your jobsite.