Myth #1 –A 5,000# anchor point is required for personal fall arrest

First of all, it is important to read the end of this paragraph! OSHA, and manufacturers of personal fall arrest equipment, have a minimum anchorage requirement of twice the anticipated with force to be applied on the system should a fall occur. This determination needs to be made by a qualified person, and/or an engineer. What this could mean in an extreme interpretation, would be that an engineer could actually determine the workers weight in particular, and design in anchorage system specifically for that workers weight at twice the anticipated force. Typical forces experienced with shock absorbing equipment is around 800 foot-pounds of force. Engineering to this typical value puts an anchor point at around 1600 foot-pounds minimum rated anchorage. The 5000 pound value was picked as a benchmark for a worker looking around and eyeballing a potential anchor point. Please note, however, that when it comes to fall Anchorage. More is usually better. Therefore, every attempt should be made to find the strongest anchorage possible, not just the minimum requirement.

Myth #2-fall restraint does not have a minimum anchor point rating

Fall restraint is when a person is rigged so that they cannot fall over the edge of an elevated platform. While it may seem intuitively true, that there would be a very small value used for restraint, it would seem that there would always be some value given by OSHA. The values I’ve been able to find is 3,500 pounds rated anchorage for restraint. While this may seem unusually high and restrictive (in that one could simply find a 5,000 pound anchor point and use PFAS) is a value that has been selected by OSHA. New fall restraint regulations are coming out shortly that may change this. While I personally think that in anchorage in the several hundred pound range would be sufficient, more is always better, ultimately.

Myth #3-if I fall in a harness, I need to simply wait for rescue

This is absolutely false. There is a phenomenon called suspension trauma, which may occur in a worker hanging from a harness, and being idle. The first thing you must do when hanging from a harness is to ensure that you are not bleeding somewhere. Check yourself over, and if you are bleeding use the proper first aid procedures to control or stop the bleeding. The next thing to do is to be aware that your legs hanging limp are going to cause blood pooling and a potentially fatal condition. Keep your legs active, especially your calves by pointing your toes, moving your legs, and trying to scoot back into your harness into more of a sitting position. What you’re trying to do is to keep the leg straps from cutting off circulation of the femoral arteries to your legs. In addition, workers from above may be able to pass down one or two ropes (or extension cords) with loops on the ends for you to put your feet into. They can then tie the ropes off and you could stand up in the stirrups and take some pressure off the harness straps. Again the important thing is to keep moving and active until rescue. After rescue, do not lie down! Remain in preferable a sitting position for 5 to 10 minutes and or, a standing position if you are able to or if someone can help hold you up. After about 10 minutes, you should be able to lie down with no problems. This allows any potentially toxic blood from your legs from overloading your heart muscles.

Myth #4-a standard shock absorbing lanyard is your best protection.

What has been the standard of the industry for decades, the standard six-foot shock absorbing lanyard is on its way out. New style lanyards now have stronger locking gates that can absorb the impact of a fall, allowing lanyards now to be wrapped back to themselves. This is especially convenient around scissors lifts, catwalks, and piping systems. However, even more importantly, is the advent of new lightweight self-retracting lifeline’s, or SRL’S. These SRL’s are now around the same price and weight as standard six-foot lanyards. However, SRL’s offer many advantages. They are effective at a much lower elevated height, even less than 6 feet above the lower level. They activate quicker, put less stress on the body, allow a lesser chance of hitting an object on the way down, and perhaps the most important feature, allow for self-rescue. There is very little strain on the body using an SRL as opposed to falling 6 feet with a shock absorbing lanyard.

Myth #5 – all fall arrest equipment, is the same.

On one hand, while all fall arrest equipment must comply with ANSI standards, equipment can vary widely among different manufacturers. There are complete fall arrest packages including an anchorage, vertical lifeline, shock absorbing lanyard and harness for $100. Then there is fall arrest equipment where the harness itself might run as high as $400. The differences will be in the ease-of-use and comfort when working and/or when hanging in the harness awaiting rescue. Generally speaking, the more expensive, the lighter weight and more comfortable the equipment will be. If you use fall arrest equipment on regular basis, it would probably pay to get the better equipment. There are no known cases of inexpensive personal fall arrest equipment failing due to their cost.

Myth #1 – guardrails are to be used just like any other railing

This is absolutely false. Guardrails are to be considered for accidental use only-that is when someone trips and falls against a guardrail. Guardrails by nature on a construction site are a temporary item and should not be considered as part of the finished building. Guardrails should not be leaned against, nor should you place your back against a guardrail and lean back into it.

Myth #2- guardrails are rated at 200 pounds.

The top rail of a guardrail has to withstand without failure a 200 pound outward force, with simultaneously a 200 pound downward force to the top rail applied at any place along the rail. The mid-rail will is required to withstand without failure a force of 150 pounds outward force with simultaneously a 150 pound downward force applied in any place along the rail. The key to remember is that all four of these forces are to be applied at the same time to the top rail and midrail. This amounts to a total of 350 pounds of total outward force, along with 350 pounds of total downward force applied at any point along the guardrail. Please note that the top guardrail is not allowed to flex or sag more than 3 inches with the downward and outward force is applied. These are tremendously high values placed on a guardrail system, and in virtually all cases, wooden guardrail systems do not comply with the standard. There are some manufactured brackets for wooden guardrails, which may satisfy this requirement. Bottom line – don’t trust guardrails.

Myth #3- there are no problems with wire rope guardrails.

Actually, there is typically one significant problem with wire rope guardrails. While wire rope guardrails can easily achieve the 200 pound and 150 pound guard rail rating, the issue is sag. Again, guardrails cannot sag more than 3 inches(and in no case less than 39 inches AFF) with the 200 pound weight applied downwardly and outwardly to the top wire rope. I have been on hundreds of job sites, and can say with confidence that virtually every wire rope guardrails system will easily sag more than 3 inches in a downward or outward fashion when far less than 200 pounds is applied to the guardrail. Wire rope guardrails need to have intermediate posts between columns to split the span and allow less sag.

Myth #4- it is okay to leave an opening in the guardrail for ladder access

While it’s obviously true that an opening is required in a guardrail for ladder access, a raw opening to below adjacent to the ladder is not the best practice, and allows for a fall exposure. You should build an L-shaped offset in the guardrail system so that no one can directly back into the opening inadvertently. In addition, if someone goes around the offset to access the ladder the actual opening to the ladder in the guardrail system needs to be no greater than 19 inches.

Myth #5 – it is okay to walk on floor covers

Absolutely not! Floor covers, much like guardrails are not to be used. Workers should make every effort to avoid stepping on floor covers. This is why floor covers are marked with the words “hole” or “cover” to point out the hazard and to allow the worker to instinctively avoid walking on it. Floor covers can certainly fail, and frequently do. They are rarely as strong as the floor itself.

Myth #1 – a written fall protection plan is an option

While OSHA allows an employer to prepare a written fall protection plan that essentially allows for fall awareness only-not physical protection from the fall, there is one important caveat. OSHA requires the employer to “prove” that conventional fall protection cannot be used. For anyone who has taken a logic class in school, it is impossible to prove a negative. Therefore, it is impossible for a contractor to conclusively prove that conventional fall protection cannot be used. The fall protection industry is a changing one, and new products and solutions are out on the market every year, even every month. It would be a safe bet that if a fall occurred, OSHA would quickly determine that conventional fall protection could’ve been used.

Myth #2- A Safety Monitor is an option.

For much the same reasons a Safety Monitor should not be used. Safety monitors will offer no physical protection against the fall, only verbal warnings are given to the worker. If you or a subcontractor is using a Safety Monitor as your primary means of fall protection, you are most likely incorrect. The OSHA regulations require conventional fall protection to be used except where unfeasible or would pose a greater danger to the worker. Again, should a person fall on your project, while using a Safety Monitor, it is almost a certainty that OSHA will determine that there was some opportunity to use conventional fall protection in this situation.

Myth #3- I can use a warning line system.

While warning line systems are acceptable to OSHA, again this is also against the caveat of unfeasibility. Traditionally, roofers have had an unwritten agreement with OSHA that a warning line system along with the Safety Monitor is adequate fall protection. However, when the chips are down (i.e., a fall occurs), all bets are off. OSHA will investigate and again will likely conclude that conventional fall protection should’ve been used. The warning line system set six feet back is to allow roofers behind the warning line to work unrestricted. Roofers between the six-foot line and a roof edge are still required to have conventional fall protection.

Myth #4- a warning line is to be set 6 feet from the roof edge

This is true only for roofing work. If you are performing other work on the roof, the warning line setback is actually 15 feet. This means that non-roofing workers on the roof can work unrestricted, but only up to 15 feet from the roof edge in the 15 foot region from the warning line to the roof edge conventional fall protection must be used

Myth #5 – I can calculate the fall hazard

This is a very tricky area. While OSHA recognizes that an employer can indeed calculate the feasibility of providing conventional fall protection, and whether it would pose a greater risk to workers, this is harder to prove that you were right when an accident has happened. You may in good faith determine in writing that it was more dangerous to provide conventional fall protection or that it would have posed a greater risk to workers to provide it, however, after an accident those calculations will not hold water under OSHA’s scrutiny. The obvious fact that an accident occurred is enough to throw to calculations out of your favor.

Myth #1 –I can wear a hardhat backwards if I choose to.

This is one of the more vexing problems on the job site. All too often, employees want to wear their hardhats backwards for no reason other than aesthetics. This is become so prevalent that now manufacturers are placing reverse donning stickers inside their hard hats. With the stickers the manufacturer is claiming and allowing the employee to where the hard hat backwards. However, most OSHA inspectors will not allow hardhats to be worn backwards unless there is a bona fide reason to do so. For instance in the mechanical crafts, who work overhead frequently, it may be appropriate. In addition, of course, hardhats are typically worn backwards for welding operations etc.

Myth #2-if I wear PPE, I can work without tool guards.

Absolutely false. This is more common in violation that he would realize. Frequently workers who wear safety glasses, his face shields, and other PPE feel that working without tool guards is safe since they are protected from flying objects. There are many reasons not to do this, however, the easiest one is that the manufacturers simply do not allow it. Therefore OSHA does not allow it.

Myth #3-to wear prescription glasses as safety glasses I have to add side shields.

Absolutely false. While side shields may help keep debris from entering a person’s eyes from side, prescription safety glasses are not rated as safety glasses. This is not because of the lenses, which are typically unbreakable, it is due to the frame itself. Common prescription frames are not rated to take the impact, and upon impact the lenses will simply pop out. The only appropriate way to wear prescription glasses is to wear OTG safety glasses or goggles over the prescription glasses.

Myth #4-OSHA requires steel toed safety shoes

Not usually. OSHA typically does not require steel toed shoes, where they rather leave it up to the employer to determine this. In special circumstances, such as jackhammering, not only steel toes, but metatarsal guards are required. And while safety shoes are typically required, in certain rare instances such as shingling a residential roof, tennis shoes are allowed when on the roof for their better traction and flexibility.

Myth #5 – if I decide to use a respirator voluntarily, I don’t need to comply with OSHA’s regulations are respirator use.

Not true. Even if you’re working in the environment which does not require respirator usage, and you decide to voluntarily use a respirator, there are still some things you need to comply with concerning OSHA regulations. The biggest problem facing employers is that each employee would still be required to be medically certified to be able to wear respirator, even if he brings one from home. The other lesser items to be strictly compliant would be recognizing that the care and use of the respirator is per manufacturers requirements, and that the employee still receives information on respirator use.

Myth #1 – Cost is an indicator of quality

Mostly true, however, it depends on what you’re looking for. If you’re looking for looks, the ability to repel water and dexterity top grain leather is best (and most expensive). However, if you’re looking for ruggedness, split leather (suede looking) is the best choice. It performs significantly better than top- grain leather in terms of wear, abrasion and tensile strength. The choice should be based on the level of protection alone. Top-grain leather is always more expensive than the suede leather version of the same glove.

Myth #2 – More layers mean more protection

Layered construction in the palm area of leather gloves also leads one to believe that a patch palm is going to double your protection. The reality with most patch-palm leather glove styles is that the patch exists as a kind of bridge between two pieces of leather to create a full palm. The fact of the matter is, if the thread wears away on the patch, the glove palm splits in two.

Myth #3 – Chemically-resistant gloves protect you from all chemicals

Use your MSDS sheet to determine what your clove has to chemically resist. However, it’s also important to know what the glove cannot come into contact with that is of utmost importance. A PVA (polyvinyl alcohol) glove, for example, which stands up to many of the harshest chemicals and solvents known to man, will dissolve in water. Another example is exposing latex gloves to , say gasoline. Knowing what chemicals a glove protects against is important, but inquiring as to which chemicals may weaken it is important, too.

Myth #4 – If the glove is heat resistant, you won’t get burnt

When it comes to a glove’s heat resistance, be sure to look for heat resistant/ insulative wording. While a glove my withstand temperature contact up to 1,000 F without burning or melting, it may do little to protect the hand inside it, not without a really good layer of insulation in between. That’s because heat resistance and insulating properties are two different things. Just because the material can take the temperature, doesn’t mean the glove has been designed to insulate against that temperature.

Myth #5 – Certain gloves are cut-proof

When talking about the property of cut resistance, the most important distinction to make is that gloves are cut-resistant, as opposed to cut-proof. In fact, there is not a glove in existence that can claim to be cut-proof. I have proven this many times in training classes.

Hopefully, most electrical workers will never see and an flash accident. However, OSHA reports there are an average of 10 Arc flash incidents everyday in the US. There are also studies that indicate up to 80% of all Electrical Worker injuries are not due to shock, but due to external burn injuries created by an arc flash explosion.

MYTH #2 Street clothes made of cotton or other natural fibers will provide protection

Only at lower arc flash energy levels. Cotton denim jeans, shirts are only acceptable at the lowest arc flash rating of 1. At any energy level above that, you must wear cotton underwear, along with fr rated clothing. Cotton and wool definitely are flammable fibers and can ignite if exposed to the intense radiant energy of an Arc flash. Flame Resistant (FR) clothing which meets the requirements of ASTM F1506 and NFPA 70E will not ignite and continue to burn on the human body, and can additionally provide thermal protection for the areas of the body that it covers.
MYTH #3 – I wear a faceshield… that should be enough

It depends upon the faceshield. In the marketplace, there are some Arc Rated Faceshields. Arc flash faceshields are required to be tested to ASTM F2178 test method to determine their arc protective rating. Arc Rated Faceshields are typically used for electrical work where the hazard is below 8 calories/ cm2 or NFPA 70E Hazard Risk Category #1 and #2.

MYTH #4 If I wear an arc flash rated faceshield I don’t need a hood

An Arc Rated faceshield provides effective protection for the areas that it covers, i.e. the face and to some degree the frontal neck area. Depending on the design, convective heat can travel under the face shield and cause burns even to the face especially for higher-level Arc flash exposures. Of course, a face shield cannot protect the sides and back of the head or the neck. An Arc Rated Hood provides uniform protection for the entire head and neck. Further, the use of an Arc Rated faceshield is limited to tasks designated by NFPA 70E Hazard Risk Category (HRC) #2. For tasks designated by HRC 2*, HRC 3 or HRC 4, the use of full hood is required.
MYTH #5 – FR Clothing is all the same.

Not true, there are two basic types of FR Clothing. Flame Retardant Treated (FRT) clothing, which is simple cotton made flame resistant due to a flame retardant chemical treatment applied to the fabric, and Inherently Flame Resistant clothing, which is made from fabrics and fibers with a chemical structure that will not burn in air. Additionally, It has been shown that the FRT Cotton clothing can lose their flame resistance if laundered incorrectly, e.g. with a bleach. With inherently FR clothing, there is no treatment so there is nothing that can be washed off.

Job Location:
Supervisor: Date:
Inspector:

Administration: Y N NA
a) Pre-construction meeting with subcontractors re: safe work practices   
b) OSHA poster and other warning signs posted   
c) Emergency phone numbers posted   
d) Written Safety Program on site including HazCom Program   
e) Weekly safety meetings documented   
f) MSDS from all subcontractors   
g) Hazardous chemical list updated for job   
h) Competent Person assigned for site   
Employee/Subcontractor/Additional:

First Aid and Emergency: Y N NA
a) First aid kit fully stocked   
b) Employees aware of personnel trained in first aid   
c) Employees aware of emergency procedures   
Employee/Subcontractor/Additional:

Housekeeping: Y N NA
a) General neat appearance of all work areas   
b) Passageways and walkways clear   
c) No projecting nails and screws   
d) Regular site cleanup and trash disposal   
e) Materials stored/stacked in orderly and safe manner   
Employee/Subcontractor/Additional:

Fire Prevention: Y N NA
a) Proper number of Fire Extinguishers provided and charged   
b)”No Smoking” posted and enforced (no cigarette butts in posted areas)   
c) Combustibles >10’ from building   
d) Approved safety cans for gasoline   
Employee/Subcontractor/Additional:

Electrical: Y N NA
a) Terminal boxes equipped with required covers   
b) GFCI’s in place (if “NO”, see f.)   
c) All extension cords are 3-wire with ground pin in place and in good condition   
d) All electric tools and machinery have ground pin in place on power cable   
e) Exposed light bulbs equipped with protective cage   
f) Competent person if assured equipment-grounding program used in lieu of GFCI   
Employee/Subcontractor/Additional:

Tools, Hand and Power: Y N NA
a) GFCI or grounded   
b) All guards in place   
c) Tools and cords in good condition   
d) Inspected and maintained   
Employee/Subcontractor/Additional:

Stairways and Ladders: Y N NA
a) Inspected and in good condition   
b) Properly secured   
c) Siderails extend 36” above top of landing   
d) Ladder available for access to scaffolding   
e) Guardrails provided for stairway landings   
f) Handrails provided for stairways with four or more risers   
g) Competent person periodically inspect ladders   
h) Competent person conducts ladder safety training   
Employee/Subcontractor/Additional:

Scaffolding: Y N NA
a) Properly erected and supervised by competent person   
b) Scaffolding tied to structure   
c) Scaffolding plumb, with cross bracing in place   
d) Fully planked with toe boards in place   
e) Base plates used ( no cinder blocks)   
f) Ladder access provided   
g) Employees tied-off while working on elevated motorized scaffolding   
h) No riding on rolling scaffolding   
Employee/Subcontractor/Additional:

Hoists, Cranes and Derricks: Y N NA
a) Inspections of cables, slings, chains, hooks, eyes by Competent Person   
b) Inspection logs maintained   
c) Power lines deactivated, removed, protected or safe distance   
d) Swing radius protected (360 degrees)   
e) Load capacity chart on machine   
f) Proper hand signals used   
Employees/Subcontractors/Additional:

Motor Vehicles & Heavy Equipment: Y N NA
a) Service brakes and trailer brake connections inspected daily   
b) Parking brake and service brake operable   
c) Tires, horn, backup alarms, seat belts inspected   
d) Lights, windshield wipers, defroster   
e) Fire Extinguisher in place and fully charged   
f) Weights and loads controlled   
g) Personnel carried safely – seat belts provided   
Employees/Subcontractors/Additional:

Excavations: Y N NA
a) Shoring adequate for soil and depth   
b) Support system in place for adjacent structures   
c) Spoil bank and equipment sufficient distance from excavation   
d) Ladders provided   
e) Competent person on site   
f) Underground utilities located prior to excavation   
g) Air samples taken prior to entry in underground tunnels/openings   
Employees/Subcontractors/Additional:

Welding and Cutting: Y N NA
a) Personnel qualified   
b) Screens, shields, goggles, gloves   
c) Gas cylinder secured in upright position   
d) Fire Extinguisher   
e) Electrical equipment grounded   
f) Valve protection caps in place when gas not in use   
g) Fire watch provided 30 min. subsequent to welding near flammable/combustibles   
Employees/Subcontractors/Additional:

Concrete and Masonry: Y N NA
a) Proper scaffolding   
b) Safe hoisting equipment   
c) Masonry walls over 8 ft. braced   
d) Limited Access Zone established   
e) Fall protection used   
f) Guard rails on all open floors   
g) All protruded rebar guarded   
h) Hard hats and safety shoes   
Employees/Subcontractors/Additional:

Highway/Work Zone: Y N NA
a) Competent Flagmen reflective garments, instructed, posted   
b) Adequate warning signs and markers   
c) Traffic control through construction area   
d) Dust control   
e) Work Zone of Heavy Equipment protected from pedestrians and other traffic   
f) Equipment inspected daily   
g) Back up alarms and horns operational   
h) Proper lighting   
Employees/Subcontractors/Additional:

Fall Protection: Y N NA
a) Floor openings   
b) Guardrails in place/replaced after each load received   
c) Safety harnesses provided and used   
d) Double-locking snap hooks on all Personal Fall Protection   
e) Floor holes protected/secured/marked   
f) Wall openings guarded   
Employees/Subcontractors/Additional:

General: Y N NA
a) Hard Hats   
b) Proper footwear   
d) Ear Protection   
e) Eye Protection   
f) Potable water   
g) Unusual exposures identified and controlled   
Additional for this inspection:

All of our safety rules must be obeyed. Failure to do so will result in strict disciplinary actions being taken.

We are especially concerned with the four major causes of death in the construction industry, namely: Fall hazards, struck by hazards, electrical hazards, and caught between hazards.

Our disciplinary actions escalate the more severe the violation.

Level One Violation
verbal warning
written warning
3 days off
permanently off site

Level Two Violation
written warning & 3 days off
permanently off site

Level Three Violation
permanently off site

Examples of Level One Violations – not likely to cause serious injury or death

1. Not having one or more MSDS’s for materials onsite. You are required to have MSDS’s for all materials and chemicals onsite. In addition, these MSDS’s need to be readily accessible by not only yourself, but by the GC, CM. Owner, etc.

2. Not having PPE available with you for customary work you may do occasionally, such as, proper gloves, goggles, respirator, hearing protection. While these items may not be used 100% of the time, you need to have these, and perhaps other items with you at all times (depending on your work) to be effectively protected when the situation arises.

3. Poor behavior, such as: wearing hardhats backwards when not approved by the manufacturer, smoking in inappropriate areas, creating a nuisance with loud radios, excessive trash in work areas, horseplay, obstructing other workers’ ability to perform their work.

Examples of Level Two Violations – may cause serious injury or death

4. Not wearing PPE that’s a 100% requirement on the project site. Examples are hardhats, safety shoes and safety glasses. Areas designated for 100% hi-visibility shirts or vests, which may be the entire site, or an area where crane or heavy equipment operations are taking place.

5. Removal of safety guards or features, and or operating equipment without safety guards correctly in place.

6. Entering an area clearly marked with red DANGER tape. These areas are marked in red because of the extreme hazards they present. Do not enter these areas without authorization.

7. Improperly using a ladder. Standing on the top platform, or top step of a stepladder, leaning a stepladder to work on it, not extending an extension ladder three feet past the upper landing area are all examples of improper ladder use.

8. Using defective power tools or extension cords. Not using GFCI receptacle, or circuits.

Examples of Level Three Violations – likely to cause serious injury or death

9. Working at heights over six feet without some physical form of fall protection. This may involve passive fall prevention methods (guardrails, covers, restraint), or active fall arrest (personal fall arrest equipment). Other fall protective measures, such as warning lines, controlled access, and safety monitors are strictly prohibited, unless specifically approved on a case-by-case basis by the GC/CM.

10. Working outside of an area protected from vehicular traffic without permission, working underneath hoisted loads or objects that are not locked out.

11. Entering a trench excavation deeper than five feet without protection. Trenches over five feet deep must be shored or sloped as required. Keep out of trenches or cuts that have not been properly shored or sloped. Also be aware that some excavations less than 5 ft may also require cave in protection in some instances.

12. Operating equipment, or holding tag lines, or working in aerial lifts, platforms, or scaffolds closer that ten feet to a powerline that is over 300 volts.

Ten common safety rules that may apply to your jobsite:

1. Submittal of morning Jobsite Hazard Analysis (JHA) +scope of work for the day.
2. Hard hats, safety shoes and safety glasses required at all times
3. Gloves when handling sharp materials.
4. High visibility shirts/ vests required at all times.
5. No radios, headphones and IPods allowed on projects.
6. Scaffold wheels locked on a mobile scaffold before climbing it.
7. 100% six foot fall protection rule for all areas except for ladder use.
8. Ladders used for the purpose they were intended
9. 100% fall protection rule when working off ladder adjacent to a greater fall hazard than the level the ladder’s on.
10. Housekeeping. Buildup of trash, cords, and scrap materials can cause slips, trips, and lacerations.

On April 22, 2010, Dr. David Michaels, head of OSHA, sent a letter to his 10 regional administrators outlining the new rules in an effort to blatantly increase the dollar amount of penalties for deterrence. The penalty changes will become effective over the next several months.

Some details on the new penalty plan are:

Looking at five years of your past violation history when assessing a current penalty rather than the current three years. If you’re clean, you may get a 10% reduction – of course this will now be 67% harder to achieve. However, if you have been cited for anything more than a “less than serious” violation, your penalty is increased 10%. Again, this is 67% more exposure.

Looking at five years of your past violation history when assessing a repeat violation penalty rather than the current three years. Again, this is 67% more exposure.

Establishing a “Gravity-based” penalty system that results in $3,000 and $7,000 for all serious violations.

No reduction in penalty for employers with 251 or more employees.

Elimination of a 10 percent reduction for employers with a strategic partnership agreement.

Establishment of a penalty floor. The minimum proposed penalty after history, size and good faith adjustments will be increased to $500.

Dr. Michaels states that these changes will generally increase the overall dollar amounts of all OSHA proposed penalties. He believes that the average penalty for a serious violation will increase from approximately $1,000 to an average of $3,000 to $4,000.

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.

Storage Basics – Inside and Out:

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.

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 20B fire extinguisher located from 25 ft. to 75 ft. away from the storage area.

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 regulations, 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 some residual pressure 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.

Usage and Handling Basics:

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.