Top Ten OSHA Violations

The first step toward making anything better is identifying what’s broken—or maybe even discovering what’s never been right in the first place. This may seem obvious, but recognizing problems isn’t necessarily as simple as it sounds. Finding flaws requires a thorough knowledge of relevant details coupled with a commitment to excellence.

And it goes without saying… if such diligence is called for in ordinary circumstances, how much more so in situations where workers face risks to their health and safety?

Where to begin

When it comes to assessing workplace safety, OSHA’s annual Top 10 Most Frequently Cited Standards is a good place to start. Unfortunately, every year companies fail to implement necessary worksite safety procedures and protocols, but you can learn from their mistakes. That’s exactly why OSHA publishes its Top Ten list: so that you “can take steps to find and fix recognized hazards addressed in these and other standards before OSHA shows up.” (emphasis added)

When it’s not a good thing to be number one

  1. The most violated OSHA standard is 29 CFR 1926.501.

This standard delineates the “duty to have fall protection” for construction industry workers. This standard addresses hazards such as unprotected sides and edges, leading edges, holes, walking/working surfaces, roofs, dangerous equipment, and more.

If 29 CFR 1926.501 applies to your worksite, take the time to reread it in detail, carefully considering the requirements specific to your environment. Questions you might ask yourself include: Are the surfaces my workers use strong and structurally sound? Are my workers positioned high enough to be protected from hazards below? Do they need guardrails or personal fall arrest systems? Are they exposed to falling objects, and, if so, are they wearing the necessary head protection? After you’ve comprehensively reviewed this standard, inspect your jobsite thoroughly for compliance.

Then—if your investigation has exposed a problem—you can do whatever is necessary to comply with the appropriate regulation(s) in a timely manner. This, in turn, will bring you peace of mind: not only will you be prepared for an OSHA inspection, but your workers will have maximized their chances of ending each day without a preventable fall-related injury.

Don’t stop there

The nine standards completing the OSHA Top 10 list are:

How Leading Edge Standards Affect Your Choice of Fall Protection Equipment

It’s crucial that employees have equipment to help protect against serious injury and death when working at heights. Fall protection is a vital part of construction, industrial maintenance, and related fields and industries.

Even though providing fall protection equipment is required by OSHA regs, as a safety professional, your commitment goes deeper than just compliance. You want your team members to go home each night to their families.

Here are some sobering statistics for the construction industry.

In 2016, OSHA (the Occupational Safety and Health Administration) reported that out of 4,693 deaths in private industry, 991 or over 21% were in construction. In other words … one in five worker fatalities.

Of those 991 construction fatalities, 384 or over a third of them were the result of falls. What’s even more disturbing is that of the top 10 most frequently cited OSHA standards violated in 2017, fall protection in construction continues to be number one. We need to improve those statistics.

One of the most talked about topics in fall protection is the “leading edge” concept and it’s been the subject of regulatory and standards organizations for the past several years.

In this article, we’ll discuss:

  • How “leading edge” is defined by OSHA
  • How it affects the design of fall protection equipment
  • What to look for when choosing SRLs (self-retracting lanyards) for leading edge applications

At the end, I’d like to relate an interesting historical anecdote related to the hidden benefits of fall protection. You can use it as a talking point with your workforce and it’s a good topic to discuss with the stakeholders who hold the purse strings to your safety equipment budget.

How leading edges are defined

A leading edge is any unprotected edge of a platform, floor, or other construction point where the elevation between the next level or the ground is greater than six feet.

Here’s how OSHA defines it. In its official publication, Fall Protection in Construction (OSHA 3146-05R 2015), OSHA states:

Leading edge: The edge of a floor, roof, or formwork for a floor or other walking or working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed. A leading edge is considered to be an “unprotected side and edge” during periods when it is not actively and continuously under construction.

An example is when installing metal decking for flooring in a multi-story building.

A guardrail system would be an ideal solution for leading edge applications. But it’s not always feasible. Some form of personal fall arrest system must also be used.

So, let’s put this in real life terms. For work above 6 feet, construction workers and others know that fall protection is necessary. And most of the time, a worker can tie off to an anchor point above the D-ring on the harness.

However, leading edge work is different in several ways. First, there’s the edge itself. Often, it’s at the open side or edge of a building where the workers are laying decking, or performing other flooring or roofing tasks. In many cases, that edge is sharp, with either a very small radius or a 90 degree sharp angle. Should a crew member fall, the lifeline will come in contact with that edge. It’s often the sharp edge that could cut or fray the cable or webbing, particularly on impact. But, it’s also likely that the worker might sway back and forth while dangling over the edge.

Unless the worker falls directly in line with the anchor point, this pendulum style movement will naturally occur. That back and forth movement can quickly sever a lifeline cable or webbing that’s not designed for it.

The other potential hazard is the anchor point itself. The anchorage is usually below D-ring level, often at foot level. Low anchorage is necessary because there’s not always an overhead, approved attachment point, such as a wall or ceiling joist, and the lower anchor point doesn’t interfere with a worker’s arm movement. However, this means that the worker could fall farther before the deceleration device on the SRL or PFL catches. The lifeline might not reach the necessary speed to engage quickly enough to prevent some dangerous fall distances.

Not all PFLs or SRLS are designed for the low anchor points necessary in leading edge tasks. When combined, the leading/sharp edge and lower anchor point require specially designed fall protection equipment.

A basic personal fall arrest system consists of an anchorage point, connectors, and a body harness. (By the way, don’t even consider a body belt. They’ve been banned for fall arrest since January 1, 1998.)

Complete systems include a lanyard, deceleration device, and a lifeline. Some use PFLs (personal fall limiters), while other employ SRLS (self-retraction lifelines).

PFLs are limited to eight feet or less in length. SRLs allow for far greater range of movement, reaching as up to 20 feet or more. SRLs or PFLs may provide a safety option for leading edge operations. The anchor point in leading edge applications sits below the D-ring attachment on the harness, often at foot level. But, it’s the leading edge/sharp edge hazards that ultimately affect the design of leading edge fall protection equipment.

How leading edges affect fall protection design

ANSI (the American National Standards Institute) has even tougher standards and pays particular attention to lifeline performance in leading edge/sharp edge applications.

As mentioned above, a sharp edge is any non-rounded edge that can potentially cut, fray, or completely sever a lifeline or lanyard. The ANSI standard for testing the fall arrest device’s lanyard is dropping it over a steel bar with a radius of .005 inches or less. If there’s any severe damage or a complete separation at the point of impact, the device fails and it’s deemed noncompliant for a leading edge application.

The SRL must meet the conditions for dynamic performance, dynamic strength, and static strength as outlined in ANSI Z359. But, it must also pass the sharp edge test standard for leading edge approval.

By the way, only SRLs that pass the sharp edge requirements are permitted to include the LE designation on their label. So, be sure that it’s labeled SRL LE.”

What to look for in leading edge permitted SRLs

The device must carry the SRL LE designation for use in leading edge/sharp edge work. But here are some other options to consider.

According to OSHA standards, every SRL (whether for leading edge or not) must be inspected prior to each use. Some devices come with a clear outer casing that let you visually check the cable, retraction dampening controls, and other internal components.

Any fall limiting device that is subjected to an incident must be taken out of service immediately, but you can put the device back into service quickly if internal components, cabling, and user-side shock absorber can be replaced onsite. This is a time saver if available.

By design, most SRLs are flat, disc-shaped mechanisms. Look for devices that include an integrated roll cage. This increases the life of the SRL LE by lessening damage caused by scraping along hard surfaces.

One final note:

Non-leading edge designated PFLS and SRLS cannot be used for leading edge or sharp edge work. But the reverse is not necessarily true. Fall arrest devices rated SRL LE can often be used in other applications.

You can save money by purchasing an SRL LE certified for other tasks as well.

Now… here’s that historical anecdote I mentioned.

The hidden benefit of effective fall protection

The year was 1933. The high-steel project? None other than the 1.2-mile-long Golden Gate Bridge, set to span the Golden Gate Straight where the San Francisco Bay emptied into the Pacific Ocean.

The problem? In those days, the number of fatalities expected was one man for every $1M of construction cost. The bridge was expected to cost well over $36M. For the lead engineer, Joseph Baermann Strauss, this loss of life was unacceptable. Along with other safety innovations—hard hats, wind goggles, and respirators, to name a few—he installed a unique, lifesaving form of fall protection.

A safety net was strung from one end of the bridge to the other. It was installed as each span was added. Once the net was in place, workers worked more quickly and efficiently, the fear of drowning all but eliminated. Nineteen men fell into the net, but they were saved from drowning in the ice waters of the Bay.

The result? The bridge was constructed $1.3M below budget… and months ahead of schedule. Fall protection can save lives, and that’s vital. But it can save time and money as well.

In a very real way, money spent on fall protection gear is not just a purchase… it’s an investment for—and in—everyone involved.

Don’t Lose Your Cool: Refrigerant Leak Detection

Your building’s mechanical equipment room is the hub of its HVAC system. But the equipment in these rooms has the potential to leak toxic gases—including costly and environmentally harmful refrigerant gas. At high concentrations, these gases can displace oxygen, endangering facility personnel.

Fundamentals

Let’s review the three primary reasons to monitor equipment rooms for refrigerant gas leaks: worker safety, economic considerations, and environmental concerns.  

The first, and most important, objective is to provide men and women with a safe work environment.

Refrigerants are toxic and considered an asphyxiate at high concentrations. ASHRAE 15—the standard governing refrigerant leak detection in machinery rooms—deals with personnel safety. It states that:

  • Each machinery room shall contain a detector located where a refrigerant leak would concentrate.
  • The detector shall trigger an audible and visual alarm both inside and outside the mechanical room and activate mechanical ventilation.

Economic factors also come into play.

The loss of refrigerant plus the recovery process plus the evacuation of the affected area equals lost productivity and higher operating costs. The most cost-effective refrigerant leak monitor uses sample-draw technology, in which a central panel pulls a sample drawn from various lengths through a sensor. Mounted inside or outside the mechanical room, the monitor uses either flexible tubing such as polyurethane or hard tubing such as stainless steel or copper.

Lastly, several regulatory bodies drive requirements concerning unauthorized greenhouse gas emissions.

Expect this trend to grow as global warming continues.

Real-World Recommendations

Since refrigerant is heavier than air, it tends to pool towards the ground; therefore, ensure that sampling lines are not placed too high to detect leaks. Best practice prescribes locating sample lines towards the barrel of the chiller on adjacent sides for complete coverage. Additionally, consider positioning a sampling line in recently serviced or known problematic areas.

A sensitive leak monitor is one of the best ways to help prevent a minor incident from becoming a crisis. The monitor should:

  • Activate exhaust ventilation systems.
  • Interface with a Building Management System (BMS) using either digital or analog communication.
  • Notify facility personnel of a hazardous situation.

Further Insight

If you’d like to learn more, a new on-demand webinar details how MSA Safety’s Chillgard® 5000 Refrigerant Monitor can help mitigate harmful and costly refrigerant leaks.

  • See how the earliest level of detection keeps leaks under control.
  • Discover how predictive maintenance results in worry-free operation.
  • Understand how a modular, scalable design allows for low cost of ownership.
Inspecting Your Safety Harness Part I: Five Steps to Help Keep You Safe on the Job

Would you drive your truck to work with a flat tire?
Nope, you’d change the tire first.

Would you fix an electrical socket without turning off the power?
Absolutely not—you definitely wouldn’t risk electrocution!

How much more, then, should you inspect your harness before you’re exposed to potential fall-associated risks on the job?

After all, you’re the person who’s wearing it—it’s your health and safety. So don’t forget to inspect your harness before initial use during each work shift. Not only is it the smart thing to do, but OSHA requires it.

Wondering where to start or not sure if you’re covering all the bases? Don’t be intimidated—inspecting your harness isn’t overly complex or time-consuming when you understand what you’re looking for. You can simplify the process by breaking it down into five manageable steps that correspond to the five harness components you should always check:

Labels

Why do labels matter? Primarily, they contain warnings, standards information, and other particulars you should be aware of, such as the harness’s weight capacity. They also identify your individual harness using a unique serial number. That’s helpful especially if your harness is involved in a fall, allowing it to be tracked by your company and the harness’s manufacturer.

Therefore, confirm that the plastic label tags are affixed to the harness, and make sure you can read them clearly.

Load Indicators

Load indicators are folds sewn into the webbing on the back of the harness. When the harness is subjected to a fall, these folds rip apart and their threads fray. If your harness’s fold indicators show signs of wear and tear, the unit should immediately be removed from service.

Webbing

This is the most common place to spot imperfections. Like any fabric, webbing is vulnerable to cuts, fraying, and abrasions; examine your harness thoroughly, taking note of these flaws as well as other excessive wear. Is any of the webbing missing? Has it been altered, such as with duct tape? If the webbing exhibits any of these defects, retire the harness.

The webbing might also have been exposed to excessive heat and chemicals. Check for burns, scorch marks, melting, or other signs that the webbing has been compromised. And if your harness is filthy, it’s disqualified from service. Why? It’s not that your harness can’t take a little dirt, but the fact is that grime can make other defects harder to see. Furthermore, some of those substances staining the harness could, in fact, be damaging it over time, perhaps abrading the fabric or corroding the buckles.

Hardware

Speaking of buckles, do not wear a harness with bent or dented metal components—D-rings, leg buckles, chest buckle. Dents suggest that your harness may have experienced a fall.

Stitching

The places where the parts of your harness are sewn together bear your body’s weight, so you want the stitches perfectly intact to maximize their holding power. Broken or missing threads mean that your harness fails inspection.

That’s it! Minimize the chance of injury on the job by using these five simple steps as a guide to inspecting your fall protection harness every time you wear it. And remember, in addition to the assessment described here, your harness should be inspected by a competent person every six months.

View a video demonstrating what we’ve discussed in this article.