Safety Blog

I was interviewed on April 11, 2024 by Delaney Tarpley of WECT following Wilmington, NC workzone fatality:

Click here to see interview.

Jon

By W. Jon Wallace, CSP, MBA

Some employers assume OSHA compliance is achieved merely by compliance with the applicable OSHA code of federal regulations (e.g. 1910 General Industry, 1915 Maritime, 1926 Construction, 1928 Agriculture). However, this does not necessarily ensure full OSHA compliance. Employers must also be familiar with other OSHA enforcement tools such as Incorporation by Reference; the General Duty Clause; Letters of Interpretation; Standard Interpretations (STD’s); and Compliance Directives (CPL’s). To help assist you with the maze of OSHA compliance, listed below is an explanation of each of these OSHA enforcement tools.

Incorporation by Reference is defined in 29 CFR 1910.6(a)(1) of the OSHA General Industry standards. OSHA lists government standards as well as consensus organization standards (e.g. ANSI, ASME, API, ASTM, CGA, NFPA, and SAE) which are incorporated by reference. These publications have the same force and effect as other OSHA standards. One example is the ASME Code for Pressure Vessels, 1968 Edition. It is important to understand, however, only the mandatory provisions (i.e. provisions containing the word “shall” or other mandatory language) within these standards are enforceable by OSHA.

The General Duty Clause is listed under Section (5)(a) of the OSH Act:

“Each employer –

(1) Shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;”

The General Duty Clause is used to cite an employer when a specific OSHA standard does not exist. Examples: heat stress, workplace violence, and ergonomics.

Publications are documents published by OSHA that have not gone through the OSHA rulemaking process. In some cases, OSHA will issue a publication, such as Ergonomics Program Management Guidelines for Meatpacking Plants and Guidelines for Preventing Workplace Violence for Health Care and Social Workers. Publications are not enforceable as OSHA standards but in some cases may be used in conjunction with the General Duty Clause to cite an employer for an unsafe work practice.

Letters of Interpretation are written responses to employers who write OSHA requesting an interpretation on a specific OSHA standard. These interpretations are available on the OSHA Web Site. Although a letter of interpretation is not enforceable, it does provide guidance on OSHA’s perspective on a specific OSHA standard.

An example is the “Permissibility of a Consent form with a waiver of liability” interpretation (July 22, 1993 – Anne Sturtz). The Bloodborne Pathogen standard [29 CFR 1910.1030(f)(1)(ii)(A)] requires the hepatitis B vaccine be made available at no cost to all employees who have occupational exposure to bloodborne pathogens. This letter of interpretation states it is not acceptable for employers to require employees to sign a waiver of liability in order to receive the hepatitis B vaccine. OSHA feels requiring an employee to sign a waiver of liability waives future rights for the employee and therefore is a cost to the employee. The entire letter of interpretation may be viewed on the OSHA Web site.

Standard Interpretations (STD’s) are issued by OSHA to amend, change, or interpret an OSHA standard. Unlike Letters of Interpretation, an STD is legally enforceable. For instance, STD 01-08-002 clarifies Medical Services and First Aid; 29 CFR 1926.50 and 51, Medical Service and First Aid, and Sanitation, Respectively; Applicable to Electric Storage Battery Charging and Maintenance Areas.

Compliance Directives (CPL’s) provide instruction to an OSHA Compliance Officer on conducting inspections on a specific OSHA standard. Comparing an existing safe work practice against an applicable OSHA CPL is a valuable tool in assessing OSHA compliance. CPL 02-00-124  addresses multi-employer worksites.

As you can see, the OSHA regulations are only one facet of ensuring OSHA compliance. As a matter of fact, if you were to place all of these documents on top of each other, the stack would be well over 6 feet high!

It must be stressed that OSHA standards should be considered a minimal set of guidelines and don’t necessarily ensure employee safety. In some cases, specific safe work practices as well as “state of the art” industry safe work practices must be implemented to ensure employee safety.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail

By W. Jon Wallace, CSP, MBA

The lockout/tagout standard – 29 CFR 1910.147 – is arguably the best OSHA standard ever written. For the price of a lock and tag, an employee can be confident they are protected from the sudden release of hazardous energy while performing maintenance, cleaning or servicing activities on equipment. When performed correctly, lockout/tagout is extremely beneficial, however, when performed incorrectly, serious injuries and fatalities may occur.

During the last fifteen years, I’ve had the opportunity to review lockout/tagout programs for a broad range of industries such as the chemical, nuclear, pharmaceutical, steel, food, furniture, paper, semiconductor, and textile industries. Listed below are critical elements necessary to ensure an effective lockout/tagout program.

1. Servicing and Maintenance activities versus lockout/tagout
   I recently observed a machinist reprogramming a CNC machine with his arms entirely inside the machine. When questioned about lockout, the machinist stated: “This is a normal production operation – lockout is not required.” This is a very unsafe practice; a multiple amputation could occur if the machine were to suddenly become energized. Do your employees follow lockout/tagout when changing the grinding wheel on an abrasive grinder, adjusting the belt speed on a drill press, or changing a light ballast on a fluorescent light? Lockout procedures must Clearly define what constitutes normal production operations versus when equipment must be locked out.
   
2. Identifying all energy sources: equipment-specific procedures
   To ensure employee safety, it is imperative that all potential energy sources are identified. Employees typically apply locks and tags on the main electrical disconnect, however, additional energy sources may exist such as thermal, hydraulic, pneumatic, radioactive, gravity, or chemical energy. OSHA requires equipment-specific lockout procedures for equipment containing two or more energy sources. [See 29 CFR 1910.147 (c)(4)].
   
3. Correct identification of energy isolating devices
   When isolating energy sources, employees frequently lock out control circuit type devices such as on/off switches, emergency stops, interlocks, and three-way selector switches. This is a very unsafe practice; control circuits do not isolate the flow of electrical energy to a piece of equipment. To achieve proper equipment isolation, an energy isolating device, such as an electrical circuit breaker or main electrical disconnect, must be locked out. For OSHA’s explanation of an energy isolating device, refer to 29 CFR 1910.147 (b).
   
4. Protection of all employees
   Lockout/tagout ensures employee protection while performing servicing, maintenance, and other activities on equipment. However, lockout/tagout is seriously compromised when more than one employee is working under the same lockout/tagout device. An employee could inadvertently remove their locks and tags, seriously exposing unprotected employees. The best practice is for each employee to apply their personal lockout/tagout devices to each energy isolating device. For complex jobs involving several employees and multiple energy sources, group lockout may be utilized.
   
5. Correct selection and use of locks
   While performing lockout audits for clients, I commonly observe the misuse of lockout locks and tags. For instance, I once observed 300 employees using identically keyed locks – employees could remove each others locks. In another case, a supervisor had the duplicate keys for all of her employees’ locks. Another problem is securing tool cribs and personal lockers with lockout locks. The best practice is to use uniquely keyed locks that come with only one key. Also, lockout and tagout devices must be standardized [see 29 CFR 1910.147(c)(5)(ii)] and must not be used for any other purpose.
   
6. Verification of isolation: Lock-Tag-Try
   Verification of isolation must be performed prior to commencing servicing and maintenance activities. Many companies refer to their lockout program as “Lock-Tag-Try”. In most cases, isolation may be verified by attempting to operate the machine [See 29 CFR 1910.147 (d)(6) and 29 CFR 1910.333 (b)(2)(iv)].
   
7. Training of all employees
   Most companies train employees who apply locks and tags to equipment (authorized employees). However, equipment operators as well as employees who may be in near proximity to equipment that is locked out (affected employees) must also be trained. In addition, all Other employees, such as management employees, need to receive awareness training on lockout/tagout and the prohibition against removing lockout locks and tags from energy isolating devices or attempting to operate locked out equipment. [See 29 CFR 1910.147 (c)(7)(i)].
   
8. Periodic (annual) inspection of lockout program
   29 CFR 1910.147 (c)(6)(i) requires employers to conduct an annual review of their lockout/tagout program to verify program effectiveness. Each equipment specific lockout procedure should be field reviewed to ensure lockout/tagout is being performed correctly. Deficiencies must be corrected through revised procedures, training, or both.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail

By W. Jon Wallace, CSP, MBA

“One worker died after entering a toluene storage tank. During the rescue attempt, a fireman was killed when the tank exploded.”

Confined space fatalities such as this example are a common occurrence in the workplace. According to NIOSH, during the 10 year period from 1980 to 1989, 585 separate fatal incidents occurred in confined spaces, claiming 670 victims. Unacceptable atmospheric conditions, such as toxic atmospheres or lack of oxygen, contributed to over half of the confined-space related deaths. Engulfment from loose materials, such as excavation cave-ins, contributed to approximately one-third of the fatalities. The remaining 10% of confined space fatalities were caused by drownings and engulfments in other materials (i.e., sludge and manure).

On January 14, 1993, in response to the large number of employees killed while working inside confined spaces, OSHA issued its final rule on Permit-required confined spaces – 29 CFR 1910.146. This standard contains several requirements intended to ensure employee safety while performing work in confined spaces.

The first step in implementing an effective confined space program is to conduct a facility-wide confined space assessment to identify all confined spaces. OSHA defines a confined space as a space that meets all three of the following criteria:

AND

2—Has limited or restricted means for entry or exit (for example, tanks, vessels, silos, storage bins, hoppers, vaults, and pits are spaces may have limited means of entry).
This condition applies when you are required to bend or stoop to enter a space – making rescue difficult. Also, spaces that require a ladder to obtain entry satisfy this condition. However, if you can stand fully upright while walking through the opening – such as walking through a door way – and walk unobstructed, this condition is not met. Also, it is not considered restricted entry when access is obtained by walking down a set of stairs. To gain access into the pit shown below, employees must use the fixed ladder.

AND

3—Is not designed for continuous employee occupancy.
Is the space designed so that an employee may safely work in the space for a prolonged period of time – such as a service pit in an automotive garage? If so, this condition does not apply. Spaces like reactors, manholes, silos, and furnaces are not designed for continuous employee occupancy and therefore, satisfy this definition. The picture below is the inside of a wastewater pit.

Once all confined spaces have been identified, the second step of the assessment is to identify those confined spaces that may pose a danger to employees. These spaces must be classified as permit-required confined spaces. To be a permit-required confined space, the space must only satisfy one or more of the following criteria:

1—Contains or has the potential to contain a hazardous atmosphere. Examples include spaces with an oxygen deficient (<19.5% oxygen) atmosphere or an oxygen enriched (>23.5% oxygen) atmosphere. Additional examples include confined spaces containing toxic atmospheres such as hydrogen sulfide gas, or spaces containing flammable vapors. The picture below is an oven heated with natural gas.

OR

2—Contains a material that has the potential for engulfing an entrant.
Grain, sand, dust, and water are examples of materials that may pose an engulfment hazard to employees. The picture shown below is a silo with product supplied from above that could engulf an employee working inside the silo.

OR

3—Has inwardly converging walls or a floor sloping down to a smaller cross-section.
Employees may become trapped in a space containing inwardly converging walls, making rescue difficult. Typical examples include hoppers, silos, and dust accumulators (shown below).

OR

4—Contains any other recognized serious safety or health hazard.
Examples include confined spaces that contain moving parts such as an auger, or a confined space containing a dangerous material such as hot molten plastic or steam. In addition, an elevator shaft would meet this condition. The photo below is a confined space that contains both a conveyor (mechanical hazard) and a radioactive source (health hazard).

The confined space assessment is now complete and all permit-required confined spaces have been identified. Employers must inform employees of the presence of confined spaces by posting danger signs, or by any other effective means, such as training and written procedures. Please remember that employers may utilize a definition of a permit-required confined space that is more stringent than OSHA’s definition.

If an employer elects not to have employees enter permit-required confined spaces, appropriate measure must be taken to prevent employees from entering these spaces. If it is decided that employees will enter permit-required confined spaces, the provisions of 29 CFR 1910.146 must be satisfied. However, a company may elect to use alternate procedures or reclassification. These options eliminate the requirements for entry permits, attendants, rescue provisions and mechanical retrieval devices.

Alternate procedures and reclassification are defined as follows:

Alternate Procedures: The employer can demonstrate that that the only hazard posed by the permit space is an actual or potential hazardous atmosphere and that continuous forced air alone is sufficient to eliminate any hazardous atmospheres and prevent their accumulation.

Reclassification: This applies to all spaces that pose no actual or potential atmospheric hazard and if all hazards are eliminated without entry into the space. Some common examples include augers that may be locked out from outside the space or an engulfment hazard where the material is removed from the confined space.

If alternate procedures or reclassification is not possible, all provisions of 29 CFR 1910.146 must be satisfied prior to employee entry into the space.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail

By W. Jon Wallace, CSP, MBA

Article published in ASSE by W. Jon Wallace:

Flammable and combustible liquids are present in nearly every workplace. Gasoline, diesel fuel, and many common products like solvents, thinners, cleaners, adhesives, paints, and polishes may be flammable or combustible. Flammable and combustible liquids play a part in our lifestyle. However, if used or stored improperly, serious fires and death may occur. This article discusses flammable and combustible liquid terminology, handling, and storage practices. 

The applicable OSHA standard is 29 CFR 1910.106–Flammable Liquids, which is based upon the 1969 version of NFPA^® 30 Flammable and Combustible Liquids Code. However, it is important to note that in 2012, in response to OSHA’s revised Hazard Communication standard (due to incorporation of the Globally Harmonized System [GHS]), OSHA revised 29 CFR OSHA 1910.106. The title of 29 CFR 1910.106 has been changed from “Flammable and Combustible Liquids” to “Flammable Liquids.” One significant change is the revised regulation lists liquids as “categories” rather than “classes.” However, the 2012 Edition of NFPA^® 30 has not been revised to reflect GHS guidelines. For instance, NFPA^® 30 continues to use the term flammable and combustible liquid and refers to “classes” of liquids.

If you are covered by OSHA, you must comply with 29 CFR OSHA 1910.106 – Flammable Liquids. As a best practice, however, it is recommended that you review both OSHA 1910.106 as well as NFPA^® 30 and comply with the standard providing the highest level of protection.

Terminology

A review of the properties and hazards of flammable and combustible liquids is in order.

Autoignition Temperature: The autoignition temperature is the lowest temperature at which a liquid will ignite without an external ignition source.  While most flammable and combustible liquids have autoignition temperatures in the range of 500°F to 1000°F, some have very low autoignition temperatures. For example, ethyl ether has an autoignition temperature of 356°F, and its vapors have been ignited by heated surfaces.

Flashpoint: This is the minimum temperature of a liquid at which sufficient vapor is given off to form an ignitable mixture with the air, either near the surface of the liquid or within the vessel used.

Fire Point: The fire point is the lowest temperature at which a liquid will ignite and achieve sustained burning when exposed to a test flame.

Vapor Pressure: Pressure, measured in pounds per Square inch–absolute (psia), exerted by a liquid.

Combustible Liquid (perNFPA^® 30): A combustible liquid has a flashpoint at or above 100°F. Combustible liquids are subdivided into Class II or Class III liquids:

Class	Flashpoint	Examples
Class II	> 100° F and < 140° F	Diesel fuel, fuel oil, kerosene, motor oil
Class IIIA	> 140° F and < 200° F	Furfural, linseed oil, mineral oil, oil-based paints
Class IIIB	> 200° F	Ethylene glycol, glycerine, neatsfoot oil

Flammable liquid (perNFPA^® 30): A flammable liquid is a liquid with a flashpoint below 100° F. Flammable liquids are subdivided into Class IA, IB, or 1C liquids:

Class	Flashpoint	Boiling Point	Examples
Class IA	<73° F	<100° F	Ethyl ether, heptane, pentane, propylene oxide, vinyl chloride
Class IB	<73° F	> 100° F	Acetone, ethanol, gasoline, isopropyl alcohol, methanol, methyl ethyl ketone, octane, toluene
Class IC	> 73° F and <100° F	All boiling points	Isobutyl alcohol, mineral spirits, styrene monomer, turpentine, xylene

Flammable Liquid (per OSHA 1910.106): A liquid with a flashpoint at or below 199.4° F. (93° C). Flammable liquids are divided into four (4) categories:

Category	Flashpoint	Boiling Point
1	< 73.4° F (23° C)	≤ 95° F (35° C)
2	< 73.4° F (23° C)	> 95° F (35° C)
3	≥ 73.4° F (23° C) and ≤ 140° F (60° C)
4	> 140° F (60° C) and ≤ 199.4° F (93° C)

Lower Explosive Limit (LEL): The minimum vapor concentration (by percent) in which a liquid can form an ignitable mixture in air is called the “lower explosive limit.” Below this limit, vapor concentration is too lean to support combustion.

Upper Explosive Limit (UEL): The maximum vapor concentration (by percent) in which a liquid can form an ignitable mixture in air is called the “upper explosive limit.”  Above this limit, vapor concentration is too rich to support combustion.

Explosive Range: The range between the LEL and UEL is the “explosive range.” If a source of ignition such as a flame, spark, or static electricity is present, an explosion may occur.  This may also be referred to as the “flammable range.”  The graph below illustrates the explosive range of gasoline. 

Grounding and Bonding: When flammable and combustible liquids travel through a pipe or through the air, static charges are accumulated. Grounding and bonding is necessary during the transfer of flammable liquids that have a flashpoint below 100° F to prevent a static spark from igniting the flammable vapors. An example of grounding and bonding is illustrated in the photograph below.

Author’s collection—Above photo illustrates flammable solvent being placed inside a 55-gallon waste drum. Funnel is bonded to drum and drum is grounded.

Read the article below for an excellent overview of grounding and bonding requirements.

Container: Any vessel with a capacity of 60 U.S. gallons or less that is used for transporting or storing liquids is referred to as a “container.”

Portable Tank: Any closed vessel having a liquid capacity over 60 U.S. gallons and not intended for fixed installation is called a “portable tank.”

Safety Can: A safety can is a listed container with a capacity of no more than 5 gallons that has a spring-closing lid and spout cover and is designed to safely relieve internal pressure when exposed to fire.  

Flammable Storage Cabinet: A “flammable storage cabinet” is a listed storage cabinet designed in accordance with NFPA^® 30: 9.5.3 (1). Such a cabinet is designed and constructed to limit the internal temperature to no more than 325°F from the center of the cabinet to within 1 inch of the top of the cabinet when subjected to a 10-minute fire test.

Fire Area: A “fire area” is an area of a building separated from the remainder of the building by special construction. This area has a fire resistance of at least 1 hour and has all communicating openings properly protected by an assembly that also has a fire resistance rating of at least 1 hour.

Storage

Storage of flammable and combustible liquids is usually a necessity. Whenever flammable and combustible liquids are stored improperly, however, they become a significant fire hazard.  For instance, NFPA^® 30: 17.6.9 prohibits Class I flammable liquids from being stored in a basement.  29 CFR 1910.106 has established the following storage practices to ensure flammable liquids are not stored in excessive quantities.

Maximum Quantities Outside of a Flammable Storage Cabinet or Inside Storage Room
Category and Container Type	Quantity
Category I Liquids in Containers	25 Gallons
Category 2, 3, or 4 Liquids in Containers	120 Gallons
Category 2, 3, or 4 Liquids in a single Portable Tank	660 Gallons

Maximum Quantities Inside of a Flammable Storage Cabinet or Inside Storage Room
Category of Liquid	Quantity
Category 1, 2, or 3	60 Gallons
Category 4	120 Gallons

Flammable Storage Cabinets—To vent or not to vent?

When I teach courses on flammable and combustible liquids, I am repeatedly asked the question: “Are we required to vent the bung on a flammable storage cabinet?”NFPA^® 30: 9.5.4 does not require bungs to be vented.  In addition, in a correspondence to Mr. Mark E. Graham dated March 28, 1978, NFPA provided a formal position concerning the issue of venting flammable storage cabinets: “The vents for flammable liquids storage cabinets are not required or even recommended by our Flammable and Combustible Liquids Code, NFPA^® 30…” 

“The fittings are sometimes provided by the manufacturers due to the fact that, in a few locations in the country, local ordinances require such vents to be provided.  Therefore, the manufacturers plug these vents [with plugs] which can be removed in those few areas where such venting is required.” 

Unless a municipality or other government agency specifically requires the bung to be vented, venting is not required, nor is it recommended.  

Handling Liquids at Point of Final Use

To understand flammable liquids it is important to know that it is the vapor, not the liquid that burns.  For instance, explosions routinely occur when mechanics drain a gasoline tank and mistakenly assume it is safe to commence repairs involving welding and/or brazing on the tank. Although the tank is empty, its vapor space contains gasoline vapors.  If the vapor concentration is within the explosive range and a source of ignition is introduced, an explosion will likely occur.

The following work practices must be followed when handling flammable and combustible liquids:     

1. Flammable liquids with a flashpoint below 100° F must be kept in covered containers when not in use.
2. Flammable liquids must be stored only in acceptable containers.
3. Grounding and bonding must be utilized when transferring flammable liquids with a flashpoint below 100° F.
4. Locations where flammable vapor-air mixtures may exist must have electrical wiring installed according to the requirements of 29 CFR 1910 Subpart S (Electrical):
   
   —Flammable vapor-air mixtures may exist under normal conditions: Class I Division I
   —Flammable vapor-air mixtures may exist under abnormal conditions: Class I Division II
   
5. Where flammable or combustible liquids are used or handled, except in closed containers, means shall be provided to dispose of leaked or spilled liquid promptly and safely.
   
6. Flammable or combustible liquids shall be drawn from or transferred into vessels, containers, or portable tanks within a building by one of the following methods:
   
   (1) Through a closed piping system
   (2) From safety cans
   (3) By means of a device drawing through the top
   (4) From containers or portable tanks by gravity through an approved self-closing Valve
   
7. Transfer operations must be provided with adequate ventilation. Sources of ignition are not permitted in areas where flammable vapors may travel.
8. Transferring liquids by means of air pressure on the container or portable tanks is prohibited. This type of transfer may result in an overpressure that could exceed what the container or tank is designed to withstand. In addition, a flammable atmosphere could be created within the container or tank. This atmosphere would be particularly sensitive to ignition because of the increased pressure. 

Please remember that this is a general overview of flammable and combustible liquids.  For more information, refer to 29 CFR 1910.106 Flammable Liquids as well as NFPA® 30 Flammable and Combustible Liquids Code.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail

By W. Jon Wallace, CSP, MBA

It’s not the fall that hurts – it’s the sudden stop.

I read the preceding statement while performing a simulated OSHA inspection. Most fall-related injuries result from the lack of fall protection. Additional injuries occur from improper use of fall protection – utilizing a body belt instead of a full body harness, improper use of lanyards, or utilizing an inadequate anchorage point. Falls from heights of 10 feet or greater almost always result in serious injury or death. It is important to note, however, that serious injuries and fatalities also commonly occur from fall heights of ten feet or less.

After retiring as Chairman of the Joint Chiefs of Staff, General Henry Shelton fell approximately 10 feet from a metal ladder while trimming an oak tree outside his house. Attending physicians were doubtful that Shelton would ever walk again. It’s ironic that a former paratrooper who made 400 jumps without incident, some from 20,000 feet at night, was nearly paralyzed from a fall off a ladder!

OSHA lists falls as one of the leading causes of traumatic occupational death, accounting for eight percent of all occupational fatalities from trauma. An OSHA study involving 99 fall-related fatalities suggests that virtually all of those deaths could have been prevented by the use of guardrails, body harnesses, safety nets, covers, or other means which would have reduced employee exposure to the fall hazard.

Fall Protection Thresholds

OSHA has several thresholds for fall protection – dependent upon the work activity involved. These thresholds are discussed in 29 CFR OSHA 1910 (General Industry) and 29 CFR OSHA 1926 (Construction). A review of these thresholds is in order:

General Industry: 4 Feet
29 CFR 1910.28 (b)(1)(i) requires open-sided floors or platforms 4 feet or more above adjacent floor or ground level to be guarded by a standard railing (guardrail) or equivalent. The standard railing shown below is equipped with a top rail, mid rail, and toe board. However, the standard railing needs to be extended to adequately protect employees.

Construction: 6 Feet
OSHA 29 CFR 1926.501 (b)(1) requires each employee on a walking/working surface with an unprotected side or edge 6 feet or more above a lower level to be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems. 29 CFR 1926.502 (d) prohibits the use of body belts for fall protection. A body belt may only be used as a positioning device where free fall potential is no more than 2 feet. The picture below shows an employee working on a window sill without any fall protection.

Scaffolds: 10 Feet
Both general industry and construction follow 1926 Subpart L (Scaffolds). OSHA 29 CFR 1926.451 (g)(1) requires each employee on a scaffold more than 10 feet above a lower level be protected from falling to that lower level. The scaffold shown at right is greater than 10 feet in height and is not equipped with fall protection.

Portable Ladders: Working Height of Ladder
Employees may work on an extension or step ladder up to the maximum working height of the ladder as specified by the ladder manufacturer. It is not permissible, however, for an employee to work on a portable ladder on an elevated surface, such as a roof, and be exposed to the fall height of the ladder plus the height of the roof – as shown in the photograph below.

Fixed Ladders: 24 Feet
OSHA 29 CFR 1910.28 (d)(1)(ii) requires safety cages or ladder safety devices on all fixed ladders more than 24 feet in height. Note: fixed ladders with cages for fall protection are being phased out by OSHA. Refer to 1910.28 (b)(9) for more details.

Steel Erection: 15 Feet
Steel erection is considered construction work and is therefore regulated by OSHA 29 CFR Part 1926 Subpart R – Steel Erection. 29 CFR 1926.760 (a)(1) requires all employees (except connectors) engaged in steel erection with an unprotected side or edge more than 15 feet to utilize adequate fall protection. 29 CFR 1926.760 (b)(1) requires connectors (workers who connect the steel to the frame) to utilize fall protection when working above a lower level of two stories or 30 feet, whichever is less.

[Photo courtesy of DBI/SALA]

Summary

A fall protection survey should be performed to identify potential fall hazards. A fall protection policy should then be developed and employees trained as needed.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail

By W. Jon Wallace, CSP, MBA

The origins of OSHA’s Process Safety Management (PSM) standard can be traced back to the December 1984 Union Carbide explosion in Bhopal, India. Many Americans became concerned that a similar incident could occur in the United States. To further heighten public concern, in August 1985 Union Carbide experienced a major incident at their Institute, West Virginia facility when approximately two tons of toxic chemicals, including the pesticide aldicarb, was released over the residential area near the factory. At least 135 people had to be treated at local hospitals and another 175 by paramedics. In addition, there were two serious chemical explosions in Houston, Texas—Phillips 66 (October 23, 1989: 23 fatalities) and ARCO (July 6, 1990: 17 fatalities). In 1992, as a result of the previously mentioned incidents, OSHA finalized the PSM standard (1910.119). The PSM standard is a comprehensive standard with 14 major components.    

Recently there have been several industrial explosions involving natural gas. At least one of these facilities was covered by OSHA’s PSM standard (1910.119). How good is your facilities PSM program? When performing PSM program audits for clients, I routinely find significant deficiencies. Listed below are some documents you need available in the event of an OSHA PSM inspection:

Documents for Review:

1. Facility PSM Program—overview of all elements
2. Organizational chart of personnel with assigned duties
3. Priority schedule for conducting PHA’s
4. PHA reports for two most hazardous processes
5. PHA recommendation status reports for facility
6. Operating procedures for two most hazardous processes
7. Incident and “near hit” reports for PSM covered processes
8. Contractor safety program
9. Overall mechanical integrity program:
10. Fixed equipment – Vessels, storage tanks, relief and vent systems
11. Rotating equipment
12. Electrical & Instrumentation—monitoring devices, interlocks, emergency shutdowns
13. API 752 facility siting survey (if applicable)
14. OSHA 300 Log for 3 previous years
15. All internal PSM audit reviews
16. Employee training records/certification
17. Canceled hot work permits

Don’t be surprised to see OSHA significantly increase their emphasis on PSM inspections in the near future. By being prepared, you will ensure employee safety as well as maintain OSHA compliance.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail

By W. Jon Wallace, CSP, MBA

“Wallace, if we lockout this machine every time we have a pill jam, we will never make any product!”

This was the testy response I received from a production manager while performing a lockout audit at a pharmaceutical plant. With the exception of minor tool changes and adjustments, and other minor servicing activities, employees are typically prohibited from placing any part of their body into the point of operation while a piece of equipment is energized. But what about the following scenarios:

• An employee is required to jam clear a machine several times each day, and locking out the machine would drop product onto the floor
• Performing lockout/tagout to change the tape roll inside a Box machine would result in loss of data to the programmable logic controller (plc)
• Programming a robot must be done inside the robot cell while the robot remains energized

The preceding scenarios illustrate the need for performing a lockout/tagout risk assessment. An example of an employee entering the die press area to remove a finished part from a plastic injection molding unit is shown in the photograph below.

ANSI/ASSE Z244.1 – 2016

The current edition of ANSI/ASSE Z244.1 – 2016: The Control of Hazardous Energy – Lockout, Tagout and Alternative Methods addresses the use of alternative methods for lockout/tagout. Section 5.4 (Alternative Methods) states that whenever lockout/tagout is not used for tasks that are routine, repetitive, and integral to the production process (e.g. tasks that are: short in duration; relatively minor in duration; occur frequently during the shift, day, or week; usually performed by operators, set-up, service, or maintenance personnel; do not involve extensive disassembly; represent predetermined cyclical activities; are expected to occur regularly; minimally interrupt the production process; exist even when optimal operating levels are achieved; require task specific personnel training), or traditional lockout/tagout prohibits the completion of those tasks, an alternative method of control shall be used.

Selection of an alternative method shall be based upon a qualitative risk assessment of the associated machine, equipment, or process and shall take into consideration that existing safeguards provided with the machine, equipment, or process may need to be removed or modified to perform a given task. ANSI/ASSE Z244.1 does not prescribe a specific methodology for performing the risk assessment. Annex A, however, provides guidance.

1. Identify all tasks: All tasks and activities should be considered including set up, installation, removal, maintenance, operating, adjusting, cleaning, troubleshooting, and programming.
2. Identify hazards: Hazards, such as electrical, gravity, mechanical, chemical, thermal, pneumatic, hydraulic, radiation, and human factors associated with each task should be considered.
3. Assess potential consequences: Assess the most severe injury that could occur with each task.
4. Assess potential exposure to hazards: Evaluate the potential exposure of all persons to the identified hazards.
5. Assess probability of occurrence: Estimate the probability of occurrence of the hazardous event by considering the following factors:
   1. Safeguards, safety devices, and safety systems
   2. Reliability, history, and failure mode
   3. Operational/maintenance demands of task
   4. Possibility of defeat or failure of safeguards
   5. Accident history of task, activity, machine, equipment, or process
   6. Competence of persons performing task
   7. Working environment
6. Evaluate the risk: Each identified hazard and task should be evaluated to determine the level of risk. This will determine if the task is an acceptable risk.
7. Achieve an acceptable level of risk: If the level of risk is found to be acceptable, the process is complete. If the risk(s) are determined to be unacceptable, the risk reduction process should be implemented.

Risk Reduction

If a risk assessment on a task results in an unacceptable risk to an employee, a hierarchical process should be utilized to reduce or control risk:

1. Risk reduction by design: Risk reduction may be achieved by implementing changes to eliminate hazards or reduce risk by substitution.
2. Risk reduction by use of engineered safeguards: This includes safeguards or safety devices utilized to protect employees from hazards that cannot be reasonably eliminated or reduced by design modification. Examples of engineered safeguards include guards (both fixed and interlocked), trapped key devices, and trip devices (light curtains, laser scanners, pressure mats, safety-rated switches, etc.). Examples of safety devices include: emergency stop buttons, enabling or hold-to-run devices, etc.
3. Risk reduction by use of warning and alerting techniques: These techniques are utilized to protect employees from hazards that cannot reasonably be eliminated or satisfactorily reduced by design, engineered safeguards, or a combination of these elements. Examples include: attendants, audible and visual signals, barricades, signs, and tags.
4. Risk reduction by use of administrative controls: Additional risk reduction may be achieved with safe work procedures, standard practices and checklists, and training.
5. Risk reduction by use of personal protective equipment (ppe): The use of PPE should be considered the last avenue of protection after the previous methods have been considered.

Summary

Lockout/tagout provides the greatest level of protection and, whenever possible, should be utilized to protect employees from hazardous energy. In situations where tasks are routine, repetitive, and integral to the production process, a risk assessment should be performed. If the task performed poses an unacceptable risk, acceptable risk reduction methods should be implemented to reduce the risk to acceptable levels.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail

By W. Jon Wallace, CSP, MBA

As a safety professional, I routinely receive accident reports from around the World. Many of these accidents are related to confined space work. Unfortunately, the same types of mistakes are repeated – resulting in injury or death. Based upon my experiences as well as the National Institute of Occupational Safety and Health (NIOSH) research on confined space incidents (http://www.cdc.gov/niosh/94-103.html), I have developed five work practices to help ensure confined space safe work practices.

Habit #1: Confined space awareness

Many people who die in confined spaces simply aren’t aware of the potential hazards. An employee is given a job task and they attempt to perform it. The first step in confined space awareness is performing a confined space assessment to identify all permit-required confined spaces and identifying the spaces by signage or employee training. Once performed, employees need to receive awareness training on the potential hazards of confined spaces and your facilities confined space entry requirements. For more information, please read my article on performing the confined space assessment.

Habit #2: Atmospheric testing of space

The majority (approximately 56%) of confined space fatalities are caused by inadequate air quality. Insufficient oxygen is the leading cause of death due to atmospheric hazards followed by hydrogen sulfide. Additional hazards include: methane gas; inert gases; sewer gases; as well as carbon monoxide. All potential atmospheric hazards must be identified and the atmosphere tested with a combustible gas meter prior to entry. In addition, the air needs to be retested periodically to verify the air remains safe for personnel.

Habit #3: Training for authorized entrants and attendants

Employees who enter confined spaces (entrants) as well as those serving as the “hole watch” (attendants) need to receive training. This should include a review of confined space hazards; confined space preparation requirements; responsibilities of entrants and attendants; and emergency response.

Habit #4: Isolating (lockout/tagout) all energy sources

In my professional opinion, the lockout/tagout standard is the best OSHA standard ever written. This is especially true with confined space entry work. All hazardous energy sources must be isolated prior to entry. Typical energy sources found in confined spaces include: electrical energy; natural gas; methane; steam; inert gas; and chemical feed lines. All energy sources must be properly isolated prior to entry.

Habit #5: Completing the confined space entry permit

Think of the entry permit form as a checklist to verify the confined space is safe for entry. When performing confined space program audits for clients, I find that approximately 75% of the entry permits are missing at least one of the 15 items required by OSHA’s permit-required confined space standard.

Summary

These five habits are essential to ensuring worker safety during confined space entry work. These elements need to be included in your facilities overall written confined space program.

If you have any questions concerning this article or other safety issues, please contact W. Jon Wallace, “The Safety Guru”, at 919.933.5548 or by e-mail