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HAND PROTECTION: Applying Ergonomics to Glove Design 8 FALL PROTECTION: Update Your Program Now 18 DISASTER PREPAREDNESS: It’s Crucial to Be Prepared 36 JANUARY 2014 VOL. 83 NO. 1 | www.ohsonline.com BREAKTHROUGH STRATEGIES: CROSS-GENERATION MOTIVATION

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  • HAND PROTECTION:Applying Ergonomics to Glove Design 8

    FALL PROTECTION:Update Your Program Now 18

    DISASTER PREPAREDNESS:Its Crucial to Be Prepared 36

    JANUARY 2014 VOL. 83 NO. 1 | www.ohsonline.comBREAKTHROUGH STRATEGIES: CROSS-GENERATION MOTIVATION

    0114ohs_c1_v6.indd 5 12/10/13 3:01 PM

  • Scan the QR code

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    www.mcrsafety.com 800-955-6887 CIRCLE 10 ON CARD

    Untitled-2 1 12/9/13 11:09 AM

  • CIRCLE 34 ON CARD

    Untitled-2 1 12/10/13 10:30 AM

  • FROM THE EDITOR

    www.ohsonline.comVOLUME 83 NUMBER 1

    EDITORIAL STAFF

    EDITOR Jerry Laws

    E-NEWS EDITOR Brent Dirks

    CONTENT DEVELOPMENT TEAM Cindy Horbrook

    Lindsay Page

    Jamie Friedlander

    Ginger Hill

    ART STAFF

    ART DIRECTOR Dale Chinn

    PRODUCTION STAFF

    DIRECTOR, PRINT AND ONLINE PRODUCTION David Seymour

    PRODUCTION MANAGER Teresa Antonio

    SALES STAFF

    WEST DISTRICT SALES MANAGER Barbara Blake 972-687-6718

    EAST DISTRICT SALES MANAGER Jenna Conwell 610-436-4372

    SECURITY, SAFETY, AND HEALTH GROUP

    PRESIDENT & GROUP PUBLISHER Kevin OGrady

    PUBLISHER Karen Cavallo

    GROUP CIRCULATION DIRECTOR Margaret Perry

    GROUP MARKETING MANAGER Susan May

    GROUP WEBSITE MANAGER Scott Newhouse

    GROUP WEBINAR ADMINISTRATOR Tammy Renne

    PRESIDENT & Neal Vitale CHIEF EXECUTIVE OFFICER

    SENIOR VICE PRESIDENT & Richard Vitale CHIEF FINANCIAL OFFICER

    EXECUTIVE VICE PRESIDENT Michael J. Valenti

    VICE PRESIDENT, Christopher M. Coates FINANCE & ADMINISTRATION

    VICE PRESIDENT, Erik A. Lindgren INFORMATION TECHNOLOGY & APPLICATION DEVELOPMENT

    VICE PRESIDENT, David F. Myers EVENT OPERATIONS

    CHAIRMAN OF THE BOARD Jeffrey S. Klein

    REACHING THE STAFFEditors can be reached via e-mail, fax, telephone, or mail. A list of editors and contact information is at www.ohsonline.com.

    Email: To e-mail any member of the staff please use the following form: [email protected].

    Dallas Offi ce: (weekdays, 8:30 a.m. 5:30 p.m. CT) Telephone: 972-687-6700; Fax: 972-687-679914901 Quorum Drive, Suite 425, Dallas, TX 75254

    Corporate Offi ce: (weekdays, 8:30 a.m. 5:30 p.m. PT) Telephone: 818-814-5200; Fax: 818-734-15229201 Oakdale Avenue, Suite 101, Chatsworth, CA 91311

    4 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    Occupational Health & Safety (ISSN 0362-4064) is published monthly by 1105 Media, Inc., 9201 Oakdale Avenue, Ste. 101, Chatsworth, CA 91311. Periodicals postage paid at Chatsworth, CA 91311-9998, and at additional mailing offi ces. Complimentary subscriptions are sent to qualifying subscribers. Annual subscription rates payable in U.S. funds for non-qualifi ed subscribers are: U.S. $79.00, International $149.00. Subscription inqui-ries, back issue requests, and address changes: Mail to: Occupational Health & Safety, P.O. Box 2166, Skok-ie, IL 60076-7866, email [email protected] or call 847-763-9688. POSTMASTER: Send address changes to Occupational Health & Safety, P.O. Box 2166, Skokie, IL 60076-7866. Canada Publications Mail Agreement No: 40612608. Return Undeliverable Canadian Addresses to Circulation Dept. or XPO Returns: P.O. Box 201, Richmond Hill, ON L4B 4R5, Canada.

    Copyright 2014 by 1105 Media, Inc. All rights re-served. Printed in the U.S.A. Reproductions in whole or part prohibited except by written permission. Mail requests to Permissions Editor, c/o Occupational Health & Safety, 14901 Quorum Dr., Ste. 425, Dallas, TX 75254.

    The information in this magazine has not undergone any formal testing by 1105 Media, Inc. and is dis-tributed without any warranty expressed or implied. Implementation or use of any information contained herein is the readers sole responsibility. While the information has been reviewed for accuracy, there is no guarantee that the same or similar results may be achieved in all environments. Technical inaccuracies may result from printing errors and/or new develop-ments in the industry.

    Corporate Headquarters: 1105 Media9201 Oakdale Ave. Ste. 101Chatsworth, CA 91311www.1105media.com

    Direct your Media Kit requests to:Lynda BrownPh: 972-687-6710 (phone)Fx: 972-687-6750 (fax)E-mail: [email protected]

    For single article reprints (in minimum quantities of 250-500), e-prints, plaques and posters contact:PARS InternationalPh: 212-221-9595E-mail: [email protected]: www.magreprints.com/QuickQuote.asp

    This publications subscriber list, as well as other lists from 1105 Media, Inc., is available for rental. For more information, please contact our list manager, Jane Long, Merit Direct. Phone: 913-685-1301; E-mail: [email protected]; Web: www.meritdirect.com/1105

    Inspections Matter

    One more reminder from the U.S. Chemical Safety and Hazard In-vestigation Board about why thor-ough inspections matter (along with correcting any problem you fi nd there-by): Stress corrosion cracking in the 8-inch-thick steel wall of a pressure vessel caused its catastrophic failure on Dec. 7, 2009, at the NDK Crystals, Inc. plant in Belvidere, Ill., ac-cording to an investigative report approved by the board Nov. 14, 2013. Th at vessel was 120 days into a 150-day crystal manufacturing cycle when it ruptured. NDK did not inspect any of the plants eight pressure vessels, and the cracking in this one went undetected for years, the board determined, as illus-trated in its Falling Th rough the Cracks video about the explosion.

    Th e blast hurled projectiles more than 200 yards, killing a motorist at a nearby fi lling station and injuring someone in a nearby building when a piece of debris crashed through a wall.

    A consultant hired by NDKs insurer investigated an earlier accident, when hot, caustic material leaked from another ves-sels lid, found that stress corrosion cracking had caused it, and strongly recommended

    that the pressure vessels not be returned to service, but NDK did not follow that rec-ommendation. No certifi ed inspector ever performed an internal inspection of the failed vessel during the six years it was in use, according to CSBs video. Th e video was released simultaneously with the CSB inves-

    tigation report.Th e video dramatically de-

    scribes the important fi ndings of the CSB investigation: Pres-sure vessels did not meet code requirements, but were granted an exemption; internal corro-sion inspections were recom-mended but never performed; and fi nally, a specifi c warning was made to the company by its insurer. But at every level, the risk of catastrophic vessel fail-ure was overlooked and public safety, literally and fi guratively, fell through the cracks, CSB Chairperson Rafael Moure-Eraso said.

    Th e video shows how cracking on and near the inner

    diameter of the vessel fragment reduced the vessel material toughness, which eventually led to large fl aws resulting in the catastroph-ic failure, CSB Lead Investigator Johnnie Banks added. JERRY [email protected]

    No certifi ed inspector ever per-formed an internal inspection of the failed vessel during the six years it was in use, according to CSBs video.

    0114ohs_004_EdNote_v2.indd 4 12/10/13 10:48 AM

  • A TOUGH HAND TO BEAT.fWORKRITE.COM

    2013 Workrite Uniform CompanyCIRCLE 12 ON CARD

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  • TABLE OF CONTENTSJANUARY 2014 | Volume 83, Number 1 | www.ohsonline.com

    6 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    featuresHAND PROTECTION

    8 Applying Ergonomics to Industrial Glove DesignPoorly designed gloves force workers to compensate for lack of support, thereby placing unnecessary stress on their muscles and joints. by Scott Corriveau

    FALL PROTECTION

    12 Keys to Preventing Ladder FallsWhat do you do about a problem that is never going away? I think you have to design around it. by David Francis

    18 Update Your Fall Protection Program NowTime, money, safety, productivity, and even employee morale are on the line when implementing equip-ment-based solutions. by Th om Kramer

    YEAR IN REVIEW/OIL & GAS SPECIAL SECTION 25

    26 Ending with a BangTwo signifi cant OSHA rulemaking actions took center stage in late 2013, which may be remembered as a milestone year for recordkeeping changes. by Jerry Laws

    30 Silica, Spills, Lawsuits & RulesThe challenges of a booming industry were met on many fronts in 2013, from training and recruitment to regulatory changes and safety stand-downs. by Jamie Friedlander

    34 Safely AloftThe height and cylindrical shape of tanker trucks can pose a real safety risk to workers who have to climb around on top of them. by Kristina Harman

    CHEMICAL SAFETY/SDS

    35 GHS: Perception vs. RealityHeres what OSHAs Dec. 1, 2013, training deadline should mean to you. by Tom Jacques

    DISASTER PREPAREDNESS

    36 Preparing for the WorstNatural disasters are not falling by the wayside. In fact, they seem to be more frequent than ever. Heres why its important to be prepared. by Jamie Friedlander

    departments4 From the Editor38 New Products40 Classifi eds40 Literature Library41 Advertiser Index42 Breakthrough Strategies by Robert Pater

    Find OHS on:Twitter http://twitter.com/OccHealthSafetyFacebook http://facebook.com/ohsmagLinkedIn http://www.linkedin.com/company/ occupational-health-and-safety-magazine

    30

    RIG

    ID LIFELIN

    ES

    34

    36

    LJB IN

    C.

    18

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  • at its peak.Drger keeps performance

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    Untitled-2 1 4/2/13 10:38 AM

    CIRCLE 2 ON CARD

  • HAND PROTECTION

    8 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    Just like helmets and safety glasses, gloves are a key component of a workers safety gear in the industrial sector. However, the critical protec-tion off ered by gloves becomes meaningless when workers refuse to wear them because they are uncomfortable or too cumbersome. Every year, ap-proximately 1 million workers in the United States are treated in emergency rooms for acute hand injuries incurred on the job. According to the Bureau of La-bor Statistics, 70 percent of workers who experienced hand injuries were not wearing gloves, and the re-maining 30 percent experienced injuries due to wear-ing damaged gloves or the improper type of glove for the application.1

    Th is is potentially due in part to workers seeking comfort over protection. Adding to the burden of hand injuries, poorly designed gloves force workers to compensate for lack of support, thereby placing un-necessary stress on their muscles and joints.

    Th e integration of ergonomic principles into in-dustrial glove design is not only based on satisfying a need for comfort, it is also critical to worker produc-tivity, health, and well-being. As the industrial market continues to grow around the globe and the workforce steadily increases and diversifi es, PPE manufacturers are exploring new ways to customize equipment to bet-ter fi t the contours of individual workers hands while also addressing the needs of specifi c applications, con-ditions, and duration of work that the gloves will be expected to endure. Identifying these factors and in-corporating them into the glove design is the key to creating eff ective, ergonomically designed equipment.

    Although both protection and comfort should be necessary in proper glove design, achieving them re-quires confl icting designs and constructions. In an ef-fort to prevent cuts and abrasions, which are typically more consequential than hand fatigue, safety manag-ers oft en rely on gloves that are thicker and bulkier to increase protection. However, these gloves make it harder for workers to function, forcing workers either to repetitively perform the same task despite the fa-tigue and muscle strain it causes or remove the gloves completely. In an eff ort to meet production quotas, many pick the latter.

    Equipment manufacturers are challenged to fi nd the right combination of comfort and performance while creating products that adhere to the safety

    regulations that employers must follow. Th e key to marrying the opposing principles of ergonomics and protection lies in shift ing the development process to incorporate the workers experience at the onset of design ideation and leveraging our insight to develop new equipment technologies. If we learn to under-stand what workers needwhether it be enhanced dexterity, fi ngertip sensitivity, moisture management, or liquid repellencethen we can tailor the design of a glove to address these concerns and build the protec-tive features to complement these needs. Th is might seem absurd in an industry based on providing pro-tective equipment, but advancements in technology have paved the way for new materials that address the comfort and feel of a glove without losing the durabil-ity needed to function in industrial environments.

    Safety is of paramount importance in any indus-trial setting, both for worker well-being and overall productivity. Worker demand for comfortable protec-tive equipment is increasing, however. Gloves play an important role in ensuring safety by protecting hands from cuts, burns, and other serious injuries, but un-less they off er comfort, performance, and precision, workers may neglect to wear them. As attention to ergonomics continues to grow by the general work-force, hand protection products that are designed to tailor-fi t a diverse and global workforce will likely be a requirement for many environments in the future. By collaborating with industry partners and applying ergonomic design principles early, it is possible that worker safety, compliance, and overall productivity can improve.

    The Future of PPEEnforcing safety in the industrial and manufacturing sector must be a collaborative eff ort upheld by gov-ernmental bodies and non-governmental organiza-tions, industry safety offi cers, and PPE manufacturers. While organizations such as OSHA develop mandates and industry standards to ensure safety, corporate offi cials modify policies to adhere to new rules and rely on PPE manufacturers to develop equipment that fulfi lls the standards and allows workers to perform under safe conditions. Th is collaboration has become crucial in recent years as the global market is expe-riencing a collective push from multiple countries to modernize, thus driving increases in construction and goods production and generating more jobs.

    Th e PPE market has benefi tted substantially from this push due to an increased demand for safety equip-ment. In fact, Global Industry Analysts, Inc. estimates the global PPE market will grow to $33.3 billion by 2015.2 With the PPE markets ongoing expansion and

    Applying Ergonomics to Industrial Glove DesignPoorly designed gloves force workers to com-pensate for lack of support, thereby placing unnecessary stress on their muscles and joints.BY SCOTT CORRIVEAU

    0114ohs_008_010_Corriveau_v3.indd 8 12/10/13 11:35 AM

  • Certain eligibilty requirements apply. To qualify, please ll out the on-line sample request form. Moldex, Ideas that wear well, Dura-Mesh, are registered trademarks. The mesh design and waved design are trademarks of Moldex-Metric, Inc. Patents Pending. 2013.

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    CIRCLE 11 ON CARD

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  • 10 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    HAND PROTECTION

    the occupational safety community looking toward the future of safety, it is imperative that leaders in equipment development rec-ognize the need to incorporate another key aspect to the safety dia-logue: the worker experience.

    OSHA constantly implements and enforces new mandates to adjust to modern work experiences, adopting new standards for heat- and fi re-resistant clothing and hearing protection. However, as several industries continue to expand the goods manufactur-ing sector alone is projected to add almost 1.8 million jobs during 2010-20203 undoubtedly it will become diffi cult to ensure these standards are upheld. Safety offi cials rely on PPE manufacturers to provide an additional layer of protection for their workers, making the technology that they develop a crucial part of the safety environ-ment yet unobtrusive enough for the worker to still get the job done.

    Technology always has been a staple of the PPE market. 3D-modeling and simulation, along with extensive testing through the recreation of conditions and machinery that enables the develop-ment of multiple prototypes, allows PPE manufacturers to expe-dite the creation of new equipment that adheres to standards set by safety organizations such as the International Safety Equipment Association. While it is important that PPE manufacturers con-tinue to utilize technology to meet these standards, it is important for the future of the industry that they also pay attention to what matters to the end user. In a rapidly growing industry, the workers main concern is not only safety, but also to perform eff ectively. If their PPE hinders their ability to do so, they will oft en choose to

    avoid using it, consequently putting them in danger.Equipment manufacturers must combine new technology with

    the needs of the worker to create solutions that matter not only for safety, but also for performance and comfort. Th e worker experi-ence must be included in the formula for new equipment develop-ment and essentially drive the products that we create. We can no longer rely only on regulatory standards as a guideline to what our products provide; we also must meet the standards of the workers who will be using our products. In doing so, we achieve a triple win: meeting new and emerging safety standards, protection and safety in the workplace, and productivity to meet the demands of a growing industrial society.

    Scott Corriveau is the president and general manager of the Industrial Global Business Unit at Ansell, a world leader in providing superior health and safety protection solutions that enhance human well-being. More information can be found at www.ansell.com.

    REFERENCES1. Shaffer, L. Where are Your Gloves? Industrial Safety & Hygiene News. No-vember 2008. http://www.ishn.com/articles/where-are-your-gloves, accessed Sept. 27, 2012.

    2. Global Industry Analysts, Personal Protective Equipment: A Global Strategic Business Report Press Release, Oct. 6, 2010, http://www.prweb.com/releas-es/protective_equipment_PPE/protective_clothing/prweb4603364.htm

    3. Monthly Labor Review, January 2012, Industry employment and output projections to 2020.

    Circle 33 on card.

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  • FALL PROTECTION

    12 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    As I travel around the country speaking about ladder safety, I have the opportunity to meet with groups from diff erent industries and talk with them about their ladder problems. Some industries face very unique challenges, but there are always a few that remain the same. Ladder accidents occur because of complacency. People have been climbing ladders since they were little children

    on the playground, and they dont think of ladders as safety equipment.

    Th e overriding rule on a job site is to get the job done, so sometimes it becomes accepted to break the rule. How do you tie off an extension ladder before you climb it? How do you maintain three points of contact while getting the work done? Some of these concerns can be addressed through training, but some need to solved by better design.

    The Number Speak for ThemselvesIn 2008, the CPSC estimated that more than 500,000 people were injured while using a ladder or stepstool. In 2010, the estimate rose to 724,000thats nearly 2,000 people injured every day. Experts estimate 100 people will suff er a long-term or permanent disability each day. And one person will die, every day.

    Th e American Ladder Institute (ALI) off ers what I consider to be the best online ladder safety training available at www.laddersafetytraining.org. Th ere are several online academies that charge a fee; but the ALI training modules are completely free. Th e website provides a pre-test, training videos, a post-test, and, upon completion, a printed certifi cate. Th e site also lets you load an unlimited number of employees and tracks their progress through the four modules.

    As national safety director at Little Giant Ladder Systems, my sole purpose is to travel to organizations and job sites all over the country performing live lad-der safety training events at no charge. If you need help training a large number of employees, look me up. Its my job.

    Last Centurys LaddersTraining is important, but training alone is not enough. We need to stop climbing grandpas ladder.

    If you stop to think about it, there are very few products we use today that are basically the same design they used 100 years ago. Sure, they went from wood to aluminum to fi berglass, but the functional design has remained the same.

    One of the problems with ordinary ladders is that they are not tested to bear up under actual use, mean-ing they arent tested and designed to be used the way people actually use them. Last centurys ladders are tested on a fl at fl oor in an ANSI-compliant testing lab with static dead weight, no movement, no human reac-tion, and no over-reaching.

    Understanding how people actually use ladders and, more importantly, how they get injured using ladders is key to designing new and safer climbing products. Studying the numbers, we can divide the majority of ladder accidents into three categories: strains and sprains from handling heavy ladders, us-

    Keys to Preventing Ladder FallsWhat do you do about a problem that is never going away? I think you have to design around it.BY DAVID FRANCIS

    LITTLE GIAN

    T LADD

    ER S

    YSTEM

    S

    0114ohs_012_016_Francis_v5.indd 12 12/10/13 3:00 PM

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  • 14 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    FALL PROTECTION

    ing the wrong type or size of ladder, and catastrophic falls from over-reaching or improper setup.

    First, nearly 50 percent of reported injuries involving ladders are caused by the awkward size and weight of the ladder. Th e easy solu-tion to this problem is to make a lighter ladder. Second, we use the wrong type or size of ladder for the job. Quite oft en, this problem is caused by the fi rst. Th e ladder that is actually tall enough to do the job is too heavy, so we grab the smaller one. And when we have to reach a little higher, we just climb on the top rung or the top step.

    Th e third category is by far the most costly per incident, both in fi nancial and human costs: falls from height due to over-reaching or improper setup. Th ese are the kinds of falls that change lives or end them, the kinds of falls that result in families left behind.

    You train your people to keep their bodies between the side rails, but you know this doesnt always happen. All too oft en, you see them stretch to reach that one last thing instead of climbing down and moving the ladder. No matter how much we train peo-pleits human nature. We have to understand this problem is not going away. But what do you do about a problem that is never going away? I think you have to design around it.

    Uneven Ground is the NormOn many job sites, it is nearly impossible to fi nd a perfectly level setup for a ladder. On an outdoor job site, the ground is almost never level. Some indoor sites are just as bad; Ive seen facilities with fl oor drains every 20 feet. To give you an idea of how much level ground can aff ect tipping, if a 28-foot extension ladder is one inch off at the base, the top of the ladder will be 19 inches off of center. Th at puts the top of the ladder completely outside the footprint of the ladder. Even if you keep your body between the side rails, you are outside the center of gravity, and your ladder will tip.

    When I ask people what they do on unlevel ground, most just use a brick or a board to build up the low side of the ladder. Spend-ing time on a scavenger hunt looking for the right-sized board to level your ladder doesnt sound very productive or safe. OSHA rec-ommends you dig out the high side of the ladder instead of build-ing up the low side, which is safer but even more time consum-ing. Aft er-market leg levelers can help, but they have two major problems. First, they add extra weight to an already heavy ladder (remember problem #1), and second, they do not give any extra stability to the ladder.

    Th ink about all of the equipment on a job site that comes with outriggers: cranes, backhoes, lift s. Why not an extension ladder? One thing I will never understand is why ANSI and OSHA require a stepladder to be wider at the bottom than the top, but not an exten-sion ladder. We send our people 20, 30, even 40 feet up an extension ladder with almost nothing beneath themit doesnt make sense.

    Think about all of the equipment on a job site that comes with outriggers: cranes, backhoes, lifts. Why not an extension ladder?

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  • FALL PROTECTION

    16 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    By adding outriggers to an extension ladder and merely doubling the base width, we can increase the side-tip stability by over 600 percent. Add in leveling to your outriggers, and now you can talk about preventing injuries and saving lives.

    Stepladders Need to Step Up, TooStepladders present a diff erent set of challenges. Over-reaching is still a huge issue on stepladders, but there is also the three-points-of-contact issue and any tie-off rules that might apply. And what do you do with a stepladder over uneven ground or a staircase?

    You should always maintain three points of contact when as-cending and descending a ladder: two feet and one hand or two hands and one foot. But what do you do when you stop climbing and start working? Most safety pros say you should still maintain three points of contact. Most workers will say its hard to get the job done using just one hand.

    Th e OSHA standard does not include portable ladders in the 6-feet-and-above tie-off requirements, but that has not stopped companies from applying tie-off rules to portable ladders. In fact, Ive visited several companies that require operators to tie off from above from as low as four feet. Even further, some companies have banned ladders altogether. Th ese rules are meant to protect the user but are very diffi cult and sometimes impossible to follow.

    Because of these diffi culties, some general contractors have gone as far as imposing pretty strict rules against using ladders on their job sites. One of the leading contractors in the world, Turner Construction, has developed a Ladders Last program that requires

    subcontractors to use approved equipment (not an ordinary lad-der) or fi nd a diff erent way to get the job done.

    Designing to Solve ProblemsBy combining the platform and handrail system of an enclosed scaff old system with an adjustable fi berglass stepladder, you can solve all of these issues. A new category of climbing equipment called aerial safety cages has recently hit the market. While working in the caged platform, you do not need to maintain three points of contact and can work freely with both hands. Th e 42-inch handrail system on the aerial safety cages satisfi es tie-off requirements, al-lowing operators to get the job done quickly and safely, especially when there is nowhere to tie off . Th e adjustable base allows it to work safely on uneven ground and stairs.

    It Takes TwoTwo things, training and innovation, are going to help us prevent injuries and save lives. Th ere are new, free training resources out there. And now you can fi nd this centurys ladders, designed and tested the way people will actually use them. Its time to stop using grandpas ladders.

    David Francis is the national safety director for Little Giant Ladder Systems of Springville, Utah. He has worked in the ladder industry for 30 years and travels all over the country performing free ladder safety training for all kinds of companies. He can be contacted via email at [email protected] or www.laddersafetyhub.com.

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  • FALL PROTECTION

    18 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    With recent and forthcoming changes to the ANSI Z359 fall protection code, the landscape of the fall protection indus-try is changing. Although OSHA still sets and enforces the law regarding fall protection, the outdated nature of the existing regulations forces or-ganizations to look to ANSI for guidance on current best practices and equipment.

    As in any other industry, manufacturers of fall protection equipment are continuously innovating to meet the needs of their customer base. While even ANSI cant keep pace with this rate of change, the Z359 family of standards outlines the most current best practices for fall protection. Th e changes that have been made to the ANSI standards in the past fi ve years canand, in my opinion, shouldhave a signifi cant impact on an organizations fall protec-tion program.

    It is, however, important to note that the updates to the ANSI Z359 standards make equipment and practices safer. Th is is not to say equipment that meets older standards is inherently unsafe. Equipment that meets newer standards is safer because it refl ects de-sign and application changes based on updated test-ing and feedback on usage. Th is is why training is so important for any equipment: Your workers need to know the use and limitations of equipment. And you need to stress to your workers that engineering con-trols always should be considered before equipment because equipment-based systems have so many op-portunities to fail.

    One of the most impactful changes to the ANSI Fall Protection Code is the ANSI Z359.2 standard, which outlines how to develop and maintain a com-prehensive managed fall protection program. From a holistic standpoint, this standard can have the great-est impact on the overall success of a fall protection program because it addresses far-reaching items, such as policy development, hazard identifi cation, proce-dures, and training. Th ese may seem like standard items for a program, but it is where we have seen many organizations struggle, especially in the hazard identifi cation area.

    Still, selecting and implementing equipment for fall protection solutions is the most visible aspect of a fall protection program. Its also the most costly. So, time, money, safety, productivity, and even em-ployee morale are on the line when implementing equipment-based solutions. For this reason, under-standing the new ANSI standards related to equip-ment components is critical for the success of a fall protection program.

    Th e following scenarios showcase a sampling of the challenges that can exist in transitioning to the new ANSI equipment component standards.

    Sample Scenarios1. Connectors Gate Strength

    Scenario: You recognize that your organization is still using connectors that meet the ANSI Z359.1-1992 (R1999) standard.

    Solution: Replace connectors as soon as feasi-bleif you havent started already. Older connectors were designed with a gate strength of 220 pounds of front load and 350 pounds of side load. Although these connectors are technically safe, the newer con-nectors that meet the ANSI Z359.1-2007 or Z359.12-2009 standards have increased gate strength. For both front and side loads, the newer connectors require gate strength of 3,600 pounds. Th is signifi -cantly minimizes the chances of a failure due to an incompatible connection.

    2. LanyardsScenario: You recognize that your organization

    Update Your Fall Protection Program Now: Apply New ANSI Z359 Equipment StandardsBY THOM KRAMER

    LJB IN

    C.

    T ime, money, safety, productivity, and even employee morale are on the line when implementing equipment-based solutions.

    0114ohs_018_021_Kramer_v3.indd 18 12/10/13 10:50 AM

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  • 20 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    FALL PROTECTION

    is still using lanyards that meet the ANSI Z359.1-1992 (R1999) standard or the ANSI Z359.1-2007 standard.

    Solution: Use a lanyard designed to meet ANSI Z359.13-2009 or limit use of pre-2009 lanyards to employees who weigh 130 to 242 pounds. Although no equip-ment manufacturers have recalled older lanyard models, an issue with weight was discovered in testing that contributed to a change in the test mass for the ANSI Z359.13 standard. To properly test lan-yards and accurately replicate a 310-pound worker, the test mass for energy-absorbing lanyards was increased to 282 pounds.

    3. Leading Edge ApplicationsScenario: You want to use a self-retract-

    ing lanyard (SRL) or vertical lifeline (VLL) in a leading edge application.

    Solution: Some SRLs do not work in the horizontal arrangement required for leading edge work. Also, if used in this manner, it is possible for the lanyard to be cut if loaded over a sharp edge. For SRLs, purchase equipment that is specifi cally de-signed for a leading edge application (SRL-LE) and meets the ANSI Z359.14-2012 standard.

    When using VLLs in a horizontal ar-rangement, the energy absorber is some-times located close to the anchorage, in-stead of close to body where it needs to be. You should provide edge padding and protection to the lifeline to avoid severing it and keep the energy absorber close to the body.

    4. Ballast-Style AnchorageScenario: Someone in your organization

    has decided that a ballast style anchorage is the best solution to protect workers per-forming roof maintenance.

    Solution: Th e functionality of ballast-style anchorages is dependent on the sur-face and other conditions. In many cases, these anchorages can move signifi cantly and unpredictably under load. Due to the variables these systems present, the ANSI standards have not yet addressed this type of product. You should critically evalu-ate this option compared to other more established alternatives. If using these an-chorages, make sure they are tested in the

    exact circumstances where they will be used and involve a qualifi ed person who is also a professional engineer. Remember, not all qualifi ed persons are professional engineers, and not all professional engi-neers are qualifi ed persons.

    5. Proprietary Horizontal Lifeline Systems

    Scenario: Someone in your organiza-tion has decided that a proprietary hori-zontal lifeline system is the best solution for an identifi ed fall hazard. Th ese propri-etary systems are sometimes referred to as a turnkey installation or are installed by a certifi ed installer.

    Solution: While an ANSI standard on

    this topic has not been formally published, it will soon become available to provide guidance for this type of proprietary sys-tem. Th e challenge with a proprietary sys-tem is that the price quoted by turnkey installers can vary greatly, making it diffi -cult for employers to ensure that they are getting what they pay for. It is critical to produce a preliminary design, or bridg-ing documents, that will give employers a

    THE ANSI Z359 FALL PROTECTION CODEANSI Z359-2007 Z359.0: Defi nitions and nomenclature Z359.1: Safety requirements for personal fall arrest systems Z359.2: Minimum requirements for a comprehensive managed fall protection program Z359.3: Safety requirements for positioning and travel restraint systems Z359.4: Safety requirements for assisted-rescue and self-rescue systems

    ANSI Z359-2009 Z359.6: Specifi cations and design requirements for active fall-protection systems Z359.12: Connecting components for personal fall arrest systems Z359.13: Personal energy absorbers and energy-absorbing lanyards

    Recent Z359 Standards Z359.7-2011: Requirements for third-party and self-certifi cation for personal fall arrest systems Z359.14-2012: Safety requirements for self-retracting devices

    Future Z359 Standards ANSI Z359.8-20XX: Rope access systems ANSI Z359.9-20XX: Descending devices ANSI Z359.11-20XX: Safety requirements for full body harness ANSI Z359.15-20XX: Safety requirements for vertical lifelines and fall arrestors ANSI Z359.16-20XX: Safety requirements for ladder climbing systems ANSI Z359.17-20XX: Safety requirements for horizontal lifelines ANSI Z359.18-20XX: Safety requirements for anchorage connectors

    The functionality of ballast-style anchorages is dependent on the surface and other conditions. In many cases, they can move signifi cantly and unpredictably under load.

    0114ohs_018_021_Kramer_v3.indd 20 12/10/13 10:50 AM

  • method to qualify proposed systems.Scenario: A proprietary horizontal life-

    line is being used, but some workers weigh more than 250 pounds.

    Solution: Have a third party verify the maximum user weight for the specifi c sys-tem. Some proprietary horizontal lifeline systems are intended only for a 220-pound user weight because they are based on Eu-ropean standards. Th is may require you to de-rate the horizontal lifeline. Another op-tion is to go through a detailed analysis of the system and use new lanyards that meet the ANSI Z359.13-2009 standard.

    6. System Certifi cationScenario: You cant fi nd any documen-

    tation for an existing horizontal lifeline system, and workers need to use it for an upcoming maintenance project.

    Solution: Follow guidelines for system certifi cation found in the ANSI Z359.6 standard. No matter how old a fall pro-tection system is, its sole purpose is to save a falling worker. But fall protection systems can function only if they are in-stalled and used properly, and the process of certifi cation provides assurances that key aspects of the system are appropriate and functional.

    Is the system appropriate for identi-fi ed hazards? Is an engineering control op-tion feasible instead?

    Are there adequate anchorages and structural support?

    Are appropriate use and rescue pro-cedures in place?

    Have users received appropriate training for the equipment and system?

    Regardless of your specifi c scenario or the status of your fall protection program, the ANSI Z359 Fall Protection Code can provide useful guidance in protecting workers at heights. Th e code provides a wide array of information, ranging from program development and management to system design to equipment use and limi-tations. If its a fall protection best practice you need, the ANSI Z359 Fall Protection Code is the place to fi nd it.

    Th omas Kramer, PE, CSP, is a principal with LJB Inc. and currently serves as the president of the International Society for Fall Protection, as well as subcommittee chair-man for two ANSI Z359 committees on active fall protection. He can be reached at [email protected].

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  • JANUARY 2014 VOL. 83 NO. 1| www.ohsonline.com

    Ending with a Bang

    Silica, Spills, Lawsuits & Rules

    Safely Aloft

    www.ohsonline.com JANUARY 2014 | Occupational Health & Safety 25

    0114ohs_025_GasCover_v3.indd 25 12/10/13 10:51 AM

  • 26 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    Two signifi cant OSHA rulemaking actions in the sec-ond half of 2013 could be game-changers for the construction workers and others who may be occu-pationally exposed to breathing silica dust, as well as

    to employers across the land. OSHA Assistant Secretary Dr. David Michaels on Aug. 23 announced a proposed rule is-sued by the agency that would set a new permissible exposure limit (PEL) of 50 micrograms of respirable crystalline silica per cubic meter of air, averaged over an eight-hour day. Th is rule had been awaiting action at OIRA, the OMB gatekeeper offi ce for proposed federal regulations, for more than a year, so the announcement was major news for employers in con-struction, natural gas drilling, and some in general industry, as well. Michaels urged the public to participate by visiting www.osha.gov/silica and reading fact sheets about the rule. Th e cur-rent PEL was set in 1971; this lower PEL would apply to con-struction and general industry, including hydraulic fracturing operations at gas drilling sites. Stakeholders have until Jan. 27 to submit comments. OSHAs informal public hearings about the proposed rule will begin March 18, 2014, in Washington, D.C., and are expected to continue for several weeks.

    If it becomes a fi nal rule, the second rulemaking action, in November, makes 2013 a milestone year for recordkeeping changes. Th is one would require establishments with more than 250 employees that are already required to keep injury and ill-ness records to electronically submit them to OSHA on a quar-terly basis and establishments with 20 or more employees in industries with high injury and illness rates to submit each year, electronically, their injury and illness logs. Earlier in the year,

    OSHA had issued a fi nal rule requiring all federal agencies to submit their injury and illness data to BLS annually.

    It was a busy year for the agency, a year puncuated by a fed-eral government shutdown that aff ected 90 percent of its work-ers. Michaels on Oct. 24 unveiled two online tools that safety organizations interpreted as a step toward updated Permissible Exposure Limits, one of the highest priorities of industrial hy-gienists and safety professionals for many years. Th e tools are annotated tables showing how OSHAs current PELs diff er from Cal/OSHA, NIOSH, and ACGIH exposure limits and a toolkit employers can use to choose safer alternative chemicals. Th e tables are available at https://www.osha.gov/dsg/annotated-pels/index.html and the toolkit at http://www.osha.gov/dsg/safer_chemicals/index.html.

    2013: The Year in ReviewTwo multi-fatality events in April 2013, the West, Texas fertilizer plant explosion and the Rana Plaza apparel factory collapse in Bangladesh, spurred the Obama administration and six major global retailers, respectively, to promise oversight changes. On the other hand, MSHAs Joe Main and the Association of Ameri-can Railroads confi rmed early in the year that 2012 had been the safest year on record for the mining and railroad industries, respectively.

    In occupational health, the Aff ordable Care Actnotable both for its support for workplace wellness programs and its rocky rolloutundoubtedly was the top story of the year. Also, FDA and some state authorities took steps to reclassify and re-label opioids or synthetic drugs to make them harder to access.

    In November 2013, Quest Diagnostics released a Drug Test-ing Index report covering the entire 25 years since President Ronald Reagan signed the Drug-Free Workplace Act into law. Analysis of urine tests during the intervening years showed a 60 percent drop in positives among the general U.S. workforce since 1992, but the experts identifi ed two big danger signs: states legalizing recreational marijuana use and increasing abuse of prescription drugs. R.H. Barry Sample, Ph.D., director of sci-ence and technology for Quest Diagnostics Employer Solutions, said the positive rate among workers for whom testing is feder-ally required fell from 2.6 percent in 1992 to 1.6 percent in 2012, while the positive rate among those tested in the general U.S. workforce fell from 10.3 percent in 1992 to 4.1 percent in 2012.

    Other signifi cant events during the year included these:January 2013 BP pleaded guilty to manslaughter charges in connection

    with the April 2010 Deepwater Horizon explosion. Th e company was ordered to pay criminal penalties totaling a record $4 billion.

    Ending with a BangTwo signifi cant OSHA rulemaking actions took center stage in late 2013, which may be remembered as a milestone year for recordkeeping changes.By Jerry Laws

    0114ohs_026_028_YearEnd_v3.indd 26 12/10/13 10:52 AM

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    February 2013 Th e Massachusetts Department of Public Health an-

    nounced Feb. 5 that, as a result of its unannounced inspec-tions of 40 compounding pharmacies triggered by the New England Compounding Center-linked fungal meningitis out-break, partial or complete cease and desist orders were issued to 11 pharmacies for a range of violations. Th e states Board of Pharmacy also issued new regulations that require sterile compounding pharmacies in Massachusetts to report volume and distribution to the state for the fi rst time.

    A Massey Energy Company executive, David Hughart, 53, of Crab Orchard, W.Va., pleaded guilty Feb. 28 to conspir-ing to impede the Mine Safety and Health Administration and also conspiring to violate mine health and safety laws. Hughart pleaded guilty to the charges in a U.S. district court in Beckley, W.Va.

    July 2013 CDC reported that more American women have died

    from drug overdoses than from motor vehicle crashes since 2007. Th e report summarized a study that found the num-ber of prescription painkiller fatal overdoses rose 400 percent among women from 1999 to 2010, compared with 265 per-cent among men. Drug overdose deaths also accounted for 34 percent of all suicides among women but only 8 percent among men. CDC reported prescription painkiller overdoses killed nearly 48,000 women between 1999 and 2010.

    Th e U.S. Chemical Safety Board on July 25 designat-ed an OSHA combustible dust standard for general indus-try as its fi rst-ever Most Wanted Safety Improvement.

    August 2013 U.S. railroads were ordered to take steps within 30 days

    to ensure trains moving hazardous materials do not move while unattended and possibly cause a disaster similar to the July 6, 2013, derailment and fi re in Lac-Mgantic, Canada.

    September 2013 Th e U.S. Department of Labor issued a rule making di-

    rect care workersthose who provide long-term care for the elderly or disabledeligible for overtime and minimum wage protection. Th e change will aff ect approximately 2 million home health and personal care workers.

    CDC warned again about antibiotic-resistant infec-tions, stating that more than 2 million people in the United States get them each year and at least 23,000 die. Th e report called this an urgent health threat for the country. Th e loss of eff ective antibiotic treatments will ripple the ability to fi ght routine infectious diseases and undermine treatment of infec-tious complications in patients with other diseases, according to CDC.

    November 2013 Th e NFL Players Association announced a new well-

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    Jerry Laws is editor of Occupational Health & Safety.

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  • 30 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    Silica, Spills, Lawsuits, and Rules

    The U.S. oil and gas industry saw a lot of action during 2013. Whether it was educational institutions creating training programs for the industry or OSHA proposing a rule to limit workers exposure to respirable crystal-

    line silica, the gears were in motion to make sure the industry was not only safe, but also continuing to fl ourish. Heres a recap of some of the key events in the industry last year and what they mean for its future.

    Protecting Workers from Silica ExposurePerhaps the most important development during 2013 was OSHAs proposed rulemaking on limiting respirable crystalline silica exposure for those who are engaged in hydraulic fractur-ing, construction, mining, and some other industries.

    Th e detrimental eff ects of inhaling silicaprimarily diseases such as silicosis, tuberculosis, lung cancer, kidney disease, and chronic obstructive pulmonary diseaseare not news in the in-dustry. Dozens of oil and gas safety professionals pressed OSHA Assistant Secretary Dr. David Michaels in December 2012, at that years OSHA Oil & Gas Safety and Health Conference held in Dallas, about how soon his agency would issue the proposed rule and fi nalize it. Th is followed a joint NIOSH/OSHA Haz-ard Alert that showed almost half of the 116 air samples NIOSH had collected at 11 fracking sites in Arkansas, Colorado, North Dakota, Pennsylvania, and Texas contained silica above the OSHA Permissible Exposure Limit and 79 percent of them were silica exposures higher than the NIOSH Recommended Expo-sure Limit of 0.05 milligrams per cubic meter. Sand mover and blender operators, and workers who are downwind of those op-erations, had the highest exposures.

    OSHA proposed a new PEL, 50 g/m3, which the proposed rule says the agency considers the lowest feasible PEL for indus-try. Replacing the current PEL, which hasnt been changed since 1971, could prevent around 700 deaths per year, according to the agencys estimate.

    OSHA published the 755-page rule in the Federal Register on Sept. 12, 2013, and set a 90-day comment period for it. Numer-ous stakeholder groups requested an extension, so OSHA ex-tended the period by 47 days, giving stakeholders until Jan. 27, 2014, to submit comments on the rule.

    Th e Hazard Alert is available at https://www.osha.gov/dts/hazardalerts/hydraulic_frac_hazard_alert.pdf.

    Valley Fever PrecautionsContinuing on the front of protecting workers health, Cal/OSHA has made a commitment to protecting workers in the

    oil and gas industryas well as wildland fi refi ghters, geologists, agricultural workers, and others engaged in earth-moving work or exposed to dusty conditionsfrom Valley Fever. Workers in these occupations in central California risk contracting Valley Fever, which is caused by a microscopic fungus that lives in the top 2 to 12 inches of soil.

    Th e agencys October 2013 fact sheet, Advice to Employers and Employees Regarding Work-Related Valley Fever, outlined the causes of the potentially serious fungal infection and pre-ventative measures while reminding employers to report cases of illness. Because there is no vaccination for Valley Fever, the fact sheet urged employers to take steps to protect their workforces, such as determining whether they work in an endemic area (mainly the Central Valley of California), adopting site plans to reduce exposure, protecting workers against exposure with NIOSH-approved respiratory protection fi lters, training work-ers on the risks of Valley Fever, and more. Th e number of new cases reported statewide has risen dramatically in recent years, the California Department of Public Health has reported.

    Employers need to be aware of the Valley Fever risk and take preventative measures when soils are disturbed in regions where the spores are likely to be present, said Christine Baker, direc-tor of the California Department of Industrial Relations, parent agency of Cal/OSHA.

    Preparing the Future WorkforceWith domestic oil and gas production booming and large num-bers of the industrys workers soon to retire, a challenge that has been dubbed the great crew change, there are concerns about at-tracting enough young people who are prepared to join the ranks. One institution, Houston Community College, responded by an-nouncing it will establish the HCC Global Oil and Gas Drilling Training Center. Th e center will provide training for entry-level oil and gas rig crews. According to the International Associa-

    The challenges of a booming industry were met on many fronts in 2013, from training and recruitment to regulatory changes and safety stand-downs.By Jamie Friedlander

    0114ohs_030_032_Friedlander_v3.indd 30 12/10/13 11:36 AM

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    tion of Drilling Contractors Drilling Contractor magazine, the center will replicate the essential components of the rig work environment for off shore roustabouts/onshore roughnecks. Th e center will house a skills and safety laboratory named RIG-ONE and will begin holding classes in spring 2014.

    On the opposite side of Houston, Honeywell Life Safety ex-ecutives cut the ribbon on a Training & Customer Experience Center on Sept. 18, 2013, welcoming hundreds of customers and media representatives to tour the $3 million facility, which includes simulated confi ned space, construction, heavy metal fabrication, oil and gas, emergency responder, and utilities/energy environments that illustrate the full spectrum of prod-ucts off ered by three HLS unitsHoneywell Safety Products, Honeywell Fire Systems, and Honeywell Gas and Flame De-tectionfor all of those industries. Mark Levy, Honeywell Life Safetys president, said the location was chosen because its in the heart of the refi neries and the energy and petrochemical industries located in and around Houston, which is a major hub for clients in Latin America, as well.

    In addition, Artesia, N.M., held an oil and gas career fair in late October for more than 225 students in middle and high schools. Th e students who participated were part of the MESA program, which is a program held in more than 100 New Mexico schools to encourage students to pursue careers in math, science, and engineering.

    Trouble in the Bakken Oil FieldTh e Bakken shale oil fi eld in North Dakota has made that state one of Americas largest oil producers (second only to Texas), but there also were signs of trouble last year.

    Mineral owners fi led a lawsuit seeking millions of dollars in royalties from energy companies working the Bakken be-cause those companies have been fl aring natural gas, rather than collecting and selling it. Th e companies say the gas is burned because they dont have pipelines in place to transport their oil production. Th e lawsuit argues the mineral owners have lost what could be millions of dollars in royalties because oil companies burn the gas instead of selling it.

    Th e Bakken fi eld also was in the news for what is con-sidered the largest oil spill in North Dakotas history, when a farmer found oil seeping from a Tesoro Pipeline Company crude oil pipeline in one of his fi elds. Th e total amount spilled was equivalent to about 20,000 barrels.

    In July 2013, a train carrying oil from the Bakken fi eld rolled unmanned into the town of Lac-Mgantic, Quebec, where it derailed and exploded. More than 40 people died in the explosion and fi re. Transport Canada responded by issued an emergency directive telling rail operators to ensure that no locomotive attached to tank cars loaded with dangerous goods be left unattended on a main track and also to ensure brakes are properly set to prevent unintended movement.

    On Aug. 7, the Federal Railroad Administration issued Emergency Order No. 28, which told U.S. freight railroads to take steps within 30 days to ensure trains moving hazardous materials do not move while unattended and possibly cause a disaster similar to the Lac-Mgantic incident. Two months lat-er, FRA and the Pipeline and Hazardous Materials Safety Ad-ministration issued a safety advisory to reinforce to railroads the importance of properly classifying Class 3 materials and ensuring the railroads safety and security plans address the vulnerabilities cited in the emergency order. Class 3 materials are fl ammable and combustible liquids. To move a large bulk quantity (792 gallons or more), railroads must develop and adhere to a transportation safety and security plan that covers personnel security, unauthorized access, and en route security.

    Construction of oil transfer facilities has been proposed in the Northwestprimarily in Washington state and Canada, eliciting both support from those who anticipate more jobs from the construction and opposition from others who cite environmental and safety concerns.

    Safety Stand-DownsSome OSHA regions helped to organize safety stand-downs with oil and gas industry partners and STEPS organizations during 2013. Th ese focused on training to address the biggest hazards in the industry, including driving hazards and struck-by injuries. NIOSH Director Dr. John Howard said in 2012 that the oil and gas exploration and production industrys most frequent type of fatal event is a motor vehicle accident, with many of the crash victims being workers driving com-pany pickup trucks.

    Jamie Friedlander is an associate content editor with Occupa-tional Health & Safety magazine.

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    CUSTOMER SERVICE DIRECT

    800-466-0071 631-474-0073 (FAX)Email: [email protected] www.occunomix.com CIRCLE 30 ON CARD

    Untitled-2 1 12/4/13 10:40 AM

  • 34 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    Fall protection was number one among the top 10 most frequently cited federal OSHA standards in 2012. In fact, according to the Bureau of Labor Statistics, the leading cause of worker deaths on construction sites is falling.

    In 2011, a staggering 35 percent of total deaths in construc-tion were due to an unprotected fall. While the existing OSHA general industry standards recognize the use of guardrails and physical barriers as the primary methods for employee protec-tion against falls, those standards also recognize that personal fall protection systems can provide more eff ective means for em-ployee protection.

    Like OSHA, our engineers believe that the majority of slips, trips, and falls are preventable. We also recognize the impor-tance of allowing employers the fl exibility to decide which fall protection system works best for their particular operation while ensuring their employees receive a suffi cient level of protection.

    Choosing an eff ective fall protection system is dependent upon each companys unique application, along with the federal guidelines outlined for that particular industry. While federal guidelines outline the need for eff ective employee protection against potential falls, the standard for employees who work atop tanker trucks is unclear. Most tanker trucks are approximately 14 feet tall. Th is height, combined with the cylindrical shape of the tanks, can pose a real safety risk to workers who have to climb around on top of them. Stephen Wallace, environmental

    health and safety manager for Intergulf Corporation, recognized the importance of fall protection as a necessary component to ensure the total safety of his workers who go atop the trucks.

    Intergulf Corporation is a leading industrial liquids manage-ment company specializing in procuring, blending, treating, and processing petroleum, petrochemical co-products, and waste streams. Th e company manages three facilities that are strategi-cally located along the Houston Ship Channel and operates in fi ve business segments: waste and recycle, petroleum products, marine services, distillation, and hazardous waste transportation.

    Wallace began to investigate various fall protection systems in 2012 to help ensure the safety of workers who perform routine duties on top of tanker trucks at the facilities. Th ose facilities now feature a total of six fall protection systems, all specially custom-ized to meet the unique needs of each facility and to eliminate potential fall hazards. Th ree of the six fall protection systems are located in Pasadena, Texas, at the companys Bay Port facility, which is used for wastewater and oil recycling. Th ese systems ensure the protection of workers who sample, treat, load, and unload liquid waste from the tops of tanker trucks.

    Th ere is a 70-foot-long fall protection system in the pit, which is an area workers use to load and unload waste materi-als. Th is particular system fi ts one truck and includes one fall protection track that runs parallel with the truck beneath it. It also includes four columns, two headers, and two self-retracting lifelines (SRLs) so that two workers can connect to the system at any given time.

    Th e second fall protection system here is in the sampling area, used for taking samples of waste materials and for load-ing and unloading trucks. Th e system is heavily customized to include a 70-foot fall protection track that extends out from columns with boom arms that lock into place. Th e track covers a total of six trucksfi ve between the columns and one at the end. Th e third system at this facility is located in the contain-ment area. Th is area is set up similar to a long driveway, where trucks can pull in and out in a single line and workers can access the waste materials from the top. Engineers designed a 300-foot system to accommodate the needs of this part of the facility. Th e system fi ts fi ve trucks and includes one lifeline that runs parallel with trucks, seven headers, 14 columns, and 10 SRLs.

    Fall Protection Systems at the Marine Terminal and 225Two of the fall protection systems are installed at Intergulf s Ma-rine Terminal facility, which is used to unload barges to ship ma-terials to diff erent locations. Both of the systems were designed to accommodate two trucks at any given time. Instead of includ-ing one fall protection track, the systems at Marine Terminal in-clude two rigid tracks that run parallel to the trucks. Part of the distinct nature of this two banger system is that the SRLs on each track can cross over one another because they are running on two separate tracks.

    Kristina Harman is a content writer and fi eld investigator for Rigid Lifelines.

    Safely AloftThe height and cylindrical shape of tanker trucks can pose a real safety risk to workers who have to climb around on top of them.By Kristina Harman

    RIG

    ID LIFELIN

    ES

    Two of the fall protection systems are installed at Intergulfs Marine Terminal facility, which is used to unload barges to ship materials to different locations.

    0114ohs_034_Harman_v3.indd 34 12/10/13 11:37 AM

  • CHEMICAL SAFETY/SDS

    www.ohsonline.com JANUARY 2014 | Occupational Health & Safety 35

    I was having a conversation recently with the safe-ty offi cer of a large health care facility about the looming Dec. 1, 2013, training deadline estab-lished by OSHA. Th e new training requirement mandates that employers provide employee training on the new GHS Safety Data Sheets (SDSs) labels, pictograms, etc. that will be available from chemical distributors during the next couple of years. I was as-tounded to hear him express how nervous he was that he would not be able to accomplish this task for his 4,000-plus employees by the deadline and by his per-ception that he would be in big trouble with OSHA.

    You can be assured this was not an isolated inci-dent, because the fact of the matter is the majority of safety offi cers I have spoken to in recent months shared the same concern regarding their perception that OSHA is going to visit them with a big fi ne if they didnt meet this training deadline. Talk about the power of suggestion and a great example of percep-tion versus reality!

    In jest, I told him that I was certain OSHA had a list of companies that its offi cers were planning to visit beginning on Dec. 2 to check on their training results, and his hospital was at the top of the list. Th e reality is, we are now in January 2014, and I doubt that any-one reading this article was visited by OSHA in the past few weeks and fi ned for not completing HazCom 2012 training on time.

    I am not in any way attempting to make light of this important topic or the training requirement es-tablished by OSHA, but dont you think it is time for a little practical thinking here? Consider this: Millions of dollars have been spent in recent months by com-panies like yours in an attempt to meet their compli-ance obligations, with little thought about what the fi nal outcome would be. For example, the new SDSs, labels, pictograms, and hazard and precautionary statements will not even be available in many cases from suppliers until 2015, so the reality is this train-ing will need to be conducted numerous times during the next few years unless your employees have photo-graphic memories.

    Th e new SDSs and other GHS elements recently adopted by OSHA were intended to provide infor-mation in a manner that employees using hazardous chemicals could comprehend, thereby reducing the rate of chemical-related accidents and illnesses. Th e reality is that a signifi cant number of our nations em-ployees comprehend at or below a ninth-grade level,

    and the new SDS will continue to be technical and confusing to those employees and most of the other audiences for which they were intended. What is amazing is the amount of emphasis that was placed on providing employee training on the new OSHA elements by Dec. 1 and how little attention has been given to the real training issue. As stated by OSHA in Paragraph (h) of the Hazard Communication Stan-dard, employers must provide eff ective information and training for every employee using chemicals.

    We perceive or assume that if we provide access to an SDS, instruct employees on the new format, and show them a video about the new changes, somehow they will be able to work more safely with chemicals and we have now met our obligation as safety profes-sionals. Th e reality is that we should be able to dem-onstrate that our employees understand the hazards they are exposed to and what measures they can take to protect themselves from being exposed. Anything short of this reality is akin to Dorothy clicking her red shoes together and ending up in Kansas.

    OSHA stated in the early Hazard Communication Standard that For any safety and health program, success depends on commitment at every level of the organization. Th is is particularly true for hazard com-munication, where success requires a change in be-haviorand this statement remains true today. Have you ever considered just how much money and time you and your staff have spent over the years generating chemical lists, collecting data, and paying for services, all in an attempt to simply comply with the letter of the rule? Th ough it may make you feel better, simply pro-viding SDS information or making it available to em-ployees does not satisfy your compliance obligation.

    If you are going to spend the time gathering this information and making a list, why not make it pro-ductive? Divide your list up by department and, in ad-dition to the chemical name, add the following com-ponents to your list: the physical and health hazards of each chemical, target organs that could be aff ected, the route of exposure (how the chemicals get into the body), and PPE. Develop your training programs to help your employees understand why this informa-tion is important, and focus especially on the target organs and how exposure to certain chemicals can permanently damage these organs.

    Numerous examples and resources are available to you. Th ey may require a little research and time in the beginning, but in the end you may fi nally reduce the gap between perception and reality.

    Tom Jacques ([email protected]) is the business manager for the MAXCOM Services Division of Haas Group International Inc.

    GHS: Perception vs. RealityHeres what OSHAs Dec. 1, 2013, training deadline should mean to you. BY TOM JACQUES

    0114ohs_035_Jacques_v3.indd 35 12/10/13 11:38 AM

  • DISASTER PREPAREDNESS

    36 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    When Hurricane Sandy hit New Jersey last year, 71,770 buildings were damaged. Of those, 5,051 underwent major damage and 501 were destroyed. Many of these buildings were businesses, and several of the businesses did not have proper insurance plans or emergency pre-paredness plans in place, putting both their employees and the future of their companies at risk.

    Th e threat natural disasters pose is real, and it is not fading away any time soon. Many natural disas-ters have occurred in the past few years alone: Sandy, the 2011 tsunami in Japan, wildfi res and fl ooding in Colorado and Texas, among others. Getting the prop-er natural disaster preparedness plan in place for your company is the key to ensuring both your employees and your business survive.

    Many employers are focused on fi nancial success and establishing their company, said Linda Sherrard, Safety Consultant II at the North Carolina Depart-ment of Public Safetys Central Prison Healthcare Complex in Raleigh, N.C. Th ey are good people who overlook the what if of emergency planning in the race to succeed in business. Oft entimes, employers delay having a plan in place, thinking it will never happen to them, and the system is overwhelmed when something does happen.

    Taking a few weeks out of the year to create a plan and train employees on that plan may seem like a

    burden, but it could mean the diff erence between a companys being destroyed aft er a natural disaster and bouncing back quickly.

    The Importance of Having a Plan in PlaceTh e climate of natural disaster preparedness has changed drastically over the last few decades. Com-panies used to sound an alarm, make sure their em-ployees were safe, and try to get back on their feet as quickly as possible aft er a disaster. Now, companies have to reach their employees in a multifaceted way to ensure their safety. Companies also have to put more legwork into creating a business continuity plan in the event that a disaster does occur so fi nancial burdens do not overwhelm the business.

    According to Sherrard, the most important thing a business can do is have the tools to meet the un-expected. Th ough severe, detrimental fl ooding may seem unlikely in Arizona, for example, businesses should never rule it out completely. Taking a handful of days to create a fl ood preparedness plan may seem like an inconvenience, but struggling to get a business back in shape aft er a fl ood happens is an infi nitely worse inconvenience.

    Angelo Pinheiro, a senior HES professional at Marathon Oil, echoed Sherrards statement. A lot of companies assume that government agencies should take care of them in the event of a natural disaster, he

    Preparing for the WorstNatural disasters are not falling by the wayside. In fact, they seem to be more frequent than ever before. Heres why its important to be prepared.BY JAMIE FRIEDLANDER

    0114ohs_036_037_Friedlander_v3.indd 36 12/10/13 2:32 PM

  • www.ohsonline.com JANUARY 2014 | Occupational Health & Safety 37

    said. And [therefore], they havent looked at the business continu-ity destruction that those disasters can have on their bottom line.

    How to Create a PlanCreating a plan starts by acknowledging that no area in the Unit-ed States is exempt from a natural disaster. (Th e map on FEMAs homepage, www.fema.gov, confi rms this.) Weve had earthquakes, massive fl oods, tornadoes, hurricanes, and blizzards, Pinheiro said. All of these events have aff ected all of the areas of the United States and have caused massive destruction. Natural disasters are all over the place.

    Companies in all industries can look to FEMA, the American Red Cross, and other local and federal organizations for informa-tion on how to begin creating an emergency preparedness plan. While creating a plan is important in every industry, its more than important in remote industries, such as oil & gas and construction: Its essential.

    If youve got people working 15 or even 100 miles away on a pipeline and theres an impending tornado in that region, you have to be able to contact them and give them enough time and notice to leave the job, secure the site, and go to a safe place, said Pinheiro, who stressed the importance of oil and gas companies having an emergency natural disaster plan in place.

    Another step to keep in mind when creating a plan is involving employees in the process. Joe Bader, vice president of the Safety and Security Group at Federal Signal, said employees oft en know more about a building or job site than their managers. In work facilities, oft entimes the employee has a better idea of where they need to go or what they need to do in certain situations because they know their work environment so intimately, he said.

    Involving employees helps each employee feel as though the com-pany has his or her best interest and safety in mind, Sherrard agreed.

    Hurdles to Creating a PlanGetting a plan in place comes with its challenges, she said. One challenge is accurately assessing the needs of the company and

    employees and allotting time to complete and maintain the infor-mation, Sherrard continued. All emergency information needs to be reviewed and updated as things change. A two-year-old em-ployee contact list will be out of date. Th ink of your disaster plan as a living entity; it has to be updated regularly or it dies a slow death from inaccuracy.

    Another challenge is ensuring communication eff orts work with employees of all ages. While disaster preparedness apps and text alerts may be the most effi cient way to communicate an emergency plan to young employees at a remote site, it may not always work with an aging workforce. Workers in their fi ft ies, sixties, and even seventies may not be equipped to communicate in this way, and employers have to take this into consideration when creating a plan. One way to tackle this challenge is ensur-ing you are letting your employees know of a natural disaster in several ways, Bader said.

    For example, dont just send a text message. Sound a loud si-ren in outdoor or remote areas, make phone calls, send emails, and more. Research shows around 10 percent of people dont listen to a warning the fi rst time around. Hitting them with the information in more than one outlet can ensure they take the threat seriously, while also covering the bases with employees who may not be tech savvy.

    An Unfortunate RealityWhat it boils down to is that no matter what, natural disasters will occur. Companies cannot prevent the elements. But what they can do is have the strongest possible plan in place to deal with a disaster when it does strike. Essentially, I cant stop a tornado from ripping through a building, said Bader. Th ere are some things you just cant stop. All someone can do is make sure they have a program in place to repair their business, get back online, and make sure their workers are safe. Sometimes your plan is How are we going to rebuild?

    Jamie Friedlander is an associate content editor at Occupational Health & Safety magazine.

    CHECKLIST: PREPARING YOUR WORKPLACE FOR A NATURAL DISASTERAre you ready to start creating a plan for your company? Take the following steps to ensure you create the most effective and thorough plan possible. Be aware of the natural disasters that could occur in your area. These include fl oods, hurricanes, tornadoes, severe storms, extreme cold, extreme heat, earthquakes, volcanoes, landslides, tsunamis, and wildfi res. Have your facility evaluated by a trained safety or emergency management professional for potential hazards. Look into the history of your location to see which types of natural disasters have occurred in the past and how frequently. Create an evacuation plan and practice it often. Asking for employee suggestions and insight can help make employees feel involved in the process and therefore more enthusiastic about participating. Write your plan so that copies can be distributed to all employees, including those in remote locations. Ensure you have the appropriate supplies on hand to deal with a natural disaster. In the event that your business is spread out (e.g., employees are working on an oil rig or a construction site), have a system in place that uses apps, text messages, phone calls, and sirens to alert employees of imminent danger. Have a media relations policy in place in the event that information needs to be released after a catastrophic event. Prepare press releases ahead of time that can be easily tweaked during an emergency. Ensure all data is backed up on a regular basis and have a set of approved vendors in place for quick replacements of equipment and bringing on temporary employees, if necessary. Ensure your company has the proper insurance policy in the event a natural disaster does occur. Most importantly, evaluate and update your plan on a regular basis. Having a plan that was created years ago may not be suffi ciently up to date to deal with the most serious risks. Sources: American Red Cross; FEMA; Linda J. Sherrard, CSP

    0114ohs_036_037_Friedlander_v3.indd 37 12/10/13 3:30 PM

  • NEW PRODUCTS WWW.OHSONLINE.COM/MCV/PRODUCTS

    38 Occupational Health & Safety | JANUARY 2014 www.ohsonline.com

    FLAME RESISTANT SHIRTMount Vernon FR has an-nounced the release of its AMTEX TC fl ame resistant fabric. The AMTEX TC is a col-lection of cotton and Tencel blends created for total com-fort, and the new line of cloth-ing addresses the challenges of maximizing both comfort and protection in protective work wear fabrics. AMTEX TC fabrics are currently offered in 7.9-ounce and 8.4-ounce twill and are unique in that they increase both comfort and durability without sacrifi cing the protection demands of the FR industry.www.ohsonline.com/productinfoCIRCLE 304 ON CARD

    LATCHING PAIL LIDNew Pig introduces the PIG 5-Gallon Latching Pail Lid, which is the fi rst latching lid designed to fi t both steel and poly 5-gallon pails. The durable, powder-coated steel lid opens and closes with a single latching hasp. A reinforced hinge, latching mechanism and nitrile gasket create a tight seal around the lid, helping to keep pail contents pure and decrease vapor emissions. In addition, a fast-latch ring makes instal-lation easy. www.ohsonline.com/productinfoCIRCLE 305 ON CARD

    LED WORKLIGHTSPatlite introduces a new design LED worklight with the performance and protection needed for performance-criti-cal environments. The CLK-SA LED Worklights are designed with a stainless steel body and clear acrylic PMMA resin lens cover, creating an IP69K rated sealed enclosure that withstands high-temperature and high-pressure wash downs, and is resistant to water and oil. The CLK-SA worklight offers bright, energy-effi cient lighting, long life and reliable operation.www.ohsonline.com/productinfoCIRCLE 306 ON CARD

    DISPOSABLE MICROFIBER SYSTEMRubbermaid Commercial Products (RCP) introduces the availability of the Rubbermaid HYGEN Disposable Microfi ber System for effi cient cleaning and infection prevention in the healthcare environment. The system is designed and proven by third-party testing to remove 99.9 percent of microbes. The system also features built-in scrubbers that enable complete dirt removal without smearing. www.ohsonline.com/productinfoCIRCLE 307 ON CARD

    ELECTRICALLY INSULATED EARMUFFS3Ms new Peltor Earmuff X3A series earmuffs feature a newly designed spacer to improve attenuation without excess bulk or weight. The X3 series earmuffs also feature high attenuation, a lightweight and compact de-sign, new ear cushion foam technology for an effective acoustic seal and reliable protection. The X3A model features a dielectric wire headband, earcups tilt for optimum comfort and a twin headband design.www.ohsonline.com/producti