As part of its ongoing fall prevention campaign, OSHA has announced a national Fall Prevention Stand-Down from June 2 to 6, 2014, to raise awareness among employers and employees about the hazards of falls. Falls account for the highest number of fatalities in the construction industry, which equates to approximately one-third of deaths from construction-related injuries.
During the stand-down, employers and workers are asked to pause their workday to talk about fall prevention in construction and discuss the potential hazards and ways to prevent workers from being injured due to falls. Some of the topics that could be discussed by utility and excavation contractors are ladder safety, falls from equipment, where fall protection is required, how to select and set up fall protection systems and working around trenches.
Fall Prevention Near Excavations
Underground and excavation utility contractors must comply with fall protection requirements; however there is an exception for trenches. OSHA’s fall protection standard, 29CFR1926.500 – Subpart M, requires that all employees exposed to falls of 6 ft or more be provided with fall protection. However, Subpart M includes an exception for trenches. The standard 1926.501(b)(7) does not require fall protection if the edge of the trench can be readily seen by the employee.
As many utility contractors already know, fall protection devices used near the edge of a trench can create problems. In the opinion of many utility contractors, fall protection around a mobile trench operation can create greater hazards.
For example, a railing encourages workers to approach the trench because it appears safe to do so. Workers, with the exception of the top person or competent person, need to be instructed to stay clear of the edge of the trench at all times. The top person and competent person should be aware of the potential hazards and be instructed to stay as far back from the edge as is possible. Where possible, they should provide signals and direction from the end of the trench.
Problems include guardrails constantly being damaged or getting in the way as the trench protective system is moved or when installing shoring. Guardrail systems can cause excavators to lift pipe and other materials higher than needed to get over the railing, often causing the excavator boom to get too close to an overhead power line. Guardrails also create a situation where a worker can be caught between the railing and the material or excavator bucket.
Where Fall Protection Is Required
According to Subpart M, if the edge of the trench cannot be seen because of plant growth or other visual barrier, fall protection is required. Not being able to see the edge of a trench is seldom a situation that occurs; therefore, in most trenching operations, fall protection is not required around the edge of the trench. However, fall protection is required at the edge of pits, wells, shafts and similar excavations 6 ft or more in depth.
There are several types of fall protection systems that can be used to comply with the OSHA requirements. They include guardrail systems, safety net systems, personal fall arrest systems (PFAS), positioning device systems, warning line systems, controlled access zones, safety monitoring systems and covers. If there is a possibility that a worker could fall 6 ft or more, then a fall protection system must be in place, except around the edge of a trench.
Guardrail systems must be set up so the top rail extends 42 in. by 3 in. above the top of the excavation or working/walking surface. They must be strong enough to withstand a 200-lb load in any direction and anywhere along the top rail. Midrails, screens, mesh or other equivalent intermediate barriers capable of withstanding 150 lbs, must be installed to prevent workers from falling between the top rail and the surface. Toe boards to prevent materials or tools from falling into the pit must be set up, too. If wire rope is used as railings turn, buckles or some other method of keeping the rope taut must be installed and the wire rope must be flagged at no more than 6-ft intervals. All points of access, such as ladder-ways, must be equipped with a gate or so offset that a worker cannot walk directly into the hole. Once installed, proper guardrail systems provide a positive form of protection and do not rely on employee actions to ensure protection.
When constructing the cave-in protective system for a pit, contractors should consider in advance what type of fall protection they will use to protect those workers around the top of the pit, such as an auger boring pit. In a situation of this type, a guardrail system would be the best way to protect all personnel topside. A guardrail system could be an independent guardrail placed all around the top of the pit, or it could be part of the shoring system. For example, if the cave-in protective system is constructed of steel sheeting, the sheeting could be extended 42 in. above the top of the excavation, or some of the sheets could be extended and wire rope could be strung from sheet to sheet to form a railing around the pit.
Fall protection is required when building structures like water treatment plants, sewer treatment plants, retaining walls or other elevated structures. Any working or walking surfaces where workers are exposed to falling 6 ft or more would require fall protection. If scaffolds are used, the requirement for providing fall protection starts when the scaffold is 10 ft or more in height.
When entering into manholes, vaults, lift stations or other underground structures 6 ft or more in depth, a PFAS may be needed. The PFAS requires several components. It requires a fall protection harness and lanyard (no body belts) for each employee entering the confined space, lifelines for employees to tie off to and engineered anchor points capable of supporting 5,000 lbs for each employee. Lanyards and lifelines must have a minimum breaking strength of 5,000 lbs. Self-retracting lanyards and lifelines are available and may be used. If a horizontal lifeline is provided, it must be designed, installed and used under the supervision of a qualified person.
The key to the successful use of PFAS is that workers will not free fall more than 6 ft or strike a lower surface. Deceleration devices may be used, but they must bring the employee to a complete stop within 3.5 ft. If you combine the 6 ft of free fall with the 3.5 ft of deceleration, excluding other factors that must be taken into consideration, a worker will fall approximately 9.5 ft before coming to a complete stop. However, a few more feet must be added to allow for the height of the worker so he or she does not hit the ground. Design of PFAS requires knowledge of how to set up and maintain the system. All PFAS must be inspected prior to each use. In addition, employee training is required to ensure that employees understand the hazards, how the system works and how to use the equipment. Unlike the guardrail system, a PFAS requires employees to use the system and to ensure that they tie off to a proper anchor point prior to exposure to the fall hazard.
Another system similar to the PFAS, but one that does not permit an employee to reach a point of being able to fall over the edge, is the motion stopping system. With this system, workers are required to wear a harness or body belt that is attached to a lifeline that is secured to a suitable anchor point. The employee exposure is prevented by ensuring that the employee cannot get close enough to the hazardous area to fall over the edge, because their movement is limited by the combination of the harness/body belt and the length of the lifeline.
When it is necessary for workers to construct form work, the worker must be provided with a harness or body belt equipped with a positioning device, which is generally a short lanyard and/or connector. The positioning device must be rigged to prevent a worker from free falling more than 2 ft if his or her feet slip off the rebar. The positioning device connector must be compatible with the anchorage and the anchorage must be capable of supporting twice the potential impact load, or 3,000 lbs, whichever is greater.
Warning line systems, controlled access zones and safety monitoring systems are primarily for roofing work. They require constant supervision and are generally not considered appropriate for excavation work.
Holes such as potholes or wells should be backfilled or covered when not in use to prevent workers from falling in. Covers located in roadways or other areas where vehicles and equipment are moving around must be capable of supporting at least twice the maximum axle load of the largest equipment or vehicle that may cross over the cover. All other covers must be able to support twice the weight of employees, equipment and materials that may cross over the cover. The covers must be secured so they cannot be accidentally moved out of place and expose the hole. Except for road plates used on roadways, hole covers must be color-coded or marked with the word “HOLE” or “COVER” to warn employees of the potential hazard below.
Ladders are some of the most common tools found in construction, and they can be very dangerous when not used properly. However, construction companies often forget to ensure their workers have been trained in how to use them safely. Ladders should always be inspected before they are used to ensure that the rungs and side rails are not broken, cracked or damaged. Damaged ladders should be removed from service. When possible, ladders should be set up at the proper angel of 4V:1H and/or tied off to ensure the ladder is secure. Ladders used to access upper areas, such as the top of a trench, must be set up so that the top of the ladder extends at least 3 ft above the upper access point. Don’t assume workers know how to safely use ladders, because there is more to ladder safety than just climbing up and down.
How to climb a ladder or on or off equipment and trucks presents a fall hazard that is often overlooked. There is a right and a wrong way to climb. In fact, there is a new variation of the importance of making three-point contact when climbing. The new concept involves the importance of three-point control, not just contact. Three-point control involves a worker using three of his or her four limbs for reliable support, which ensures a solid grip on a ladder rung, handle or other support. Have you discussed this with your employees? It is a relatively new concept that many workers don’t know about and it makes a lot of sense.
Employees exposed to fall hazards must be trained to recognize the fall hazards in the work area, the correct procedures for installing, maintaining and using fall protection equipment, the limitations of the equipment and more. The training must be provided by a competent person who is knowledgeable about fall protection hazards and the methods used to minimize the hazards. The employer is responsible for preparing a record of who was trained, when they were trained, who conducted the training and certifying the training was completed.
Retraining is also necessary when equipment or changes in the training become obsolete, and when it is determined that the employee has not retained the information necessary to protect him or herself from fall hazards. For example, when an employee is repeatedly observed not following the fall protection requirements established for the jobsite, he or she should be retrained.
Although the need for fall protection on utility construction jobsites may not be as obvious as it is at building or bridge construction sites, participating in the Fall Prevention Stand-Down during the week of June 2 to 6 is a good time to help ensure that your workers know and understand the potential fall hazards that exist within the utility and excavation industry. It is also a way NUCA members can support the construction industry in an attempt to reduce the number of fall-related injuries and deaths.
Falls are a leading cause of worker injuries and fatal accidents; therefore, the hazards must be identified and controlled at every jobsite. Failure to comply with the regulations can lead to expensive and unnecessary penalties, lawsuits and, most importantly, the loss of a good worker. For more information about fall hazards, how to conduct a Fall Prevention Stand-Down in English and Spanish and to download a certificate of participation in the stand-down, visit the OSHA’s stand-down webpage at www.osha.gov/StopFallsStandDown/index.html.
George Kennedy is NUCA Vice President of Safety.