National Safety Council San Diego Oct 5 th 2010

Transcription

1 Fall Protection Compliance Options J. Nigel Ellis Ph.D., CSP, P.E., CPE National Safety Council San Diego Oct 5 th 2010

2 What we will talk about: Compliance means: show of hands Meets your Fall Protection Program? Meets General Industry OSHA? Meets OSHA Construction? Meets CalOSHA requirements? Meets ANSI Z359 or A10.32 stds? Meets EN or AS or your country stds? All require preplanning and preparation after having identified site fall hazards

3 What s New in Fall Protection Federal OSHA General Industry P Cranes & Derricks in Constr n R P = Proposed Rule R = Final Rule

4 ANSI Z359 Fall Protection Code First Z359.1 PFAS (be withdrawn soon) Then Z359.2 Managed Fall Protection Z Pos g & Travel Restraint t Z359.4 Rescue Systems New Z359.6 Design Req. for Active FPS Z Connecting Components Z Lanyards and Energy Abs More to come through h Z Z359.0 Definitions is free

5 Current Federal Guardrails, No PFAS, Fixed Ladders Exterior Bldg Maintenance Appendix C PFAS exception 1989 Current ANSI/CSA Z359 General Industry 2007 A10.32 Constr n to adopt Z359 tests 11 I Window Cleaning

6 New OSHA Proposed General Industry Rules, Subpart D & I &.140 Guardrails and PFAS including fixed ladder climbing Requires Body Harness for Fall Arrest Rope Descent Systems < 300 ft?? Proposal resembles Construction ti Rules /503 Training understandable to each worker Retraining for understanding & skill Update of Comments Closed

7 Portable Ladder Considerations 3 ft minimum extension* 5 ft may tip Slope is critical 76 deg. 70 deg slope will slip 80 deg slope fall back Inspect ladder shoes!! *Proposed (c)(11) Tip Slide

8 Portable Ladders Workers do not voluntarily do 3 ft extension.. Try new system* Gain 3 ft of ladder length Courtesy AES Raptor *Horizontal bars shown to be critical to prevent sliding and falling (UMich report 10 09)

9 OSHA does not prohibit two Hole Protection protective devices Cover and a net may be a good investment: Protect walking/working surfaces Protect HVAC installer Proposed (b)(3) (c) Hole Cover and Net

10 What to do? Comply with Proposed OSHA Std? ANSI Z359? Do both? Yes both! Proposed OSHA is de minimis Z359 Surveys, Pre-planning, Training Scaffolds: follow Cranes follow: (new) Hoists: follow ANSI A ;.5; A92.9 Truck flatbeds: adopt temporary & permanent installation eg Boom anchor or HLL; elevated portable anchors

11 Scaffolds Headroom must be sufficient for standing 84 min. (JNE) If only 58, access to ladder becomes near impossible (unsafe) Proposed (b)(12) ref (e)(9) Safe Access Offshore Fall Hazard corrected

12 Skylight dangers 70 million unit skylights: Do You Have? Commercial mostly acrylic domes Also fiberglass panels in metal bldgs Sunlight degradation certain What Solution would you choose: 1. Curbs >42 2. Guardrails >42 3. Fall Arrest anchors? 4. Cover them with nets, boards 5. Tested with 312 lbs/3 ft/conical Sandbag 5.5 /18 6. Stay away from skylights

13 America s Solution after fall through Arched screens

14 Skylights possible Fall Arrest/Restraint Fall Restraint Fall Arrest Warning! HVAC or Skylight base anchor must be inspected

15 OSHA GI Alone October 2010 Does not Work examples: 200 lbs sand bag on a skylight is OK? No swing gate on a supported scaffold? No requirement for harnesses No Fall Protection exc. Guardrails/Covers Big Gaps in OSHA 1910

16 Truck net feasibility FMCSA regs are for the truck not the trailer Fall clearance diagram required, specification by Qualified Person

17 Should you follow new Standards? Yes: There are good reasons for updates Changes are fought over vigorously Personal responsibility over design? Always be contention over user should know Design eventually prevails after deaths Liability issues more at Question time ask me!

18 Snaphook Gate Strengths dilemma A10.32 the only standard w/220/350 lbs Most equipment still sold has 220/350 Weak gates especially on Y-lanyards with distort & fly-by nose or stick open Angle Iron forces nose open Pics 220 lbs and 3600 lbs gate

19 What s New in Snaphooks? Z359.0 through Z359.4 all new except for Z359.1 (Revised Snaphook gates 3600 lbs v. the old 220/350lbs) Z359.2 Managed Fall Protection Program: fall protection planning minimum training 3600 lbs Gate Ellis Recommendation 10/05/10: OSHA old, A10.32 old : Don t buy Presently use only Z compliant snaphooks >5000 lbs

20 Snaphook Gate Gate Distortion 220 lbs v lbs Gate Strength

21 The case of Boilermaker lanyard with 220 lbs snaphook gates OSHA said: employer did not train to anchor properly based on fall system Analysis said worker climbed out of aerial lift and lanyard was never used (no wear marks or stitches broken) If overhead anchor points installed earlier from aerial lift, no incident pics would have occurred

22 Tower Climber 40 ft fall OSHA citation said Failure to train Analysis showed large snaphook gate pushed past nose If 3600 lbs gate used on snaphooks per Z then incident id likely l would not have occurred

23 Anchor Point Technology Inventory of temp. and permanent anchors Inspection program Rescue Plan anchors Fall Protection Plan for using anchor points and number of persons attached

24 Compliance by PrePlanning No preplan p means leaving to the worker Worker choices: follow company guidelines; ignore company guidelines or do makeshift guidelines Should worker do his own inspection? No: except cursory eg almost cut/burned through; competent person needs to document the formal inspection

25 Where and what are the Hazards? : Do Survey per Z359 Use grid method: Hazard v. Solution Ref: Dave MacCollum s book: 2007 McGraw Hill (Construction) Safety Engineering Principles

26 Recognized Recognized Eliminate Eliminate Guard Guard Safety Safety F t F t Redundancy Redundancy Relia Relia bility bility A Tool to recognize ALL Worksite Hazards Hazard / Hazard / Solutions Solutions Factor Factor bility bility List List Hazard Hazard Safet Safety Sol Sol n List List Hazard Hazard Safety Safety Sol Sol n List List Hazard Hazard Safety Safety Sol n Sol n List List Hazard Hazard Safety Safety Sol Sol n Admin Admin Natural Natural Human Human Factors Factors Structural/ Structural/ Mechanical Mechanical Electrical Electrical Chemical Chemical RadiantEnerg RadiantEnergy Fire Fire Biological Biological Artificial Artificial Intelligence Intelligence

27 Recognized Hazard / Solutions Gravity Structural/ Mechanical * Use Tool to recognize Skylight Fall Hazards List Hazard Fall Collapse Eliminate Safety Sol n Remove sky light Cover List Hazard Fall collapse Guard Safety Sol n Screen or curb at 42 Burglar bars Safety Factor List Hazard Fall collapse Safety Sol n Strong skylight Test for 97%ile Redundancy List Hazard Fall Fall Through Safety Sol n Guardrail & cover Screen & bars Reliab ility Admin Planning & surveys Inspect Strength report Radiant Energy *Attractive nuisance *Burglar entry *Maintain skylight/screen UV Degrad n Firefighter Access Sit on Burglar access Replace skylight Screen 20 yrs or Less than 12 gap screen Crazing at screw holes Bounce* Bungee Screen And Replace Guard rail leaks Stand on Test for 20 yrs, Replace screen Exposue to replace Two person Use change- out tool screen Test Miami Dade 5 yrs Add warnings Secure Fill Add Screws Larger Two Screen & Evaluat access & opening grill remove w/tool hazard bars burglar grill s method Use change out No barrier Use DBInet frame Weak structur e Alum. Ribs in skylight Not enough protect Add PFAS to Burglar B Design screen limited opening

28 2. Use Tool to recognize Aerial Lift Fall Hazards Recognized Hazard / Solutions Gravity Structural/ Mechanical List Hazard Fall out while reaching Collapse due to bearing failure,, Lean on controls near ceiling Eliminate Safety Sol n Restrain Regular maintain check the certs Lock-out out & design of controls List Hazard Fall while step up on midrail Ejection: Auto impact at base Duck under rail: head injury Guard Safety Sol n Safety Factor List Hazard Screen Fall up to while 42 transfer PFAS and self- rescue Use swing gate access Collapse boom or tip over Lift does not respond to controls Safety Sol n Wishbone connect, follow procedure Check outrigrs fully out & PFAS Bleed hydraulics and/or descent device Redundancy List Hazard Fall hazard and rescue Bucket inverts Anchor Pt too low in bucket Safety Sol n Guardrail & PFAS, training Restraint and PFAS & rescue method Anchor Pt on bucket at 5 ft and or boom Reliab ility Admin PrePlan Train to stay if rocking Inspect Strength report Train: instrns for proper use Walk mast Prevent access Tip over Outrigg ers Stalls w/ load & angle Higher capacity lift Tip over Guard and PFAS Biological i l Attack by Remote Attack by PFAS Descent Increase Attack Add suit bees distance bees Control not fast descent by and tools Descent enough speed bees headgear Electrical Touch power line Keep 10 distance per OSHA & alarm Touch while on ground Training stay away or jump Conduct n Use insulatd remote tools Other hazards Increase insulated equip t tools Add alarm & warnings David MacCollum: Construction Safety Engineering Principles, 2007

29 Training After a survey of Hazards and Selection of Methods Do it right choose your trainer well Trainer gets good ratings Site Specific training Examples from site or similar site Demo equipment where possible Test in writing or verbally if necessary Your Pass Rate is 70% or 90%?

30 Monitor where possible Is your plan being followed? Trained, Certificate, Passed Test, Periodic Re-training i Proper tools to do job

31 100% Tie-Off Means no exception to protection rule Transitions too Movement/Access Approved Anchorages Trigger Height 4ft GI, 6 ft general Construction, 7.5 ft CalOSHA Fall Protection System

32 Labels on Fall Equipment Z359.1 Good for the life of the product? App. C(g)

33 Summary Detect/Survey Fall Hazards Resolve Conflicts between mixed hazards eg Electrical and Falls Apply 1910/1926 regs proposed/final Apply Z359 for training guidance/detail Pre-Plan Plan train, observe and inspect

34 Questions