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Safe, Safer, Safest

The U.S. Department of Labor’s Bureau of Labor Statistics recently issued preliminary 2008 data on construction industry injuries and fatalities, and it is good news. Fatalities are down by almost 20 percent, and the same holds true for injuries resulting in days away from work, job restriction or transfer.




Some may suggest that this is due to fewer people working in 2008, but the recession did not really affect us until 2009. Besides, the injury statistic reflects how many cases were reported per 100 full-time workers, which reflects trend independently of the total size of the work force.




Now, we love to disagree. And to be polite, we say that we agree to disagree.




So it was with quite a pinch of interest that we put this scenario to the AWCI safety directors we interviewed for this article: Assume that you could only deploy three types of safety equipment in your company; what three types would they be?




Kathy Coffey at Grayhawk, LLC in Kentucky does not hesitate for a second: “Personal fall-arrest systems. Gloves. Safety glasses.”




Shelley Sigurdson at Expert Drywall in Washington follows suite: “Fall protection. Hand protection. Eye protection.”




Tim Wies, owner of T.J. Wies Contracting in Missouri, does not hesitate either: “Harness and lanyard. Eye Protection. Kevlar Gloves.” And adds, “It stands to reason since most injures occur as a result of falls.”




The next great mind to weigh in is Gerry Golt, safety director at Precision Walls in North Carolina. “My number one would be fall protection equipment,” he says, “because falls are the biggest injurer and killer in our industry. My second choice would be hard hats. Third would be eye-protection.




“Though, really, fall protection should be number one, two, and three.”




Gary Elledge, operations manager at Brady Company in Los Angeles, says that he “won’t pick one area over another.” Why? Because, he says, “all components of safety work hand-in-hand. You need them all.”




No argument there.




Dave Lanza, regional safety manager at Performance Contracting, Inc. (PCI) in Arizona, agrees. “Fall protection is definitely what we use the most today. And always with the retractable lanyards now.”




When asked whether they all, like PCI, use retractable lanyards or lifelines with their body harnesses today, the only answer was “Yes.”




Electrical Fatalities


A sobering fact: According to ScienceDirect, occupational fatalities due to contact with electricity account for approximately 9 percent of all deaths in the construction industry and is the fourth leading cause of death.




The best way to protect against accidental electrocution is using a ground fault circuit interrupter. This is an inexpensive device that detects ground faults, and the moment it does, cuts the current.




We checked with our safety directors about whether they now, as a rule, are using GFCIs for their crews.




Elledge and Golt report that for them, GFCI is standard safety equipment, and Coffey reports “a 100 percent ground fault protection program.”




Sigurdson says, “Any time the building goes permanent, or we’re doing a remodel, it’s mandatory for our guys to use GFCIs.”




“We certainly have them,” says Wies as well. “The biggest problem, though, is getting the guys in the field to use them.”




Age versus Safety


One issue that crops up now and then is the “old school” philosophy, the one that suggests that if you entered the trade before the inception of OSHA, safety rules don’t apply to you.




Joe O’Connor of INTEC in Pennsylvania (and also AWCI’s safety consultant) is familiar with this. “We’re talking about an agency that was created in December 1970. Old-timers were, and can still be, slow to accept OSHA regulations. Younger workers, however, have grown up with OSHA and are aware of it, respect it and accept safety as a way of life.”




Wies agrees and says, “It’s easy to make the younger guys, especially those we have brought into the organization, use the equipment. That’s all they’ve ever known, and they use this equipment. They don’t remember a time when OSHA didn’t exist.”




Needless to say, OSHA does not exempt anyone from its regulations.




The Key “Equipment”


When all is said and done, however, the best safety “equipment” is a skilled, aware and focused worker. An employee dead-set on injuring himself will succeed, no matter what regulations, equipment, etc. are placed between him and his goal.




“If a guy wants to cut his fingers off with a Skil saw,” says Lanza, “he’ll cut his fingers off. It’s a tool. You learn how to use it. You become expert at it. You get the job done. Now, if you want to regulate cut fingers out of existence, you would have to regulate the teeth off the blade, and the blade into rubber. Of course, you won’t get any work done.”




Elledge could not agree more, the best safety equipment you can have is a trained and focused employee. “In fact, that’s one thing we focus on,” he says. “I employ a group we call ‘safety partners’ that walk the jobs and coach the work force on a daily basis. And that’s the only way to bring about a trained and focused employee—a lot of coaching.”




Golt sees eye-to-eye on this as well. He says, “We also focus on training to create skilled, alert and focused employees.”




Legal Surfing



An OSHA regulation that many keep a keen eye on these days is Title 29 CFR 1926.452(w)(2), which says, “Scaffold casters and wheels shall be locked with positive wheel and/or wheel and swivel locks, or equivalent means, to prevent movement of the scaffold while the scaffold is used in a stationary manner [italics added].”




Self-Propelling (Surfing). As any wall and ceiling contractor knows, climbing up and down a Baker scaffold all day to disengage and re-engage casters, even if it the safest way to go, is certainly not the fastest. It is so much easier simply not to lock the casters and pull yourself (and the scaffold) along to the next span of ceiling or wall to be worked. This practice is referred to as “riding the scaffold,” “self-propelling,” or simply “surfing.”




This, of course, is an OSHA no-no, and when caught in the act earns the perpetrator a citation.




But what if, in your experience, climbing up and down all day is not only too slow for comfort, but is indeed a greater cause of injury than surfing?




Or, as Lanza puts it: “We went back 18 years, and we could not find a single accident of one of our acoustical ceiling guys falling off because his wheels weren’t locked. We noted several accidents, however, from climbing off and on.”




OSHA’s View. OSHA, meanwhile, in a June 8, 1998, Interpretation Letter, relaxes the requirement a little, and in fact OKs the practice of surfing—but under certain conditions: “If a device were installed to permit the casters to be locked while on the scaffold, this requirement could be met without dismounting [italics added].”




This was confirmed and clarified in a June 17, 2005, OSHA Interpretation Letter, where this question was asked: “I understand that §1926.452(w)(2) requires the wheels on a mobile scaffold to be locked when the scaffold is used ‘in a stationary manner.’ We repeatedly reposition our scaffolds (every few minutes) in the course of doing overhead work. In this situation, is the scaffold being used ‘in a stationary manner’ or is it permissible to work from the scaffold without constantly locking and unlocking the wheels?”




To which OSHA replied (in relevant part): “[T]he standard requires that while the work tasks are performed, the scaffold (which at that point is being used in a stationary manner) must have its wheels/casters locked [italics added].




“Note that, as OSHA indicated in a letter dated June 8, 1998, a way of complying with this provision without having to constantly dismount and re-mount the scaffold is to use a scaffold fitted with a device that permits the worker to lock and unlock the casters/wheels while on the scaffold [italics added].




So far so good. The state of California, however, never recognized this interpretation in its Code of Regulations, where Section 1646 outlawed the practice.




California Regulations. For Lanza and PCI, this came to a head in the late 2000s when both OSHA and state inspectors would cite contractors for surfing, since, as yet, no device existed that would meet the OSHA requirement; and even should such a device have been found, California Regulations had still not changed to reflect OSHA’s Interpretation Letter, and so they still allowed only manually locking and unlocking scaffold wheels.




For this and other reasons, a petition was filed with California’s Occupational Safety and Health Standards Board to allow the practice, if conforming to OSHA interpretation. At an Advisory Committee Hearing on April 24, 2008, contractors and manufacturers were asked to provide input for or against the proposal.




At the meeting, the petitioner’s representative, Joel Cohen, was given the opportunity to explain the reason for submitting the petition. Among other things he said that, “workers must climb up and down the scaffold as many as 80 to over 100 times for eight hours a day to move the rolling scaffold.” He further asserted that “this constant climbing up and down poses a greater hazard for falls and repetitive motion injuries than any hazards from self-propelling at a maximum platform height of 4 feet or less.”




Lanza, who was also invited to the meeting, said that, “In the ceiling work, there is usually no one available to push a scaffold from below, and this is where we find a need to permit self-propelling.”




He added, “At all ceiling contractor job sites, the practice of self-propelling is prevalent and normally factored into the bidding process as a must to submit a competitive bid.”




As for injuries, he went on to say, “Over a several year period, and covering our 7,000 employees, we had 162 scaffold related injuries for scaffolds of all types, including exterior scaffolding. Of these, 31 accidents were specific to climbing on or off of rolling scaffolds while no employees were injured while self-propelling or surfing.”




After deliberation, this petition was approved and the state of California revised the regulations in effect to allow surfing—that is, if it is done according OSHA’s letters.




The Solution


Given the above, all a contractor needs legally to surf the scaffold to his or her heart’s content, is to locate an efficient way to unlock and lock the casters (or equivalent means, as the code puts it) while remaining on the scaffold.




The good news is that are now devices on the market that meet OSHA’s requirement and indeed make surfing legal. And that should be good news for one and all—old and not-so-old timers alike.




Coeur d’Alene, Idaho–based Ulf Wolf writes for the construction industry as Words & Images.

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