Aurora OSHA Construction News

OSHA News for Industry DRAFT

Aurora, Illinois Area Office

Volume 1, Number 2

5/--/98

1. Temporary Employees - In April we initiated two amputation inspections involving temporary employees. One employee lost a thumb, while the other had four fingers were cut off. Over the past three years we have observed several other similar cases. Generally speaking, better lockout training, machine guarding, and supervision would have prevented these accidents.

2. Interim Targeting Program - Since the CCP is on hold due to court challenge, OSHA has set up an Interim Targeting Plan until the court makes a determination. We began making inspections under this system on 4/13/98. From the top 99 BLS high rate industries, 1996 data initiative sites having injury/illness rates in excess of their industry average have been selected.

3. Injury/Illness Rates and Temporary Employees - To accurately calculate the Lost Work Day Injury/Illness Rate, the host employer needs to include temporary employee hours worked and injuries/illnesses experienced. Inspections made under the Interim Targeting Program have revealed a problem in that some employers failed to include temporary worker hours, resulting in a higher LWDII rate.

4. Significant Cases - A number of Aurora's $100K citation cases concern "authorized employee" lockout issues. The cited companies have implemented lockout programs, but failed to apply the lockout standard to line employees exposed to machine startup hazards. In the regulation the second part of the authorized employee definition states "An affected employee becomes an authorized employee when that employee's duties include performing servicing or maintenance covered under this section". Per the servicing and maintenance definition, this includes machine set up, cleaning, and unjamming equipment. If your machine operators are exposed to injury from unexpected start up of machinery when performing operations such as jam clearing and set up, they need to lockout the machinery.

5. Chicago Area Fatalities - Within the past year, 80% of the general industry fatalities have been caused by the same hazards that OSHA focuses on in construction: falls, electrocutions, caught between, and struck by. Maintenance employees are particularly at risk with 30% of the fatalities occurring in maintenance operations. A sample of the incidents follows:

a. Employee was troubleshooting a grinder, opening a circuit panel to check for voltage and was electrocuted.

b. Maintenance supervisor was removing a light fixture from an outside pole when he contacted an energized cabinet. The aluminum ladder he was standing on became the path to ground.

c. A truck driver was in the process of removing an air dolly from underneath a tank when his head got caught between the tongue and the bottom of the tank.

d. A property management employee was hanging Christmas lights on a mall building and apparently walked backwards off the edge of the roof.

e. Employee doing maintenance on a bulldozer inadvertently bumped and activated a crane pendant control. The crane was holding the several hundred pound bulldozer grill; the employee was pinned between the grill and the dozer blade.

f. Baler operator and helper went around baler guardrail into the ram area three times to unjam paper, using the emergency stop to shut the system off. After the third time, the operator started the baler without knowing the helper fell into the baler press box.

g. Auto fell off the lift, pinning the employee's head and chest.

6. Power Press - A word of caution! Many of the new ergonomic hand controls for press initiation are NOT to be used as point of operation safeguarding. Check with the control manufacturer to see if they are suitable for point of operation safeguarding.

7. Standards - Every six months all government agencies publish their regulatory agendas in the Federal Register. The 4/27/98 FR shows the following final rule dates for these proposed OSHA standards:

Respirator Assigned Protection Factors 12/98

Glycol Ethers 12/98

Powered Industrial Truck Operator Training 9/98

Recordkeeping 3/99

Permit Req'd Confined Space (amendment) 6/98

Standards Improvement Project (streamlining) 6/98

8. Process Safety Management - The independent Chemical Safety Board (CSB) is now conducting root cause incident investigations of chemical releases. OSHA will continue to do compliance investigations, but will not issue public reports in cases the CSB investigates. OSHA, EPA, and the CSB are in the process of developing an incident investigation protocol to be used when all three entities are investigating the same release.

9. Hazard Communication Directive Update - The OSHA haz com enforcement directive has been updated for the first time in eight years (CPL 2-2.38D, 3/20/1998; under Other OSHA Documents/Directives on the 'Net). One issue which continues to surface is electronic access to Material Safety Data Sheets (MSDS). The use of electronic access is clearly allowed by the standard as long as there are no barriers to immediate employee access during the shift. The employer has the flexibility to determine how this is done. Employees will need to be trained in how to use the electronic access system and there needs to be an adequate back up system for rapid access to MSDS in the event of an emergency.

An appendix to the directive contains two sample written haz com programs.

10. Establishment History Search - In case you missed it, Establishment Search for any company's OSHA inspection history is again operational on the OSHA web site. Check www.osha.gov (Statistics and Data, Establishment Search).

11. Respirator Standard - Although OSHA has been sued by at least four different organizations on the new respirator standard, there is no court or administrative stay of the standard and compliance with the regulation is due 10/5/98. The Small Entity Compliance Guide is not on the OSHA web site yet, but the OSHA National Office hopes to have this published by June. A draft interactive advisor is almost finished (see other interactive advisors such as confined space, asbestos, cadmium, and fire safety at www.osha.gov under OSHA Software/Advisors). The respirator enforcement directive will not be completed until September.

A full day respirator training session is being planned for the ASSE/OSHA Joint Safety Conference, September 21-23, 1998 at the Holiday Inn in Rosemont, Illinois. Please notify charlie.shields@aurora.osha.gov of your street address if you want to be included on the mailing list for this meeting.

12. VPPPA Conference - The Region 5 VPP Participant's Association is having their annual conference 6/16-17/98 at the Pfister Hotel in Milwaukee. The conference agenda looks great and includes topics such as behavior-based safety, ergonomics, annual self-evaluations, and innovative safety training; for more information please call Jodi Shapiro 847-632-6553, Amy Gibson 815-730-0012, or Monty Gartin 815-423-5571 x4336.

13. Compliance Photos - Last year we began scanning construction inspection photos (mostly pictures of scaffolds) into a database to use in presentations, outreach, and publication. Local consultants were invited to print color overhead slides of these inspection photos for their use, and they often reported that our photos were the best part of their training course. Class participants were very interested to see actual inspection photos of compliance and noncompliance, plus pictures make the regulations much easier to understand. In addition, safety professionals like the photos just to bone up their knowledge of the construction standards. Finally, our March 1998 thirty page photo guide on pump jack/ladder jack scaffolds was well received by the Residential Construction Employers Council.

We recently began to scan general industry photos into the computer in categories such as cranes, electrical, fire protection, lockout, guarding, and power press. We do not have many of these yet, but would like your input on worthwhile subject matter and best methods of making these available to you (OSHA home page, direct transmission via file transfer protocol, other methods...).

You are our customers. What can we do that would be useful to you?

Please direct any comments or suggestions to Area Director Charlie Shields, 630-896-8700, charlie.shields@aurora.osha.gov We welcome additional E-mail subscribers.

Common Power Press NEP Citations in Aurora Since the 8/1/1997 Start of the NEP

32 inspections, 26 with citations, 89 total violations, $266,212 total assessed.

1. 217 e 1 I - 19 No press inspection records with certification of the person conducted inspection, date of inspection, and identifier of machine inspected.

2. 147 c 4 ii - 9 Written lockout procedures did not outline the step by step procedure for each individual machine that may be locked out.

3. 147 c 1 - 5 No written lockout program

4. 217 c 1 I - 4 No point of operation guard or not adjusted properly.

5. 217 b 4 I- 4 Not protecting foot pedal

6. 217 c 2 I a 4 Guard design did not prevent access to point of operation

Three Citations

7. 217 b 1 Unsecured guards and components of presses

8. 217 b 3 I Full revolution press had no single stoke mechanism

9. 212 a 3 ii Not guarding hydraulic presses

10. 147 c 4 I No lockout when working on a press changing dies

Two Citations

217 b 7 ii Part revolution press had no emergency stop button
217 e 1 ii - 3 Weekly inspection per standard was not conducted - antirepeat, etc.
217 c 2 I b Guard openings did not meeting table O -10
304 f 4 Press was not grounded
305 g 1 I Use of extension cords to power presses (vs. conduit to a knife switch)
305 g 2 iii Strain relief for electrical at press
242 b Compressed air used to clean press was over 30 psi
253 b 4 iii Oxygen and acetylene stored together

Other press standard citations

212 a 1 Not guarding press brakes
217 b 4 ii Non slip pad missing on foot pedal
217 b 6 I Press palm buttons had no ring guards
217 b 7 v a Part revolution press palm buttons not concurrent
217 b 10 Press with airline (for clutch) had no filters
217 c 3 iv d Pullbacks not inspected at beginning of each operator's shift
217 c 5 I No brake monitor on a part revolution press
217 d 9 iv Not using safety blocks for die setting adjustment (no blocks onsite)
217 e 3 Maintenance personnel inspecting presses not trained in the OSHA standard for presses
217 c 3 iii f Presence sensing device had openings which were not guarded (side of press)

Common Forklift Issues 1997

Fatalities

• Lifting personnel on pallet
• Going off dock or ramp - crushed by overhead guard
• Not chocking trailer and forklift fell when trailer moved
• Striking employee while moving in forward gear with obstructed load
• Employee riding on forks
• Not blocking forks in up position when necessary to be under it
• Overexposure to carbon monoxide
• Unbalanced load falls on another employee

Damaged Equipment:

• Leaking hydraulic fluid
• No/broken backup alarm for obstructed view
• Broken horn
• Broken lights
• Broken turn signals
• Damaged tires
• No slip resistant pads on brake and clutch
• Leaking fuel
• Missing fork lateral stops (Using rebar)
• No manufacturers identification plate
• Out of tune, generating too much carbon monoxide

Tire Changing (Large single or multi-piece rims)

• Not using proper cage
• No single rim poster
• No inline regulator
• No clip on chuck
• Worker not trained OSHA requirements for tire changing

Operation

• No monitoring of new employee
• Not following in-plant training program for new employees
• Leaving load up and unattended

Common Indoor Crane Issues 1997

Fatalities:

• Not de-energizing crane and touching crane conductors
• Overloading sling, load falls
• Load set down and unbalanced and falls
• Fall from crane while servicing
• Employee hit while in path of crane load

Damaged Equipment:

• No bumpers on bridge
• No rail sweep
• No hook proof test or documentation for self fabricated hook
• Damaged sheave on load block
• Labels worn on pendant control
• Not having a proper rail stop for crane
• Tonnage sign dirty, not readable
• Open resistors on top of crane
• Fixed ladder to cranes is loose
• Kinked rope near block
• No midrail for operator cabs
• Spreader bars not tested or labeled
• Chain/Synthetic slings - no tags
• Wire rope slings kinked

Operation

• Workers did not know how to calculate sling leg load capacity
• No annual inspection of cranes
• Daily crane inspections are routinely missing obvious hazards
• No follow up on discrepancies on daily inspection so crane operator ignores them after a while
• Rigging is not inspected before use for visible defects

FREQUENTLY CITED VIOLATIONS

AURORA AREA OFFICE

GENERAL INDUSTRY

FIRST HALF OF FISCAL YEAR 1998

1. 1910.1200(h) hazard communication training
2. 1910.1200(e)(1) hazard communication program
3. 1910.147(c)(4)(ii) specific lockout procedures
4. 1910.217(e)(1)(I) regular press inspection with certification
5. 1910.151(c) eyewash
6. 1910.147(c)(1) lockout program
7. 1910.219(d)(1) power transmission guarding
8. 1910.212(a)(1) general machine guarding
9. 1910.212(a)(3)(ii) point of operation guarding
10. 1910.242(b) greater than 30 psi compressed air used for cleaning

Explanation of Aurora Frequently Cited Serious Violations

1. Hazard communication training - Many companies did training years ago, but have not trained newly hired employees.

2. Hazard communication program - Employers lost programs that they implemented years ago. Also, companies we inspected for the first time did not have a program.

3. Specific lockout procedures - The standard requires that lockout procedures specific to the machine or the type of machine be developed. Many companies have generic programs but have failed to evaluate energy source hazards, develop procedures, and communicate this information to employees. We do not accept generic programs!

4. Press inspection and certification - In addition to the weekly inspections for the clutch/brake mechanism, antirepeat feature, and single stroke mechanism, periodic inspections of the entire mechanical power press must be performed. Written certification of all maintenance work and inspections are required. This is high on the frequently violated list due to inspections made under the Power Press National Emphasis Program.

5. Eyewash - A squirt bottle is not acceptable. There needs to be a 15 minute supply of flushing solution (an ANSI standard requirement).

6. Lockout program - As with hazard communication, some of the companies we inspected for the first time had no program.

7. Power transmission guarding - All power transmission devices such as belts and pulleys, gears, shafts, chains and sprockets, and flywheels must be guarded or enclosed up to seven feet from the floor or work platform. A better practice would be to guard up to eight feet, however, OSHA can only enforce the seven foot rule.

8. General machine guarding - We used this standard for a several machine hazards in the first half of the fiscal year, including rotating lathe chucks, unused portions of metal saw blades, and head and tail pulleys on conveyors.

9. Point of operation guarding - This standard was used for safeguarding of hydraulic presses.

10. Compressed air for cleaning - Full line pressure is often used for cleaning purposes. This is usually corrected by purchase of commercially available 30 psi "OSHA" air guns.