Maysville Community And Technical CollegeSusan Harwood Training GrantResidential And Commercial Roofing Hazards Susan Harwood Grant SH-16597-07
Disclaimer • Note: • This training is specifically designed to be in compliance with Fall Protection Regulations • Related to : • Residential Construction activities that fall under Kentucky OSHA. This training in many respects mirrors Federal OSHA Fall Protection regulations involving Residential Construction. However, Kentucky allows a ten ( 10 ) foot action level for implementation of a fall protection system. Federal OSHA and most state - operated OSHA programs mandate a six ( 6) foot fall action level for implementation of fall protection system . The ten ( 10 ) foot rule , as mentioned in the context of this training applies solely to employers and employees performing residential construction activities within the borders of Kentucky • Always check with the State in which you may be working in for State / Federal Regulations • Please be aware some companies require a 4 foot fall protection trigger .
Kentucky Fatalities – Overview • 3 Year History • 2007 2006 2005 • Residential - 3 2 3 • Commercial - 8 17 10 • Total 28 35 32 • See Handout
Kentucky Statistics • Top 10 Standards Violated • 1. Scaffolding • This standard covers general safety requirements for scaffolding. Employers are bound to protect construction workers from falls and from falling objects while working on or near scaffolding at a height of 10 feet or more. Top 5 sections cited: 1926.451 (g)(1) Failure to provide fall protection 1926.451 (e)(1) Failure to provide proper access 1926.451 (b)(1) Failure to ensure adequate platform construction 1926.451 (c)(2) Failure to properly support scaffolding 1926.451 (g)(1)(vii) Lack of personal fall arrest or guardrail systems
Continued • 2. Fall Protection • This standard outlines where fall protection is required, which systems are appropriate for given situations, the proper construction and installation of safety systems, and the proper supervision of employees to prevent falls. Top 5 sections cited: 1926.501 (b)(13) Failure to provide protection – residential construction 1926.501 (b)(1) Failure to use a guardrail, safety net or personal fall arrest system 1926.501 (b)(10) Failure to provide protection – low slope roofs 1926.501 (b)(11) Failure to provide protection – steep roofs 1926.501 (b)(14) Failure to provide protection – wall openings
Continued • 3. Hazard Communications • This standard addresses chemical hazards, both chemicals produced in the work place and imported into the workplace. It also governs the communication of those to the workers. Top 5 sections cited: 1910.1200 (e)(1) Failure to develop and maintain a written program 1910.1200 (h)(1) Failure to maintain training 1910.1200 (g)(1) Failure to have a MSDS for each hazardous chemical 1910.1200 (h) Lack of employee training 1910.1200 (g)(8) Failure to maintain in the workplace copies of the required MSDS
Continued • Respiratory Protection • This standard directs employers in establishing or maintaining a respiratory protection program. Top 5 sections cited: 1910.134 (c)(1) Failure to establish a program 1910.134 (e)(1) Failure to provide a medical evaluation to determine the employee’s ability to use a respirator • 1910.134 (f)(2) Failure to ensure an employee using a tight-fitting face piece respirator is fit-tested prior to initial use of the respirator, whenever a different respirator face piece (size, style, model or make) is used, and at least annually thereafter 1910.134 (c)(2)(i) Failure to provide respirators at the request of employees or permit employees to use their own respirators 1910.134 (f)(1) Failure to ensure employees using a tight-fitting face piece respirator pass an appropriate qualitative or quantitative fit test.
Continued • 5. Lockout/Tagout • This standard outlines minimum performance requirements for the control of hazardous energy during machinery maintenance. Top 5 sections cited: 1910.147 (c)(4)(i) Failure to develop, document and utilize procedures for the control of potentially hazardous energy 1910.147 (c)(1) Failure to establish and implement a written program 1910.147 (c)(6) Failure to conduct a periodic inspection of the energy control procedure 1910.147 (c)(7)(i) Failure to provide training to ensure the purpose and function of the energy control program are understood by employees, and the knowledge and skills required for the safe application, usage and removal of the energy controls are acquired by employees 1910.147 (c)(4)(ii) Failure to clearly and specifically outline the scope, purpose, authorization, rules ad techniques to be utilized for the control of hazardous energy, and the means to enforce compliance
Continued • Powered Industrial Trucks • This standard covers the design, maintenance and operation of powered industrial trucks, including forklifts and motorized hand trucks. Top 5 sections cited: 1910.178 (L)(1)(i) Failure to ensure each powered industrial truck operator is competent to operate a powered industrial truck safely 1910.178 (p)(i) Failure to take damaged powered industrial trucks out of service 1910.178 (L)(6) Failure to certify that each operator has been trained and evaluated 1910.178 (L)(4)(iii) Failure to evaluate powered industrial truck operator’s performance at least once every three years 1910.178 (q)(7) Failure to examine powered industrial trucks before placing in service
Continued • 7. Electrical – wiring • This standard covers the grounding of electrical equipment, wiring and insulation. It includes temporary wiring and splicing such as flexible cords and cables. Top 5 sections cited: 1910.305 (b)(1) Failure to effectively close conductors entering boxes, cabinets or fittings and protect form abrasion 1910.305 (b)(2) Failure to provide all pull boxes, junction boxes and fittings with covers approved for the purpose 1910.305 (g)(1)(iii) Failure to connect flexible cords to devices and fittings so strain relief is provided to prevent pull from being directly transmitted to joints or terminal screws 1910.305 (g)(1)(iii) Flexible cords and cables may not be used • 1910.305 (g)(1)(iii)(A)Flexible cords and cables may not be used as a substitute for the fixed wiring of a structure
Continued • 8. Ladders • This standards covers general requirements for all ladders. Top 5 sections cited: 1926.1053 (b)(1) Failure to extend ladder side rails at least 3 feet above the upper landing surface to which the ladder is used to gain access 1926.1053 (b)(4) Using a ladder for the purpose other than for which they were designed 1926.1053 (b)(13) Using the top or top a step of a step ladder as a step 1926.1053 (b)(16) Failure to mark portable ladders with structural defects in a manner readily identifying them as defective, or withdrawing them from service until repaired. 1926.1053 (b)(6) Failure to use ladders on stable or level surfaces
Continued • 9. Machine Guarding • This standard covers general safety requirements for the use of machine guards. Top 5 sections cited: 1910.212 (a)(1) Failure to provide one or more methods of machine guarding 1910.212 (a)(3)(ii) Failure to guard the point of operation of machines whose operation exposes an employee to injury 1910.212 (b) Failure to anchor fixed machinery 1910.212 (a)(5) Failure to guard blades 1910.212 (a)(2) Failure to affix guards to machines
Continued • 10. Electrical – General Requirements • This standard covers general safety requirements for designing electrical systems. Top 5 sections cited: 1910.303 (b)(2) Failure to install and use electrical equipment according to factory instructions 1910.303 (g)(2)(i) Failure to guard electrical equipment 1910.303 (f) Failure to identify disconnecting means of circuits 1910.303 (g)(1)(ii) Failure to keep work spaces clear 1910.303 (b)(1) Use of electrical equipment containing recognized hazards
Top 10 Willful Violations • Top 10 “Willful” Violations • Standard Total Violations • 1910.147 Lockout/Tagout 70 • 1926.652 Excavation – Requirements for Protective Systems 65 • 1926.451 Scaffolding 56 • 1910.119 Process Safety Management 34 • 1926.501 Fall Protection 30 • 1926.651 Excavation – Specific Requirements 20 • 1926.1101 Asbestos 19 • 1910.212 Machine Guarding 18 • 1926.062 Lead in Construction 15 • 1910.134 Respiratory Protection 14
Top 10 Serious • Top 10 “Serious” Violations • Standard Total Violations • 1926.451 Scaffolding 9,341 • 1926.501 Fall Protection 6,070 • 1910.1200 Hazard Communication 3,750 • 1910.147 Lockout/Tagout 3,249 • 1910.178 Powered Industrial Trucks 2,615 • 1926.1053 Ladders 2,504 • 1910.212 Machine Guarding 2,473 • 1910.134 Respiratory Protection 2,440 • 1910.305 Electrical - Wiring 2,439 • 1910.303 Electrical – General Requirements 1,820
Competent Person • OSHA Definition • "Competent person" means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them.
Residential and Commercial Topics • Fall Protection – 1926.500 – 803 KAR 2:412 Subpart M • Electrical -1926 Subpart K - 803 KAR 2 :410 • Fire Protection -1926 Subpart K – 803 KAR 2 410 • Personal Protective Equipment Subpart 1926 803 KAR 2: 404
Residential and Commercial Topics • Cranes, Hoists , Derricks , Elevators, and Conveyors 1926 Subpart N • Scaffolds / Ladders 1926 Subpart L • Aerial Lifts – 1926 .453 Subpart L • Length of Class will be 4 hours (Actual Class Time)
Roofing Sector Growth • 16.4 % by 2014 Projected Growth 0f 22 % statewide • Bureau Of Labor Statistics (BLR) reported 13,500 incidences of nonfatal occupational injuries • Rate of 8.2 per 100 full time roofing employees • Double the rate 4.6 rate for the entire private sector
September 2005 – September 2006Federal OSHA cited 8,394 – 6 million in fines SIC 1761 Special Trade Contractors
Most Frequently Cited By OSHA • Duty To Have Fall Protection - CFR1926.501 • Kentucky Citations -211 to SIC 1761 average fine or penalty of $1500.00 • More than 60% citations issued was for Duty to have Fall Protection
Fall Protection –The Why Of It all • Residential – 10 FEET • Commercial – 6 FEET • Duty To Have Fall Protection • Incorporation By Reference • CFR 1926 -1919
Fall Protection – Case 1 • Construction worker falls to his death in Cleveland • Created: 12/12/2007 11:34:42 AM • Updated:12/12/2007 6:56:08 PM • CLEVELAND -- Cleveland police say 45 year old Joseph Albanese died after slipping and falling from scaffolding. • The worker was on site at West 7th, in between Jefferson and College Street, renovating the United Gospel Press Building when he fell approximately six stories.Investigators say it appears Albanese slipped on wet lumber as he was trying to clamp on a safety harness, falling in between the building and the scaffold.Albanese worked for B.F.C. Inc out of Cuyahoga Falls. Police say he has one son and lives on Hall Street in Akron.OSHA is now investigating whether there are any safety violations. OSHA says it will look into things like the worker's fall protection, the scaffolding, the work surfaces, protective equipment and what level of training workers receive.The United Gospel Press building dates back to the 1800's. It once housed Cleveland University and then turned into a gospel publishing building. The structure has been vacant for years and is now being rehabbed for new apartments.Albanese is 1st cousin to the husband of Akron City Councilwoman Terry Albanese.
Fall Protection Programs – Why? • KY FACE #03KY097Date of Incident: October 7, 2003Report Release Date: May 27, 2004 • Roofing Laborer Dies After 60-Foot Fall
Fall Protection Programs -Why • Summary • At 8:00 AM on the morning of October 7, 2003, a 33-year-old laborer, working for a roofing contractor, was removing debris from a commercial building roof when he slipped and fell 60 feet to the sidewalk below. There were 2 other laborers and the contractor at the work site that morning. It was the second work day at this particular job site and the three workers were to finish discarding bags of debris from the roof. The decedent and one of the laborers accessed the roof through the building interior, up a flight of stairs to a five-step ladder which led to the roof opening. Two personal fall arrest systems were available for the laborers to wear before they accessed the roof area. The personal fall arrest systems were secured to roof anchors by 25 foot lanyards so that when the laborers entered the roof area, they were wearing a personal fall arrest system and already tied off. The third laborer was in a pick-up truck parked next the building and the contractor was standing by the truck to load the bags of debris dropped off the roof by the two laborers.
Fall Protection Programs –Why ? • When the laborers approached the roof access, Laborer No. 1 used the personal fall arrest system and accessed the roof first. Laborer No. 2, the decedent, accessed the roof without using the personal fall arrest system. He grabbed a bag of trash and began walking toward the edge of the roof when he slipped and fell 60 feet to the sidewalk below. He died due to multiple blunt force injuries.
Fall Protection Programs - Why • To prevent future occurrences of similar incidents, the following recommendations have been made: • Employers should have a written safety policy outlining safety practices, procedures and which state the consequences of not following the company policies. • Employers should provide appropriate personal safety equipment and training on the proper use of that equipment. • A competent person should conduct a hazard assessment of the job site prior to commencement of work. Control of the identified hazards and safe work procedures should be discussed. • Employers should have a site specific fall protection plan written by a qualified person.
Fall Protection - Why • Background • A roofing company in business for approximately one year was contracted to replace a roof on a commercial building. The owner of the company had 15 years of roofing experience working for other contractors. During the last five years as an employee for other contractors, the employer had started a part-time roofing and siding business of his own. Laborers were employed on an as-needed basis. • All personal fall arrest equipment needed for each job was provided to each employee by the employer. Company safety procedures required each employee to wear and use necessary safety equipment and personal protective equipment. Failure to comply with company safety rules resulted in the termination of employees. Safety procedures were discussed, but the company did not have a written safety manual. • Several months before the incident, the decedent had worked as a temporary employee for the company for one day. The decedent had been re-hired by the company the day before the incident.
Fall Protection Program - Why • Investigation • At 8:00 AM on the morning of October 7, 2003, a 33-year-old roofing laborer, was discarding his first bag of debris off a commercial building’s roof when he slipped and fell 60 feet to the sidewalk below. There were 2 other laborers and the contractor at the work site that morning. It was the second work day at this particular job site and the three were to finish removing bags of debris from the roof as they had done the day before. The decedent and one of the laborers accessed the roof through the building, up stairs and various ladders to a five-step step-ladder which led to the roof opening. A safety harness and a safety belt, each with attached lanyards clipped to roof anchors, were located inside the roof access. Before entering the roof area, each laborer was to wear a personal fall protection system. After putting on the safety equipment, the laborers could then access the roof safely. It was suspected that there was dew on the roof. It is unknown and if either man was wearing anti-skid shoes or gloves. A third laborer was sitting in the cab of the pick-up truck parked on the sidewalk parallel to the building. The contractor was standing on the sidewalk by the truck waiting for the two laborers on the roof to throw down bags of debris into the bed of the pick-up truck.
Fall Protection - Why • As the laborers approached the roof access, Laborer No. 1 dressed in the safety harness and accessed the roof. Laborer No. 2, the decedent, accessed the roof without dressing in the safety belt. Laborer No. 1 did not see Laborer No. 2 climb past the safety belt without putting it on and access the roof. Without it, Laborer No. 2 grabbed a bag of trash and began walking toward the edge of the roof when he slipped and fell 60 feet to the sidewalk below. Laborer No. 1 did not see Laborer No. 2 fall, but heard him falling off the roof. After the laborer fell, the owner and other laborer on the ground went to him, assessed the situation and called emergency services who arrived on the scene within minutes. Several people observed the laborer fall from the roof. One witness also called emergency services. Emergency personnel arrived and contacted the coroner who declared the victim dead at the scene.
Fall Protection - Why • Cause of Death • According to the autopsy report, death was due to multiple blunt force trauma caused by a fall from a great height.
Fall Protection Program - Why • Recommendations/Discussion • Recommendation No. 1: Employers should have a written safety policy outlining safety practices, procedures and which state the consequences of not following the company policies. • Discussion: The company involved in this fatality did not have written safety procedures. Employees were verbally instructed to wear personal fall arrest equipment and shown how to use it. One employee interviewed stated that if safety equipment was not worn, they were not allowed to work. Occupational Safety Health Standard CFR 1926.503(a)(1) states that the employer is responsible for providing a training program for each employee that might be exposed to fall hazards. This training should be in writing with explanations of consequences if the program is not followed. All training should be documented. Employees should be required to sign that they understand the safety and training program, the enforcement and consequences for failure to follow safety instructions.
Fall Protection Program - Why • Recommendation No. 2: Employers should provide appropriate personal safety equipment and training on the proper use of that equipment. • Discussion: A body belt and a harness were the personal fall arrest equipment provided by the company for the victim and the survivor to wear as fall arrest systems. The Occupational Safety and Health Standard CFR 1926.502(d) states that body belts can be used as positioning devices but they are unacceptable for use as a fall protection system. A full body harness should have been provided for mandatory use by all employees and all employees should be trained in the proper use of this equipment.
Fall Protection Program –Why ? • Recommendation No. 3: A competent person should conduct a hazard assessment of the job site prior to commencement of work. Control of the identified hazards and safe work procedures should be discussed. • Discussion: A hazard assessment of each job site should be performed each day before work commences. The identified hazards and safe work practices should be examined and discussed with all affected employees. It is thought that there may have been dew on the roof and appropriate precautions should have been taken (i.e.: anti-skid shoes in addition to the appropriate personal fall arrest system). • Recommendation No. 4: Employers should have a site specific fall protection plan written by a qualified person. • Discussion: Occupational Safety and Health Standard CFR 1926(503)(k)(1) states that a fall protection plan shall be prepared by a qualified person and developed specifically for the site where the work is being performed. Employees should be reminded every work day of the hazards identified for the work place and to wear the personal protective equipment to prevent injury while working • TRAIN, TRAIN AND MORE TRAINING!
Case Study By Kentucky Fatality Assessment and Control Evaluation Program • The Kentucky Fatality Assessment & Control Evaluation Program (FACE) is funded by a grant from the Centers for Disease Control and the National Institute of Safety and Health. Face's purpose is to aid in the research and prevention of occupational fatalities by evaluating events leading to, during, and after a work related fatality. Recommendations are made to aid employers and employees to have a safer work environment. The current foci of the program are occupational fatalities involving: construction, machinery, immigrant workers (particularly Hispanics) or youths.
What is A Roof ? • Roofmeans the exterior surface on the top of a building. This does not include floors or formwork which, because a building has not been completed, temporarily become the top surface of a building.Roofing work means the hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck.1926.500 (b)
Low Slope Roof • Section 1926.500 defines "Low-slope roof" as: a roof having a slope less than or equal to 4 in 12 (vertical to horizontal).
Steep Roofs • Steep roof means a roof having a slope greater than 4 in 12 (vertical to horizontal).1926.(b) (2)
Falls Accidental? • December 2007 • Construction Worker Falls 30 Feet To His DeathConstruction Worker Falls From Roof • A construction worker is dead after falling off a roof in Bourbon County. The accident happened Monday morning in the town of Little Rock, just outside Paris. • Neighbors say two workers were repairing the roof of the Little Rock Masonic Lodge, when a sprinkling of rain made the tin roof very slippery. We're told 43-year-old Donny Burk halter fell about 30 feet to the ground. • "He started slipping, so he grabbed the friends legs and his friend was trying to hold tight and he just dropped, he let go," said neighbor, Dorothy Pruitt. • Pruitt says she could tell from the way Burk halter landed and the height of the fall that he wasn't going to make it. • "After the man hit the ground, the friend jumped down and then looked at him and then ran to the Little Rock store and called for help," she said. • Before the ambulance arrived, two other neighbors, both trained in CPR, attempted to save the man. They continued their efforts for 5 to 10 minutes until EMS workers arrived. • Burk halter was taken to Bourbon Community Hospital then flown to UK hospital where he was pronounced dead due to his injuries. • The coroner says he died from blunt force trauma to the chest. His death has been ruled accidental.
Residential Fall Protection Requirements • Residential- Summary of Kentucky Fall Protection Standards • General Standards • Residential Construction means construction work on a stand alone single family dwelling, duplex, three (3) plex, or four (4) plex structure. • Employees engaged in residential construction activities ten (10) feet or more above a lower level shall be protected by guardrail systems, safety net systems, personal fall arrest systems (positive fall protection systems) or the approved alternative measures.
Commercial Fall Protection Requirements • Commercial – At 6 feet Fall Protection is Required Or can be less if required by the employer • Restriction on Application for Roofing Work. The alternative procedures in this Instruction may only be used for this work where: (a) the roof slope is 8 in 12 or less, and (b) the fall distance, measured from the eave to the ground level, is 25 feet or less. • General Requirements. • Trained Workers Only.Only workers who have been trained to be proficient in the alternative methods of fall protection shall be allowed onto the roof. In addition, each affected employee shall be trained to ensure specific awareness of the fall hazards associated with work on roofs with rake edges ("rake edges" are inclined roof edges, such as those on the gable end of a building).