OSHA CITATIONS 2017
Studying the
citation statistics for 2017, one is ultimately forced into an alarming
conclusion, considering that citations only represent the tip of the iceberg
(only the unlucky folk that are caught by OHSA) If we work on a 33% ratio, then
it is safe to assume that 66% of all incidents/accidents go unchecked or
unnoticed.
Really scary
and thought provoking, that in the modern era we can lag with addressing this
dilemma.
OHSA
CITATION STATISTICS 2017
1. Fall Protection – General Requirements (1926.501): 6,072 violations
2. Hazard Communication (1910.1200): 4,176
3. Scaffolding (1926.451): 3,288
4. Respiratory Protection (1910.134): 3,097
5. Lockout/Tagout (1910.147): 2,877
6. Ladders (1926.1053): 2,241
7. Powered Industrial Trucks (1910.178): 2,162
8. Machine Guarding (1910.212): 1,933
9. Fall Protection – Training Requirements: 1,523
10. Electrical – Wiring Methods (1910.305): 1,405
The top-ten list!!!
Of the top-ten the following
represent elevated work.
1. Fall Protection
2. Scaffolding
3. Ladders
4. Fall Protection – Training Requirements
A further category to elevated work,
could possibly included – Hazard Communication!
Thus we can conclude that 50% of all
citations are elevated work related.
Why do we
have this dilemma?
If we
conduct a thorough Risk Assessment based on live situational input, the
conclusion would be – High Probability X High Severity. That particular quadrant would point to –
Terminating or curtailing that particular activity. Many activities at an elevated height are
temporary in nature and their duration leads us to believe we can control
consequence in most instances of elevated work.
Can we
really control a myriad of risk, hazard factors to absolute satisfaction?
Never would
be the answer!!
What would
be the answer?
1. Fall Protection Plan – The mechanics
remain constant, good planning brings good results. Make F.P.P. compulsory for all work at an
elevated height.
2. Compiling a F.P.P. ensures that all
elevated work should be certifiable – e.g. – New Building – Maintenance
(Infrastructure)- Maintenance (Machinery) – Live electrical (HV)(MV)LV)
Roofing, this can define levels of:
i.
Energy
ii.
Risk
iii.
Expertise
iv.
Duration
v.
Equipment
vi.
PPE
vii.
Access
viii.
Egress
ix.
Rescue
x.
Post
task analysis
3. Secondly, all tradesman, workers, and
artisans should undergo a compulsory annual medical check, and be in possession
of such proof. Lifestyle diseases creep
up on us and could lead to devastating workplace accidents. Responsibility is waning dramatically, and
responsibility should be a standard condition of employment or service.
4. Employer obligations with regard to
elevated work are very conveniently not always understood, issuing an annual
OHSA “licence” for elevated work would alleviate this perceived ignorance, the
small fee payable would then be spent on extra inspectors and regional
expenses.
5. Perhaps all elevated work should be
subject to a “work permit” being issued by a recognised issuing authority. The permit should include a comprehensive
checklist.
6. There is a dire need for improved
training, in South Africa it is absolutely woeful, outdated reference material,
outdated unit standards and unqualified facilitators. In USA it cannot be different, thus, we can
safely conclude that the training is far short of required standards.
7. Assessment of training is even worse;
one cannot definitely gauge the candidate’s competency and comprehension or
gravity of the demands of elevated work.
The foundational assessment should be tough and ask the right questions,
multiple- choice answers on a printed sheet do not meet stringent requirements;
it is a simple matter of life or death.
8. Equipment, quality equipment is not cheap, a
retractable lifeline is a great example, and employers place a value or price
premium that could make the task at hand prohibitively expensive. A good business idea awaits the right
entrepreneur, start a hire company that hires out safety equipment. The working at heights helmet is 15 times
more expensive than a conventional hard hat, this is a no brainer when making economic
decisions, and a conventional hard hat is preferred 9 out of 10 times with the
resulting dire consequence waiting.
9. The ladder, a logical springboard or
access to elevated work is in most instances totally ignored in the elevated
work curriculum, NO decent ladder training is available, no ladder inspection
registers are, maintained, no material specification (no steel ladder on
electrical installations).Ladder accidents account for approximately 3000
deaths globally annually.
10. Finally, a miniscule amount of
operators and organizations have a sustainable rescue plan, the answer they
offer is normally “we do not plan for a failure” yip, these wise asses then use
up time and resources to effect a rescue they did not plan for.
This alarming statistic cannot be, ignored; OHSA has an
obligation to get tougher on working at heights compliance and enforcement.
Vernon is a freelance safety facilitator in South Africa,
working at heights is a personal passion...
