UNIT II STUDY GUIDE Subparts D-F; Walking/Working Surfaces, Life Safety, and Personnel Lifting Devices Course Learning Outcomes for Unit II Upon completion of this unit, students should be able to: 1. Apply OSHA safety and health standards to the workplace. 1.1 Identify compliance requirements of OSHA Subparts O S. 4. Analyze workplace compliance with OSHA standards. Reading Assignment This course does not have a specific textbook. Instead, you will be using actual OSHA standards from the U.S. Department of Labor s OSHA website as well as other relevant materials. To access the required reading material for this unit, copy and paste the URL into your Internet browser. Become familiar with the subject areas in the table of contents for OSHA standards 1910.212 through 1910.399 and 1910.29. Occupational Safety & Health Administration. (n.d.). OSHA standards: 1910.212 through 1910.399. Retrieved from http://www.osha.gov/pls/oshaweb/owastand.display_standard_group?p_toc_level=1&p_part_number =1910 Occupational Safety & Health Administration. (n.d.). Fall protection systems and falling object protection- Criteria and practices. Retrieved from https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=standards&p_id=9721 Unit Lesson A safety poster that was displayed in 1942-1943 (National Archives and Records Administration, 2011) The Occupational Safety & Health Administration (OSHA) General Industry Standards can be found at 29 CFR Part 1910. Part 1910 is organized into Subparts A through Z, and each subpart is comprised of related standards. The standards are numbered sequentially, starting with 1910.1 in Subpart A and ending with 1910.1450 in Subpart Z; while it is helpful to be able to identify subparts, only the standard number is really needed to locate a specific requirement. Parts A, B, and C are primarily administrative guidelines, explanations, and definitions. We begin this unit with Subpart D, Walking-Working Surfaces. Subpart D According to OSHA, slips, trips, and falls constitute the majority of general industry accidents. They cause 15% of all accidental deaths and are second only to motor vehicles as a cause of fatalities. The OSHA standards for walking-working surfaces apply to all permanent places of employment, except where only domestic, mining, or agricultural work is performed (OSHA, n.d.-a, para 1). The walking-working surfaces standards encompass 1910.22 through 1910.30. They provide specifications for safe aisles, floors, walkways, stairs, ladders, and platforms that employees utilize during their workday. In other words, these standards require a workplace free from tripping and slipping hazards and from hazards that might result in falling from BOS 4025, OSHA Standards 1
one level to another. Structurally sound ladders, stairs, and platforms with proper UNIT railings x STUDY and GUIDE similar systems are required to prevent employees from falling when moving from one level to another. Some important provisions of the standard are highlighted below. Stairs Open sides of stairs over 30 inches high (or four or more risers) must be protected by stair rails that include a top rail and midrail. Stair rails must be able to withstand 200 pounds of pressure. The top stair rail must be between 36-37 inches in height. Top rails on open stair landings must be 42 inches in height. Ladders Maximum length for single-section portable ladders is 30 feet. Maximum length for stepladders is 20 feet. (Note that this is the length of the front section, not the height of the ladder when in use.) Metal-sided ladders may not be used near exposed energized electrical equipment. The minimum clear distance between side rails is 11.5 inches. When used to access an upper landing, the side rails of a ladder must extend at least three feet beyond the landing. Non self-supporting portable ladders must be positioned against a wall so that the horizontal distance from the top support to the foot of the ladder is ¼ the working ladder length of the ladder. The standard provides specifications for both ladder construction and ladder use. According to OSHA, the new rules for fall protection are meant to align general industry requirements as much as possible with existing fall protection requirements in the construction industry. Click here for additional information: Subpart E (Stevens, 2006) (INCOSV, 2009) Subpart E includes 1910.33 through 1910.39. These standards were put in place to assure safe and orderly egress during emergency situations, particularly emergencies related to fire. They apply to all workplaces in general industry, except mobile workplaces such as vehicles or vessels. The egress standards are based primarily on various iterations of the National Fire Protection Association's (NFPA) Life Safety Code, NFPA 101, although they do not include the same coverage and level of detail as the NFPA standards. The NFPA standards include many types of occupancies not regulated by OSHA, such as private dwellings, apartment buildings, schools, and places of assembly. (Alza, 2009) OSHA s walking-working surfaces standards (1910.22-1910.30) provide specifications for safe aisles, floors, walkways, stairs, Means of egress: 1910.36 and 1910.37 deal primarily with egress and exit issues related to the physical facilities of a given workplace. They include specifications and regulations for exits, exit routes, doorways, and emergency lighting. In July of 2013, OSHA issued an enforcement memorandum, highlighting the need for its inspectors to pay particular attention to the means of egress in all facility inspections. The increased emphasis was the result of a fire at a chicken processing plant in China; 119 workers died because they were BOS 4025, OSHA Standards 2
unable to exit the facility. A similar incident took place in Hamlet, North Carolina UNIT in 1993, x STUDY and 25 GUIDE employees died. Three egress requirements are particularly important and deserve mention here (Conn, 2013, para 3): Employers must determine how many exit routes are required in its building. Exit routes must be maintained to be unobstructed, and the exit doors must remain unlocked from the inside. Exit routes and doors must be properly labeled and maintained. Emergency action plans: 1910.38 outlines the requirements for an effective emergency action plan (EAP) to ensure safe and orderly evacuations from the facility in the case of an emergency. A written EAP is required for employers when they are covered by another OSHA standard that specifically requires an EAP. These standards include the following items: Process safety management of highly hazardous chemicals: 1910.119; Fixed extinguishing systems, general: 1910.160; Fire detection systems: 1910.164; Grain handling: 1910.272; Ethylene oxide: 1910.1047; Methylenedianiline: 1910.1050; and 1,3-Butadiene: 1910.1051 (OSHA, 2003). Fire prevention plans: 1910.39 is the fire prevention plan standard and provides requirements for facilities with operations that increase the likelihood of fire. Much like the EAP requirements, OSHA requires a written fire prevention plan (FPP) only when required by another section of the standards. FPPs are required for employers covered by these standards listed below: Ethylene oxide: 1910.1047, Methylenedianiline: 1910.1050, and 1,3-Butadiene: 1910.1051 (OSHA, 2003). Although the requirements for formal emergency action plans and fire prevention plans are limited, OSHA does strongly encourage all employers to develop these plans. This brings up an interesting question: Can OSHA cite an employer for not having an EAP or FPP if OSHA can demonstrate that, despite not being required, the presence of these plans would have prevented a fatality or other serious incident? We will look into this type of situation in Unit VIII when we discuss the General Duty Clause of the Occupational Safety and Health Act (OSH Act). Subpart F In Subpart F, 1910.66, and 1910.67 deal primarily with powered platforms in tall facilities such as grain elevators and high-rise structures. Many safety professionals will never have to deal with these issues, but it is still important to be familiar with the requirements. Vehicle-mounted elevating and rotating work platforms, 1910.67, has broad application in many industries. These platforms are often used to elevate workers to perform tasks, ranging from changing light bulbs in warehouses to working on outdoor utility lines. Think of the cherry pickers you see utility workers using in your neighborhood. Most of the standards covered in this unit are specification standards; therefore, they are explicit guidelines, such as the height of guardrails or the width of exits. As we continue in the course, we will see more specification standards, but we will also begin to see more performance standards, which describe the desired outcome but are not as explicit on how to achieve it. References Alza. (2009, February 16). Warehouse ladder [Image]. Retrieved from http://commons.wikimedia.org/wiki/file:sklady_alza_cz2.jpg BOS 4025, OSHA Standards 3
Conn, E. J. (2013, July 15). OSHA to target exits and exit routes. Retrieved from UNIT x STUDY GUIDE http://www.oshalawupdate.com/2013/07/15/osha-to-target-exits-and-exit-routes/ INCOSV. (2009, June 12). Inco ladder [Image]. Retrieved from http://commons.wikimedia.org/wiki/file:inco_ladder.jpg National Archives and Records Administration. (2011). We ask, is this a good scaffold? Attention! Mr. Supervisor. Good supervision and planning make safety [Image]. Retrieved from https://commons.wikimedia.org/wiki/file:we_ask,_is_this_a_good_scaffold%5e_attention%5e_mr._s upervisor._good_supervision_and_planning_make_safety._-_nara_-_535273.jpg Occupational Safety & Health Administration. (n.d.-a). Notice of proposed rulemaking for subparts D and I. Retrieved from https://www.osha.gov/as/opa/proposed-rulemaking-factsheet.html Occupational Safety & Health Administration. (n.d.-b). Walking/working surfaces. Retrieved from http://www.osha.gov/sltc/walkingworkingsurfaces/index.html Occupational Safety & Health Administration. (2003). OSHA fact sheet: Emergency exit routes. Retrieved from https://www.osha.gov/oshdoc/data_general_facts/emergency-exit-routes-factsheet.pdf Occupational Safety & Health Administration. (2016, November). OSHA fact sheet: OSHA s final rule to update, align, and provide greater flexibility in its general industry walking-working surfaces and fall protection standards. Retrieved from https://www.osha.gov/publications/osha3903.pdf Stevens, M. O. (2006, November 18). Oregon Supreme Court stairs [Image]. Retrieved from https://commons.wikimedia.org/wiki/file:oregon_supreme_court_stairs.jpg Suggested Reading In the reading below, you will learn about emergency exit routes. Occupational Safety & Health Administration. (n.d.). Emergency exit routes. Retrieved from https://www.osha.gov/oshdoc/data_general_facts/emergency-exit-routes-factsheet.pdf Click here to access a PDF version of this document. The resource below discusses various concepts covered in Unit II. Occupational Safety & Health Administration. (n.d.). Exit routes, emergency action plans, fire preventation plans, and fire protection. Retrieved from https://online.columbiasouthern.edu/csu_content/courses/emergency_services/bos/bos4025/12c /UnitII_EgressFireProtectionPresentation.pdf In the reading below, you will learn how to protect yourself or co-workers from falls. Occupational Safety & Health Administration. (n.d.). Fall protection. Retrieved from http://online.columbiasouthern.edu/csu_content/courses/emergency_services/bos/bos4025/12c/ UnitII_FallProtectionPresentation.pdf In the reading below, you will learn how to protect yourself when working on scaffolds. Occupational Safety & Health Administration. (n.d.). Scaffolds. Retrieved from http://online.columbiasouthern.edu/csu_content/courses/emergency_services/bos/bos4025/12c/ UnitII_ScaffoldsPresentation.pdf In the reading below, you will learn about safety dealing with stairways and ladders. BOS 4025, OSHA Standards 4
Occupational Safety & Health Administration. (n.d.). Stairways and ladders. Retrieved UNIT x STUDY from GUIDE https://online.columbiasouthern.edu/csu_content/courses/emergency_services/bos/bos4025/12c /UnitII_StairLaddersPresentation.pdf Learning Activities (Non-Graded) This is a non-graded assignment, so you do not have to submit it. However, if you have difficulty with any terms or concepts, contact your instructor for additional guidance and information. 1. Visit your local library, and see if they have a copy of the National Electrical Code Handbook published by the National Fire Protection Association (NFPA). This is one of the best references for understanding electrical safety requirements. Most of the original standards in Subpart S came from NFPA s National Electrical Code (NFPA 70). 2. Visit a local auto repair shop, and ask if you can get a tour of the welding operations (tell them that it is research for a college course). Take note of any violations of the welding standards you observe. If the shop owner is interested, discuss what you found, and provide suggestions for improving compliance and making the operation safer. BOS 4025, OSHA Standards 5