Tennessee Association of Roofing Contractors

TOSHA believes the information in this presentation to be accurate and delivers this presentation as a community service. As such, it is an academic presentation which cannot apply to every specific fact or situation; nor is it a substitute for any provisions of 29 CFR Part 1910 and/or Part 1926 of the Occupational Safety and Health Standards as adopted by the Tennessee Department of Labor and Workforce Development or of the Occupational Safety and Health Rules of the Tennessee Department of Labor and Workforce Development.

This training is NOT to be used in lieu of annual or initial

safety & health training. Management is required to

conduct onsite specific training.

Review of the most cited construction hazards…

#20 – 1926.102 Eye & Face Protection

• Eye and face protection & maintenance (keep clean & in good repair) exposing employees to physical, chemical and radiation eye hazards

• Table E-1 – eye and face protection selection guide

• Table E-2 – filter lens shade numbers for protection against radiant energy – welding operations

• Table E-3 – selecting laser safety glass

#19 – 1926.1060 Ladders: Training Requirements

• Training program provided for employees using stairways and ladders – Nature of all hazards related to

ladders and stairways – Correct procedures for erecting,

maintaining, and disassembling fall protection systems

– Proper construction, use, placement and care in handling of all stairways and ladders

– The maximum intended load-carrying capacities of ladders

– Retraining when? – ensure employee maintains the understanding and knowledge

#18 – 1926.651 Specific Excavation Requirements

• Daily inspection of excavation by a competent person – Access and egress – Spoil pile – Hazardous atmospheres – Protection of employees

from loose rock or soil – Fall loads – Warning system for mobile

equipment – Testing and controls – Underground installations – Water accumulation

#17 – 1926.1101 Asbestos • Is there asbestos? - building

predates 1981

• Demo or salvage, removal or encapsulation, construction, alteration, repair, maintenance or renovation, installation, emergency clean up or spill, transportation, disposal, storage, containment of and housekeeping activities involving asbestos

• Work is broken into classes – based on activity (I – IV)

#17 – 1926.1101 Asbestos

• PEL 0.1 f/cc (fiber per cubic centimeter of air) for a TWA (8 hours) • Excursion limit – 1.0 f/cc as averaged over a sampling period of 30

minutes • Exposure assessments • Periodic monitoring • Methods of compliance – wet methods, vacuum cleaners, HEPA filters,

local exhaust, enclosure or isolation, dry sweep or shoveling • Appropriate engineering controls for class of work • Water Spray Process System • Respiratory protection & PPE • Laundering • Hygiene facilities – decon areas • Signs – posting – training • Competent person onsite – EPA training

#16 – 1926.100 Head Protection

• Head protection provided

• Head protection from high voltage electric shock

• ANSI Z89.1-2009, 2003 & 1997

#15 – 1926.103/1910.134 Respiratory Protection

• Proper selection

• Written program

• Medical evaluation

• Annual fit testing

• Care, use, cleaning, storage, maintenance, emergencies, limitations

• Appendix D – voluntary use

• Training – initially & annually

• Program review

#14 – 1926.50 Medical Services & First Aid

• Trained to render first aid – 3/4 minutes from emergency medical care - 1 per shift

• First aid supplies easily accessible

• First aid kit placed in a weatherproof container with individual sealed packages

• Proper equipment for prompt transport to hospital

• Eyewash – corrosives • Appendix A – first aid kits • NOTE: Exposure Control Plan

1910.1030

#13 – 1926.502 Fall Protection: Criteria & Practices

• Guardrail systems - Top rails of guardrail systems not 42 inches plus or minus 3 inches above the walking/working level

• Safety Net systems

• Positioning devices

• Access zones

• Safety monitoring systems

• Personal fall arrest equipment

#12 – 1926.404 Wiring Design & Protection

• Permanent and continuous path to ground

• Conductors

• Circuit breakers

• Grounding path

• Outlet covers

#11 – 1926.1052 Stairways

• Stairways not permanent - Landings

• Stairs installed 30-50 degree from horizontal

• Riser height and tread depth

• Temporary service

• Stair rails and handrails

• Unprotected sides

#10 – 1926.452 Scaffolds: Specific Types

• Fabricated frame scaffold not properly cross-braced

#9 – 1926.416 Electrical Safety Related Work Practices: General Requirements

• Worn or frayed electric cords/cables used

• Working around energized equipment

• Posting warning signs

#8 – 1926.454 Scaffolds: Training Requirements

• Training employees working on scaffolds

• The training shall include the following topics: – The nature of scaffold hazards – The correct procedures for

erecting, disassembling, moving, operating, repairing, inspection, and maintaining the type of scaffold in question

– The design criteria, maximum intended load-carrying capacity and intended use of the scaffold

– Any other pertinent requirements

#7 – 1926.405 Electrical Wiring Methods

• Strain relief on flexible cords

• Proper cabinets

• Boxes

• Fittings

• Splices

• Damp and wet locations

• Protection of live parts

#6 – 1926.453 Aerial Lifts

• Fall protection – “ejection hazard”

• Proper use of equipment

• Stand firmly on floor of basket

#5 – 1926.503 Fall Protection: Training Requirements

• Training on fall hazards • Training shall include:

– The nature of fall hazards in the work area

– The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used

– The use and operation of the fall protection systems to be used

– The role of each employee in the safety monitoring system

– The limitations of the use of mechanical equipment

– The role of employees in fall protection plans

– Fall protection standards

#4 – 1926.1053 Ladders

• Ladder side rails extend 3 feet above upper surface

• Improper use of ladders

#4 – 1926.1053 Ladders

• Unsecured ladders placed in passageways, doorways, etc

• Top or top step of ladder used as a step

#3 – 1926.501 Duty to Have Fall Protection

• Fall protection for unprotected sides and edges above six feet

• Fall protection for employees working on low-slope roofs

#3 – 1926.501 Duty to Have Fall Protection

• Fall protection while on a steep roof

#2 – 1926.59/1910.1200 Hazard Communication

• Written program

• SDS – Safety Data Sheets

• Labels – signal word, pictogram, hazard statements

• Training – basic recall

• GHS – June 2015 – Written program

– Labels

– Pictograms

– SDS

#2 – 1926.59/1910.1200 Hazard Communication

• Basic Recall of training: – What is this training about? – What hazardous chemicals are you exposed to? – Where are these chemicals present? – What are the short and long term effects? – How can you detect if you are overexposed? – How can you protect yourself? – Where are the MSDS (SDS) and written program? – What do the pictograms mean? – What is the new format for Safety Data Sheets?

NOTE: Always interview staff for knowledge of safety and health policies

#1 – 1926.451 General Requirements for Scaffolding

• Scaffold platforms fully planked or decked

• Base plates and mud sills

#1 – 1926.451 General Requirements for Scaffolding

• Unstable objects used to support scaffold

• Front end loaders, etc. to support scaffold

#1 – 1926.451 General Requirements for Scaffolding

• Ladder provided to access scaffold – cross braces shall not be used as means of access

• Scaffolds inspected by competent person before each work shift

• Scaffolds erected, dismantled, moved under supervision of competent person

#1 – 1926.451 General Requirements for Scaffolding

• Fall protection on scaffolds 10 feet or higher

• Guardrails on open sides and ends of platforms

Review of TOSHA investigated fatalities…

Fall

Fall

Fall

Fall

2015 Construction Related • Fall through roof removing tin • 25’ fall from greenhouse roof under constr. • Fall from cabin roof under construction • Thrown from telehandler, drive shaft broke, hit

ditch • Fall from fixed ladder when bracket broke • Marking road for paving, hit by backing dump

truck • Fall through roof, installing/removing metal

roofing

Review of the TOSHA regulatory updates…

0800-1-3-.05(1)(a&b) Incident Reporting

TOSHA rule change 2015 NEW in 2015: • All Work related fatalities within 8 hours (same) • All work related in-patient hospitalizations of 1

or more employees within 24 hours • All work related amputations within 24 hours • All work related losses of an eye within 24 hours

– Replaces catastrophe 3 or more hospitalized reporting requirements but TOSHA FOM states will still conduct an inspection for castastrophe

– Federal Final Rule enforceable January 1st, 2015. TN OSHA enforceable approximately same date may be a few months later.

– Note: only fatalities occurring within 30 days of the work-related incident must be reported to TOSHA. In patient hospitalization, amputation or loss of an eye, these incidents must be reported to TOSHA only if they occur within 24 hours of the work-related event.

0800-1-3-.05 Fatality / Catastrophe / Incident Reporting

• Call OSHA - 800-321-6742

• Call TOSHA – 800-249-8510 – 615-741-2793

Online: OSHA is developing a new means of reporting events electronically – www.osha.gov/report_online

If after hours must call the OSHA number. Can not leave a message on answer machine, email or fax…

Incident Reporting TOSHA Response to Reports

• Inspections may be conducted of the following incident reports –

– Under 3 hospitalized following same incident

– All loss of eye injuries (not loss of sight)

– Amputation of multiple digits (more than one toe, finger)

– Amputation of limb (foot, hand, leg, or arm)

– Injury to worker under 18 years old

– Employer with known history of same or similar injury at site within past 12 months

– Employer has been issued willful, failure to abate, or repeat violations within past 12 months

**Area office supervisor has discretion

Incident Reporting TOSHA Response to Reports

• If an inspection is not warranted area office supervisor will request a Rapid Response Investigation “RRI” & ask the employer to conduct an investigation into the incident. Employer will have 5 working days to respond to the Supervisor in writing or TOSHA must conduct onsite investigation.

Fatality/Catastrophe Reporting

https://www.osha.gov/recordkeeping/index.html

Subpart AA―Confined Spaces in

Construction • 1926.1200 Reserved

• 1926.1201 Scope • 1926.1202 Definitions • 1926.1203 General requirements • 1926.1204 PRCS program • 1926.1205 Permitting process • 1926.1206 Entry permit • 1926.1207 Training • 1926.1208 Duties of authorized entrants • 1926.1209 Duties of attendants • 1926.1210 Duties of entry supervisors • 1926.1211 Rescue and emergency services • 1926.1212 Employee participation • 1926.1213 Provision of documents to Secretary Authority

Confined Spaces: Small Employer’s Guide

(can find overview of std, sample programs, permits, etc.)

• https://www.osha.gov/Publications/OSHA3825.pdf

Confined Spaces:

Scope--Construction Standard • Applies to Construction activities –

enforceable in TN August 3rd, 2015

• Standard does not apply to Subpart P - Excavations, Subpart S - Underground Construction, Caisson, Cofferdams, etc. & Subpart Y – Diving

• Where this standard applies and there is a provision that addresses a hazard in another applicable TOSHA standard, the employer must comply with both that requirement and the provisions of this standard.

What is a Confined Space?

• is large enough and so configured that an employee can bodily enter and perform assigned work; and

• has limited or restricted means for entry or exit; and

• is not designed for continuous employee occupancy

• A space must meet all three of these criteria in order to be classified as a confined space.

A space that:

What is a Permit-Required Confined Space?

• A confined space is a permit required space if it has ONE or more of the four specific characteristics that make the space potentially hazardous

• Any one of these characteristics makes a confined space a permit space

1. Hazardous atmosphere

2. Engulfing materials

3. Inwardly converging wall, or

4. Other serious hazards

Confined Spaces: 1207 Training

• At no cost, ensure employees

– Possess the understanding, knowledge, & skills to perform duties under this standard

– Know the hazards of the space & methods used to isolate, control & protect ‘ees while in the space

– Make no attempt to rescue if not authorized to enter

• Maintain training records 1207(a) – (c)

– employee’s name, name of trainers, & dates of training.

– keep while employed

Confined Spaces: 1207 Training

• Before employee is first assigned duties under this standard

• In language & vocabulary they can understand

• Establish proficiency in the duties

• Before there is a change in assigned duties

• Whenever there is a change in permit space entry operation that presents a hazard about which an employee has not previously been trained; and

• Wherever there is evidence of a deviation from permit space entry

TOSHA Resources www.osha.gov

http://www.tn.gov/workforce/section/tosha

www.cdc.gov

www.cdc.gov/niosh

Memphis Office 901-543-7259

Jackson Office 731-423-5640

Nashville Office 615-741-2793

1-800-249-8510

Knoxville Office 865-594-6180

Kingsport Office 423-224-2042

Chattanooga 423-634-6424

Consultative Services 1-800-325-9901