Monthly Archives: September 2014

OSHA Red Tags

OSHA Red tag procedures are implemented when workers are exposed to “hazards from power sources or injuries from moving equipment”. Anytime workers are required to work around equipment or machinery at heights without safety guards or emergency-stop devices, the lockout regulations apply.

OSHA Safety Color Codes can then apply to both equipment, exterior walkways or temporary platform or scaffolding to stand on and perform work above ground level.

Scaffolding rigging or exterior walkway design requires proper assembly by law for fall protection. A three-colored tag system notifies bystanders and workers of the status of the fall protection devices such as scaffolding.

OSHA Safety Color Codes

  • Green – Fall protection equipment is safe for its intended use.
  • Yellow — Fall protection construction does not to meet specific work conditions or requirements. All attempts should be made to restore a yellow tag to a green tag as soon as is practicable.
  • Red — Fall protection is unfit for use.

Requirements

Green tags are placed after construction has been inspected and approved. Yellow tags must list the modifications required, preventive measures reducing risk to workers, and the name of the individual or representative responsible for modification of the scaffolding or other fall protection. Red tags state “DANGER — UNFIT FOR USE”, and list the reason for the red tag, the number and name and date of the inspection.

Regulation

The Occupational Safety and Health Administration (OSHA) is the indicted agency for ensuring standards for the proper erection, modification and dismantling of scaffolding or other fall protection.

Considerations

According to OSHA, a competent person must inspect the fall protection equipment before placing the appropriate tag. “By way of training and/or experience, a competent person is knowledgeable of applicable standards, is capable of identifying workplace hazards relating to the specific operation, and has the authority to correct them. Some standards add additional specific requirements which must be met by the competent person.”

However, there are currently no specific standards regarding competent persons. Read more about OSAH definitions of competent persons.

Consider hiring a safety services team or structural engineer if your exterior or rooftop equipment is red tagged.

All Skylights Require Fall Protection

The OSHA letter of interpretation regarding Skylights confirms that fall protection is required.

“29 CFR 1910.21(a)(1) … defines floor opening as: ‘An opening measuring 12 inches or more in its least dimension, in any floor, platform, pavement, or yard through which persons may fall, such as a hatchway, stair or ladder opening, pit, or large manhole.’

A definition given in Webster’s New Collegiate Dictionary (1977 edition) for ‘hatch’ is ‘an opening in the … floor or roof of a building’; the same entry gives ‘hatchway’ as a synonym.

Using these definitions, therefore, OSHA concludes that a skylight should be regarded as a hatchway, i.e., an opening in the roof of a building through which persons may fall. 29 CFR 1910.23(a)(4), therefore, requires that skylights in the roof of buildings through which persons may fall while walking or working shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.

When a skylight screen is selected for safeguarding the opening, and in the event the skylight is constructed of plastic material subject to fracture (as glass would be), then the skylight must at a minimum be provided with a skylight screen capable of withstanding a load of at least 200 pounds applied perpendicularly at any one area on the screen.

On the other hand, a plastic skylight which can provide the necessary structural integrity to support the 200-pound load would not be required to be further safeguarded, since it would meet the intended function of a screen as well.

As expressed in 29 CFR 1910.23(e)(8), the primary function of the screen is to support at least a 200-pound load such as a person may place upon it. This provision further relates that the screen shall provide a minimum deflection so as not to break the glass; but that portion of the requirement may be inapplicable when no glass is present. (The concern for breaking the glass results from the possible fragment exposure to persons beneath the skylight.)”

Look for more OSHA letter of interpretation at:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19180

About CSG Safety Services Group, LLC: CSG Safety Services Group, LLC designs and installs window washing systems nationwide. CSG provides inspections, testing and certifications for all window cleaning equipment. CSG provides consulting up to full design/build services. The CSG Safety Services Group promotes window washing system solutions with safety, usability, and cost effectiveness in mind. www.windowwashingsystems.com.