Category Archives: Workplace Safety

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.

Required Safety Measures for Building Owners

As OSHA shifts focus to enforcement, building owners need to understand new compliance requirements.

The American National Standards Institute (ANSI) include building owner compliance requirements under a general duty clause.

A new Window Cleaning Safety Standard holds building owners responsible for ensuring that worker safety and public protection standards are in compliance for window cleaning procedures in all buildings three stories and higher.

Buildings without appropriate anchor point for suspended work are non-compliant. Building work surfaces must be retrofitted with certified anchor points before any work can begin. Moving forward, new buildings three stories or higher design plans must have these anchor points.

For worker protection, the American National Standards Institute (ANSI) approved IWCA I-14.1-2001 holds building owners, property professionals, and window washing contractors responsible for:

  • Providing written documentation from a professional structural engineer that roof anchors are certified to withstand the expected load,
  • The documentation of maintenance and inspection of any permanent equipment being used for window,
  • Maintaining Manufacturer Instructions on all equipment including the load ratings, limitations, and intended use,
  • Ensuring that window cleaning contractor own equipment attached to any part of the building, is inspected to ensure that the anchor point will hold the expected load.

The Occupational Safety and Health Administration (OSHA) also holds building owners responsible for providing safe and healthful workplaces for their employees. Read more at CSGCARES BLOG.

Fall Protections citations

Think you can save money without a professional installation team?

Fall protection is the top OSHA-cited workplace safety violation with more than 8,000 citations last year. According to Federal OSHA, as well as Cal-OSHA, falls continue to be the leading cause of fatalities in construction.

A rise in falls due to lack of fall protection and recent changes in regulations for light-frame residential construction means more targeted random jobsite inspections  industry wide. Construction industry management must be responsible for fall protection to prevent accidents and avoid costly and reputation damaging Cal-OSHA citations.

OSHA citation fines cost companies, small and large, millions of dollars each year. Check out some routine OSHA citations for construction firms.

  • An unregulated scaffold at 30 feet with no fall protection gear or training for workers cost $62,000.
  • A firm with past OSHA violations issues was cited for $243,000 for having workers on a steep pitch roof without fall protection.
  • Average fines for not having a Hazard Communication Plan, Material Safety Data Sheets or maintaining employee training can cost $281.00 per violation.
  • Ladder related citations as high as $139,260 in proposed fines for issues including using a damaged extension ladder, improper ladder use, ladder unsecured or ladder not inspected prior to use.

The customer absorbs these costs when contractors fail to provide adequate fall protection on job sites in unexpected charges or fees for new documentation. New laws in California hold a building owner responsible for ensuring worker safety as required by OSHA regulations.

Work with a professional installation team with Fall Protection Consulting experience for your window washing systems or exterior building maintenance projects to prevent accidents and avoid costly and reputation damaging Cal-OSHA citations.

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.