Seasons Greetings to All from No Fall Company

We'd like to thank everyone for a great 2009 and wish you all our best Season's Greetings and a very Happy New Year!

 

Kind Regards,

David Kuketz, Manager

No Fall Company, LLC

 

OSHA's Reports Working at Heights in Top Ten Violations for 2009 - Three (3) Times!

OSHA recently reported the top three violations for 2009

- Scaffolding (over 9000 violations)
- Fall Protection (nearly 7000 violations)
- Ladders (over 3000 violations)

A quick look at the 2009 citations by OSHA show penalties often in the tens of thousands and into the hundreds of thousands for such violations (http://www.osha.gov). The government statistics do not show the impact to business, morale, or legal fees, litigation and the resulting settlements due to such violations and / or accidents that lead up to them.

Fall Protection Violations Are Up and 2nd in top 10 Violations in 2009 So Far!

A preliminary report issued by the National Safety Council shows 6,771 Fall Protection Violations in 2009 so far (as of October) and up about 30% since 2008.

The report does not tally the dollar figure for the violations cited by OSHA, nor the litigation or settlement costs of any fall accidents for the same time period.

See the report here:
http://www.nsc.org/Pages/OSHAReportsonTop10SafetyViolationsfor2009.aspx

OSHA Issues RECORD-BREAKING Fines to BP, More than $87,000,000!

What is a life worth? What is safety worth? Well in this case, with the fines, legal fees, damage to reputation and good will, and actual costs incurred - it is measured in the $B's of dollars ...

Taken from OSHA National News Release, U.S. Department of Labor, OSHA, Office of Communications

BOMA Supports the ANSI / IWCA I-14.1

BOMA (the International Building Owners and Managers Association) fully endorses and supports the ANSI / IWCA I-14.1 Window Cleaning Safety Standard, now a National Concensus Standard of OSHA, and used extensively for citations in support of fines, fees and also being used by attorneys to litigate accidents, negligence and risk issues.

The full link (as of 2009, Oct 28) here: http://www.boma.org/Advocacy/Standards/Pages/WindowCleaningSafetyStandard-IWCA1-14.1.aspx

What is a Personal Fall Arrest System?

Confused about what is a personal fall arrest system (PFAS) and more importantly, the rules for anchorage of PFAS?

OSHA defines a PFAS in at least three separate documents:

Types of Falls

The most general type of falls involving buildings are "falls from roof". Another category, usually for new construction sites, is "falls from roof structural member".

Falls from roof can be from "unprotected" walking surface, that is, no guard rail or no parapet wall of proper height. This is quite common, and can be easily avoided.

There is another particular classification of falls, the "falls thru roof", as follows:

• roof opening
• sky lights
• non-supportive materials (old, weak, deteriorated)
• unspecified

Many falls are caused simply due to carelessness or lack of fall prevention equipment. Most fall injuries can be avoided or minimized via the use of fall protection equipment.

Fall Statistics

The source of this information is OSHA, the Department of Labor (DOL), or the Center for Disease Control (CDC):

• 14% of all fall accidents are fatal.
• Since 1992 serious injuries and fatalities due to falls have been on the rise in spite of new regulations and better operations and practices.
• In 2006 there were 809 fall accident fatalities in the USA; from roofs, unprotected walks, ladders, scaffolding, staging, etc.
• Surprisingly, the distribution of falls of various heights from 6' to over 100' is roughly evenly spread out. Fatalities from falls of under 6' are rare. Falls to hard surfaces tend to be more fatal (abrupt deceleration causes severe unjuries, head injuries substantial).
• Falls cost businesses over $170B a year in medical, wages, lower productivity, lower morale and other negative impacts.
• The actual number of non-fatal fall accidents is unknown, as not all are reported.
• The costs of litigation and settlements is unknown.
• The costs of OSHA citations can be quite substantial.

The OSHA "General Duty" Clause

Each employer has a fiduciary responsibility for safety and safe working conditions.

According to OSHA Act of 1970 // SEC. 5. Duties

(a) Each employer -- (1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees; and (2) shall comply with occupational safety and health standards promulgated under this Act.

(b) Each employee -- shall comply with occupational safety and health standards and all rules, regulations, and orders issued pursuant to this Act which are applicable to his own actions and conduct.

OSHA Annual Inspection - Don't Forget to Inspect *AND* Keep Records!

Don't forget your OSHA Annual Inspections of your roof anchors and engineered fall protection systems and window cleaning equipment - a competent person (qualified person) shall inspect roof anchors, davits, horizontal lifelines and other permanently installed fall protection and prevention and window cleaning equipment on buildings each and every year.

See our post about the OSHA requirements per the ANSI/IWCA I-14.1 from August 2008. See also the OSHA code 1910.66 at http://www.osha.gov/, regarding inspecting. And,

Fallacy of Fall Protection From Manually Rigged Horizontal Lines

Over the past several years, we have seen many a "jury rigged" fall protection "system" on the roof tops of buildings. By this we mean a chaotic assembly of hand-tied ropes and / or cables, attached to roof vents, plumbing, HVAC equipment stands, conduits or other 'structures', thus spreading the 'load' of the suspended worker(s) and their powered platforms or boatswain chairs, or the load of a worker falling from an unprotected roof edge or walking / working surface.

FIGURE:1
Effect of a rigged horizontal line being used to suspend a 1,250 lb. working load, when the sag is only 1.2" and the line is 20' in length; the load in the line is 41,663 lbs. !!! Sag must be sufficiently increased so the load in the line is less than 5,000 lbs.


Problem #1
Ropes are

Certain OSHA Regulations Regarding Working at Heights

People are often confused by what regulations are actually in OSHA codes vs. which are incorporated by reference in consensus standards such as the ANSI/IWCA I-14.1. Below are a few OSHA codes that are mandatory ...

ANSI / IWCA 1-14.1 Important Lifesaving Standard Guidelines

CERTAIN OSHA CONCENSUS STANDARD CODES FROM IWCA/ANSI I-14.1-2001
Below are excerpts from the I-14.1 explaining certain codes that must be followed in the window cleaning industry, which includes the workers, the window cleaning companies, the building management companies that hire them, and the building owners ...

Boatswain Chair Usage With Safety Tieback Anchors; Angles for Lifelines

Standard Interpretations 04/19/2006 - Safe tieback angles for controlled boatswain's chairs. Click title for more ...

OSHA Interpretation of Single Point Anchor for Simultaneous Usage

Standard Interpretations 03/08/2002 - Acceptable use of single point anchor systems for window cleaning operations. Click title for more ...

Regulations for Fall Protection and Prevention at Extreme Heights

In window cleaning and other suspended work industries, there are specific regulations for work at certain heights. The breakpoints are at 130’ and 300’. Read on for additional info ...

OSHA Interpretation Letter of March 28, 2005; ANSI/IWCA I-14.1

This OSHA Interpretation Letter was taken from http://www.osha.gov/ and outlines the rules regarding the ANSI / IWCA I-14.1-2001 and how it will be used in citations. Click title to read more ...

OSHA Interpretation Letter of October 1, 1998; Rules for 300'

This letter taken from http://www.osha.gov/ outlines rules for suspended work over 300' using a powered platform. Click title to read more ...

Florida Roofing Firm Fined $54,100 for 9 Violations

OSHA cited a Pompano, FL roofing company with 9 violations and $54,100 in fines 6 months after a worker fell 30 feet to his death., because this worker had no fall protection and also because the roofing company continued to expose workers to the very same hazard!

The complete article can be viewed at:
http://www.sun-sentinel.com/news/local/breakingnews/sfl-bn-0311roofer,0,3202455.story

Engineered Fall Prevention System

In this photo clearly visible, certified anchors are being used for three purposes, as follows:

1) The first purpose is to

$70,000 OSHA Fine to Contractor in Massachusetts

This incident was "willfull" and the potential fall was 50' high - no fall occured and no injury occured. OSHA is doing the right thing!

http://safetyduck.blogspot.com/2009/03/i-just-dont-get-it.html

It's like getting people to wear seat belts (or helmets) - inconvenient, time consuming, uncomfortable - and it flies in the face of the "it won't happen to me" attitude. The fact is, people have car (and motorcycle) accidents and seat belts (and helmets) save lives, and prevent injury - at least as compared to not wearing one. Think about the costs to business of all the accidents that could be avoided. Think about the cost to businesses when a worker dies. Insurance companies should charge higher premiums to those who don't comply, and offer discounts to those who do (like safe driver programs). Workers who fail to wear their PPE should get fines (ie "tickets") every time it happens, and 3 strikes and you are out ("FIRED!"). If the employer or the property owner / manager or general contractor doesn't enforce this, they should be fined severely - and let those fines help pay for the financial bailouts (ha!).

Fall Protection is the 3rd Most Cited Issue per OSHA

For 2008 there were nearly 5,000 violations of "Fall Protection" discovered by OSHA. They are getting serious about saving lives, and consequently, about writing citations and issuing fines. Numerous citations have been over $100,000. The cost of prevention and having the proper equipment is significantly less - do you want to play safety roulette?