Aerial lift CSREM Sept 2012 TSI - CSR

Construction Safety Roundtable of
Eastern Massachusetts
October 9, 2012
Occupational Safety and Health
Administration
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Thanks to our host
and sponsor!
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Housekeeping Items
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Emergency Exits
Restrooms
Cell Phones
Pledge of Allegiance
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Happy Birthday
Karen Curran 21
Tim Irving 29
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AGENDA
• Tim Irving–Aerial lift information
• Bob Kunz – Aerial lift training and
resources
• Harry Carlson – Lessons Learned
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Welcome Guest
First time attendee self introduction
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New Members Signing
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National News Release:
Secretary of Labor Hilda L. Solis appoints 6 members
to Advisory Committee on Construction Safety and
Health
Jeremy Bethancourt, Letitia K. Davis, director, Roger Erickson, Walter
A. Jones, Gary L. Batykefer, Laurie A. Shadrick, Erich J. (Pete)
Stafford, Kristi K. BarberDonald L. Pratt, Kevin R. Cannon, Thomas
Marrero, William E. Hering, Steven D. Hawkins, Charles Stribling, Matt
Gillen.
Region 1 News Release
Everett, Mass., contractor faces more than $40,000 in fines from
US Labor Department's OSHA for excavation hazard at Chelsea job
site
• ANDOVER, Mass. – The U.S. Department of Labor's Occupational
Safety and Health Administration has cited Cavalieri Construction
Co. Inc. for alleged willful and serious violations of safety standards
at a Chelsea worksite. The Everett-based contractor faces a total of
$40,700 in proposed fines for excavation hazards identified during
OSHA's April inspection of the work site located at Washington and
Addison streets.
Individual Indicted in Louisiana for Impersonating an OSHA
Employee to Conduct Fraudulent Hazardous Waste Safety
Trainings During Gulf Oil Spill Clean up
• A 22-count federal indictment was unsealed today in
federal court in New Orleans charging Connie M. Knight,
46, with impersonating a federal employee for the
purpose of enticing people to pay her for fraudulent
hazardous waste safety training.
• The indictment also charges Knight with possessing
false federal identification documents, creating false
federal identification documents and transferring false
federal identification documents to her employees.
Aerial Lift Presentation
Objective
• Review some of the frequently cited OSHA
scaffold standards and how they relate to Aerial
Lifts
• Review the hazards associated with aerial lifts
and accident prevention techniques
• Review of several accidents
• Review other training resources available
– Note: This is only an overview of some of the OSHA
standards and not a comprehensive stand alone
aerial lift training
Standard & Subpart - 1926.
Most Frequently Cited Serious Violations
in Construction
Fall protection – Residential construction 6’ or more
501(b)(13) - M
2468
Fall protection - Unprotected sides & edges
501(b)(1) - M
1575
Portable ladders 3 feet above landing surface
1053(b)(1) - X
1421
Fall hazards training program
503(a)(1) - M
1360
Head protection
100(a) - E
1204
Eye & face protection
102(a)(1) - E
1029
Aerial Lifts - Body belt and lanyard
453(b)(2)(v) - L
948
Scaffolds - Fall protection
451(g)(1) - L
451(e)(1) - L
451(b)(1) - L
943
Scaffolds - Access
840
Scaffolds - Platform construction
754
Note: The charts do not include information entered into the new OSHA Information System (OIS).
Number of Serious
Violations - FY 2011
13
Subpart L - Scaffolds
(1926.450 - 454)
Aerial lifts - Body belt & lanyard
948
453(b)(2)(v)
Standard - 1926.
Scaffolds above 10 ft. - Fall protection
943
451(g)(1)
Scaffold access
840
451(e)(1)
Scaffold platform construction
754
451(b)(1)
Training for employees using scaffolds
454(a)
593
Number of Serious
Violations - FY 2011
SIC Code 17 - Subcontractors
$ 2,214.00 per Citation
What Standards apply?
Is it General Industry
Maintenance?
Is it construction
repair?
Is he roofing?
So CFR 1910 or 1926?
What Standards apply?
Common Causes of Aerial lift
accidents
• Tip Over/failure
• base not stable, base not level, hole, excavation, outside
capabilities of equipment, mechanical failure, fatigue, other
• Crushing
• inadvertent use of controls, not in view
• Electrical overhead line strike
• Falls
• Not anchored to equipment
BLS – Lift accidents
Employees are wearing their fall protection
but it is not connected
1926.453(b)(2)(v)
A body belt shall be worn and a lanyard
attached to the boom or basket when
working from an aerial lift.
SOL Complainant v Jesco Inc
Docket 10-0265
Contest: 29 C. F. R. § 1910.67(b)(2), for using a “field modified” aerial lift without first obtaining written
certification from the manufacturer of the aerial lift. The Secretary proposed a penalty of $ 4,500.00 for the
violation.
Finding: The court finds the Secretary established a serious violation of 29 C. F. R. § 1910.67(b)(2). Item 1 of
Citation No. 1 is affirmed, and a penalty of $ 2,500.00 is assessed.
•
•
•
employees performed an unapproved field modification of a rented JLG Aerial Boom Lift by
using clamps to attach 325-pound, 31-foot long beams to the guardrails of the Lift’s
platform and using the Lift to lower and lift the beams to the ceiling, 31-feet above. The
Operation and Safety Manual for the Lift instructs users to “not carry materials directly on
platform railing” and further states that “[s]upplies or tools which extend outside the
platform are prohibited unless approved by JLG.”
(b) On or about August 29, 2009, at Mueller Copper Fittings, employees performed an
unapproved field modification of a rented JLG Aerial Boom Lift by placing 325-pound, 31foot long beams on the guardrails of the Lift’s platform and
using the Lift to lower and lift the beams to the ceiling, 31.5-feet above. The Operation and
Safety Manual for the Lift instructs users to “not carry materials directly on platform
railing” and further states that “[s]upplies or tools which extend outside the platform are
prohibited unless approved by JLG.”
Excavation Standard – EE had
clear view - Deleted
• 1926.651(f) Warning system for mobile
equipment. When mobile equipment is operated
adjacent to an excavation, or when such
equipment is required to approach the edge of
an excavation, and the operator does not have a
clear and direct view of the edge of the
excavation, a warning system shall be utilized
such as barricades, hand or mechanical signals,
or stop logs. If possible, the grade should be
away from the excavation.
CFR 1926.453(a)(1)
•
Unless otherwise provided in this section, aerial lifts acquired for use on or
after January 22, 1973 shall be designed and constructed in conformance
with the applicable requirements of the American National Standards for
"Vehicle Mounted Elevating and Rotating Work Platforms," ANSI A92.21969, including appendix. Aerial lifts acquired before January 22, 1973
which do not meet the requirements of ANSI A92.2-1969, may not be used
after January 1, 1976, unless they shall have been modified so as to
conform with the applicable design and construction requirements of ANSI
A92.2-1969. Aerial lifts include the following types of vehicle-mounted aerial
devices used to elevate personnel to job-sites above ground:
Question (1): Does §1926.453(b)(2)(i) through (xii) apply to self
propelled boom-supported elevating work platforms, such as those dealt
with in ANSI A92.5 (1992), or does it only cover elevating and rotating
work platforms mounted on vehicles?
Answer: The "aerial lifts" covered by this section are those that are considered aerial lifts
in ANSI A92.2-1969 (see §1926.453(a)). The ANSI A92.2-1969 standard, under 1.1.1
"Equipment Covered," states that it covers: the following types of vehicle-mounted aerial
devices used to elevate personnel to job sites above ground: (1) Extensible boom
platforms; (2) aerial ladders; (3) articulating boom platforms; (4) vertical towers; (5) a
combination of any of the above. These devices are made of metal, wood, fiberglass
reinforced plastic (FRP), or other material and are powered or manually operated;
whether or not they are capable or rotating about a substantially vertical axis. Under
section 2 of the ANSI standard ("Definitions"), "vehicle" is defined as "any carrier that is
not manually propelled." So, to be within the coverage of the ANSI standard, and thus the
requirements of §1926.453, the "aerial device" can be powered or manually operated, but
it must be vehicle-mounted -- and the vehicle must be a "carrier that is not manually
propelled."
Because the ANSI definition of "vehicle" is so broad, "vehicle" is not limited to over-theroad trucks. In answer to your question, boom-supported elevating work platforms
identified in ANSI A92.5 (1992) are covered by §§1926.453(b)(2)(i) through (xii) if they
are mounted on powered carriers.
ANSI A 92.5
ANSI/SIA A92.5-2006
American National Standard Boom-Supported Elevating Work
Platforms
1.1.1 Equipment Covered. This standard applies to self-propelled
integral chassis aerial platforms having a platform that can be
positioned completely beyond the base and are used to position
personnel, along with their necessary tools and materials, at work
locations. Aerial platforms are power operated with primary
functions, including drive, controlled from the platform. Such aerial
platforms are intended to be occupied when driven.
….(3) Responsibilities for dealers, owners, users, operators, lessors,
lessees and brokers. All provisions detailed for dealers, owners,
users, operators, lessors, lessees and brokers apply to both new
and existing units delivered by sale, lease, rental or any form of
beneficial use on or after the effective date.
ANSI/SIA A92.6-2006
ANSI/SIA A92.6-2006
Self-Propelled Elevating Work Platforms
• Applies to self-propelled, integral chassis
aerial platforms having a platform that
cannot be positioned completely beyond
the base and are used to position
personnel, along with their necessary tools
and materials, at work locations. Platforms
are adjustable by manual or powered
means and shall not be occupied when
moved horizontally.
Manufactures Warnings
Aerial Lift Anchorage
Note: Decal
indicates Body
Belt not PFAS
on upper
guardrail
Aerial Lift Anchorage
Note: Decal
indicates
PFAS on
lower portion
of basket
Manufactures Nameplate
Crushing Hazards
Crushing Hazards
Fatal accident
Location of emergency stop
How to recognize hazards
Not tied off
Work zone
Safety
Base Support – know what is
beneath the lift
Before and After
Bucket truck tip over
Boom Failure
• Stress fracture/
fatigue due to a
failure to properly
secure boom in
the cradle during
transport.
1926.453(b)(2)(xii)
Before moving an aerial lift for travel, the
boom(s) shall be inspected to see that it is
properly cradled and outriggers are in
stowed position except as provided in
paragraph (b)(2)(viii) of this section.
Publication Date: 02/24/2010
Publication Type: Notice
Fed Register #: 75:8406-8407
Standard Number: 1926.453
•Title: Aerial Lifts; Extension of the Office of
Management and Budget's (OMB)
Approval of an Information Collection
(Paperwork) Requirement.
How do I
know what
to inspect?
Question: Is it permissible to allow workers to stand on boom lift1
guardrails or scissor lift guardrails in order to perform work if they
use a personal fall arrest system?
Aerial lifts
The answer is no for aerial lifts. Section 1926.453(b)(2)(iv) states that "employees shall
always stand firmly on the floor of the basket, and shall not sit or climb on the edge of the
basket or use planks, ladders, or other devices for a work position."
Scissor lifts
The requirements of 29 CFR Part 1926 Subpart L (Scaffolds) applies to scissor lifts.
There is no single provision in the scaffold standard that states that this practice is
prohibited. However, as a practical matter, it is unlikely that all the requirements of the
scaffold standard could be met while engaging in this practice.
Use of personal fall protection would not be a substitute for compliance with these
scaffold requirements - these plus the fall protection requirements2 must be met. Note
that §1926.502(d)(23) prohibits personal fall arrest systems to be attached to guardrails
systems. Therefore, the system would have to be anchored to either the scissor lift or an
adjacent structure.3
Question 1: Do the OSHA standards permit employers to use
aerial lifts to transport workers to and from elevated work stations
where the basket is either set down on an elevated surface or
placed at the edge of a structure?
Answer: OSHA standards do not prohibit employees from exiting or
entering an aerial lift basket that rests on or adjacent to an elevated
surface. Section 1926.453(b)(2)(v) requires that employees working
from aerial lifts be tied-off. On the other hand, when employees move
from the basket to the elevated surface, the requirements in 29 CFR
Part 1926 Subpart M apply. In particular, §1926.501(b)(1) requires fall
protection at 6 feet above a lower level. A worker may enter or exit an
aerial lift (at heights above 6 feet) provided that fall protection such as
guardrails or a fall arrest system is used while the worker moves
between the lift and the working surface. A fall arrest system and its
components must meet the criteria in §1926.502(d). During entry to and
egress from the lift, a worker may tie-off to the lift (if the lift is designed
to withstand the vertical and lateral loads imposed by the employee's
movement itself or by an arrested fall) or to an appropriate nearby
structure.
Fatality Assessment and Control
Evaluation (FACE)
FACE
Recommendation and Discussion
FACE
Recommendation and Discussion
FACE
Recommendation and Discussion
FACE
Recommendation and Discussion
Thanks to our host
and sponsor!
The End
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