Or has it? It’s virtually impossible to tell unless we take a good look back into the past as well as toward the future. There are three important questions you should ask yourself first: How did these items get here in the first place? What will be their actual fate months or even years from now? Who’s ultimately responsible for all this stuff?
Where did these come from?Several days or weeks before the shipment arrived, someone working for your firm thought (or was told) they needed some equipment to get the job done. Perhaps the need was for personal protective equipment such as chemical-resistant gloves, hearing protection, full-body harness or shock-absorber lanyard.
Engineering controls should always be considered the first line of hazard defense because they are actually designed to eliminate the hazard rather than just protect the worker from the dangerous effects. Sometimes the worker’s safety is to be protected by using an engineering hazard control, such as a portable guardrail system to attach to the parapet, or a high-volume ventilation fan to prevent toxic fumes from accumulating next to roof vents.
Ask your workers if they would rather wear a full-face respirator during an eight-hour shift in an area with a potential for deadly accumulation of vapors; or set up a high-volume exhaust fan with an opposing quantity make-up air source to create and maintain a breathable atmosphere. Would they rather set up a vertical rope lifeline off ridge anchors on a pitched roof in order to tie off their body harness with a lanyard to a rope grab; or, set up 10-inch eave-mounted stop boards with guard-railed scaffold catch platforms at all the potential fall zones?
If the employer establishes a safety equipment management program, he or she designates one or more employees as Competent Person/safety equipment manager (CP/SEM). The employer should verify that the employee has sufficient experience with the equipment and training in the governing OSHA regulations before entering his or her name in the corporate safety and health program and assigning responsibilities. Depending solely on individual training and experience, a safety monitor can either prevent potential accidents, or unfortunately, provide a witness to what went wrong. Simply announcing that an inexperienced, untrained employee is your designated CP/SEM, will not protect your workers from receiving insufficient, inadequate or inappropriate protective equipment.
Taking “prompt corrective measures” does not always mean specifying new respirators or purchasing new lifelines. A CP/SEM should be capable of determining which equipment may be considered a safety issue. A gas-powered demolition saw may operate inadequately on the job. But when the safety guard is missing or the carburetor fuel leaks, the CP/SEM may tag it out-of-service and establish a biannual preventive maintenance program for all gas-powered tools and equipment. A hammer drill with a work electrical cord or a ladder with a damaged rung may be immediately tagged out-of-service. The drill may be replaced with a new one while it is being repaired, and the ladder may be tagged, destroyed and replaced.
What happened to the stuff we had?Several years ago, I was hired by a construction company as a safety officer on an aerial job above live railroad tracks. The host client, regulated by the Federal Railroad Administration, required that I submit a detailed, site-specific safety plan. The plan included a critical path schedule and a complete inventory, description and explanation of use of all the construction and safety-related equipment we were planning to bring onto their property — everything from Gatorade and halogen bulbs to personal fall arrest systems and safety debris nets.
My first obligation was to find out what equipment my employer currently owned as opposed to what he thought he owned. Within days, I located 40 full-body harnesses, dozens of shock-absorber lanyards, and yards of horizontal/vertical/retractable lifelines (nylon and wire rope), carabiners and rope grabs. Once I thoroughly cleaned them, I began inspecting their condition. With a current market replacement value of almost $6,000, I was surprised to find none of the lifelines and only three harnesses and lanyards to be in acceptable (code-compliant) condition. While much of the damage and deterioration apparently occurred during normal use, almost half had obviously deteriorated because of poor housekeeping and neglect.
The contractor had in one year purchased over $10,000 worth of fall protection. Apparently 40 percent of the equipment had “grown legs” or been lost on the job. It had been months since their return from the job and no one knew what they still owned and how much of it was still useable.
Inspecting your construction equipment on a monthly basis will help prevent an untimely discovery of missing or damaged equipment. Purchasing large amounts of expensive replacement safety equipment prior to starting a new job can often tax the project’s budget. If 10 new 40-foot IA fiberglass replacement ladders must be purchased before entering a host employer’s site, some other segment of the material-labor-equipment budget will undoubtedly suffer. On a small job it could even lead to losing revenue entirely. Auditing and purchasing 15-percent replacement of full-body harnesses by the CP/SEM on a regular schedule provides an adequate reserve, when the need to change out a defective item occurs. Replacement costs can then be defrayed over multiple budgets.
For example, when the job-site fire extinguisher needs to be replaced or recharged, I might return to the tool crib to take one of the six inspected extinguishers kept in reserve. If none are available, costly retail purchases may have to be made. If the CP/SEM reviewed the equipment logs on a weekly basis, he or she might have noticed that fire watches have depleted all of the six extinguishers kept in reserve (five returned need recharging and one damaged that must be replaced). It all starts with a complete equipment inventory. Each item or device should be thoroughly cleaned and inspected. Once entered on the log sheet, each item should receive an individual number stamp, tag or other means of identification. If your fire extinguishers are not individually numbered, how do you know if you missed one or counted one twice?
There are many durable, reuseable safety equipment inspection and out-of-service tags available today (call Emedco at 800.344.3633) with item-specific checklists and tear-off repair orders. Sometimes a piece of duct tape with a waterproof marker will be adequate. Large pieces of equipment may be better danger-taped around its perimeter to indicate an ongoing inspection or out-of-service status. Remember: Using a tagged defective tool or machine may multiply your OSHA penalty as it is considered a willful violation. ID tags or labels should never be applied in a manner that interferes with a thorough, visual inspection.
Whose job is this?As an owner of a construction firm, when is the last time you took a walk in to your tool crib, storage room or equipment shed and took a careful look around? If your firm is like most, even the best-organized policies fall apart when it comes to tool and equipment sign-out, return, storage, repair and inventory. Typically, it’s funded by an overhead account, but when the construction economy turns soft, who can afford that? Even larger companies with a full-time mechanic or parts/equipment manager often have poor inventory control. Not only are inventory man-hours considered a low-priority, it is often the job function that has the least monetary return.
At least one CP should be designated by the employer as a SEM, in the written Safety and Health Program. This CP should be experienced in those task-specific areas wherever personal protective equipment or safety-related equipment may be required. By definition, a CP is one who a) by way of experience and training is capable of identifying existing and potential hazardous, dangerous or unsanitary conditions in the workplace; and b) has the authority (released by the employer) to take prompt corrective measures to correct or abate those safety conditions in a timely manner. If this individual determines that hazard abatement cannot be implemented with safety equipment in a timely manner, the CP must remove workers from the hazardous area until the hazard is mitigated.
As I have mentioned many times, the CP should be utilized on every management level, particularly in the bid phase. Safety reviews of all bid proposals will certainly highlight the need for safe work procedures and equipment necessary to perform these tasks. Without exception, a CP or other safety personnel should be permitted access to the scope of work, plans, pre-bid site inspections, and specifications of a bid proposal to determine if all safety aspects have been identified and properly addressed.
As a former construction estimator, project manager and safety director, I understand the challenge of estimating in order to win a bid and then bring the project in under budget and on schedule. The training and experience of your CP/SEM should help your estimator understand the safety implications of each phase of your bid and facilitate your project supervisor in safe work performance. Unfortunately, delaying a safety analysis until the post-bid or construction phase will inevitably impact the project’s profit margin and scheduled completion.
To be honest, the only way to get your profits back out of safety is to bring all of your employees into the formula. By addressing your workers, their tasks and the equipment that protects them every day on the job, you improve the implementation of your safety equipment management policy. The key is a simple job safety analysis (JSA). The JSA entails training your foremen or supervisors to: 1) list the phases and individual tasks of their daily jobs; 2) identify specific potential and existing hazards for each task; and 3) specify the hazard abatement or mitigation methods to reduce or eliminate these hazards.
The final step to this program is critical to your capital investment: a cost analysis of the hazard abatement method. Your safety equipment management program should perform a hazard analysis to determine:
The relative probability of an accident or illness occurring as a result of performing a job task (1=absolute, 2=moderate, 3=unlikley, 4=improbable). We can assume that working on a 20:12 pitch steeple puts the roofer at a greater risk than on a 2:12 pitch warehouse roof.
The relative severity of the effects if an accident/illness occurs (A=catastrophic, B=severe, C=moderate, D=slight). While a fall from 6 feet may result in as much damage as a fall from 60 feet, experience indicates one is more survivable than the other.
By assigning a rating anywhere from 1A to 4D to each task-hazard line on the JSA, the CP/SEM can better assess the amount, type and cost of protective equipment required and the training necessary to use it. Decisions on the amount, the design features or accessories of the equipment may be facilitated by the hazard analysis. The cost of these purchases or repairs may be greatly affected.
A thoroughly researched and comprehensively written safety equipment management program can be another auditing tool with the ability to produce profit for your firm of hundreds, if not thousands, of dollars above the cost of its implementation.