July/August 2006
When you do what I do for a living, you end up with a drawer full of scraps of paper noting topics the safety column should address one day. More often than not, those topics don’t merit columns unto themselves, thus the notes continue to accumulate.
Enough! It’s high time I do my part to support our paper members by consigning a few of these scraps to the recycling bin. Before tossing them, however, I’d like to share some of them with you.
“The scrap pile is not Home Depot.” I wrote this one to myself after visiting a yard
in which workers had tied a dilapidated stepladder to the base of a 4-foot platform to provide a permanent means of access and egress from one level to another. When I asked my host the obvious question, he told me—with no small amount of pride—that this particular solution literally fell at his feet as a Bobcat was dumping a load of aluminum scrap. There, among a twisted pile of stuff, was a “perfectly good” ladder that was the precise height for the problem the company was trying to solve.
Goodness gracious, where do I start? First of all, the stepladder was not perfectly good. Several of the welds were cracked, and at least one of the steps was bent. I’m guessing that’s at least part of the reason the previous owner decided to scrap the ladder in the first place. More than that, you can’t use portable equipment for permanent solutions. If you need stairs, build stairs, and when you build them, build them to code.
Speaking of building codes …
“If you don’t know what it will hold, you can’t put anything on it.” This one involves so-called “mezzanine storage.” We’ve seen a spate of OSHA citations recently that hammer recyclers for storing materials on elevated platforms that do not have posted load ratings. The citations have applied to all kinds of platforms, from warehouse shelving to office ceilings.
The rule here is simple, and in its simplicity it is consistent with many other OSHA standards: If you can’t quantify a hazard, you must, by law, assume the worst. In this context, then, if people or equipment are able to pass under a storage platform (not that they ever have or ever will be allowed to, but merely if they can), the employer must post the maximum load limit and ensure the load does not exceed the maximum limit. If the employer doesn’t know the rating, then nothing can be placed on the platform.
Where do those load limits come from? From the engineer who either designed the platform or evaluated the platform you designed and constructed yourself.
“If you didn’t write it down, you didn’t do it.” OK, this one’s not new to this column, but it still bears repeating. To modify a cliché, the road to OSHA citations is paved with good intentions. If you have a solid safety program in which new employees undergo comprehensive orientation sessions and receive thorough instruction on the hazards of their job duties, and if they then participate in regular safety meetings and training sessions, there’s no arguing that you’re well on your way to a terrific, comprehensive safety program. Congratulations.
Unfortunately, even with all of that, you might still find yourself in trouble with OSHA. One of the agency’s first requests during a compliance inspection will be to see your employee training records. OSHA will want to know who attended what training on what date, who the instructor was, and what topics the training covered. If you’ve got the documentation, the inspector will smile; if you don’t, the inspector will frown. Frowning is bad.
“Every foot on a rung, every rung in its place.” Forgive me for returning to ladders, but I confess that this is one of my sore spots. I’ve spent countless hours on ladders over the years, and because they’ve served me so well, I thought I’d spill some ink on their behalf.
A ladder is an engineered product. It is a device designed for vertical travel. It is not a bridge for crossing horizontally from one point to another.
A ladder derives 100 percent of its strength from the reinforcement provided to the rails (the long sides) by all of the rungs (the short crosspieces). If you remove even one of the rungs (or bend it, pinch it, or twist it), the ladder loses significant strength. In fact, from the moment one of those rungs becomes severely damaged, you can’t even call it a ladder anymore; it’s scrap.
A collapsing ladder is the definition of a catastrophic failure. One instant you’re supported above the ground, the next instant you’re a dent in it.
Every time you or one of your employees starts climbing a ladder, I urge you to remind yourself that all that stands between you and a nasty gravity storm is a collection of assembled parts.
—John Gilstrap, ReMA director of safety
When you do what I do for a living, you end up with a drawer full of scraps of paper noting topics the safety column should address one day. More often than not, those topics don’t merit columns unto themselves, thus the notes continue to accumulate.