#OSHAstandards

[thomsonscaffolding]

Regulatory Compliance in Commercial Scaffolding

Regulatory compliance in commercial scaffolding involves adhering to safety standards set by authorities like OSHA and local building codes. This includes proper installation, regular inspections, and ensuring worker safety. Compliance ensures structural stability, reduces risks of accidents, and maintains legal requirements, promoting safe construction practices.

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Tower Climbing Safety Standards and Protocols for WISP Operations

Introduction

In the dynamic landscape of Wireless Internet Service Providers (WISPs), the efficient functioning of networks is reliant on the tireless efforts of tower climbers. These skilled professionals face the unique challenge of scaling heights to install, maintain, and troubleshoot wireless infrastructure. With the inherent risks associated with tower climbing, it is imperative for WISPs to establish and adhere to stringent safety standards and protocols. In this comprehensive discussion, we will delve deeper into U.S. government regulations, compliance necessities, and best practices aimed at safeguarding the well-being of tower climbers in WISP operations.

Government Safety Regulations for Tower Climbers in WISPs

FCC Regulations: The FCC, as the regulatory authority overseeing wireless communications, imposes guidelines to ensure the safety of both workers and the general public. FCC regulations encompass two critical aspects: radiofrequency emissions and structural integrity. Tower climbers must adhere to prescribed emission limits and follow structural guidelines to prevent tower collapses. Compliance with FCC regulations is not only a legal requirement but is instrumental in securing licenses and maintaining the integrity of wireless networks.

OSHA Standards: OSHA, the cornerstone of workplace safety in the U.S., has established specific standards for tower climbing operations. These standards cover a range of safety measures, including fall protection, equipment specifications, and comprehensive training requirements. WISPs are obligated to meet these standards to guarantee a secure working environment for tower climbers and mitigate the risks associated with working at heights.

Compliance and Best Practices for Tower Climbing Safety

Comprehensive Training Programs: Tower climbing demands a unique skill set that extends beyond technical proficiency. WISPs must invest in comprehensive training programs that not only impart technical know-how but also instill a strong emphasis on safety protocols, emergency procedures, and the correct utilization of personal protective equipment (PPE). Certifications such as the Tower Climbing Safety and Rescue Training are instrumental in ensuring climbers are well-prepared for the challenges they may encounter.

Equipment Inspection and Maintenance: Regular and meticulous inspection of climbing equipment is imperative to identifying potential risks. Harnesses, lanyards, helmets, and other safety gear should undergo scrutiny before each use. Prompt replacement of faulty or worn-out equipment is vital to preventing accidents and ensuring the reliability of safety measures.

Fall Protection Systems: Fall protection systems serve as a critical line of defense for tower climbers. WISPs must implement and enforce robust fall protection measures, including certified fall arrest systems, guardrails, and ladder safety devices. These measures not only minimize the risk of falls but also provide climbers with effective protection in the event of an unexpected descent.

Communication Protocols: Effective communication is paramount during tower climbing operations. WISPs should establish standardized communication protocols that minimize the risk of misunderstandings and enable climbers to convey critical information promptly. Clear communication channels with ground personnel, fellow climbers, and relevant stakeholders enhance overall safety and coordination.

Emergency Response Plans: Developing and regularly reviewing emergency response plans specific to tower climbing operations is essential. These plans should outline procedures for responding to injuries, rescuing climbers in distress, and coordinating with emergency services. Regular drills and simulations contribute to the preparedness of all involved parties.

Weather Monitoring: Given the exposure of tower climbers to the elements, WISPs should implement robust weather monitoring protocols. Establishing clear guidelines for suspending climbing activities during adverse weather conditions, such as high winds, thunderstorms, or icy conditions, is crucial to ensuring the safety of climbers.

Documentation and Record-Keeping: Maintaining meticulous records of safety training, equipment inspections, and any incidents that occur during tower climbing operations is integral. These records not only serve as evidence of compliance with regulations but also offer valuable insights for the continuous improvement of safety protocols.

Conclusion

In the realm of WISP operations, where success is measured by connectivity and coverage, ensuring the safety of tower climbers is non-negotiable. By rigorously adhering to government safety regulations, investing in comprehensive training, and implementing best practices, WISPs can fortify the safety of their tower climbers. In an industry that reaches new heights every day, the well-being of those who scale the towers should remain a steadfast priority, reflecting a commitment to both regulatory compliance and the preservation of human life.

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[oshalockouttagoutguide]

OSHA Lockout Tagout Standard - Lockout Tagout devices must be Standardized & Identifiable

Under section (B) of (c)(5)(ii) of the OSHA Standard 1910.147, requires that Lockout Tagout Devices must be standardized in either colour, shape, size, print or format. The requirement of the standardized devices is meant to ensure that they are readily identifiable, unique, and distinguished from other similar devices found in the workplace. The intent of these provisions is to elevate the importance of Lockout Tagout devices and ensure that all the employees understand their distinct and exclusive purpose - to protect services & maintenance employees from accidental start-up or the release of stored energy. Section (c)(5)(ii)(D) of the standard requires that Lockout Tagout devices identify the employees who apply them. This requirement adds a degree of accountability to the LOTO program. Once the involved employee is identified, he/she can be located when needed. This identification is also essential as it enables the employer to quickly determine the identity of the employee who forgot to remove his lockout Tagout device. Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

[esquareloto]

OSHA Standard 29 CFR 1910.147 - Definition of Hot Tap and & Normal Production Operations

Hot Tap:

As discussed in our previous post, OSHA standard 29 CFR 1910.147(a)(2) does not apply to Hot Tap and Normal Production Operations.

Hot tapping, or pressure tapping, is the method of making a connection to the existing piping or pressure vessels without interrupting the servicing for air, gas, water, steam, and petrochemical distribution systems. This means that a pipe can continue to be in operation while maintenance or modifications are being done to it. Only if the employer demonstrates that

·   continuity of service is essential

·  shutdown of the system is impractical

·   documented procedures are followed, and special equipment is used which will provide proven effective protection for employees.

Normal Production Operation:

Certain tasks such as minor and repetitive adjustments are considered normal production operations when they are integral to the use of the equipment, and when they do not increase the risk of injury to employees.

So, OSHA Standard, 29 CFR 1910.147 (a)(2) does not apply to Hot tap and Normal Production Operations only when the employees working on it are considered to be SAFE.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-explained/

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[oshalockouttagoutguide]

OSHA Lockout Tagout 1910.147(c)(5): Lockout Tagout devices must be Substantial

Lockout Devices typically Locks, hold energy Isolation Devices in a safe, off or neutral position. They provide protection by preventing machines or equipment from becoming energized because they are positive restraints, consequently. They should be substantial enough to prevent their removal by an authorized person without the use of excessive force or special techniques.

Tags and their means of attachment constructed must be substantial enough to minimize the potential for them to be disconnected, lost or accidentally removed. Tag attachment means are further required to be attachable by hand, and equivalent in strength to a one-piece non-releasable, self-locking cable tie. To meet these requirements, environment tolerant nylon cable tie that has an unlocking strength of about 50 pounds is used for attaching tags.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-standard/

[oshalockouttagoutguide]

OSHA Lockout Tagout Standard - 1910.147(c)(5)(ii)(A) - Protective Material and Hardware - Durability

According to OSHA Standard 1910.147(c)(5)(ii)(A) - The Lockout Tagout devices must be DURABLE. The durability requirements are intended to ensure that the Lockout Tagout devices will not fail to perform their intended job. The LOTO Devices must be durable enough to resist the harsh environmental conditions - chemicals, abrasion and temperatures, to which they are exposed to for the expected period of time.

Tags and their means of attachment must be constructed and printed, so that the exposure to weather or other environmental conditions does not cause them to become unserviceable or the message on the Tag to become illegible. Using laminated Tags with reinforcing eyelets is generally adequate for the vast majority of work environment.

Tags so constructed, must also be durable enough to withstand the corrosive environment, especially the areas where acid and alkali chemicals are handled and stored.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-standard/

[oshalockouttagoutguide]

OSHA Lockout Tagout 1910.147(c): Protective Materials and Hardware

To perform service or maintenance safely and effectively under Lockout Tagout, employees must be provided with protective equipment, hardware and appliances for isolating, securing, or blocking of machines & equipment from their energy sources. Under paragraph (c)(5) of the OSHA Standard, it is the employers’ responsibility to provide necessary devices. Protective material and hardware that may be needed include locks, tags, cable ties, chains, breakers and valve lockouts, wedges, blocks, blinds, pins, fasteners and other hardware.

When launching a lockout tagout program, a survey of the workplace is needed, not only to identify the machines, equipment and processes that are covered by the program, but also to become familiar with the configuration of the equipment. When ordering the necessary hardware, the employer must also ensure that the hardware meets specific requirements for design & construction.

Under paragraph (c)(5)(ii) it states that the Lockout & Tagout devices should be singularly identified. Which means- the best suitable device should be placed on the isolating point and should not be used for any other purpose apart from Lockout Tagout on machines & equipment.

Section A-D of paragraph (c)(5)(ii) specifies certain requirements of lockout Tagout devices, i.e. The device must be durable, Standardized, Substantial and Identifiable.

In paragraph 1910.147(c)(5)(iii), OSHA requires that the major message printed on the tag “warn against hazardous condition of the equipment is re-energized. Five examples of acceptable warnings are provided, including Do Not Start. Do Not Open. Do Not Close. Do Not Energize. Do Not Operate. In all cases, employees must know and understand the meaning of the Tag.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

[oshalockouttagoutguide]

OSHA 1910.147(c)(4)(i) - Exceptions to Energy Control Procedures

Energy Control Procedures or Machine Specific Procedures need to be developed, documented & utilized always for full employee protection. If the total employee protection is obtained without ECP, then the need for developing ECP can be exempted. But all the essential elements required for complete safety of the employees have to be fulfilled.

The exemption is mostly for the simple equipment, when the Lockout device is under the exclusive control of the authorized employee, there is no potential for inadvertent release of stored or residual energy, and a single lockout device can achieve a locked-out condition. But in industries, even the complicated machines do not have the ECP. Many times when there are replicas of the same equipment, then the generic or common ECPs are used which leads to a lot of confusion & adequate energy control is not achieved, resulting in serious accidents.

So, ECPs are required for the isolation of hazardous energies & absence of ECP is the most common violation as per OSHA Standard 29 CFR 1910.147.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-explained/

[oshalockouttagoutguide]

OSHA 1910.147(c)(4) Energy Control Procedure

Most of the OSHA Violations are due to the unavailability of Energy Control Procedures (ECP) or Machine Specific Procedures (MSP) in organisations. Companies buy Local products, just to become LOTO compliant, but they do not know the correct procedure for safe isolation and control of Hazardous energies. Successful implementation of Energy Control Program requires an understanding and awareness of Hazardous energy types and magnitude, the methods, techniques, and devices used to control that energy.

To provide guidance to employees for putting the program into practice, written Energy Control Procedures should be developed. These procedures must define the purpose, scope, and application of the program, deploy the responsibilities of the managers, supervisors, and employees for implementing a systematic Lockout Tagout program.

A written Energy Control procedures (ECP) / Machine Specific procedures (MSP) needs to be developed, documented as it clearly and specifically outlines the steps to be followed, techniques to be used, and measures to be applied for the control of potentially Hazardous Energy.

This includes specific steps to shut down, isolate, block, secure, place, and remove lockout or tagout devices, and to determine the effectiveness of those devices by following verification steps.

The written ECP/MSP must have pictorial representation for isolation, installed images of LOTO devices that specifies procedural steps for the placement, removal and transfer of Lockout Devices or tagout devices.

Lack of compliance can lead to serious disciplinary actions. Industries need to mention the consequences in case of non-compliance of Lockout Tagout due to any reason, whatsoever.

Periodic inspections are mandatory to help ensure that the energy control procedures and the requirements of the standard are being followed.

Services of LOTO can be taken for developing ECPs/MSPs as they have vast industrial knowledge to prescribe the proper steps for the safe isolation by the correct use of Lockout Tagout.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-documentation/

[oshalockouttagoutguide]

OSHA Lockout Tagout: Full Employee Protection

OSHAs Lockout Tagout Standard does not prescribe the specifics of the energy control measures to be employed. Although, the standard lays down general procedures to be achieved, giving the employers flexibility in choosing the control procedures to be implemented, it focuses on achieving full employee protection.

Full Employee Protection:

As per OSHA Standard 1910.147(c)(3) - A lockout device should always be used when the machine’s energy isolating devices are capable of being locked out. But, there might be situations when, an isolating device is not capable of being locked out, a Tagout device is used alone in place of a Lockout device {1910.147(c)(3)(i)}.

In such a situation, it must provide a level of safety equivalent to that obtained by using a Lockout device, and the Tagout device must be attached at the same location, where the Lockout device would have been attached.

The employer must demonstrate full compliance with all Tagout related provisions of this standard. Additional protective measures, such as the removal of an isolating circuit element, blocking of a controlling switch, opening of an extra disconnecting device, or the removal of a valve handle to reduce the probability of inadvertent energization are needed to demonstrate that full employee protection has been achieved. Along with this, if an energy isolation device is not capable of being locked out, it must be redesigned or modified to accept the lock whenever major replacement, repair, renovation or modification of the machine is performed. The main motive is to achieve Full Employee Protection always. Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-standard/

[oshalockouttagoutguide]

OSHA 1910.147 (c)(2) General - Lockout Tagout

The OSHA Standard, 1910.147 (c) set forth nine general principles which provide the framework for ensuring the safety of personnel who maintain the machines.

OSHA Standard 1910.147(c)(2) emphasizes on the importance of Full Employee protection by Lockout Tagout.

Generally, the isolation devices should be capable of being locked out in majority of circumstances. But, there can be incidences where a Tagout device is used instead. A Tagout device, without a Lockout, may be used only when energy isolating device, is not capable of being locked out, or when the employer demonstrates that use of the tagout system alone, is substantial enough to be used in place, where the Lockout device is not applicable. It must provide a level of safety equivalent to that obtained by using a Lockout device, and the Tagout device must be attached at the same location, where the Lockout device would have been attached.

In such a situation, it solely becomes the responsibility of the employer to provide ‘full employee protection.’

After January 2, 1990 according to the standard 1910.147 (c)(2)(iii), it has become mandatory for the manufacturers, that in case of modification of machines and equipments, whenever replacement, major repair or installation of new machines are done, the energy isolating devices for such machines or equipment shall be designed to accept a lockout device.

Check OSHA Guidelines - https://www.safetylock.net/learn-lockout-tagout/osha-29-cfr-1910-147-explained/