Monthly Archives: February 2016

Up on the Roof

Did you know that falls from heights are one of the most common sources of injury and death? This goes for the workplace as well as the home environment. As an employer, you are required under OSHA’s general duty clause to provide and maintain a safe work environment. For example, when employees are on a flat roof of a finished structure, they must stay at least 6 feet from the roof edge unless there is a parapet that meets OSHA standards for height. If there is no conforming physical barrier at the roof edge, then employees must say at least six feet from the edge of the roof. Sometimes companies overlook employee safety outside of the manufacturing environment. So you should also consider the work environment for your maintenance personnel.

In the work environment, OSHA requires that fall protection is provided at elevations of four feet and higher in general industry, five foot and higher in the maritime industry and six feet and higher in the construction industry.

For more information see:

Although the need for fall protection may be apparent, you still should assess task hazards with a job hazard analysis (JHA) or similar assessment tool to better determine what type of fall protection is needed to protect workers.

Using the OSHA hierarchy, first remove the hazard if possible and/or re-design the task(s) so that employees are not exposed to the hazard. If this can’t be done or is not fully effective, then install engineering controls such as guard rails and other features to physically prevent a fall from one level to a lower level. When all else fails, then you may employ PPE (personal protective equipment) to protect the worker. Use a JHA to document your assessment determination; it becomes your reference point and proof of concept.

When managing a work environment with fall hazards, as applicable, be sure to incorporate these aspects:

  1. provide and maintain fall protection equipment;
  2. engineer, install and/or maintain fall protection devices such as railings;
  3. train employee on the use and care of fall protection PPE;
  4. use approved designated and/or engineered fall protection attachment points;
  5. inspect fall protection PPE;
  6. remove damaged fall protection equipment and/or PPE from service;
  7. properly manage and document fall protection equipment put into service;
  8. properly wear and adjust fall protection PPE;
  9. maintain 100 percent tie-off when using fall protection PPE;
  10. wear fall protection PPE while in boom lift baskets and other aerial work platforms.

This list is not intended to be all inclusive. As an employer, the onus is on you to provide a safe and health workplace for your employees.

From our experience, while violations occur across industries, residential and commercial construction are typically problematic.

EHS Program Checklist

Here are a few things to remember about maintain a functional and applicable environmental, health and safety program:

  1. Be sure that you have a written program with documented procedures;
  2. Avoid generic language when it should be specific to your circumstances;
  3. Keep it brief and to the point;
  4. Periodically review and update your program elements with an eye on improvement;
  5. Ensure that your EHS program elements stay current. Be aware of internal and external changes such as roll-out of new equipment and/or process and/or changes to regulatory requirements and make program modifications as necessary
  6. Incorporate your program elements into your employee awareness and training program. A great written plan that is not understood or applied is pretty useless. Likewise your plan elements should exist as living documents that are a ready reference and resource.

 Of course, this is what we do; prepare, revise, implement and improve EHS programs. Ask us how we can assist.


In 2015, OSHA indicated that the Final Rule for the Occupational Exposure to Crystalline Silica would be published in February 2016. The silica rule will likely be enforceable within 90 to 180 days after it becomes final. Employers are encouraged to start planning now for the possible changes that could occur–especially for the exposure monitoring, engineering and administrative controls, and medical surveillance components. Potentially affected business sectors include those in the construction industry especially. Looking ahead, here are some aspects that are expected for the new Rule:

Exposure Monitoring and Assessment – Employers must provide periodic exposure monitoring of employees who are or may reasonably be expected to be exposed to respirable crystalline silica at or above the Action Level of 25µg/m³ if the initial monitoring indicates that employee exposures are at or above the Action Level and if the initial monitoring indicates that employee exposures are above the PEL   (permissible exposure limit).

 Regulated Areas or Access Control Plan –  Establish and implement either a regulated area(s) or an access control plan whenever an employee’s exposure to respirable crystalline silica is, or can reasonably be expected to be, in excess of the PEL.

Engineering and Administrative Controls – Establish and implement controls such as local exhaust ventilation and wet cutting whenever feasible, for reducing exposures to crystalline silica before implementing respiratory protection.

Protective Work Clothing and Respiratory Protection – Provide appropriate protective clothing such as coveralls or similar full-bodied clothing or a means to remove excessive silica dust from contaminated clothing if there is a potential for employee work clothing to become grossly contaminated with crystalline silica. Provide respiratory protection when employees may be exposed to silica about the PEL or during periods when the employee is in a regulated area. Note that before employing respiratory protection PPE, you must first assess the feasibility of engineering and administrativecontrols first and use these preferred means to protect employee health. If and only if after those control methods prove to be either partially or completely ineffective can the employer institute a PPE program.

Medical Surveillance –  Employers must provide medical surveillance at no cost for each employee who will be occupationally exposed to respirable crystalline silica above the PEL for 30 or more days per year. Medical surveillance includes a medical examination within 30 days after initial assignment and periodic medical examinations at least every three years or more.

Hazard Communication and Training – Communicate and train employees on respirable crystalline silica hazards under the Hazard Communication Standard, 29 C.F.R. § 1910.1200, and ensure that each employee has access to labels on containers of crystalline silica and safety data sheets.


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