Making a list – And checking it twice

OSHA knows who’s been naughty and who’s been nice (and safe).  The Deputy Director for OSHA’s Directorate of Environmental Programs, Patrick Kapust, provided the new list of the top 10 violations for fiscal year 2011 (October 1, 2010 to September 30, 2011).  The list includes a mix of general industry and construction standards:

The following items may have been a violation at work sites other than in the performing arts, however, take a moment to reflect on each of these and ask yourself (and your crew) – “Have we been doing this, too?”

  1. Fall protection in construction (1926.501): 7,139 violations; the Bureau of Labor Statistics (BLS) says 260 workers died in fiscal year 2010 due to violations of this standard.
  • In the theatre this is applicable to temporary and permanent catwalks and elevated platforms having proper floors, kick-plates, and railings.
  • In the theatre this applies to work situations that may require body harnesses, fall restraint lanyards, fall arrest lanyards, and other working at height precautions.
  1. Scaffolding in construction (1926.451): 7,069 violations; BLS says in FY 2010, 37 workers died because of incidents involving faulty scaffolding.
  • In the theatre this is applicable to temporary structures that may be used for erecting scenic elements, painting, aiming lights, rigging, or even used as scenic elements.
  1. Hazard communication (1910.1200): 6,538 violations; Kapust says in one fatal incident involving hazard communication, an employee lit a lighter to see the level of material inside a barrel, and the substance ignited.  Proper labeling should have indicated how full the barrel was and that the material inside was combustible.
  • What is in our paint cabinet?  Cleaning materials closet?  Or other chemical and/or gas storage areas?
  1. Respiratory protection (1910.134): 3,944 violations; five million workers in the U.S. are covered under this standard and are required to wear respirators at their jobs.
  • This number probably doesn’t include all the folks working in costume and prop shops and backstage in the theatre.  Respiratory protection is needed for both dusts and gaseous effluents from caustic chemicals.  If you don’t know how to fit a respirator, or what kind of respirator or dust mask is needed, then don’t do the work.  Dust and chemicals can clog your airways and damage the tissues permanently, and sometimes fatally.
  1. Lock Out/ Tag Out (LOTO) (1910.147): 3,639 violations; the average days away from work for employees injured in incidents connected to this standard is 24.
  • LOTO procedures apply to many types of theatre equipment including electrical (lighting, motors, sound, computers, video), mechanical (spring loaded, counterweighted), pneumatic (air hoses), hydraulic (lift cylinders), and any other system that can release energy and injure someone.
  1. Electrical wiring methods (1910.305); 3,584 violations; employees affected by this standard range from engineers, electricians, and other professionals who work with electricity directly, to office workers and administrative staff who use any type of electrical equipment.
  • Jury-rigged extension cords, makeshift outlet boxes, loose cable clamps, abraded or broken wires and/or insulation, separated conduit joints, and the list goes on . . .
  1. Powered industrial trucks (1910.178); 3,432 violations; BLS says in FY 2010, there were 8,410 injuries connected to use of powered industrial trucks, such as forklifts.
  • For larger facilities that have fork lifts, golf carts, or other mobile equipment, one has to be careful to ensure that operators are trained and licensed where necessary.  Driving off of an open loading dock or the front of the stage into the orchestra pit can do enormous damage and can result in serious injuries.
  1. Ladders in construction (1926.1053): 3,244 violations; falls are consistently one of the top three causes of worker fatalities.
  • OSHA and NIOSH both have extensive information about ladder safety.  There are different regulations regarding fixed ladders attached to the building and portable ladders.  If you follow the rules there are actually very few tasks in the theatre that you can actually perform from a portable ladder – all the more reason to look into buying a portable man-lift.
  1. Electrical general requirements (1910.303): 2,863 violations; this standard seeks to prevent injuries and deaths from electric shock, fires and explosions.
  • Hooking into the Company Switch?  Pulling all the dimmers out of the dimmer rack?  Can you say “Arc Flash”?  Sure you can – after the skin heals.  If you work with electricity – learn about Arc Flash work procedures and protective equipment.  It may save more than just your eyebrows.
  1. Machine guarding (1910.212): 2,748 violations; this standard also covers anchoring of equipment.
  • Sticking your hand into moving machinery is easier done than said.  Drill presses, planers, saws, routers, hoists, orchestra pits lifts, and even counter-weighted rigging can have exposed parts that can snag, cut, shear, shred, or otherwise ruin your day.  Understand what guards are required on machinery and how to work around unguarded areas that can be hazardous.

Don’t be ‘That Guy’ – You know:  The one that they had to cart away in an ambulance.  OSHA violation or not, if it seems wrong, figure-out what the hazard may be and establish a procedure to or means to mitigate the problem.

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Tags: Fall, Hazard, Ladders, OSHA, Protection, Safety, dust, electrical, fork, lifts, More…respirator

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Comment by Kevin M Mitchell on January 30, 2012 at 8:45am

This is great -- look for Erich's input in an upcoming article on rigging I just completed for SD.

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