cal-osha and fumigation even some osha & general pest pest control operators of california the...

Cal-OSHA and FumigationEven

Some OSHA & General Pest

Pest Control Operators of California

The Peacock Group Inc. www.pcocinsurance.com

Copyright 2002 Pest Control Operators of California Inc.

Fumigation & Cal/OSHA Exposure to employee of heights

of 4.5 feet or higher must be covered under a fall protection plan.

Additional Standards above 6 feet Fumigators in non-compliance Two recent incidents in San Diego One recent incident in San Jose And a 1998 Fumigation Death

have caused Cal/OSHA to re-examine fumigators.


Incidents which triggered Cal/OSHA Investigation

First San Diego Incident: October 2001 – San Diego fumigator carrying a tarp up

a ladder on a single story house. As he steps off the ladder he slips and falls to the ground breaking his neck: Many violations possible, but the two big issues are: Fall Protection Ladder Use (still a fall protection issue)


2nd San Diego Incident December 2001 – San Diego fumigator is

electrocuted when the aerial he is taking down hits a power line. Many violations possible, clearly the accident itself is reason for worry and something we all should be concerned with when lowering an aerial. But the concern Cal/OSHA brought to my attention from this incident as it relates to the industry as a whole are: Fall Protection Ladder Use (still a fall protection issue)


San Jose Incident

January 2002 – San Jose fumigator falls from roof breaking his back. Fumigator beginning to get some movement into his legs. Employer still awaiting the official Cal-OSHA investigation; they told him they would perform a “surprise” inspection and investigation “sometime in March”. We anticipate them making an issue of: Fall Protection Ladder Use (still a fall protection issue)


1998 Fumigation fall death

assessment


Fall Protection Recommendations:

Recommendation #1

Fumigation employers should provide fall protection for employees who work at heights

Acknowledges that fall protection for our industry is difficult, but still necessary

“Must engineer or have fall protection engineered to meet requirements of the American National Standards Institute, Inc.,(ANSI) and Cal/OSHA.

Continued on next slide


Recommendation #1 Continued

If fall protection in not feasible, then an alternative method must be used to

protect the employee. For example:

A. Aerial lifts, meetings regulations for lifting a person or persons could be used to access the tarps at or near the leading edge of roofs.

B. Safety harnesses and lanyards may be used if they can be attached at an approved anchor point.



Recommendation #2

Employers should employ external lighting when working after dark.

With no lighting and dark colored tarps, it most likely would have been difficult for the decedent to discern the edge of the roof. Proper portable lighting for employees may have prevented this incident.



Recommendation #3

Employers should ensure employees do not approach a roof edge so closely that it places them in danger of falling off

Tarps do not provide safe footing Folds in tarps can provide tripping hazard Without fall protection “this is a very dangerous

task”



Recommendation #4Employers should develop a written procedure

which covers the manner in which tarp laying should be performed

The employer failed to provide written instructions describing the tarp laying procedure to employees. Such instructions would normally contain safety precautions such as not walking too close to roof edges, use of ladders and fall protection, etc. When the tarps have been laid, the roof edge becomes less distinct because it is hidden by the tarp. In such cases, it is especially important to adhere to those safety precautions that address falling. If such instructions were provided, and followed, this fatality may not

have happened.


Fall Hazard Issues: OSHA mandates fall protection for

employees. It is pretty clear that one way or another, fumigators fall under these standards.

Most Common OSHA solutions to our height hazards: Scaffolding Fall protection systems with harnesses.

Industry Response: Cost are Prohibitive OSHA Response:

expense is NEVER an acceptable reason not to implement systems to protect worker health & safety.

Costs should be simply passed along to the consumer


The Oregon Negotiated Solution Professionally

installed, or industry (fumigator) installed OSHA approved Anchor Points, and connecting wires and…


Oregon Agreement Continued

Employee Harnesses and full OSHA fall protection plan …..

Not mandated (from what I saw in writing) but probably a necessary are Self-Retracting life lines as pictured on the left.


Horizontal Lifeline anchored to ends of ridgeline


Sloped Roof Fall Arrest System

Anchored at ridgeline and near roof edge


Practical Sloped Roof Fall Arrest Systems:

Kits for compliance are readily available: the one pictured sells on the web for less than $200.00

c


Fall Protection Continued

Probably the most difficult part of this system to set up and be addressed is the restriction of movement as to prevent the employee from falling off or from hitting the ground should he fall. This limitation will restrict the ability of the

fumigator to move about

the rooftop.


Additional Possible Solution for Working near Edges

Portable Tie-offs Scaffolds


Ladder Use

Issues of maximum weight on ladder

Both hands must be used for climbing or working from ladder

Can’t carry anything which might interfere with climbing ladder


Ladders: Weight Rating

Most ladders come in 200, 225, 250, and 300 pound ratings.

Even using the 300 pound rating ladder it is still easy to exceed the weight rating when you combine the weight of the fumigator 160-190 pounds average with the weight of the tarp 90-150 pounds.

Many fumigators have lower weight rated ladders in service.


Ladders: Carrying Items

Cal/OSHA Code says we can not have anything in our hands which will interfere with climbing the ladder.

Basic rule both hands need to be free when climbing ladder

Working from ladder as shown on the left is an OSHA no-no.

In Hawaii – fumigators specifically must use “lifts” to carry tarps up to the rooftop.


In Hawaii: OSHA has said specifically that Ladder Lifts or something similar

are to carry tarps up to roof: Other lifts have

been used as well, but this general design (several manufacturers) seems most practical if we are to comply with the law


Hand crank & more power Lifts


Securing LaddersWorking From Ladders

Ladders need to be secured both at the bottom and top to ensure it does not slip

Industry has discussed “tying off” workers to ladders to ensure safety, and allow the workers to clip seams from ladders. This is a great idea, but we will have to properly secure the ladders so they will support the worker should they fall: In a June 4, 1991 Interpretation letter of Section 1910 makes it clear that industry must demonstrate how and that the ladder will stay in place if a tied off worker were to fall.


PCOC Working with OSHA

We are tracking these situations to see what fines and violations are issued

Provided Cal-OSHA with the Height and Ladder safety programs which are part of the larger PCOC Fumigation Safety Package.


PCOC Exploring Options: Seek Variance: - normally only done by

individual companies, not industries. Develop Plan for how we might fit into the

current regulatory structure. We will write up a compliance plan for the

industry We may write and as for “interpretations” to

clarify existing law to see if our creative compliance ideas really do fit into the law.

Seek Regulatory Changes so that we have our own set of law which applies to us.

Learning More from Hawaii Representatives from the PCOC Fumigation

Committee along with Northern & Southern California Subcontract fumigators groups: meeting to develop strategy & address these issues.


Current Plan: Develop an OSHA Compliant Protocol

Work under Roofing Rules Ladders Secured at top & bottom Lifts for tarps Personal Fall Protection Plan and

equipment for structures with any portion of the roof over 21 feet.

Currently testing equipment


Pest Control Technician Dies in 100 Foot Fall from Roof in Massachusetts

On August 13, 1997, a 25 year old male pest control technician died when he fell from the roof of an apartment building. The technician was spraying for spiders in the vents and other parts of the roof when the incident occurred. While spraying along a gutter of a roof-top penthouse, the technician walked off the edge of the roof and fell nine stories to the parking lot below.

The victim was a 25 year old male pest control technician. He was employed by the company for approximately seven months and was at the jobsite for less than an hour at the time of the incident. He had formal training in college in integrated pest management prior to joining the company.


OSHA Fatality Assessment & Control Evaluation of Tech Death: Recommendation #1: Employers should develop

and implement a site specific health and safety plan for each site under contract.

Recommendation #2: Employers should employ alternative controls for fall hazards when personal fall arrest systems are not required or appropriate.

Recommendation #3: Building owners should consider the installation of guardrails at the perimeter of flat roofs wherever possible.


Fumigation Risk Management : From 1996 through 1999 the PCOC

Safety Committee worked with the PCOC Termite Committee to develop a semi-comprehensive “Fumigation Risk Management” package for PCOC members.

Adopted June 19, 1999 by the PCOC Board of Directors as a “recommendation to PCOC member companies”

It was developed to address these issues by the fumigation industry insisted that the “standards” and issues addressed in this book do not go beyond what was their current practices.


Fumigation Risk Management Package

1. Cal-OSHA General Standards as edited for the Fumigation Industry

2. Fumigation Ladder Safety

3. Fumigation Lifting Safety

4. Fumigation Hazard of Heights

5. Fumigation General Hazards & Ground Crew

6. Fumigation Rain & Wind Hazards

contains the following core documents:


Additionally the Package contains: Written Injury & Illness Prevention

Program Outline SCBA Training Bi-annual Defensive Drivers

Training (OSHA & DOT Mandated) Bi-annual HM 181 & 126f Training

DOT Mandated Random Drug & Alcohol Testing information

Pesticide Safety Training Hazard Communication Training


Bonus Safety Meetingsalso included

1. Defensive Driving Tips & Quiz2. What to do in Case of a Traffic

Accident3. Vehicle Code & Safety Quiz4. How to Properly Sit in Your

Vehicle5. Safety at Work and Home:

Children's Safety Seats 6. Physical Laws of Driving7. Driving in the Dark 8. Defensive Driving Quiz9. Driving & Car Phones10. Seat Belts11. Speeding12. 1997 CHP Fatal and Injury Traffic

Collision Statistics13. 1997 CHP Quick Collision Facts14. CHP & OTS Winter Driving Fact &

Tip Sheet15. Fumigation & Auto Sensor Lights16. Fumigator Back Injuries17. Hidden Hazards 18. Water & Rain Hazards19. Preventing Back Injuries

20. WORKER RIGHT TO KNOW/ HAZARD COMMUNICATION

21. COMPRESSED GAS CYLINDERS

22. DOT HAZMAT RULES REVIEW

23. ACCIDENT$ CO$T YOU MONEY

24. ANIMAL BITES A FORGOTTEN HAZARD

25. Falls Are Not Funny26. Safe Use of Ladders for

PCOs - Review27. The Dangerous Four28. Erection and Use of

Ladders29. Falling Objects30. Falls31. Guardrails32. Hazards of Falls 33. Ladder Safety 34. Slips Trips & Falls 35. Safe Scaffolding 36. Ladder Accident Analysis

& Prevention


More Safety Resources from the Peacock Group – PCOC

Insurance Program

www.pcoc.orgwww.peacockgroup.org

www.pcocinsurance.com

cal-osha and fumigation even some osha & general pest pest control operators of california the...

Documents

fall protection issue

slide slide

fall protection plan

protection ladder use

san diego fumigator

san jose incident

san jose fumigator

nd san diego incident