Guest Column | September 2, 2014

Occupational Safety And Utility Compliance: The Top 5 Fall Protection Hazards Overlooked By Utilities

Sheldon Primus

By Sheldon Primus

Fall hazards are the number one killers in the construction field according to the Occupational Safety & Health Administration (OSHA). In 2010, fatalities from falls to lower levels was 255 out of 264 recorded fall deaths ( However, other industries and sectors are also affected by fall hazard in day to day task. Utilities have several exposure points for fall hazards. This article will only highlight the top 5 fall protection hazards overlooked by utilities and way to mitigate this hazard.

  1. Ladder Safety

In the Occupational Safety and Health Administration (OSHA) general industry standard of 1910, there is no specific wording on fall protection for working on a metal ladder (29 CFR 1910.26), which becomes the working surface. Utilities have various needs for using a ladder throughout the plant and in the field. Twenty-foot step ladders are sometimes used to change light bulbs or gain access to other areas of the plant.

Ladder use and care are very important to prevent fall hazards from occurring at the utility. It is common for the utility staff routinely do limp cutting, put up shutters on upper levels, and travel up and down ladders for tank entries and roof access. These tips will keep the workers safe and help with state OSHA compliance:

  • Read the manufacturer’s recommendations on the ladder care and use.
  • Remove broken ladders from service.
  • Instruct workers on the proper use of ladders.
  • Be aware of the ladder duty and weight guidelines.
  1. Scaffolding and Articulated Boom Truck

Falls from scaffolding and articulated booms can be fatal, due to the heights related to the nature of the work. Many operators have to use scaffolding for accessing elevated work surfaces of the plant for maintenance work and some construction. As a point of clarification, there must be an understanding of what is classified as construction and what is classified as maintenance. OSHA, in a 2003 letter of interpretation, explains construction under these considerations:

  • Consider the physical condition of the equipment/structure being worked on by the worker. Does this item need to be removed completely?
  • Was the replacement material for prevention of a state of failure or to supplant deteriorated sections?
  • What are the physical characteristics (height, weight, width, and material) of the equipment or structure?
  • Is work being performed by a contractor other than employees?
  • Is this work done during an annual scheduling?

Maintenance is described in a 1999 letter of interpretation as:

  • Efforts to keep equipment or structures in proper condition through “routine, scheduled, or anticipated measure without having to significantly alter the structure or equipment in the process (OSHA, 1999).”

If the nature of the job is construction, then the utility should follow the 29 CFR 1926. 450 (Subpart L) rules and guidance on Scaffolding and 1926.500 (Subpart M) Fall Protection.  If the task is deemed to be maintenance, then follow the 29 CFR 1910.28-.29 requirements for scaffolding.

Tips for compliance and hazard mitigation are:

  • Have the scaffolding constructed and broken down by a competent person.
  • Inspect the elements of the scaffold and articulated boom for any damage.
  • Instruct workers to stay within the rails of the protective system.
  • Use fall arrest systems when appropriate and “tie off” on the approved anchor points per the manufacturer’s recommendation.
  1. Floor Holes

Floor openings are all over treatment plants and collection/distribution systems. Anything that is 12” or more is considered a floor opening under 29 CFR 1910.21 and works must be protected from falling to a lower level. Many places in the treatment plant have hydrogen sulfide and other gases that are corrosive in nature. Workers must walk on grates, covers, and lids often in their day to day duties. If any of the brackets or track that hold the covers are compromised, then the worker can sustain injuries. Here are some steps to protect from floor opening hazards.

  • Put checks of the floor opening on the checklists used in daily operations. The worker should be checking the integrity of the cover, tracks, and any hardware.
  • Replace corroding hardware with stainless steel or other hard to corrode hardware.
  • Use agents that will reduce sulfides in lift stations where at all possible.
  • Use engineering controls to protect workers from exposures during entries or maintenance to the covered structure.
  1. Tank Maintenance

Clarifier, digester, and holding tank cleanings are always a challenge for the operator, due to the heights and being over water. In some cases, the work area has not been engineered for proper cleaning at every location of the tank. Therefore, the worker has to adapt to the work environment in order to get the work accomplished. In the above picture, the worker is prepared for the event that he may fall into the tank, by wearing a life preserver. However, if he loses his balance and were to fall backwards he would suffer injury from the fall. Employers have a duty to protect their workers from known hazards and to provide a safe work condition under the Occupational Safety and Health Act General Duty Clause 5(a)(1). The workers can be protected by the following steps:

  • Perform a Job Hazard Analysis prior to performing the work.
    • List the step of the task one by one
    • Identify the hazards related to each step
    • Identify a control (Engineering, Administrative, and/or PPE) for each step listed
  • Engineer a walkway with a railing system as a capital budget item issue when possible.
  • Provide a fall protection system.
    • Safety Net
    • Fall Arrest System
    • Fall restraint system
  1. Vehicles

Falls from vehicles and heavy equipment is also a concern for the utility sector. In order to maintain or check critical components on an elevated vehicle, the workers are exposed to a fall hazard. Even short checks on the top of a tanker, truck, or trailer can prove to be a major hazard with debilitating consequences. Again, it’s up to the employer to provide a workplace free of known or suspected hazards in the work environment. Here are some tips to keeping the workers safe from falls off of vehicles:

  • Use a portable anchoring system with a retractable lifeline.
  • Use a platform to access the truck top.
  • Wear the proper foot PPE to protect from slippery walking surfaces.

In conclusion, each treatment plant has several fall hazards present, but though the hazard exists, the worker can be protected by reduced exposure, engineering, administrative, or PPE controls. It is up to the utility to provide a work environment free from any known or suspected hazard.