Working away from the plant requires a different set of safety rules than working at the plant.
By Gustavo A. Gonzalez
Most precast concrete plant employees spend their working days in and around the plant performing their daily activities and rarely venture out to perform work in the field. A select few, however, perform most of their work away from the plant, and they live under a separate set of safety guidelines.
There are many reasons a precast manufacturer may send its employees to perform work in the field. Among them are:
- Repair products at the job site
- Deliver and set underground products
- Erect prestressed structures
- Erect precast building panels
At the plant itself, OSHA Standard 29 CFR 1910, “Safety and Health Regulations for General Industry,” govern all the safety activities. Away from the plant, however, these regulations are superseded by 29 CFR 1926, “Safety and Health Regulations for Construction,” and 1910 no longer applies.
Repairing products at the job site
Field repairs by precast manufacturers can usually be avoided by applying and enforcing quality control procedures at the plant, which will eliminate the need to send employees out to work in unfamiliar and potentially unsafe environments. However, if repairs at the job site become necessary, they typically involve activities such as drilling missing inserts, relocating holes in the structure, installing missing components and cosmetic repair. The tools and equipment necessary to perform these repairs usually include drills, extension cords, generators, ladders and concrete saws.
Under the Construction standard, any extension cord either must be plugged into a GFCI (ground fault circuit interrupter) or have a GFCI on it, preferably installed at the plug end of the cord. Likewise some generators are required to have a GFCI receptacle on them.
Powder-actuated tools can be used only by operators trained in their use, and such training is usually provided at no cost by the manufacturer’s representatives. Further information in regards to the use of these tools can be found in Standard 1926.302(e).
If the work involves entering a buried manhole or vault, then the provisions of OSHA Confined Space Regulations must be strictly followed. These provisions can be found in Standard 1910. 146, “Permit-required confined spaces.” (Note: In November 2007, OSHA proposed new rules for Confined Spaces in construction, although there is no definitive date when or if they will take effect. This is one of the instances where OSHA references 1910 for construction settings.)
Working around or near traffic could involve the use of flaggers to direct vehicles as required. In 1926.201, “Signaling,” OSHA incorporates by reference Part VI of the Manual on Uniform Traffic Control Devices, which covers all the required material for flaggers and traffic control in general.
Delivering and setting products
Of all the plant personnel, the driver spends most of his day at customers’ job sites delivering and setting the manufactured product. In some instances, such as deliveries from flatbed trucks, it is the customer’s responsibility to unload the product. However, quite a few plants deliver product using boom trucks, which in most instances are also used to set manholes or vaults into the ground.
OSHA considers a boom truck a “truck crane,” and its operation is regulated by Standards 1910.180, “Crawler locomotive and truck cranes,” and 1926.550, “Cranes and derricks.” Standard 1926.251, “Rigging equipment for material handling,” would also apply in these circumstances.
Here are some basic safety rules to follow when operating booms trucks:
- Cranes are to be operated only by qualified and trained personnel.
- A designated competent person must inspect the crane and all crane controls before use.
- Be sure the crane is on a firm/stable surface and level.
- Fully extend outriggers.
- Watch for overhead electric power lines, and maintain at least a 10-foot safe working clearance from the lines.
- Inspect all rigging prior to use; do not wrap hoist lines around the load.
- Do not exceed the boom’s load chart capacity while making lifts.
- Raise the load a few inches, hold it, verify the capacity/balance and test the brake system before delivering the load.
- Do not move loads above workers.
- Be sure to follow signals and manufacturer’s instructions while operating cranes.
If the operations involve lifting precast members into place, you must comply with Standard 1926.704, “Requirements for precast concrete.” This standard specifies that lifting hardware must be capable of supporting at least five times the maximum intended load applied and that no employee shall be permitted under precast concrete members being lifted or tilted into position except those employees required for the erection of those members. Note that even if OSHA allows for erectors to be under the lifted members, all efforts should be made to eliminate the need to place workers in a potentially hazardous situation. For example, the use of tag lines would eliminate most of these problems.
Under OSHA directive number CPL 2-0.124, or the Multi-Employer Citation Policy, on multi-employer worksites, OSHA may cite more than one employer for a hazardous condition that violates an OSHA standard. For example, if the plant decides to hire multiple subcontractors, such as one company to set the product and another to do excavating, any violations of the Regulations by the subcontractors could also be cited to the contractor – in this case the plant. OSHA has very detailed procedures on how to apply the Multi-Employer Citation Policy. See OSHA’s Web site for details.
Erecting prestressed structures or wall panels
Some precast concrete plants perform a complete service by designing, producing, delivering and erecting the structure. These so-called “turnkey projects” involve many construction operations in the delivering and erecting stage of the project, some which may take weeks or months to complete.
During the erection stage, two areas of main concern are the operation of aerial lifts covered by Standard 1926.453 and fall protection covered by Standards 1926.500 to 503.
Fall protection in construction is somewhat different than in industry, and the supervisor at a construction site must become familiar with the regulations contained in 1926. Falls are the No. 1 killer in construction work, and they are also the most cited violation under 1926. During the assembly of prestressed or precast products such as walls, floor slabs and double tees, employees are exposed to fall hazards that are not encountered in regular plant operations but instead need to be addressed for each particular situation.
Under Standard 1926.501(b)(12), “Precast concrete erection,” OSHA states that “each employee engaged in the erection of precast concrete members (including but not limited to the erection of wall panels, columns, beams, and floor and roof “tees” and related operations such as grouting), who is 6 feet or more above lower levels shall be protected from falling by guardrail systems, safety net systems or personal fall arrest systems, unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.”
This regulation is also very specific about the type of training the employee must receive for fall hazards. Among the requirements are:
- The nature of fall hazards in the work area
- The correct procedures for erecting, maintaining, disassembling and inspecting the fall protection systems to be used
- The use and operation of fall protection systems
- The role of each employee in the safety monitoring system
- The role of employees in fall protection plans
- The standards contained in the subpart
If the work involves the use of scaffolds or aerial lifts, then 1926 Subpart L will apply. Only authorized employees are allowed to operate aerial lifts using the required fall protection equipment. As with any other piece of rolling equipment, aerial lifts must be inspected before each use.
Any work to be done inside trenches or excavations must be performed according to 1926 Subpart P. The main concerns in this area are delivery drivers going into the trench or hole in the ground to help set the product or to disconnect the lifting hardware; and employees entering the excavation to fix or repair products already set in place.
Some other points to consider at a remote site include:
- Location of the first aid kit
- Procedures to summon emergency services
- Lines of communications with the plant
- Proper storage of flammable materials in the trucks
- Never sending one employee only – send at least two
While most plants do a good job training their employees in all safety-related issues as they pertain to the plant, most overlook or do not recognize the fact that once outside the plant a different set of rules may apply, and they could be cited under those different rules. It is also important to emphasize that employers could be exposing their employees to hazardous conditions that the employees may not be able to identify because they lack the proper training on the subject.
Recent state laws enacted in Massachusetts, Rhode Island, Connecticut, New Hampshire and New York require 10-hour construction training for workers on various-sized publicly funded projects. Other states may follow this trend.
Whether precast plant employees head out into the field for repairs, deliveries or installations, they become subject to the rules of safety for the construction industry, and they leave the customary general industry safety rules behind at the plant.
SIDEBAR: Canadian Provinces Issue Safety Codes
In Canada, the federal government is responsible for the health and safety of its own employees and federal corporations, which comprises about 10 percent of the Canadian workforce. The remaining 90 percent of Canadian workers fall under the legislation of the province or territory in which they work.
Each province – from British Columbia to Quebec – produces its own industry safety code. For example, Alberta’s “Occupational Health and Safety Code 2006” is the current rule for that province. Canadian provinces issue safety codes that are generally consistent with OSHA in intent, but there are distinct differences. For example, under Part 9, Fall Protection of the Alberta code, Section 143 requires “employers to prepare a fall protection plan if a worker at a work site could fall 3 metres (9.8 feet) or more and is not protected by guardrails.” Three metres is in variance with OSHA’s 6-foot limit described under Standard 1926.501(b) (12).
In another instance, Section 68, Load Weight of the Alberta code does not indicate that lifting hardware should support at least “five times the intended load” as does OSHA’s Standard 1926.704. Rather, Section 68 says the person in charge of the lift “has ultimate responsibility at the lift site for the lift’s safe execution.”
Gustavo Gonzalez has 20 years of experience in the precast concrete industry and safety. He has a bachelor’s degree in Industrial Engineering Technology from Florida International University and is a former precast concrete plant manager. He is an instructor and Spanish translator for the National Precast Concrete Association and an OSHA Outreach Trainer.