I almost died applying OSHA's standards. The time for reflection and change is now.
Occasionally, I have the opportunity to cover job sites for folks taking time away from their full-time assignment. I enjoy these chances to get out of the office and into the field. I feel it is vital to keep a pulse of how processes are being applied in practical application and most importantly, discuss/learn about common-sense practices from field personnel.
Understanding life as a safety professional assigned full-time to a project, I am aware the majority of attention is focused on the immediate needs of the project: the challenge of the day, chasing down corrective actions, planning the next high-risk activity, running an extra orientation, following up on a request or question, or completing a performance report. These urgent matters deserve the immediate and focused attention of a safety professional, and rightfully so, but this comes at a cost.
Over time, I have learned the focus on immediate needs of daily operations results in areas of the project potentially being neglected. In most cases, I have found these to be long-term fixed defenses (i.e. barriers, perimeter fencing, guardrail systems, temporary walls, signage). Areas that are frequently viewed and passed often become part of the scenery and can be taken for granted. When on a short-term assignment for coverage, I try to supplement these areas by walking the perimeter fencing, walking areas not frequently traveled, and checking the integrity of guardrail systems.
On this particular day, I was covering a seven-story, 117,000 square foot building. With over 200 trade personnel onsite, the project was at peak man-power and was very busy. On my morning walk, I focused on getting acclimated with the project, personnel and activities by traveling from the basement to the roof and back down, observing the activity on each floor.
After the walk, I stopped into the office to touch base with the project team. We exchanged pleasantries and discussed the day’s operational activities. In the discussion, guardrails were mentioned as they were being removed and/or relocated in some areas. This raised the question as to the last time the guardrail system had been inspected in all areas of the building. The team was not sure of the most recent inspection and agreed to allow me to assist.
The project has a cable guardrail system in place protecting the exterior leading edge on floors 2-7. My strategy was simple, start on 2nd floor, inspect all exterior guardrails, move on to the above floor, and repeat until I reached the 7th floor.
Before I continue, here’s a little OSHA 101 refresher on the inspection of guardrails:
Inspection of the cable guardrails per OSHA 1926 is to ensure the “cables are capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied in a downward or outward direction within 2 inches (5 cm) of the top edge, at any point along the top rail". Simply put, push on the cable downward and also, outward with an ideal force of 200 pounds.
I inspected the cable guardrail systems by means of visual and physical inspection. Visual inspection consisted of attempting to identify damage and maintenance needs. The physical inspection was completed by pushing downward and outward on every section, as it is suggested by the OSHA standard.
I had worked my way throughout floors 2, 3 and 4 of the building with all cable guardrails passing visual and physical inspections, per OSHA. The 5th floor is where things took a distinct turn.
Coming up the north stairwell to the 5th floor, I identified cable guardrail on the northwest corner of the building and began the exterior cable guardrail inspection. At the corner, the cable secured by two stations approximately 10 feet apart. The visual inspection revealed the cable to be in good operational condition and did not have any slack between the vertical stanchions.
I reached for the cable to apply the “200 pounds of force in a downward and outward” manner, but by chance, on this cable pulled inward first. As I pulled, I found myself falling backward with cable in-hand and eventually landed, back to the ground, on the floor. The cable failed to hold any weight.
I picked myself off of the floor confused and in disbelief, with two questions in my head:
I. How did the cable fail in such dramatic fashion?
I investigated immediately, and the results are a case study in itself. Discussions with project personnel quickly revealed a carpenter had recently conducted maintenance activities on the cable guardrail on the northwest corner of the 5th floor. In the middle of the maintenance activity, the carpenter was requested in a different location for an immediate need. Rather than fully completing the cable guardrail maintenance activity to meet expectations (fixing cable in place with three cable saddles), the cable was secured with one hand-tight cable saddle. Multiple causal factors, including competency issues, task prioritization, man-power, amongst others were identified and corresponding corrective actions were implemented by project personnel.
II. What if I would have not pulled inward first and instead followed OSHA’s sole direction to apply “a force of at least 200 pounds applied in a downward or outward direction”?
If I would have followed OSHA’s guidance for inspection, I would have fallen forward off of the 5th floor. Best case scenario, I would have received life-altering injuries, but likely would have not survived the fall. I got lucky.
We cannot accept luck as a determining factor of success. We must learn. We must evolve. We must take advantage of every opportunity to improve. This is our responsibility. This is one of those times.
I call on OSHA to not only adjust language to facilitate safe application of this particular standard, but also, evaluate the language they provide in the standards to ensure we are not unintentionally being led into harm’s way. If you are aware of a gap in standard application, you have a responsibility to speak up and relentlessly pursue improvement.
Whatever operational activities you happen to support, please do your best to protect everyone by raising awareness of this story. Please ensure your teams are aware and not in danger working around guardrails. Take the time to ensure competency levels are aligned amongst new apprentices, seasoned journeymen, safety professionals, project managers, field supervisions and guests to your projects.
The time to make a difference is now.