b'SAFETY CULTURE AND THE ENTREPRENEUR OSHA UPDATEGarys CornerupdateGary Auman, MRCA Legal CounselT his is going to be a general safety issues month. I want to2.Always be aware of what is around them and what is cover some very important issues that impact your safetygoing on around them.program and performance. 3.Always give 100% attention to what they are doing.Hazard Recognition4.Always consider the task they are about to perform and This is a very important issue for all employers in thewhat exposures they might have while performing it.construction industry. No, I am not talking about Hazard5.Whenever they feel that they might be exposed to a Communication; that is a completely different topic. I am talkinghazard consult with their supervisor before proceeding.about the recognition of hazardous conditions on the worksite. We conduct new employee safety orientation of one kind orJob Safety Analysis (JSA)another. In this orientation we cover a variety of topics rangingThe Job Safety Analysis should be performed by the crew from fall protection to PPE to distracted driving. One topic mostleader or foreman every day before any employee enters the work employers miss in their orientation training is hazard recognition.area. The supervisor should take time before work begins to walk Hazard recognition is basically teaching situational awareness. Inthe entire job site, but especially the area in which work is to be other words pay attention to what you are doing, where you areperformed on that day. He should note any changes in the work and what is around you at all times. Evaluate every action you arearea that may have occurred between the time work was completed going to take before you take it to be sure that you are not going tothe day before and that morning walk around. He should note any be in danger. hazards that the crew may confront as they complete the tasks for For example, you are going to perform work on a low sloped roof with the available fall protection of warning lines and a safetyyou need to be sure they understand the monitor. Based on the OSHA standards this fall protection isrules and their obligations to complyin compliance with the OSHA standards for fall protection on low-sloped roofs. As your employees ascend to the work area on athe day. I always suggest that as soon as the crew arrives and before fall morning the first person on the roof may notice that it is verythey begin their work, the supervisor who did the JSA should go slippery with a heavy dew and patchy frost. He has just recognizedover his findings with them. He should also make sure that there a potential hazard in that an employee might slip on a patch ofis adequate PPE on site for any hazards identified and that any frost; slide under the warning line and off the edge of the roof. Heguards required are in place and functional.is aware of a new hazard, one that the warning line system mayYou cannot do enough training, but I do not consider the JSA not provide adequate protection. This is hazard recognition. Themorning briefing training. You are assisting your employees with employee should be trained to raise that issue to you and requesthazard recognition and you are training them in very important protection from this new hazard which was not contemplatedconcept. I have been seeing more and more citations, especially when the warning lines were installed. following an on the job accident, for failure to train employees in Another example is a situation in which your employeehazard recognition. The morning JSA performed by the crew leader will be exposed to a hazard, which is not a hazard under normalor foreman is intended to evaluate the worksite in light of the work operating conditions. For example, an employer is working in ato be performed that day and to acquaint all employees on the job manufacturing facility. There is an exhaust fan twenty feet up anwith the supervisors observations.outside wall. It is not a hazard to anyone because it is more thanPart of the JSA should have the supervisor performing it seven feet above the floor. But if your employee was given a job toconfirm the integrity of all working and walking surfaces his perform that he determines will bring him into close proximity toemployees will be using that day. As I have discussed before, there the fan, he should, if he was trained in hazard recognition, identifyis a section of the fall protection standards, Section 1926.501(a)the potential hazard and bring it to the attention of his supervisor. (2) that requires the employer to determine that all surfaces on Training employees in hazard recognition is required bywhich employees will walk or work have the structural integrity to 1926.21(b)(2). This standard requires you to train your employeessupport the weight of employees safely. The employer shall only in hazard recognition and avoidance. This standard is citedpermit employees on those surfaces that are able to support their frequently in case where the compliance officer is performing anweight safely. This is a requirement before the start of any shift investigation following an employee injury. A citation may beon the project and should also be done any time anything occurs issued alleging that if the employee had been properly trainedthat could, in any way, affect the integrity of a walking or working under this standard they would have identified the hazard and takesurface an employee will work on. I strongly recommend that a action to avoid exposure to it.written record of thee daily (at least) determination be maintained Coming full circle, the trainingfor hazard recognition is forfor the duration of the project. your employees to: We Have to Get Past Our Macho Mindset1.Always be aware of where they are. Within the past week something occurred to me that spurred 8 www.mrca.orgMidwest Roofer'