Safety Sense-Stepping out safely.
August 1, 2007
Recently, there was a discussion on www.rpls.com about safety shoes. The conversation covered all aspects of footwear and several other areas of safety. Since I wasn’t able to participate in the online discussion at the time, in this column I will answer a few of the questions posed and hopefully clear up some misconceptions.
One poster started off a thread by asking, “Is it mandatory to wear safety shoes in the field, or is it company by company policy?” That is a loaded question. The first thing that must be done is a hazard analysis. What are the field crewmembers doing on a particular day? Are they in a wide-open field? Climbing a mountain? Walking along the edge of a seashore? Working on a large commercial construction site? All of these situations may have specific requirements for footwear. Tennis shoes may be perfectly acceptable along the seashore, but appropriate work boots most likely need to be worn on a construction site. When climbing a mountain you may need specific shoes made just for that purpose, while in a wide-open field you would need to know the exact conditions of the field to determine the type of footwear needed.
Even if your situation isn’t covered by any specific portion of OSHA’s Personal Protective Equipment (PPE) standards, there is a General Duty Clause that fills in the gaps. Section 5a1 of the Occupational Safety and Health Act of 1970 states that each employer “shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” That means if a hazard is predictable, then the employer is required to protect employees from that hazard. Protective footwear covers a lot more types of footwear than just “steel-toed work boots.” There may be a need to protect metatarsals (the long bones in the midfoot), soles and arches, or ankles and legs. You may need a boot that is waterproof, chemical resistant, or has heavily caulked soles for walking in mud and snow. I always recommend to our customers that field crews wear a good work boot with toe protection and a rise of 6" to 8". The rise helps prevent those sprained and broken ankles that I see so often when reviewing injury reports. Your flip-flops may be the most appropriate footwear if you are walking along the seashore, but I wouldn’t advise wearing them on a construction site.
Another poster brought up wearing hardhats backward. In response, one poster told an anecdote of how he once asked a safety guy on a construction project to cite the code that said they couldn’t wear a hardhat backward. The safety guy couldn’t cite the code so they kept wearing them backward and still do so today. Actually, OSHA says that hardhats must meet ANSI Z89.1-1986 if they were purchased after July 5, 1986. While OSHA itself doesn’t have a regulation against wearing a hardhat backward, ANSI standards require the hardhats to be tested “as worn” by the worker. Therefore, if the hardhat was tested while worn in the brim front position, that is the way it must be worn.
However, there are now some manufacturers who have tested at least some of their hardhats in the reverse position--and they can now be worn in reverse without any repercussions from OSHA. Check out manufacturers on the Web and you will find some of them list the fact that they have been tested in reverse in the specification data. Surveyors rejoice! You can now legally wear that hardhat backward.
Note that it is very important to your field crews to follow OSHA’s regulations that state when a hardhat should be worn. (See the sidebar on page 53 for the general descriptions of situations that require a hardhat.) And there is one more time that OSHA can and will cite a company. If the project has a sign that says “Hardhats Required” or some similar verbiage, then OSHA can cite a company even if none of the listed requirements are present. OSHA has always allowed a “controlling employer” to set standards higher than OSHA requirements. If the general contractor on a project says that everyone should wear a hardhat, then OSHA can cite anyone not wearing a hardhat because they aren’t obeying the safety rules for that particular jobsite. So wear it forward or backward, but wear it when needed!
One poster said that you had to wear safety goggles on construction sites in the metro New York area. While I haven’t visited any construction sites there, I would just about bet that most of them have signs alerting all workers that hardhats and eye protection are required on the jobsite. As mentioned above, OSHA can cite a company according to the signage, but it’s important to consider working conditions other than a construction jobsite. What if your field crew is in the middle of a 200-acre field and there are no buildings or ongoing construction anywhere near their location? Would they need eye protection? Again, you need to look at the individual situation and make that determination. The sidebar lists one of the reasons for wearing eye protection as the hazard of “flying particles.” If you’re in the country when a two-month drought has dried out the ground and there is no grass and a strong wind, you had better be wearing something to protect your eyes. This is another item that I have seen in a number of accident reports for surveyors. Wearing dark safety glasses with side shields may prevent the employee from getting dust in his or her eyes. In severe cases, goggles may be needed.
I hope this has helped answer some of the posters’ questions and clarified just a bit of what safety equipment is required. If anyone has questions on surveying safety, feel free to contact POB and I will try to answer them in a future column. Time to put on the hardhat backward and go to work!
Visit www.RPLS.com for more safety discussions.
Sidebar: OSHA RegulationsProtective Footwear
1910.136 – “The employer shall ensure that each affected employee uses protective footwear when working in areas where there is a danger of foot injuries due to falling or rolling objects, or objects piercing the sole, and where such employee’s feet are exposed to electrical hazards.”
1910.135 – “The employer shall ensure that each affected employee wears a protective helmet when working in areas where there is a potential for injury to the head from falling objects.”
“The employer shall ensure that a protective helmet designed to reduce electrical shock hazard is worn by each such affected employee when near exposed electrical conductors which could contact the head.”
Eye and Face Protection
1910.133 – “The employer shall ensure that each affected employee uses appropriate eye or face protection when exposed to eye or face hazards from flying particles, molten metal, liquid chemicals, acids or caustic liquids, chemical gases or vapors, or potentially injurious light radiation.”
“The employer shall ensure that each affected employee uses eye protection that provides side protection when there is a hazard from flying objects. Detachable side protectors (e.g. clip-on or slide-on side shields) meeting the pertinent requirements of this section are acceptable.”
General Duty Clause
SECTION 5a1 - “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.”