OSHA gets a “D”

Grade of a D

Recently, another safety trainer and I were discussing ladders and how many people teach “3-points of contact“. This is a great rule to teach, but I pointed out that it is not an OSHA rule! The other trainer contested saying that it was, but then I took him into the the construction standards (the bare minimum) and explained that OSHA gets a “D”.

That’s what OSHA puts out: The bare minimum that a company must comply with in order to maintain the safety and health of their employees. I learned that phrase “OSHA gets a ‘D’” from another trainer. It is such a great way to emphasize that if a supervisor, owner or company is walking the line or not even complying with the OSHA standards (which are the bare minimum), then they are surely failing!

Let’s face it, a “D” in school is 6 out of 10 on a spelling test, or 60 out of a 100% on a math quiz. That’s barely passing. You don’t want to even share your grade. Imagine the conversation:

  • Your friend says, “So hey, what did you get on that test?”
  • You reply, “Ah, I passed.”

Yeah, you got a “D”. That stinks! You barely passed and in some places that doesn’t even cut it. So, as a broad way to look at the OSHA standards, they are barely cutting it. So -again- if you are pushing or trying to see if you barely comply with the OSHA standards, then you are most likely failing.

Let’s look at some examples of this.

  1. 3 Points of Contact:  This is a very safe practice (although actually it is often misunderstood and not taught correctly), but it is not an OSHA rule. It is misunderstood and improperly taught because some people teach or understand that you must maintain 3 points of contact at all times on a ladder. That is not what this safe practice is saying. Properly taught, 3 points of contact means that when moving up or down the ladder, you should strive to maintain 3 points of contact at all times. This makes it very difficult to carry large or heavy things and it makes it very difficult to fall. So, what does OSHA say? What OSHA says is just two lonely sentences: “Each employee shall use at least one hand to grasp the ladder when progressing up and/or down the ladder.” And secondly, “An employee shall not carry any object or load that could cause the employee to lose balance and fall.” I’m telling you, “OSHA gets a ‘D'”. Three points of contact is much better, but to be fair to OSHA, they have to draw a line in the sand with each regulation they make. And -by definition- they establish the minimum standard. These two sentences above are found in 1926.1053(b)(21) and (b)(22). in the construction regulations.
  2. Other examples of OSHA getting a “D” is with excavations. OSHA’s bare minimum standard in 1926.652(a)(1) states “Each employee in an excavation shall be protected from cave-ins by an adequate protective system … except when: … Excavations are less than 5 feet in depth and examination of the ground by a competent person provides no indication of a potential cave-in.”  Now, there is sooo much to this standard and I don’t want to dumb it down but, truthfully, so many people just quickly mention that you must have physical protection like a trench box when the excavation gets to 5 feet. (There is so much to this because if it is less than 5 feet a “competent person” must examine the excavation to see if there is any indication of a potential cave-in. That is sooo important.) But, I was on a job site where the safety guy said to about 5 men, “Hey, you need to put in that trench box because that trench is deeper than 5 feet.” The employees replied, “No, sir! Measure it. It ain’t 5 feet.” The results of various depth with the measuring tape were 4’10”, 4’9″, 4’11”, 4’6″, etc. So, no, technically, they didn’t “need” the trench box.

My point! Could you die from squatting down an laying pipe in a 4’9″ trench? ABSOLUTELY! Therefore, even though you were following the OSHA rules, you could still get seriously injured or die.

That is why recognizing that OSHA puts out the bare minimum standard and treating it as something you should surpass at every chance possible is always a safe or best practice. That is why we teach 3 points of contact, because it is the safest. But at the same time a good trainer must note what is the OSHA rule and what is company policy or best practice.

And I will close this article by saying that many times the OSHA standards do draw the line with a large safety factor or a “very safe” rule. An example is the rule of 5000 lbs per worker on the anchorage point for fall protection. This doesn’t seem like a “D” to me. But generally speaking, I like to explain that the OSHA rules are the bare minimum standard by teaching people to think of them as if it were a grade of a “D” in school.

Until next time,

Steve!

Spanish OSHA Guy!

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