In January of 2012, the Safety and Health Department launched several new initiatives designed to increase safety performance and "target the deadly dozen hazardous activities that lead to fatalities and disabling injuries." The focus of this article is to highlight the common hazards during the decking process that historically, have produced the highest percentage of fatalities and disabling injuries. Incident trends and investigative reports clearly indicate the primary causation factors are stemming from the same common hazards and activities during leading edge and related decking operations.
The Importance of Training and Regulatory Requirements
Prior to performing the installation of floor and roof metal decking, apprentices and journeymen must be trained on the recognition and avoidance of common hazards during the installation process to prevent serious incidents. The Ironworkers National Training Fund has developed a comprehensive training module that utilizes job site footage, student manuals, and instructor PowerPoint photographs to illustrate common hazards, proper installation and work techniques. In many cases, incident reports have revealed the lack of instruction on specific hazards as a contributing factor. The OSHA Subpart R-Steel Erection standard requires special training for all ironworkers working within a Controlled Decking Zone (CDZ). The OSHA 1926.760(c)(3)(i) requires training on "the nature of the hazards associated with work within a controlled decking zone" and additionally, the OSHA 1926.761(c)(3)(ii) standard requires training on "the establishment, access, proper installation techniques and work practices." The Ironworkers National Training Fund training module pertaining to the installation of floor and roof decking was reviewed by the Occupational Safety and Health Administration (OSHA) to ensure compliance with the applicable Subpart R standards and was also approved for training OSHA compliance personnel throughout the country.
Preventing Fall Hazards from Lack of Sheet Bearing and Lap Splicing
When floor and roof decking sheets are placed during the progression of leading edge installation, both ends of the sheets must have sufficient bearing on structural support to prevent sheet deflection and collapse. When decking sheets are placed in their final position, the male-female lap splices must be interlocked to help ensure temporary stability and prevent the sheets from sliding open. Walking and working on decking sheets with insufficient end bearing on structural members and sheets that have not been properly lap spliced along the leading edge has been attributed to fatalities and serious incidents from falls through the sheets.
Prevent Perimeter and Interior Fall Hazards
Fall hazards created by open-sided floors and unprotected interior floor openings have attributed to fatalities and serious incidents during the decking process. The OSHA 1926.760(a)(2)standard requires "on multi-story structures, perimeter safety cables shall be installed at the final interior and exterior of the floors as soon as the metal decking has been installed." However, in some areas throughout the country, it is a common practice for the safety cables to be installed prior to the decking process.
Prevent Floor Opening Hazards
The installation of roof and floor decking around stairways, elevator shafts, and other openings create fall hazards. The OSHA 1926.754(e)(2)(ii) standard requires "roof and floor openings shall be covered during the decking process. Where the structural design does not allow openings to be covered, they shall be protected by perimeter safety cable systems, guardrail systems, safety net systems, or personal fall arrest or fall restraint systems." If covers such as plywood are used, the OSHA 1926.760(d)(1)(ii) standard requires "covers shall be capable of supporting, without failure, twice the weight of employees, equipment and materials that may be imposed on the cover at any one time."
Requirements for Maintaining a Tightly Decked Floor
There has been much confusion regarding the OSHA requirements pertaining to the decking and planking floors on multi-story structures. The International Association regrets that OSHA, under the previous Administration issued a compliance directive that was contrary to the OSHA Subpart R-Steel Erection standard and contributed to several serious incidents and fatalities. The OSHA Subpart RÐSteel Erection 1926.754(b)(3) standard requires "a fully planked or decked floor nets shall be maintained within two stories or 30 feet, whichever is less, directly under any erection work being performed." This standard provides the following additional safety provisions to our members and others on the job site.
1. Decking provides protection from falling objects.
2. Decking provides a safe work platform for rescue.
3. Decking limits the fall distance.
Fall Protection Requirements for a Controlled Decking Zone
There are two primary fall protection requirements pertaining to ironworkers installing metal decking. The first OSHA 1926.760(c) standard states, "a controlled decking zone may be established on a structure over 15 and up to 30 feet above a lower level where metal decking is initially being installed and forma the leading edge of a work area." The second OSHA 1926.760(c)(1) states, "each employee working at the leading edge in a controlled decking zone shall be protected from falls hazards of more than two stories of 30 feet, whichever is less." Note: there are additional OSHA requirements regarding the use of controlled decking zones that must be addressed prior to the commencement of metal decking operations.
The "2012 Zero Fatality" campaign will challenge all members to "intervene and prevent unsafe conditions and unsafe acts" in the workplace. This campaign will include hard-hat stickers, gang-box stickers, and posters for training facilities and local unions. I will work closely with district councils, local unions, and IMPACT regional advisory boards to promote the International Association's "2012 Zero Fatality" campaign by "targeting the deadly dozen hazardous activities that lead to fatalities and disabling injuries."