Commitment to Achieve Zero Fatalities
In January of 2012, under the leadership of General President Wise, the International Association launched the "2012 Zero Fatality Campaign" to prevent job site fatalities that result in emotional, physical, and financial hardships to our members and their families. The campaign slogan "See Something-Say Something" has been labeled on hard hat stickers and gang-box stickers that have been distributed to local unions and training facilities throughout the United States and Canada. The focus of this campaign is to target the deadly dozen hazardous activities that have contributed to the highest percentage of fatalities and disabling injuries to our members. Decade after decade the International Association has observed incident trends and primary causation factors for fatalities stemming from specific hazards and activities. We realize that workplace fatalities have occurred from many other causes; however, the following list represents the primary core of hazards and activities that we have labeled "the deadly dozen.
Targeting the Deadly Dozen Hazards
1. Falls through unprotected or inadequate floor opening covers
Unprotected floor openings on elevated steel structures or poured-in-place concrete decks must be guarded by conventional guardrail systems or adequate covers to prevent fall hazards to the next lower level. Ironworkers traveling across these decks have walked directly into these openings, or tripped or slipped causing them to fall through the opening. In other cases, floor opening covers were not properly placed or made of sufficient strength to withstand the weight of personnel and materials that were imposed on them.
2. Collapse of unsecured open web steel joists
The structural collapse of open web steel joists has been attributed to ironworkers accessing joists or landing loads on the joists that have not been adequately bridged or secured at the joist ends. The J, LH, and DLH series joists have specific requirements for the installation of bridging and securing joist ends to maintain stability and prevent collapse during the erection process.
3. Lack of fall protection and inadequate use of fall arrest equipment
The failure to use fall protection equipment or use the equipment correctly has resulted in falls during common steel erection and reinforcing steel work activities. Training must be provided on anchorage points for personal fall arrest systems, positioning devices, and horizontal life line systems to prevent falls and a false sense of security. Knowing when and how to use fall protection systems is one of the key components of the training courses provided by the National Training Fund.
4. Falls during installation of floor and roof decking
The installation of floor and roof decking remains the number one hazardous activity during the steel erection process that accounted for approximately 23 percent of fatalities. Training on the serious hazards associated with metal decking installation must be provided to all ironworkers engaged in leading edge metal decking or roofing installation.
5. Material handling incidents during steel erection and reinforcing steel activities
Hoisting, rigging and material handling incidents have been directly linked to improper rigging equipment and techniques, lack of training, and the lack of qualified and competent personnel on the job site. The Iron Workers qualified rigger and signalperson training courses offered by the National Training Fund are designed to provide classroom instruction and hands-on training pertaining to common hoisting, rigging, and material handling operations.
6. Column collapse due to anchor bolt failure and/or insufficient concrete strength
Incident trends pertaining to anchor bolt failure and column collapse have significantly decreased since 2001 when the revised Subpart R – Steel Erection standard was circulated by OSHA. However, fast-track projects with accelerated work schedules continue to create hazards associated with anchor bolt modifications and insufficient concrete strength. The OSHA standard requires the controlling contractor to provide the steel erection contractor with written notification of the concrete strength in footings, piers and walls. Additionally, if any columns or anchor bolts have been altered or modified, the controlling contractor is responsible for notifying the steel erection contractor. These notifications must be provided prior to the commencement of steel erection.
7. Structural collapse of unsupported reinforcing steel columns, walls, and decks
The structural collapse of rebar columns, walls, and decks continues to present hazards to our reinforcing ironworkers. The lack of guying procedures during columns erection, and the failure of other subcontractors to adequately brace and shore formwork prior to access and landing loads has resulted in many serious incidents. The International Association in conjunction with industry stakeholders has petitioned OSHA to pursue new standards for reinforcing steel and post-tensioning to address these hazards.
8. Struck-by injuries from falling objects, tools, and materials
Falling objects such as tools, equipment, and materials during the steel erection and reinforcing steel process pose significant hazards to our members and other trades working below. It is important to recognize that the OSHA Subpart R – Steel Erection standard contains specific requirements for the controlling contractor to bar all other employees and trades to work below the steel erection process.
9. Caught-between injuries during hoisting and rigging operations
Hoisting and placing structural columns, beams, and reinforcing steel creates "caught-between" hazards that have resulted in fatalities and serious crushing injuries. Staging areas and hoisting operations must be preplanned to help prevent "caught-between" hazards. Qualified rigger and signal person training offered through the National Training Fund is one of the preventative measures that all members must take.
10. Impalement from unprotected reinforcing dowels or other vertical projections
Impalement hazards from protruding reinforcing dowels or other projections must be avoided and protected by covers that are designed to prevent impalement. Working over or around unprotected rebar dowels or other projections have resulted in fatalities and serious injuries. The responsibility for installing and maintaining protective covers must be addressed prior to the commencement of work. The use of plastic dowel covers embedded with steel plates and troughs are common to protect ironworkers from impalement hazards.
11. Electrical hazards and injuries from high-voltage power lines
Making contact with high voltage power lines continues to occur on projects. Contact with high voltage power lines has occurred with cranes during the steel erection process, fork-lifts during metal building operations, and use of aerial lift equipment. Power line voltage and minimum distance must be identified prior to the commencement of any work operations that occur near power lines. On the job site, the National Training Fund has developed specific training programs that address working near high voltage power lines.
12. Heat illness and toxic exposure to chemicals and air-borne contaminants
During the summer months or in facilities that produce high heat, heat illness remains a serious hazard and can strike with short notice. During the 2011 heat wave where temperatures were reported to be above 105 degrees, several incidents involving heat illness occurred. Long-term exposure to air-borne contaminants such as lead, asbestos, silica, welding fumes, and other toxic materials has resulted in death and disabling illnesses that could have been detected and avoided. The Iron Workers National Training Fund provides apprentice and journeyman upgrading training on these health exposures and we encourage our members to take advantage of these training programs at your nearest local training facility.
As part of the 2012 Zero Fatality Campaign, we encourage every member to visit the Iron Workers International website at www.ironworkers.org to view information and the 2012 countdown clock that commenced on January 1, 2012. A special address by General President Wise to our members throughout the United States and Canada challenges every member to make 2012 a Zero Fatality Year. The "See Something—Say Something" slogan on hart hat stickers and gang-box stickers will serve as a continuous reminder for everyone to go home safe.
Pursuit of New OSHA Standards for Reinforcing Steel and Post-Tensioning
In April of 2010, General President Hunt, General Secretary Walter Wise, General Treasurer Ed McHugh, IMPACT Management Co-Chairman Bill Brown, IMPACT CEO Eric Waterman, and IMPACT Director of Western Region Steve Rank met with Dr. David Michaels, assistant secretary of labor for the Occupational Safety and Health Administration (OSHA) to submit a formal petition to the agency to adopt new safety standards for reinforcing steel and post-tensioning activities. The petition was signed by an industry coalition of stakeholders that included the Iron Workers International, Department of Reinforcing Ironworkers Advisory Committee, IMPACT, Concrete Reinforcing Steel Institute, Post Tensioning Institute, National Association of Reinforcing Steel Contractors, the Center for Construction Research and Training, and the Western Steel Council.
The petition to OSHA from the industry coalition of stakeholders submitted included facts and rationale for pursing new safety standards for reinforcing steel and post-tensioning activities. Following are the key points contained in the petition.
Industry Coalition Facts and Rationale for New OSHA Standards
1. The current OSHA Subpart Q – Concrete and Masonry standard is antiquated and only contains three references specifically pertaining to reinforcing steel and two for post tensioning. It does not adequately address specific workplace hazards associated with the reinforcing steel and post-tensioning activities in the ironworking industry.
2. Fatality and accident trends in the reinforcing steel and post-tensioning industry indicate a direct correlation between accident causation factors and lack of specific regulations.
3. The usage of steel reinforced and post-tensioned poured-in-place concrete is expected to double by 2015 from its 1990 level and may comprise a majority of commercial and industrial construction.
4. The Negotiated Rulemaking process will produce the best safety standard and regulations through the cooperative efforts of OSHA, stakeholders, and experts in the reinforcing steel and post-tensioning industry.
Additional information and facts presented to agency officials included the examination of fatalities, incident trends and causation factors. Following are the primary areas of reinforcing steel activities where new OSHA standards are needed to address incident trends.
Material HandLing Injuries - Many ironworkers have sustained material handling injuries due to inadequate and unacceptable job site conditions. Reinforcing ironworkers and contractors are not provided with the same safety provisions for site conditions as steel erection contractors and ironworkers under the Subpart R - Steel Erection Standard.
Structural Collapse of Vertical Formwork and Decks - Fatalities and disabling injuries continue to occur due to the lack of specific requirements for the appropriate parties to evaluate the structural integrity of structures. The current Subpart Q standard does not designate the appropriate parties to ensure that formwork is adequately supported prior to the reinforcing steel ironworkers accessing the formwork. Our ironworkers and contractors should not be in the position to evaluate the structural integrity of formwork installed by the general contractor or other subcontractors on the job site. This is a duty best performed by the controlling contractor or their authorized representative.
Structural Collapse of Vertical and Horizontal Columns - Fatalities and disabling injuries continue to occur to due to the lack of specific guying and bracing requirements for vertical and horizontal columns. The current Subpart Q standard does not adequately address specific requirements and responsibility for guying and bracing of columns.
Impalement by protruding Reinforcing Steel Dowels - Many serious accidents and legal issues involve the use, inspection, and responsibility to maintain dowel impalement covers during reinforcing steel activities. The current Subpart Q standard does not adequately address impalement hazards and responsibilities of appropriate parties during the construction process.
Post-Tensioning Standards - Serious accidents and fatalities have occurred when the use of post-tensioning equipment is not used properly and employees are not provided with adequate training and instruction. Specific regulations pertaining to training and the use of post-tensioning equipment are needed to help prevent workplace hazards and reoccurring accidents during post-tensioning operations.
In July of 2011, industry stakeholders provided testimony before the OSHA - Advisory Committee on Construction Safety and Health (ACCSH) in Washington, D.C., to obtain their support for pursing new safety standards. After compelling testimony and information presented to ACCSH from industry stakeholders, the committee voted unanimously for the agency to pursue new safety standards for reinforcing steel and post-tensioning activities.
In March of 2012, the Office of Management and Budget approved OSHA's request to pursue a Request for Information (RFI) for the development of new reinforcing steel and post-tensioning safety standards. This achievement did not come easy, and we would like to thank our industry stakeholders for their support that included conference calls, letters to agency officials, and testimony in Washington, D.C. Our collective efforts will help to obtain new OSHA standards for reinforcing steel and post-tensioning activities, and prevent fatalities and serious injuries to our members.
Demand for Consistent Interpretation and Enforcement of OSHA Standards
There has been much confusion regarding the OSHA Subpart R - 1926.754(b)(3) standard that requires "A fully planked or decked floor or nets shall be maintained within two stories or 30 feet, whichever is less, directly under any erection work being performed." The requirements for maintaining a planked or decked floors on multi-story structures has been a long-standing safety standard since 1971 and was a working rule in collective bargaining agreements before the OSHA was enacted. This standard affords many safety provisions to our members including protection from falling objects such as tools and equipment, a work platform for rescue, and limiting the fall distance to the uppermost erection floor.
We regret that under the previous administration, OSHA promulgated a compliance directive for steel erection in 2002 that effectively removed these safety provisions and created a policy that continues to perpetuate the lack of enforcement of this standard. In May of 2012, the agency released a subsequent enforcement letter stating that no citations would be issued to steel erection contractors for failing to maintain a planked or decked floor on multi-story structures, provided the following provisions were substituted.
- The employer is providing a 100 percent fall protection policy
- Workers have been properly trained in the correct use of fall protection systems
- The employer has provided a plan for immediate rescue in absence of a floor below
- The employer has prevented falling object hazards to workers below steel erection activities
It is important for our members to know that the International Association and IMPACT strongly oppose this OSHA policy and have aggressively pursued this issue with agency officials. The OSHA compliance directive has been one of the primary causation factors in fatalities and serious incidents since it was promulgated by the previous administration in 2002.
Our general officers and representatives from IMPACT have met with agency officials on several occasions to prompt the agency to rescind this dangerous compliance directive and reinstate the enforcement of the standard. Many state-approved OSHA plans such as Calif., Nev. and others have denounced the OSHA compliance directive and refused to recognize them. The International Association has maintained the position that the OSHA Subpart R - 1926.754(b)(3) standard requiring "a fully planked or decked floor or nets shall be maintained within two stories or 30 feet, whichever is less, directly under any erection work being performed" is an important safety standard that serves to protect our members during the steel erection process. Conversely, the International Association stands firm that the OSHA compliance directive and policy creates many dangerous hazards, unnecessary and costly litigation, and non-enforcement of the standard.
Another OSHA compliance directive that has been contested by the International Association and IMPACT pertains to the Subpart R - Steel Erection standard 1926.754(c)(1)(i) that requires "shear connectors (such as headed steel studs, steel bars or steel lugs), reinforcing bars, deformed anchors or threaded studs shall not be attached to the top flanges of beams, joists or beam attachments so that they project vertically from or horizontally across the top flange of the member until after the metal decking, or other walking/working surface, has been installed."
During the revision of the Subpart R - Steel Erection standard and evaluation of 673 fatality reports, it was discovered that tripping hazards from shear-studs was the primary causation factor for many fatal falls and disabling injuries. Once again, we regret that under the previous administration, OSHA circulated a compliance directive for steel erection in 2002 that effectively removed these safety provisions. The OSHA enforcement policy allows shear-studs to be shop attached and beams erected on structures provided that all employees were required to use "100 percent fall protection." The agency adopted a de minimis policy and will not issue citations where the component was fabricated with shear connectors or other similar devices prior to April 30, 2011, or where the contract date for fabrication of the component with factory-installed shear connectors or other similar devices was prior to April 30, 2011. The International Association and IMPACT strongly opposes OSHA's "phase-in" period and the policy that allows the use of 100 percent fall protection as a substitute to supersede the lack of compliance with the standard. Many state-approved OSHA plans such as Calif., Nev. and others have denounced the OSHA compliance directive and refused to recognize them. The International Association strongly disagrees with OSHA that requiring 100 percent fall protection is a safe substitute for complying with the standard, and prohibiting shop installed shear-studs on the top flange of beams.