Caution! Watch Out for These Safety Violations

Sending your crews home unharmed at the end of the day requires special training — and you can get it for free courtesy of the Washington On-Site Sewage Association.
Caution! Watch Out for These Safety Violations
This worker fails to protect against pathogen exposure while cleaning up after off-loading septage.

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“In 15 seconds, I am completely passed out, no more air. And that’s it.” Keith Pelzel, owner of Westside Septic Design in Puyallup, Washington, died in a collapsed trench one day, but was revived and tells his story in a free safety-training program available through the Washington On-Site Sewage Association. “I had never, ever experienced anything as painful as that,” he adds in one of the video vignettes used in the training.

“In a conversation recently with an employee of a service provider, I wasn’t surprised to hear that people consider safety rules to be nothing more than a burden, written by government employees sitting in an office somewhere with no real life experience,” says WOSSA Executive Director John Thomas. “Regulations are based on actual accident investigations in the construction industry and trades going back to 1972. They are not there to burden the owner, they exist to protect workers from getting killed or injured.”

WOSSA has developed a comprehensive safety-training program specifically for the onsite wastewater industry using an Occupational Safety and Health Administration (OSHA) Susan Harwood training grant of $139,000. Thomas and Administrative Director Chuck Ahrens have presented the free training over the last year in a half-dozen states. With a 2016 grant extension of $125,000, Thomas hopes to hit more states this year. He says he can also provide the training for large companies or WOSSA can provide the materials and do train-the-trainer sessions for organizations or companies that want to conduct their own sessions.

The hands-on training includes videos featuring accident victims, a workbook, exercises in root cause analysis and other material designed to raise awareness of risks workers face every day.

It covers the Focus Four hazards identified by OSHA for the construction industry; falls, caught in or between, struck-by, and electrocution. The training can be done in sessions of four or eight hours and is designed for groups of up to 25 people. All costs are covered by the OSHA grant.

Why is this training needed?

Thomas: Most folks recognize unsafe conditions, but don’t recognize what pushes them into making bad decisions or they have the wrong skills or experience when faced with a new situation. This training raises awareness of the employer’s responsibility and workers’ rights under OSHA or state-approved plans in context with the work we do every day in the onsite industry. It’s an interactive class and we have participants work in small groups throughout the day in each of the Focus Four areas to develop skills to better understand risk and conduct job safety analysis.

What did you learn as you developed this training?

Thomas: When we did our initial field interviews of companies that work in our industry, we generally characterized them into one of three categories: companies that knew about the OSHA or state rules and had programs in place and resources committed to keep it running; companies that knew about the rules and at least some effort had gone into safe work practices in the field, but they didn’t have a program robust enough to ensure that field staff were actually working safely; and lastly, we came across a few owners that either incorrectly thought the rules didn’t apply to them, or just choose to ignore them. We had some say things like “it is an acceptable business risk” as a justification for knowingly minimizing or not adhering to a rule or practice. They do this at their own peril.

What barriers do onsite companies face when it comes to having solid safety programs?

Thomas: The first is just a lack of resources to focus on safety, and I don’t mean the money side of it. The majority of the companies in our industry are small businesses with two to 10 employees. Owners are working just as hard as their staff, and managing safety and working safely are really two different things. Owners finding the time to actually read and understand the requirements under OSHA or their state-approved plan is pretty tough. Then you have to actually write a company policy and administer your safety management plan.

The other is getting the employees to think about safety as they go through their workday. It’s one thing to remember to put on safety glasses, it’s completely another to jump into a six- or eight-foot trench or tank excavation to rake out the gravel. But they do it every day. Changing behaviors is a challenge for employers who may want their guys to work safely but may not understand what they need to do it.

Lastly, I would say that it can be overwhelming for small-business owners as they read the rules to try and comply with everything. So many focus on doing their best to work safely but fall pretty short when it comes to meeting the administrative requirements.

Where does someone begin?

Thomas: Just start. Start with looking at the most severe exposures in the work that you do. It’s pretty easy to figure out the big stuff and what will kill somebody ... so start there. The four focus areas are a good place to begin because 79 percent of fatalities nationally and almost 90 percent of all penalties and noncompliance fines are associated with one or more of these areas.

What are some common examples?

Thomas: This is based on the feedback from the hundreds of people who have been in our courses:

  • Falls — from ladders, off of equipment, and in and around excavations.
  • Struck by — equipment, tools, binders on trailers, rocks and debris, eyes and face such as splash-back or baptism by sewage when a hose breaks, and in one case, injection into the chest when struck by a jetter hose. Those are the obvious ones, but OSHA also looks at excessive noise as a “struck-by” category.
  • Caught in or between — equipment and vehicles, connecting trailers, equipment moving while not chocked or a brake not set, working on or adjacent to moving machinery, and maintenance work. But the big one for us is engulfment in an excavation or trench. We have heard a ton of stories from guys who have been in a trench with no protection and a wall comes in.
  • Electrocution — we have a lot of work being done in the field by people who may or may not really understand what they are doing. In some states, electrical work is done by licensed electricians, other states don’t have any licensing requirements for electricians, and of course you may have your homeowner messing about in the line as well.

In Missouri for example, outside of some major cities, there is no trade licensing requirements by the state for electrical work. It naturally increases the electrocution hazard involving pumps and controls from years of unskilled workers doing the work. In some states, where trade licensing requirements are clear, unlicensed work continues. Worse, we have seen places where local county regulations that call out specific tasks allowed by O & M contractors are in direct conflict with state law.

In our training sessions, I ask, “Who has ever gotten a jolt while working on a system?” Almost all hands go up every time. The saying in the safety world is “It’s not the voltage, but the amps that will kill you.” Virtually everything we work on has enough amperage to kill you if it hits you right.

Are there some common areas that are misunderstood?

Thomas: Here are two good examples, lock out/tag out and confined space.

Most people think that LO/TO (lock out/tag out) is associated with electricity. The rule for LO/TO is broader and includes the need to define procedures to work on anything with “stored energy.” Think of steam lines, rigging under tension, or any other lines or vessels with pressure. Anytime we talked about how this procedure is managed, owners had a lot right, but were missing a few things because of how they think the rule applies. We have examples in the workplace that LO/TO procedures would prevent some pretty serious “struck-by” types of accidents, not just those relating to electrical hazards.

We found companies that had confined-space entry (CSE) procedures in place, but they were lacking correct protocol in keeping workers safe because most people think of CSE being limited to controlling the atmosphere. But it is much more when you think about things like going into a septic tank to do a crack repair. The rule says you have to have a rescue plan. Virtually everybody we ask in the classes says their rescue plan is 911. Unless they’ve actually talked to the local fire department, that’s inadequate under the rule. If your local responders are volunteers with no specific training, it will turn into a body recovery, not a rescue.

It’s a concrete structure that, because it is cracked, has been compromised from an engineering standpoint. Add the element of depth and water tables and now you’re going to go down and use a roto-hammer on a wall with a 5-foot crack in it. Most people would look at that and say “you can’t pay me enough to go in there.” If all your pre-entry evaluation considers is atmospheric testing, then sooner or later you’re likely to get into a mess.

What do you want to accomplish in this training?

Thomas: The point of the exercises in the training is to get people to change how they think about work processes, exposures, risk management and mitigation either as an employer before things happen or as an employee out in the field wearing a safety hat and safety vest standing in a trench under a 50,000 pound excavator.


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