Safety and Health in The Protective Coatings Industry: Daniel P. Adley and Stanford T. Liang
Safety and Health in The Protective Coatings Industry: Daniel P. Adley and Stanford T. Liang
Safety and Health in The Protective Coatings Industry: Daniel P. Adley and Stanford T. Liang
420
proper precautions are taken. A certified industrial than brushes or rolled paint. Therefore, all spray
hygienist or certified safety professional should be equipment must be grounded to prevent accidental
consulted for advice about safe working conditions, ignition by static electricity. This includes containers.
particularly in confined spaces. Painters should bond their empty bucket to the bulk
drum while filling it, and the drum should be properly
grounded.
Pure solvent vapors are heavier than air and
tend to move along the ground when in confined
areas. Thus, all flames near the area must be extin-
guished. Solvent vapors must be mechanically ex-
hausted from all enclosed areas with the ventilation
designed for efficient airflow. Explosion-proof lighting
must be used. All electric motors should be turned off.
The following precautions will help prevent the
possibility of fires.
• Store solvents in Underwriter’s Laboratory (UL) listed
containers.
Figure 1. Paint vapors can be flammable if adequate • Prohibit smoking wherever solvent-thinned paint is
ventilation is not provided. stored, mixed, or used. Allow no other sources of
ignition, such as electric coffee pots, hot plates, or
Because of the flammability of solvent-thinned other such appliances to be used in the area.
paints, precautions need to be taken when handling • Provide adequate ventilation in all working areas to
these types of coating systems. Two examples of prevent a build-up of explosive concentrations of
solvent-thinned paints include: solvent vapor. Properly calibrated direct reading
• Two-Component Paints: Two-component paints detection instruments should be used to monitor
should never be mixed in large quantities, generally no confined areas or closed spaces to be sure vapor
more than five gallons at a time. They usually create concentrations are maintained below explosive limits.
heat because they react immediately upon mixing. The •Use nonmetallic ladders in confined areas or within
larger the volume mixed, the higher the temperature. 10 ft. (3.05 m) of exposed electric wiring.
The temperature may become high enough to create • Use non-sparking tools to clean metal surfaces
a hazard. where fire hazards are present.
• Extinguish all sources of flame in the area. Turn off
• Oil Paints and Specialty Coatings: Waste or wiping all gas valves and open all electrical switches if
rags soaked with paints based on linseed oil may working in confined areas or near electrical equipment.
catch fire spontaneously if left lying around, especially • Be sure that all equipment, motors, and lights in the
during warm weather. Spillage of peroxide catalysts area are grounded, and consider using only explosion-
used in polyester laminates and other similar chemi- proof lighting.
cals can cause combustion. • Keep fire extinguishers nearby. Be sure that they are
Most paint solvents are volatile and will flash of the proper type, as follows:
in the presence of a flame or an electric spark. Usually,
the faster the solvent evaporates, the lower its flash Class A—Paper, wood, rubbish, where water is
point. Therefore, solvent-thinned brushing or rolling effective;
paints, which dry relatively slowly, will contain solvents Class B—Burning liquids, where smothering action is
with a flash point of about 105°F (41°C) or somewhat required;
higher. A solvent-thinned spray paint that requires fast Class C—Electrical equipment, where the extinguish-
evaporating solvents may contain solvents that flash ing agent must be non-conductive.
as low as 30°F (1°C). A spray gun, which applies a pint
to many quarts of paint per minute under high pres- • Keep pails of sand or similar absorbent materials
sure, will produce a greater volume of solvent vapor near dispensing pumps and spigots to absorb any
421
spills. Replace all leaking containers. modified by the addition of reactive diluents (glycidyl
• Clean up before, during, and immediately after ethers) that are themselves irritants to the skin, the
painting operations. Wet down sweepings, rags, and eyes, and the respiratory tract.
waste with water and store in closed metal containers.
Dispose of daily. •Aliphatic and Aromatic Polyamines, Polyamine
• Always clean up paint or solvent spills immediately. Adducts, and Polyamides: Are used as curing
agents in two-component epoxy coating systems. The
Health Hazards aliphatic amines are potent irritants and sensitizers;
A variety of paint ingredients or chemicals may the aromatic amines are somewhat less potent. The
be harmful to the human body. For instance, some polyamide resins are relatively harmless. Acid anhy-
chemicals may cause irritation sensitization, central drides and formaldehyde resins are used as
nervous system effects, or systemic effects. Most cross-linking agents in powder coatings and baking
people can withstand chemical exposures for short enamels. The acid anhydrides are irritants and sensi-
periods of time at low doses; however, some people tizers. Formaldehyde is a strong irritant and is also
are immediately sensitive to some ingredients and considered a human carcinogen.
almost everyone will be affected to some degree if
exposed for a sufficient period of time. Continued • Epoxy Resins: Are commonly reacted with fatty
exposure may cause the body to become sensitized acids to produce epoxy esters. Because coatings
so that subsequent contact may result in an aggra- produced with these resins contain no un-reacted
vated reaction, especially for anyone with a chronic epoxy groups, no hazard exists.
illness.
• Urethane Resins: Organic isocyanates are the
Types and Components of Paints. The term paint is principal hazard associated with urethane coatings.
commonly used to identify a range of products Isocyanates can cause severe irritation to the conjunc-
including conventional paints, varnishes, enamels, and tiva, as well as respiratory distress. They react with
lacquers. Conventional paint is an inorganic pigment various protein functional groups and should be
dispersed in a vehicle consisting of a binder and capable of forming antigens. A typical response to
solvent, with selected fillers and additives. Varnish is a isocyanate inhalation, either as a vapor or an aerosol,
non-pigmented product based on oil and resin in a is the manifestation of an asthma-like syndrome,
solvent that dries first by the evaporation of the solvent characterized by a feeling of chest constriction and
and then by the oxidation and polymerization of the difficult breathing, sometimes accompanied by a dry,
resin binder. A pigmented varnish is called an enamel. irritating cough. A small percentage of the population
Lacquers are coatings that are commonly based on a may become sensitized to isocyanates, whereupon the
cellulose ester in a solvent that dries by evaporation, above symptoms are produced on exposure to even
leaving a film that can be re-dissolved in the original low airborne concentrations. The toxicity can be
solver. minimized, however, by avoiding use of smaller
molecular weight species.
•Alkyd Paints: Employ metal soaps of organic acids
to catalyze the oxidation of the drying component. Hazards of Solvents and Thinners. Most solvents are
Because lead soaps are commonly used, lead is a toxic to some degree, depending upon the exposure.
potential hazard in any drying oil-type paint (alkyd, Solvents may enter or affect the body in three ways.
epoxy ester, oleoresin, and urethane-oil). Lead used The most frequent way solvents affect the body is
as an oxidation catalyst may comprise 0.5–1.0% of the through skin contact. When a solvent is allowed to
paint solids by weight. (For more information, see the contact the skin, even for a short period of time, it will
section Hazards of Pigments and Other Additives.) start to damage the skin or cause dermatitis (a red-
dening and swelling of the skin). The second route of
• Liquid Epoxy Resins and Curing Agents: Are entry of solvents into the body is by breathing, or
primarily used in solvent-borne and waterborne inhalation. Once solvents are inhaled, the vapors can
two-component epoxy paints. These liquid resins are pass from the lungs directly to the blood. The solvent
422
may irritate the respiratory tract and/or cause adverse • Wear appropriate gloves and clothing when handling
health effects to other body systems by being trans- dermatitic materials. Change and clean work clothing
ferred through the blood stream. The third route of daily.
entry of solvents into the body is by ingestion. Inges- • Avoid touching any part of the body when handling
tion of solvents may affect the gastrointestinal tract as dermatitic materials. Wash hands, face, and arms
well as other body organs. The following precautions thoroughly before eating and at the end of the day. Try
should be used while working with toxic solvents: to shower at or near the job site. Change clothing
• Properly label, seal, and store all toxic solvents when before leaving. Toxicants can be transferred easily.
not in use. • Paint removers containing solvents are often toxic.
• Adequately ventilate all areas where solvents are They should be used only with ventilation controls and/
used or stored. or respiratory protection.
• Wear the proper respirator and eye protection.
• If a solvent gets splashed into the eye, immediately Hazards of Pigments and Other Additives. Heavy
flush the eye with water for a minimum of fifteen metal pigments are another paint component that may
minutes and seek medical attention. be toxic to the human body. The most common contain
• Wear the appropriate gloves and clothing when lead, chromium, and oxides of iron, titanium, and zinc.
handling solvents. Precautions such as ventilation, respirators, hygiene
• Practice good personal hygiene after handling any facilities, and personal protective clothing should be
solvents. implemented when applying or removing paints
• Consult the Material Safety Data Sheet (MSDS) to containing these pigments. The substitution of hazard-
determine the toxicity of the material that is in use and ous pigments with non-hazardous pigments is the best
the specified protective equipment needed when using method of controlling future occupational health
the material. hazards.
• If permissible exposure limits are exceeded, as The removal of paints containing heavy metal
determined through air monitoring conducted by an pigments without control measures greatly increases
industrial hygienist, then engineering control and an employee’s chances of developing heavy metal
respiratory protection becomes necessary. poisoning. Airborne pigments such as lead may enter
the body by inhalation and ingestion. Exposure to lead
Prevention of Health Hazards. The following precau- may affect each person differently. Even before
tions should help reduce potential hazards. They symptoms appear, lead may cause unseen injury to
describe a common sense approach to avoiding the body. During early stages of lead poisoning, mild
contact: symptoms may be overlooked as everyday medical
• Identify and seal all toxic and dermatitic materials complaints, including: loss of appetite, trouble sleep-
when not in use. ing, irritability, fatigue, headache, joint and muscle
• Adequately ventilate all painting areas. Provide aches, metallic taste, lack of concentration, and
general exhaust ventilation in the form of blowers and moodiness. Brief but intense exposure or prolonged
fans supplying fresh outside air to the work area where overexposure may result in severe damage to the
necessary, and use National Institute for Occupational blood-forming, nervous, kidney, and reproductive
Safety and Health/Mine Safety and Health Administra- systems. Some noticeable medical problems include:
tion approved respiratory protection equipment if the stomach pains, wrist or foot drop, high blood pressure,
vapors cause irritation or intoxication. nausea, anemia, constipation or diarrhea, tremors,
• When surface preparation involves removal of old convulsions, or seizures.
paint films, take care to minimize dusting to protect Silica (both crystalline and amorphous) and
workers from the dust and to properly dispose of the silicates clay, diatomaceous earth, mica, and talc
coating residues in accordance with applicable state are widely used as extender pigments. With the
and federal regulations. exception of clay, all have been demonstrated to
• Wear goggles and the proper respirator when spray produce fibrosis of the lung. A preliminary study of the
painting or performing any operation where an abnor- health hazards in the painting trades suggested that
mal amount of vapor or dust is formed. “mixed dust pneumoconiosis” is common among
423
painters. While extender pigments are used in sub- particles, the toxicity of the materials in the dust, and
stantial quantities in some paint formulations, these the amount of dust breathed into the lungs. To deter-
materials may be at least partially locked up by mine the toxicity of the dust, refer to the MSDS for the
encapsulation in the resinous binder. abrasive in use, then identify the chemical makeup of
The chronic hazards posed by organic pig- the coating being removed and the substrate or object
ments are largely unknown. Many of the pigments are being cleaned. To control workers’ exposures to
based on dyestuffs; the dyestuff is combined with an potentially toxic dust, a well-designed ventilation
inorganic compound to produce an insoluble pigment. system should be installed. Respirators and proper
The dyestuffs have been studied more extensively protective equipment should also be used to ensure
than the pigments, and several have been implicated adequate protection.
as carcinogenic. In paint, the biological availability of
these materials is probably limited by the insolubility of
the pigments and their partial encapsulation in the
paint resin matrix. Fat and/or water-soluble dyes are
used in some wood stains, increasing the potential
hazard.
Activators and catalysts found in some coat-
ings, such as mercury compounds, can be very
harmful if proper protective clothing and respiratory
protection is not used.
424
had died from this condition. NIOSH also identified contains hazardous materials. If the coating contains
inadequate engineering controls, inadequate respira- potentially hazardous constituents then respiratory and
tory protection, and failure to conduct adequate protective clothing should be worn while working with
medical surveillance programs as contributing to the the removed material.
development of silicosis. NIOSH recommends a series All spills should be cleaned up immediately
of preventative measures, including substitution of and workers should wash immediately if their skin
alternative abrasives, air monitoring, use of contain- comes into contact with a hazardous substance. If a
ment structures, personal hygiene, protective clothing, solvent chemical gets splashed into the eye, immedi-
respiratory protection, medical monitoring, posting of ately flush the eye with water for a minimum of fifteen
warning signs, and worker training. minutes and seek medical attention. Wear the appro-
The Texas Department of Health also issued priate gloves and clothing when handling spills.
an advisory on the hazards of using silica abrasives to Practice good personal hygiene after handling any
the oil and gas pipe coating industry. Both documents spills. Consult the MSDS to determine the toxicity of
strongly recommend observing the OSHA PEL (Per- the material that is in use, and the specific protective
missible Exposure Limit). The PEL is based on an equipment needed when using the material. Store and
8-hour time-weighted average and is calculated using dispose of all oily or solvent wetted rags in metal
a formula that requires an analytical laboratory to containers with tightly sealed lids. Respiratory protec-
determine the percentage of crystalline silica in tion should be worn if the spill creates a hazardous
respirable dust collected during worker exposure- atmosphere, or the MSDS indicates it is necessary.
monitoring.
Chemical strippers are used to soften the Paint Application
existing coating for removal by scraping and/or flush- Paint products are used widely in industry to
ing. Chemical strippers eliminate airborne hazards, but provide a surface coating for protection against
proper protective clothing such as coveralls, gloves, corrosion, for appearance, as electrical insulation, and
and glasses should be worn to prevent skin and eye for a number of special purposes. Common methods
irritation. Caustic compounds in some chemical of application include airless spray, conventional spray
strippers can cause burns if not immediately washed (air atomizing), and electrostatic spray.
off the skin and can cause eyes, nose, and throat Because airless spray systems operate at high
irritation upon inhalation. Solvent-based strippers are pressure, special attention must be given to them to
also available. Health hazards may vary from irritation ensure safety during operation. A tip guard and trigger
and central nervous system depression, possible with lock must be present on airless spray guns. Fluid
substances such as xylene, to the possibility of sprayed from the gun is propelled with sufficient force
carcinogens affecting humans, as with methylene to penetrate skin and cause serious damage. In the
chloride. Methylene chloride is also regulated by an event of injection, special treatment by a physician is
OSHA standard as a carcinogen. Use of methylene required. The attending physician should be advised of
chloride should be avoided whenever possible. the material’s ingredients (an MSDS would be helpful)
Chemical strippers containing solvents may require and of the nature of the injection (high pressure). The
use of respiratory protective devices. Refer to SSPC entire system is pressurized so that hose ruptures or
Technology Update (TU 6), Chemical Stripping of leaks at fittings can result in dangerous high-pressure
Organic Coatings from Steel Surfaces for additional spray.
information on the safe use of chemical strippers. Some important safety practices to help avoid
Acids and alkalis commonly found in “wash these hazards include:
primers” and chemical strippers (e.g., sodium hydrox- • Never point the gun at anyone.
ide and phosphoric acid) are highly corrosive, and • Do not make adjustments to the equipment setup,
appropriate measures should be instituted concerning such as changing nozzles or fittings, without first
storage, handling, waste disposal, ventilation, personal shutting off the pump and releasing the system
protection, and first aid. pressure.
A pre-job analysis of the surface materials • Always make sure the fluid hose is in good condition
should be conducted to determine whether the coating before spraying; kinks or abrasion can develop into a
425
rupture. Store the hose in a dry area. method. All electrostatic equipment must be properly
• Do not use standard hardware on an airless system; grounded.
only high-pressure fittings can be used. A high- When using a compressor during any of these
pressure hose is required for fluid flow. The hose must three application methods, never overload it. Place the
never be bent or kinked in less than a 4-inch (102-mm) compressor in an open and level area in a remote
radius. location because it requires a good supply of clean,
• Ground airless spray equipment to prevent static fresh air in order to properly operate. It should also be
sparking. If extension cords are used, make sure that grounded before being started. Allow a reasonable
they have a ground wire and that the ground is con- amount of time for it to warm up before building up
nected. pressure in the receiving tank and never tamper with
• Do not spray solvent through the nozzle tip, because preset safety valves.
this can cause a build-up of static electricity and an
explosion or fire. Take the tip off before spraying
solvent through the system.
• Secure the blast hose at a point no more than 10 ft.
(30.5 m) from the operator.
• Conduct hydrostatic tests at least once, and prefer-
ably twice, a year. Check all valves, including safety
valves, daily.
The conventional, or air atomizing, spray gun
is widely used due to its versatility, its low cost, and
because it creates a high-quality finish. In this method,
cold pressed air provides the energy to atomize the
finish. The atomization is produced by an air nozzle.
Two types of nozzles are used: external mix and Figure 4. Airless spray systems exert considerable force
internal mix. In the external mix nozzle, the coating and can cause serious injury if not handled carefully.
and the compressed air exit from separate orifices and
are mixed outside the nozzle. The jet atomizes and Gauges should be kept clean and visible at all
shapes the spray fan. Internal mix nozzles combine times. Workers need to see the gauges to tell whether
the compressed air and finishing materials in a all air pressure has been released before disconnect-
chamber inside the nozzle. The atomized mixture is ing any couplings or opening any lids. The gauges are
shaped by the geometry of the chamber opening. also used to ensure that the compressor is operating
Regardless of which paint method is used, most safely.
industrial spray paint operations require exhaust Do not add fuel to a gasoline-powered com-
ventilation, the use of air-supplied respirators, protec- pressor when it is hot or running. The fuel can easily
tive clothing, and adequate washing facilities. ignite, causing a fire or explosion. All re-fueling of the
In electrostatic spraying, an electrical charge compressor should be done in the morning before
is applied to the atomized coating particles, either by start-up. The compressor should be kept tuned-up and
the creation of an ionized zone within the spray area, out of confined spaces. If compressors are used to
or by imparting a charge to the fluid stream prior to its supply breathing air for respirators they must be
release from the spray gun head. The charged, equipped with carbon monoxide monitor and filter
atomized paint particles are attracted the conductive systems capable of providing Grade D air.
object being finished by the electrostatic potential
between the paint and the object. Surface Preparation
The level of exposure to the paint is deter-
mined by the overspray and rebound that occurs Abrasive Blast Cleaning. Without proper precautions,
during spraying. Effective ventilation controls should the high pressures used in blast cleaning can cause
be in place, and protective clothing and respiratory injuries. Injections of water beneath the skin should be
protection should be worn while using this painting treated as seriously as any other chemical injection. In
426
addition, abrasive material may cause harm at high or showing wear must be replaced to prevent sudden
even moderate pressures, and continuous exposure to parting and whipping under pressure.
the dust may result in lung disease.
Hand and Power Tools. Common hand tools used for
hand tool cleaning are sandpaper, non-woven abra-
sive pads, wire brushes, chipping hammers, scrapers,
and chisels. Prolonged use of chipping hammers and
chisels may cause trauma to the hands, wrists, and
elbows. Use of shock absorbing gloves and/or wrist
supports or ergonomically designed tools may be
advisable.
Common power tools are pneumatically driven
hammers or rotary hammers, needle guns, roto peens,
rotary grinders, sanders, or wire brushing tools. It is
important to have a proper equipment setup when
using power tools. Follow the manufacturer’s instruc-
tions for the tool being used.
Power tools can be dangerous, and safety
precautions must be taken when operating them.
Protective equipment must be worn. In addition to a
hardhat and eye protection, work gloves should be
Figure 5. Specialized protective equipment is required worn. Power tool cleaning may be very noisy, and it is
for abrasive blast cleaning. therefore very important to use adequate hearing
protection. Respiratory protection and coveralls are
Protective equipment is essential to protect advisable whenever hand or power tools are used to
the abrasive blaster and fellow workers from the remove paint, and are required for removal of lead-
hazards of the job. At a minimum, a continuous flow based paints.
respirator with helmet and wide angle, clear vision lens If electrically driven (rather than air-powered)
must be used by the abrasive blaster. The helmet must tools are used, they must be adequately grounded or
fit completely over the head and neck to the shoulders. double insulated, and used in a dry atmosphere to
The helmet should be equipped with a constant supply avoid the possibility of shock. Ground Fault Circuit
of clean air (Grade D or better) of not less than 6 ft.3 Interrupters (GFCI) should be used with all electric
(.168 m3) per minute. The air-line should be equipped cords and tools. In confined spaces and other areas
with air-purifying filters, pressure regulator gauge, where there may be a danger of explosion, power tool
relief valve, air-flow control valve and a NIOSH/MSHA cleaning should not be conducted because of the
approved blasting respirator. The abrasive blaster possibility of sparking.
should also be equipped with appropriate work gloves, The operator must be certain that the tools in
coveralls, and other clothing. use are checked and safe. Make sure that the abra-
The blaster must use a “dead-man” control sive media is attached securely and tightened. Tools
valve on the blasting nozzle to cut off the air and should not be operated above maximum operating
abrasive stream when the pressure on the control is speed or run at all unless in contact with the work
released. The hoses for the blasting equipment must surface. Manufacturer’s directions should always be
be equipped with a static dissipating tube or be lined strictly followed.
with carbon black. This prevents shock from static
electricity build-up. Such a shock could cause the Waterjetting. Although water itself is relatively safe, the
operator to fall if working on an elevated surface. extremely high pressure often used for waterjetting
Before starting any abrasive blasting opera- can be hazardous. Prior to waterjetting, employees
tion, thoroughly examine the condition of hoses, hose should examine the condition of the hoses, hose
fittings, couplings, and unions. Any of the above fittings, couplings, and unions. All equipment showing
427
wear should be replaced to prevent sudden parting protection devices (ear plugs or earmuffs) should also
and whipping under pressure. be worn.
Waterjetting hoses should be secured to the Never force the lid off the sandblast pot. If the
staging at the working level, leaving only enough free lid is difficult to open, stop and check the air pressure.
hose so the hose weight can be properly and safely The pot must be depressurized before opening the pot
handled by the blaster. Any electrical equipment in the lid, or before any changes to hose couplings or repairs
area of operations that presents a hazard to the of any kind are allowed. A blast machine should never
operator should be de-energized, shielded, or other- be moved while it contains abrasives. Abrasive
wise made safe. Operators should wear appropriate blasting machines that will be towed on a highway
waterproof clothing, head, eye, and hearing protection should be equipped with properly operating brakes,
during all waterjetting operations. taillights, fenders, and side reflectors.
When waterjetting operations are conducted in
confined spaces, the blaster should be in constant Access and Rigging
communication with the stand-by person. Employees Ladders. Use the following procedures in storing,
should take precautions to protect the water blasting setting up, and using ladders:
equipment from freezing in cold weather and signs • Use safety shoes.
should be posted to advise others in the area when • Store ladders off the ground in a warm, dry arc
water blasting operations are being performed. As protected from the weather.
always, injection of water beneath the skin should be • Protect wood ladders with a clear finish so that
treated as seriously as any other chemical injection, defects are visible.
and a physician should be consulted. • Inspect ladders daily during use. Keep them clean
and free of oil or grease.
Welding, Cutting, or Heating. All welding, cutting, or • Use ladders that can be carried and erected by two
heating on surfaces with preservative coatings should workers.
be performed according to OSHA standard 29 CFR • Use a stepladder that is less than 12 ft. (4 m) high.
1926.354, Welding, Cutting, and Heating in Way of • Ladders should be fully opened with a locking device.
Preservative Coatings. Before welding, cutting, or • Do not stand on the top step. One worker should
heating, the potential toxicity and flammability of hold a ladder if the worker climbing the ladder will be
preservatives should be evaluated. All surfaces more than 8 ft. (2 m) from the ground.
covered with toxic coatings require the use of protec- • Avoid placing ladders in front of doorways, unless the
tive clothing and a respirator that is capable of filtering door is blocked.
out the emissions generated during surface cleaning. • Only one worker should work on a ladder at a time.
Means for fire protection and proper ventilation should • Do not use a ladder as a horizontal scaffold member.
also be provided during welding, cutting, or heating. • The ladder should extend at least 3 ft. (.92 m) above
the point of support and should be tied off when
Pressure Pots. Sandblast pots and related blast accessing unusually high levels.
machinery should be built to standards set by the
American Society of Mechanical Engineers (ASME) or Fall Hazards. Falls from heights are a significant
National Board Code. Pots not meeting these require- hazard faced by painters and blasters in day-to-day
ments must not be used. The ASME code means that work. Because falls are a routine hazard, there is a
everything has been done to make the vessel as safe tendency to ignore some of the precautions necessary
as possible. The code prohibits any field welding on when working on elevated surfaces, but safety cannot
blast machines. Blast pressures should stay within the be taken for granted. The hazards of high work subject
manufacturer’s blast machine ratings. employees to possible injury and death, and an
Pot tenders and others working near abrasive employer to possible OSHA citations and fines.
blasting operations may need to be equipped with The primary means for protecting workers
respirators, gloves, hard hats, and safety glasses. from hazards of falls from heights is the use of a
Most abrasive blasting operations produce noise standard guardrail consisting of top rail, intermediate
levels in excess of 90 decibels, therefore hearing rail, and toeboard. Guardrails and toeboards should
428
be installed on all open sides and ends of platforms to rope suspended between two fixed anchorages. The
give maximum protection. The OSHA standard safety harness is connected directly to the horizontal
pertaining to this protection is 29 CFR 1926.502(b), lifeline via a lanyard. OSHA requires that horizontal
which refers specifically to work on floors, platforms, lifelines be designed, installed, and used under the
and runways. Other OSHA standards that discuss the supervision of a qualified person. An evaluation of the
use of guardrails are 1926.451(g), pertaining to horizontal lifeline should be performed to verify that it
scaffold arrangements, and 1926.550(9), pertaining to maintains a safety factor of two, as required by OSHA.
suspended personnel platforms. Horizontal lifelines should be used for multiple tie-offs
only after the qualified person determines the maxi-
mum number of workers who can use the lifeline.
The vertical lifeline or dropline is a rope
system used with a harness. The harness is attached
to a lanyard and rope-grabbing device. The rope-
grabbing device is attached to a lifeline that must have
a minimum breaking strength of 5,000 pounds (2,270
kg). The rope-grabbing device should be installed and
used in accordance with the manufacturer’s manual.
Improper use or installation (e.g., installing the rope-
grab upside down) can result in failure. Only one
worker at a time is permitted to be connected to a
vertical lifeline.
A retractable lifeline is a device with an
integral line that moves upward or downward with the
worker, preventing slack from developing. This lifeline
is connected directly to the safety harness. Retracting
lifelines have a centrifugal locking or braking system to
prevent further decent in the event of a fall. Retract-
Figure 6. Failure to use proper access equipment can able lifelines must be kept overhead as much as
lead to falls, a common source of injury in coating possible. As the worker moves horizontally away from
operations. the anchor point, the severity of a “swing fall” in the
event of an arrested fall increases. A “swing fall” is
Guardrails and toeboards cannot be used in pendulum like motion that can occur in an arrested fall.
all fall hazard situations. When guardrails are neither During a “swing fall,” collisions with obstructions in the
practical nor feasible, use a secondary means of fall path of travel can occur with as much destructive
protection, or personal fall arrest equipment. Personal energy as by hitting the ground in a vertical fall.
fall arrest equipment consists of a safety harness Retractable lifelines should not be used with horizontal
connected by a lanyard to an anchorage. Federal lifelines unless the manufacturer approves such use.
regulations prohibit the use of body belts as part of a Improper connection of a retractable lifeline to a
personal fall arrest system. Use of body belts, even horizontal lifeline can result in failure of the lifeline’s
when properly worn, can cause severe internal injuries locking mechanism during an arrested fall.
or suffocation in an arrested fall. OSHA regulates the Anchorages for direct connection of lanyards
use of personal fall arrest systems in 29 CFR or connection of lifelines must be independent of any
1926.502(d). anchorage used to support or suspend platforms.
While personal fall arrest equipment can be Anchorages must be capable of supporting at least
anchored directly to a structure, personal fall equip- 5,000 pounds (2,220 kg) per employee attached or be
ment is typically attached to a lifeline system. There used and designed as follows: (1) as part of a com-
are three basic types of lifelines: horizontal, vertical, plete fall arrest system, which maintains a safety factor
and retractable. of at least two; and (2) under the supervision of a
Horizontal lifelines consist of a fiber or wire qualified person.
429
Shock-absorbing lanyards should be used investigated. These devices limit free fall to 2 ft. (.61
unless lanyards are connected to equipment that limits m), making use of a shock absorber unnecessary and
free fall distance to 2 ft. (.61 m). The free fall distance eliminating the deceleration distance of 3.5 ft. (1.07
is the distance traveled in an arrested fall until the fall m). Other options to reduce the amount of clearance
protection device begins to slow decent. An example needed include use of a shorter lanyard or simply
of a device that limits the free fall distance to 2 ft. (.61 moving the anchor point to a higher location. Keeping
m) is the retractable lifeline. free fall distances to less than 6 ft. (1.83 m) is accom-
Lanyards are only to be connected to the D- plished by using lanyards that are 6 ft. (1.83 m) or less
ring on the back of the harness approximately between in length (or by using a retractable lifeline) and by
the worker’s shoulder blades. Harnesses may have D- maintaining the anchor point location above the D-ring
rings at other locations for connecting other types of on the back of the harness.
fall protection equipment (e.g., D-rings at waist level OSHA requires employers who rely on per-
for connection to positioning systems, such as belts). sonal fall arrest systems to have pre-planned rescue
Use of the incorrect D-ring for lanyards can result in procedures in the event of a fall. As an alternative to
severe injury or death. Lanyards must also be developing rescue procedures, employers can provide
equipped with the correct attachment device (e.g., employees with equipment that allows for self-rescue.
snaphook) for connection to the anchorage (e.g., An example of a self-rescue device is a retractable
lifeline). lanyard with a controlled decent mechanism that
OSHA requires the use of locking snaphooks permits employees to lower themselves to the ground
to prevent “roll out” where the snaphook keeper is after arrested falls. Since improper installation, use,
accidentally depressed in an arrested fall, resulting in and maintenance of fall protection can result in serious
disengagement. Snaphooks cannot be connected to injury and death, workers must be trained when
objects that are not compatibly shaped (e.g., the exposed to fall hazards. OSHA training requirements
keeper of the snaphook is unable to close after are addressed under 29 CFR 1926.503. Training
attachment to the anchorage). When snaphooks are should also include information in the manufacturer’s
not able to be directly connected to the anchorage, the manual for personal fall arrest equipment used by
use of anchorage connection devices (e.g., cross arm workers.
strap, carabiner) should be investigated. Snaphooks Sometimes personal fall arrest systems,
should not be connected directly to horizontal lifelines guardrails, or other conventional protective equipment
unless it is of a locking type and unless the manufac- may be impractical or not feasible for the work method.
turer recommends such use. In these situations, personnel safety nets can be
Personal fall arrest systems must be rigged so installed under and around the work area. Personnel
that workers will not free fall more than 6 ft., (1.83 m) safety nets are typically used in bridge work and
nor contact a lower level. The amount of clearance long-term structural projects where workers are
beneath the anchor point needed to meet this require- exposed to significant fall hazards.
ment is determined by the free fall distance (6 ft. [1.83 Personnel safety nets must be manufactured
m] if a six foot lanyard is used), the deceleration and tested in accordance with all pertaining ANSI
distance (3.5 ft. [1.07 m] if the lanyard is equipped with standards and OSHA standard requirements. They
a shock absorber), and the length of the worker’s body should bear a label displaying the manufacturer’s
suspended beneath the D-ring on the back of the name, date of manufacture, and proof of load testing.
harness (about 5 ft. [1.53 m] ). Every net should also carry a serial number so that
A safety factor of about 4 ft. should also be records can be kept of details such as repairs, inspec-
included in the amount of clearance required to allow tions, and load test results. OSHA’s requirements for
for D-ring slide and stretching in lifelines and webbing safety nets can be found in 29 CFR 1926.502 (c).
in the harness and lanyard. This safety factor may
have to be increased for horizontal lifelines depending Aerial Lifts. OSHA regulates aerial lifts under 29 CFR
on the amount of sag permitted by the qualified 1926.453. According to the OSHA standard, aerial lifts
person. Where there is insufficient clearance beneath include the following vehicle mounted aerial devices
the anchor point, use of a retractable lifeline should be used to elevate personnel to job sites above
430
the ground: Many injuries and fatalities associated with the
• Extensible boom platforms use of aerial lifts are due to falls. Typical causes of
• Articulating boom platforms falls from aerial lifts include mechanical failures in the
• Vertical towers hydraulic system that cause the basket to tip, operat-
• A combination of any such devices ing the aerial lift on an incline causing the unit to tip
over, falling while climbing out of the basket onto a
These requirements are specifically applicable scaffold or other elevated work surface, or falling out
to extensible boom and articulating boom platforms: of the basket while standing on the guardrail or
• Only authorized persons shall operate an aerial lift. makeshift platform (e.g., board suspended from the
• Belting off (i.e., connecting personal fall arrest guard rails or a bucket).
equipment) to an adjacent pole, structure, or equip- OSHA requires personal fall arrest equipment for
ment while working from an aerial lift shall not be all occupants in an aerial lift. In lieu of personal fall
permitted. arrest, which protects occupants if they fall from the
• Employees shall always stand firmly on the floor of aerial lift, OSHA permits occupants to be provided with
the basket and shall not sit or climb on the edge of the a restraint system as an alternative. A restraint system
basket or use planks, ladders, or other devices for a may consist of a body belt (note this exception for the
work position. use of body belts with “restraint systems” only), or a
• Boom and basket limits specified by the manufac- harness and lanyard that must be short enough to
turer shall not be exceeded. prevent the occupants from leaving the basket.
• The brakes shall be set and when outriggers are Lanyards used in restraint systems for aerial lifts
used they shall be positioned on pads or a solid typically must be less than 4 ft. (1.22 m) long.
surface. Wheel chocks shall be installed before using Only if scissor lifts are equipped with standard
an aerial lift on an incline, provided that they can be guardrails does OSHA permit, in a letter of interpreta-
safely installed. tion dated August 8, 1995, an exemption to the re-
• An aerial lift truck shall not be moved when the boom quirement to provide occupants with personal fall
is elevated in a working position with workers in the arrest or restraint systems. OSHA stated in this letter
basket, except for equipment that is specifically that this exemption does not apply if guardrails are
designed for this type of operation in accordance with removed or are not effective. The use of personal fall
29 CFR 1926.453 (a)(1) and (a)(2). arrest for scissor lift occupants should also be consid-
• Articulating boom and extensible boom platforms that ered if there is the possibility that occupants may climb
are primarily designed as personnel carriers shall have out of the platform or (improperly) stand on guardrails
both upper and lower controls. Upper controls shall be while working from these platforms.
in or beside the platform within easy reach of the In two letters of interpretation dated January 25,
operator. Lower controls shall provide for overriding 1988 and September 5, 1998, OSHA addressed
the upper controls. Controls shall be plainly marked as control measures for fall hazards when workers
to their function. Lower level controls shall not be transfer between elevated work surfaces and aerial
operated unless permission has been obtained from lifts. These letters state that employees should attach
the employee in the lift, except in case of emergency. their lanyards to an attachment point on the fixed
• Climbers (i.e., spurs or spikes attached to the shoe) structure (e.g., bridge) before exiting the basket. A
shall not be worn while performing work from an vertical lifeline is given as an example of a means of
aerial lift. attachment. Any lifelines, including their anchorages,
• The insulated portion of an aerial lift shall not used for connection of personal fall arrest must meet
be altered in any manner that might reduce its the requirement of 29 CFR 1926.502 (d).
insulating value. OSHA warns, in the September 5, 1998, interpre-
• Before moving an aerial lift for travel, the boom(s) tation letter, that attachment of personal fall arrest
shall be inspected to see that it is properly cradled and equipment to the aerial lift basket may be inappropri-
outriggers are in the stowed position, except when the ate if the manufacturer of the lift cannot certify that the
requirement described above is met for moving the lift will not tip over if a person, tied off to the lift, fell
aerial lift when the boom is elevated. from a position on top of the basket guardrail. The use
431
of dual lanyards should also be considered to allow in response to petitions from other parties including
workers to be tied off at all times when disconnecting NIOSH, state and local governments, groups that
their lanyards from the aerial lift basket and connecting develop voluntary industrial standards or labor
them to a lifeline suspended from the structure. representatives. Once the need for a new standard
The manufacturer’s manual must be con- has been identified, OSHA Advisory Committees,
sulted before operating an aerial lift on an inclined which include representatives of management, labor,
surface. The limits in the manual for an acceptable and state agencies, develop recommendations.
incline surface must not be exceeded. Many newer In the very early stages of the process, OSHA
aerial lifts are equipped with devices that prevent may request additional information needed for the
operation if the aerial lift is tilted beyond acceptable development of a standard by publishing an “Advance
limits. Notice of Proposed Rulemaking” in the Federal
Register, a daily record of federal business. When a
Confined Spaces. OSHA’s Permit-Required Confined first draft of the proposed regulations has been
Space Standard 1910.146 defines a confined space as completed, a “Notice of Proposed Rulemaking” must
a “space the is large enough and so configured that an appear in the Federal Register. Interested parties must
employee can bodily enter and perform assigned work; then have at least 30 days to comment on the way
and has limited or restricted means for entry or exit proposed regulations will impact them. Following this
(e.g., tanks, vessels, silos, storage bins, hoppers, comment period, the final regulations are published in
vaults and pits are spaces that may have limited the Federal Register, and incorporated into the Code
means of entry); and is not designed for continuous of Federal Regulations, a permanent record of
occupancy.” government regulations organized by subject.
The confined space standard states the Those who feel they will be adversely affected
minimal requirements for safe entry, continuous work by a standard may request a judicial review.
in, and exit from tanks and other confined spaces. A Employers who cannot meet the standard, or believe
confined space program should include training in: an exception should be made in their cases because
• The duties of a standby person their facilities or methods are “at least as effective,”
• Use of ventilating equipment can request a temporary or permanent variance.
• Isolation of systems When new or particularly hazardous
• Atmospheric testing conditions warrant, OSHA may develop emergency
• Confined space entry limits standards, which take effect immediately. Once these
• The use/purpose of an entry permit standards have been published in the Federal
Register, they are also subject to comment and review
Understanding OSHA before they are published as permanent standards.
432
Table 1. Possible Fines for OSHA Violations.
are associated with high rates of illness or injury OSHA, it is entirely voluntary. No penalties are issued,
If OSHA discovers violations during an inspec- and OSHA enforcement compliance officers do not
tion, the employer will receive a citation, which details see the results.
the violation and includes information about penalties State officials or university staff often operate
and a schedule for compliance. Penalties may depend the Consultation Service. They may point out weak-
on the seriousness of the violation, knowledge of the nesses in an employer’s health and safety program
violation, and a show of cooperation or good faith. and provide the training and technical assistance
Serious penalties are also possible for repeat viola- needed to resolve any problems. Firms that participate
tions and failure to correct previous violations. Em- in the program receive a limited one-year exemption
ployers may want to schedule an informal meeting from OSHA inspection.
with OSHA’s area director, who is authorized to enter OSHA’s Voluntary Protection Programs
into settlement agreements that revise citations and encourage employers to take their health and safety
penalties. programs beyond the letter of the law and provide
The employer may also contest both a citation recognition for those who accept the challenge. The
and associated penalties within 15 days. The written Star, Merit, and Demonstration Programs are coopera-
Notice of Contest will be evaluated by the Occupa- tive programs, and participants are volunteers. These
tional Safety and Health Review Commission. Unfa- firms also receive limited exemptions from inspection.
vorable decisions can be appealed at this level and to Local OSHA offices can also provide publica-
the U.S. Court of Appeals. tions, speakers, audiovisual materials, and technical
Painting contractors are considered part of the advice. OSHA provides funds to nonprofit organiza-
construction industry for OSHA record-keeping tions to conduct workplace training and education. A
purposes. These businesses are most frequently cited number of private firms and universities also offer
for failure to comply with the Lead Standard. They are OSHA compliance training.
also frequently cited for respiratory protection, scaf-
folding (i.e., general requirements, manually propelled Components of OSHA Compliance
ladder stands and scaffolds, and training), hazard Company safety and health programs should
communication, and fall protection. be designed to be used in conjunction with the current
copy of the OSHA Construction Industry Standards 29
Consultation Assistance CFR 1926, and the General Industry Standards 29
OSHA provides a Consultation Service that CFR 1910. OSHA states in 29 CFR 1926.20 General
can help employers evaluate and improve their Safety and Health Provisions: “It shall be the responsi-
compliance. The service was developed with small bility of the employer to initiate and maintain such
employers in mind. Although the program is funded by programs as may be necessary to comply with this
433
part” (part refers to all of 29 CFR 1926). and their related General Industry standards include
The purpose of an OSHA Compliance Pro- the following:
gram is to establish and maintain policies, programs, • Abrasive Blasting: No specific standard applies to
and procedures that are necessary to comply with all blasting in the field, but many aspects of blasting
applicable OSHA standards, and to establish and operations fall under other applicable standards.
maintain an effective program to prevent accidents,
injuries, and illnesses. • Noise/Hearing Conservation: Noise protection
The components of an OSHA Compliance should be provided, and a Hearing Conservation
Program should include: Program should be in place and be in compliance with
• Policy statement establishing goals and commitment OSHA standard 29 CFR 1910.95, Occupational Noise
of management and the means for communicating Exposure.
these to all employees
• Delegation of responsibilities for implementing the • Respiratory Protection: The selection, issue, use,
program inspection, cleaning, storage, and repair of respirators
• Methods for identifying hazards and hazardous should comply with the OSHA Respiratory Protection
activities and for controlling them Standard, 29 CFR 1926.103. See section III F for more
• Commitment to ongoing training and education of all information on choosing respirators.
supervisors and employees on all aspects of job safety
and health • Confined Spaces: Practices and procedures used to
• Proper reporting, record-keeping, and investigation of protect employees from the hazards of entry into
all accidents, injuries, and illnesses permit required confined spaces should comply with
• Methods and procedures for complying with specific OSHA Standard, 1910.146, Permit-Required Confined
OSHA standards Spaces.
• Periodic review of the program with revisions made
as necessary
434
to the manufacturer’s specifications and limitations Gases, Vapors, Fumes, Dusts, and Mists is prohibited.
and OSHA standards 29 CFR 1926.300-305, Tools– Generally, OSHA requires employers to
Hand and Power. minimize employee exposure to air contaminants as
much as possible through the use of engineering
• Compressed Air: There is no existing OSHA stan- controls such as enclosure or confinement of an
dard for compressed air. However, there are standards operation, ventilation, or substitution of less toxic
set by the American Society of Mechanical Engineers materials. Only when acceptable levels of exposure
(ASME). cannot be achieved through these approaches (as is
often the case in coating operations) may employers
• Electrical: All electrical systems and equipment use respiratory protective devices to comply with these
should be designed and installed according to OSHA standards.
standards 29 CFR 1926.402-408, Installation Safety
Requirements, and the most current edition of NFPA • Housekeeping: During the workday, work areas,
70, National Electric Code. All employees performing passageways, and stairs in and around buildings or
work on electrical equipment or systems should other structures must be kept clear of debris according
comply with the work practices in OSHA standards 29 to OSHA Standard 1926.25, Housekeeping.
CFR 1926.416-417, Safety-Related Work Practices.
• Ladders and Scaffolding: Stairways and ladders
• Eye and Face: Eye and face protection should be must be designed, constructed, and used according to
provided when machines or operations present the manufacturers’ specifications and limitations and
potential eye or face injury from physical and chemical OSHA standards CFR 1926.1050 through 29 CFR
hazards as required by OSHA Standard 29 CFR 1926. 1060. Job-made ladders must conform to the
1926.102, Eye and Face Protection. Eye and face design and construction specifications of these OSHA
protection equipment required by OSHA should meet standards. The design, construction, load-bearing
the requirements specified in American National capabilities, platform guarding, and use of all scaffold-
Standards Institute Z87.1, Practice for Occupational ing must comply with OSHA standard, 29 CFR
and Educational Eye and Face Protection. 1926.450-454, Scaffolding.
• Fire Protection/Flammable, Combustible Liquids: • Personal Protective Equipment for head, foot,
Fire protection should be developed for all company and body: Hard hats must be used where there is a
activities according to OSHA standard 29 CFR possible danger of head injury from impact, from
1926.150, Fire Protection. This should include provid- falling objects, or from electrical burns as required by
ing, maintaining, inspecting, and testing fire suppres- OSHA standard 29 CFR 1926.100, Head Protection.
sion systems and portable fire extinguishers, as Helmets and hardhats for the protection of employees
required by this OSHA standard. The fire prevention against impact and penetration of falling and flying
requirements, specified in OSHA standard 29 CFR objects should meet the specification contained in
1926.151, Fire Prevention, should be implemented for American National Standards Institute, Z89.1, Safety
all jobs. Requirements for Industrial Head Protection. Helmets
The storage, handling, use, and fire protection for the head protection of employee exposed to high
requirements for flammable and combustible liquids voltage electrical shock and burns should meet the
and their containers should be in compliance with specifications contained in American National Stan-
OSHA standard 29 CFR 1926.152, Flammable and dards Institute Z89.
Combustible Liquids. Where the potential for serious foot injury
exists, safety-toe footwear for employees should be
• Exposure to Gases, Vapors, Dusts, Mists, and required and meet the requirements specified in
Fumes: Employee inhalation, ingestion, skin absorp- American National Standard for Personnel Protection–
tion, or contact with any material or substance at a Protective Footwear, Z41. Employees working with
concentration above the permissible exposure limit chemicals or materials that can cause damage to the
(PEL) specified in OSHA standard 29 CFR 1926.55, skin or that can be absorbed should be provided
435
Table 2. Task-Related Triggers Under the Construction Industry Lead Standard.
436
many surface preparation techniques may quickly protection factors of up to 1000.
overload the filtering systems on which air-purifying
respirators are based, and air-purifying equipment
may not be adequate to protect workers from high
lead levels associated with containment systems.
437
protection factors assigned by NIOSH, except in Monitor and maintain records relating to
cases where protection factors have been published accidents, injuries, illnesses, medical examinations,
in substance-specific standards (e.g., cadmium) or training, fit testing, and exposure monitoring for the life
are addressed by OSHA in separate letters of of the company. Analyze the firm’s total workers
interpretation. compensation costs over the years. Compare accident
rates and evaluate changes in employee attitudes and
Breathing Air Requirements. With any of the work quality. Seek assistance from employees to get
supplied-air respirators, including abrasive blast feedback on the success of the program.
hoods, it is essential that Grade D breathing air reach
the respirator. ANSI Standard Z 86.1/Compressed Gas Owner Evaluation and Monitoring of Contractor
Association commodity specification G-7.1 for Grade Programs
D Air requires oxygen levels of 19.5–23.5%, no more A representative of each facility owner should
than 5 mg/m3 condensed hydrocarbon contamination, evaluate and monitor all contractor health and safety
no more than 10 ppm carbon monoxide, no pro- and OSHA compliance programs. These programs
nounced odor, and a maximum of 1,000 ppm carbon should be submitted, approved, and monitored by a
dioxide. Controls must be installed on compressors to qualified individual, such as a certified safety profes-
achieve and verify compliance with these require- sional (CSP) or certified industrial hygienist (CIH). The
ments, or special-built, dedicated breathing air com- program evaluations should be completed before any
pressors must be used. The control/filter systems of work begins. Monitoring should be conducted through
existing oil lubricated compressors must be equipped job site visits and review of daily work logs.
with a constant monitor for carbon monoxide or a OSHA Standard 1910.119 Process Safety
heat-rise alarm with frequent measurement of in-line Management of Highly Hazardous Chemicals contains
carbon monoxide. In addition, periodic samples from the specific requirements and responsibilities for
the air stream should be drawn, bottled, and sent to a owner and contractor safety and health programs.
laboratory to verify that each parameter of Grade D This standard states that the owner is responsible for
breathing air has been met. obtaining and evaluating information regarding con-
tractor safety performance and programs.
Implementation of Safety and Health A good example of a safety program that each
Problems contractor in the coatings industry should have is
OSHA 1910.146 Permit-Required Confined Spaces.
Establishing Worker Safety and Health Programs Under this standard, the contractor must develop a
A worker safety and health program should written permit space entry program that complies with
first establish and then maintain those policies, the requirements of the standard. This program must
programs, and procedures necessary to comply with be reviewed by the owner to verify that contractor
all applicable OSHA standards, while also effectively safety procedures and practices are adequate and are
preventing accidents, injuries, and illnesses. After being followed.
identifying the program components, it is important to Maintaining a site injury and illness log, OSHA
dedicate the time to sit down with all company Injury and Illness Records Form 300, is another
managers and supervisors to review the program and method employers must use to track work activities
set specified goals for implementing its requirements. involving contract employees working on or adjacent
Have managers and supervisors do the same for all to covered processes. Injury and illness logs of both
the employees. Encourage participation. Be honest the employer’s employees and contract employees
and sincere. Continually ask for feedback and ways allow an employer to have full knowledge of process
for improving the program. Let everyone know they injury and illness experience. This log will also contain
will be consistently held accountable for fulfilling their information that will be of use to those auditing pro-
responsibilities under the program. Let good cess safety management compliance and those
performers know that they are doing a good job. At the involved in incident investigations.
same time, do not let poor or mediocre performance It is very important for owners to write OSHA
go unnoticed. compliance requirements into their contracts and
438
specifications. This will help ensure that the contrac-
tors are complying with the applicable OSHA
standards.
439