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1.1.
Some standards are frequently cited because these standards cover (1)
areas in which industries are having difficulty complying, or (2) areas
in which enforcement agencies are giving a great deal of attention, or
both.
1.2.
Many aspects about the standards might be useful. The text emphasizes
the importance of the "why" behind the standards that do exist.
1.3.
1.4.
1.5.
1.6.
1.7.
1.8.
Some valid examples are spray paint, coal dust, benzene, and carbon
disulfide.
1.9.
1.10.
Health hazards are usually more subtle than safety hazards; the
industrial hygienist must look for "unseen" hazards.
1.11.
Safety hazards may appear more grave, but there are probably many
health hazard-related illnesses and deaths which are not documented.
1.12.
1.13.
1.14.
1.15.
1.16.
1.17.
1.18.
1.20.
1.21.
Prior to passage of the OSHA law occupational health seemed remote and
not of a great deal of concern. Plant nurses were concerned with first
aid and physical examinations. After OSHA, occupational disease
prevention rose in importance.
RESEARCH EXERCISES
1.22.
www.nsc.org
Resources include library resources, safety training, professional
development seminars, videos.
www.asse.org
Resources include training, professional development, standards,
publications, annual conference and exposition, government
affairs information, and a national registry of safety engineers
in various areas of specialty.
www.aiha.org
Resources include employment services, laboratory services, education,
annual meetings, a consultant registry, and training support
materials, such as power point lecture outlines on various topics
related to industrial hygiene.
1.23.
The best websites for checking these requirements are the boards that
set the requirements. Following are the respective websites for the
certifications:
CSP: www.bcsp.com/
CIH: www.abih.org
1.24.
1.25.
1.26.
1.27.
1.28.
1.29.
Health hazards are usually due to unseen agents that must be identified
with scientific instruments. It is even difficult to determine and
quantify the degree of hazard, because health hazards have subtle
effects on the body. Another difficulty is long latency periods. A
worker's health is sometimes significantly and irreversibly affected,
but the effects do not appear until many years later. Safety hazards,
by comparison, have dramatic and instantaneous effects that can easily
be seen.
CHAPTER 2
2.1.
2.2.
2.3.
They too often are such emotional crusaders for the cause that they
lose their credibility and with it their eligibility to be considered a
"manager."
2.4.
2.5.
2.6.
2.7.
2.8.
2.9.
2.10.
2.11.
2.12.
2.13.
The "lost workdays" method would not reveal some very serious
accidents, especially fatalities, that do not cause a loss of a
workday.
2.14.
2.15.
25 x 200,000
300 x 40 x 50
2.16.
2.17.
2.18.
The
25 = 8.33
3
2.19.
2.20.
Yes; they can help to discover hazards, but they can also dilute
responsibility for workplace safety and health and can degenerate into
spy parties. Without adequate orientation, safety and health
committees can often become unreasonable.
2.21.
Direct costs are the "tip of the iceberg" compared to indirect costs.
2.22.
(1)
(2)
(3)
(4)
(5)
(6)
(7)
(8)
(9)
(10)
Costs of wages paid for time lost by workers who were not
injured.
Cost of damage to material or equipment.
Cost of wages paid for time lost by the injured worker.
Extra cost of overtime work necessitated by the accident.
Cost of wages paid supervisors for time required for activities
necessitated by the accident.
Wage cost caused by decreased output of injured worker after
return to work.
Cost of learning period of new worker.
Uninsured medical cost borne by the company.
Cost of time spent by higher supervision and clerical workers.
Miscellaneous costs such as public liability claims, rental
equipment, and lost sales.
2.23.
2.24.
First-line supervisors
2.25.
2.26.
LWDI
2.27.
(2 + 1) x 200,000
-----------------------25 x 2000
300/25 = 12
1 x 200,000
25 x 2000
(3+1+1+1+1) x 200,000
62 x 2000
11.29
(7+7+42) x 200,000
62 x 2000
90.3
(c)
LWDI
1 x 200,000
62 x 2000
1.6
3 x 200,000
135 x (4/12) x 2000
Since 6.67 > 3.6, this would indicate that improvement is needed to
meet the objective. However, if no more lost time injuries occurred
for the year (an unlikely outcome):
LWDI = 3 x 200,000 = 300
135 x 2000
135
= 2.22
File
1
2
3
4
5
6
7
8
9
10
11
12
M1
M2
M3
M4
M5
not recordable
X
14
not recordable
X
28
X
X
X
X
X
not recordable
X
14
not recordable
X
Column Totals:
(a) LWDI
X
4
42
70
3
38
X
X
4
= 1 x 200,000 = 1 = .11
900 x 2000
9
1 x 200,000 = 1 = .11
900 x 2000
9
Number-of-lost-workdays rate
108/9
12
= (1 + 1) x 200,000
900 x 2000
= 2/9 = .22
(b) Comparing National Safety Council Statistics for 2000 (see Figure
2.2 of the text):
Total incidence (including fatalities)
.89 << 6.1
therefore, much safer than the all industry average
2.30. To complete the table, add up the columns to get the following totals:
File
Column totals:
G
1
H
2
I
3
J
3
K
67
L
16
M1
4
M2
2
M3
2
M4
0
M5
1
M3
2
M4
0
M5
1
5 x 200,000 = 10
50 x 2000
2.31.
1998 premium
1998 modifier
unadjusted premium:
2001 modifier
2001 premium:
Actual savings:
% savings
2.32.
2.33.
166
$120,000
1.05
$120,000/1.05 = $114,286
.80
$114,286 x .80 = $91,429
$120,000 - $91,429 = $28,571
= ($28,571/120,000) x 100% = 23.8%
To complete the table, add up the columns to get the following totals:
File
Column totals:
G
1
H
2
I
3
J
3
K
67
L
16
M1
4
M2
2
= (1+2) x 200,000
165 x 2000
1.82
5.45
vs 6.1 (NSC)
16 x 200,000 =
165 x 2000
9.70
(Injury Facts, 2002 edition, reports 85,000,000 days away from work for
injuries incurred in the previous year (2001). The total worker force
was estimated at approximately 136,500,000. Applying the formula to the
national data:
Days Away From Work
85,000,000 x 200,000
136,500,000 x 2000
62.27
This figure is considerably higher than the 9.70 figure calculated for
the data in this problem.
2.34.
2.35.
The text shows the current National Safety Council cost estimates as
follows:
fatality: $790,000
work injury: $28,000
Each year the NSC publishes updates for these estimates in Injury
Facts. Students might want to check the library for the latest update.
The 2002 edition shows the following estimates:
fatality: $1,020,000
work injury: $29,000
2.36.
$120
2.38.
2.39.
Workplace violence
2.40.
The company did preemployment drug screening tests for all applicants
in a three month hiring period (750 applicants). Surprisingly, half of
the 750 applicants failed the test. The test was a urinalysis designed
to indicate whether drugs had been used in the preceding two or three
days and was conducted by a hospital laboratory service. The test
results indicated that the use of marijuana was the most prevalent.
ALCOA hired 130 applicants who passed the test and reported that as a
group those hired were better workers than those hired prior to the
drug screening program.
2.41.
The firm may face discrimination charges unless it is fair and evenhanded in its policies for hiring and employee termination in cases of
alcohol or drug abuse. The same rules that are applied to new
employees should be applied to existing employees.
2.42.
2.43.
2.44.
a.
b.
c.
d.
e.
f.
g.
h.
2.45.
control of sharps
effective system of housekeeping
effective laundry
effective disposal of waste
washing, cleaning, and disinfecting exposed surfaces
provision for storage and consumption of food in areas protected
from exposure
prohibition of application of cosmetics, lip balm, or contact
lenses in exposed areas of the plant
provision of personal protective equipment.
the eyes
RESEARCH EXERCISES
2.46.
2.47.
The answer to this question will vary from year to year. The most
recent issue (2002) of the NSCs Injury Facts at the time of this
writing (2003) showed statistics for the nine-year period 1992 - 2000,
to be 10,287. The most recent single year statistics are found in the
2000 edition and report 709 occurrences of workplace violence. The
incidence of workplace violence has diminished in recent years. Still,
workplace violence ranks number 2, just behind traffic accidents, as
the leading cause of worker fatalities. The 2003 edition of Injury
Facts will likely include victims of the September 11, 2001 tragedies
and will show a significant difference in the statistics due to this
tragic day in the history of the American worker.
2.48.
OSHA News Release 96-99 (3/14/96) reports one study done by the U.S.
Department of Justice in a National Crime Victimization Survey, which
showed approximately one million persons assaulted each year in the
five-year period of the study (1987 to 1992). Of this number, 600,000
were simple assaults, 200,000 were aggravated assaults, nearly 80,000
were robberies, and more than 13,000 were rapes.
2.49.
2.50.
CHAPTER 3
3.1.
3.2.
De minimus
3.3.
Author's opinion:
3.4.
3.5.
3.6.
3.7.
3.8.
Unsafe acts
Unsafe conditions
Unsafe causes
3.9.
3.10.
crane hoists
3.11.
3.12.
3.13.
3.14.
88%
10%
2%
100%
5:1
Ratio = 88:10
scaffolds
4:1
scaffold ropes
3.15.
6:1
3.16.
3.17.
faults
faults
worker
3.18.
Proximal causes are primary and are direct causes of accidents in the
conventional sense. Distal causes are secondary, more indirect causes,
but can be as important as proximal causes because the distal causes
create and shape the proximal causes. Management policy should be
considered a distal cause.
3.19.
3.20.
3.21.
(a)
(b) Probability =
P[11] = P[5]P[6] + P[6]P[5]
= 1/6 1/6 + 1/6 1/6
= 1/36 + 1/36 = 2/36
(c) Yes; you can roll a "5" on the first die and "6" on the second
or you can roll a "6" on the first die and "5" on the second but
3.22.
3.23.
3.24.
Tangible cost/incident
15,000
Intangible cost/incident 250,000
Total cost/incident 265,000
Expected cost/year = Cost per incident x annual incidence
frequency
Before installation:
Expected cost/year = $265,000 x .01 = $2650
After installation:
Expected cost/year = [$265,000 x .01] = $1325
Annual benefit = $1325
3.25.
Costs
Amortization
Maintenance
Utilities
Total Costs
Benefits
Cleaning
Resp eqpmt savings
Short Term Illnesses
Long Term Illnesses
Total Benefits
$15,000
600
1,800
$17,400
$1,200
4,000
3,600
6,000
$14,800
lowest
6
7
2
1
2
1
7
2
highest
10
10
9
8
8
7
10
9
average
7.36
8.24
6.43
4.50
5.88
2.20
8.43
4.78
The
sample size
22
25
25
24
24
25
23
23
3.27.
3.28.
When the events are not mutually exclusive; when both events can happen
there is a finite probability that both will happen. Therefore, the
probability that both will occur is non-zero and must be subtracted
from the sum of the probabilities that each event will occur.
3.29.
3.30.
3.31.
=
=
=
One concept would be safety factor. A proper safety factor would have
allowed for shock loads that would be anticipated if a large number of
people began to move or jump on the skywalk in unison. Another
engineering concept is the failsafe Principle of Worst Case. A
properly applied Worst Case Principle might have considered the
possibility that large groups might move in unison.
3.33.
3.34.
There are many examples of the use of the concept of redundancy. One
example is the provision for emergency backup power generators in the
design of hospitals. Another example that applies to occupational
safety and health is the provision of independent, battery-powered
emergency lighting to provide illumination of means of egress from
buildings in the event of power failure.
3.35.
3.36.
3.37.
3.39.
3.40.
3.41.
RESEARCH EXERCISES
3.42.
3.43.
3.44.
3.45.
3.46.
Using the keyword search capability in the NCM Database, a query was
constructed on the following character string: *train* (This base
string was used in the query, instead of "training", "trained",
"trains", etc. so as not to limit the search to certain stems of the
word.) Using *train* the total number of citations was reported as
28029. Doing a "new search" for the total number of serious citations,
using the same character string *train* the total number of serious
citations was reported as 13250. Using these two results the percentage
of serious citations is calculated as 13250/28029 = .47 or 47%.
3.47.
CHAPTER 4
4.1.
4.2.
4.3.
The OSHA law provides for the right for employers to appeal a citation
through the judiciary system. The appeal can be taken as far as the US
Supreme Court.
4.4.
4.5.
4.6.
A standard which was adopted by OSHA during OSHA's first two years of
existence. These standards bypassed the procedural safeguards to allow
"existing standards" already in use to be adopted. None have been
adopted since the Nixon administration because the authority to adopt
"national consensus standards" expired in 1973.
4.7.
Performance standards:
(1) are somewhat vague,
(2) permit judgment to determine the best method to correct a
situation
Specification standards:
(1) provide a clear means of determining whether a given facility
or equipment meets a standard
(2) permit no latitude in choosing alternate ways to eliminate or
reduce the hazard
4.8.
4.9.
4.10.
4.11.
4.12.
Specification standards:
standard.
4.13.
(1)
(2)
(3)
(4)
Imminent danger
Fatalities and major accidents
Employee complaints
High-hazard industries
4.14.
4.15.
4.16.
4.17.
4.18.
4.19.
4.20.
4.21.
The first appearance of the predecessor agency was 1914 when the agency
was part of the Department of Industrial Hygiene and Sanitation in
Pennsylvania. The agency went through several reorganizations before
safety was added to its mission with passage of the OSHA law in 1970.
4.22.
4.23.
4.24.
Construction
4.25.
4.26.
When a state plan for standards and enforcement has been approved by
OSHA for the state to enforce its own occupational safety and health
standards. Also, some states are imposing standards enforcement
through implementation of extra-hazardous employer programs
administered by the state Workers Compensation system.
4.27.
processing plant. The fact that the tragedy occurred in North Carolina
was significant, because North Carolina was the first state to receive
federal OSHA approval for state standards development and enforcement.
The tragedy focused attention on state plan effectiveness in general.
4.28.
The text does not explain this difficulty in detail. The following
explanation is offered: once a standard has been in effect and firms
have been fined for failure to comply, it is difficult for the federal
government to justify to the public a reversal and conclude that the
standard was not really needed in the first place. There will always
be two sides to the issue of revocation (or promulgation) for a given
standard. In light of such controversies it becomes difficult to
justify a revocation of an existing standard.
4.29.
RESEARCH EXERCISES
4.30.
4.31.
4.32.
For the employEE version of the General Duty Clause, do not expect to
find any OSHA citations. The NCM Database can be used to search for
Section 5(B) by entering the following standard number: 5B (no
blanks). The NCM Database will return a message that no violations were
found relevant to this query.
4.33.
4.34.
This data was once available on the Internet but the website may have
been taken offline or the data removed from it. Possible places to
look: OSHA website or the Bureau of Labor Statistics
4.35.
4.36.
Some large fines have been assessed. Check the Internet for the latest
statistics. Some sample text from the Internet:
SAN ANTONIO (Apr 23, 1996 - 19:12 EST) -- Deaf basketball fans filed a
class-action lawsuit against the NBA and the San Antonio Spurs on
Tuesday, seeking video captioning on television monitors in all the
league's arenas.
REF:http://www.nando.net/newsroom/ap/bkb/1996/nba/san/feat/archive/042396/san10115.html
Settlement Agreement Between the U.S. and the Board of Education of
the City of Chicago. Settlement agreement concerning Title I case
referred by EEOC to the DOJ for refusal to relocate classroom as an
accommodation for a teacher and forcing him to take sick leave and
ultimate retirement; $20,599 awarded as compensatory damages; November
30, 1995 (Settlement Agreement). REF: http://www.pacdbtac.org/press.html
..United Artists will also pay monetary damages to the plaintiffs
who filed the private suit and will set up a $429,000 fund for
moviegoers with disabilities who can show they encountered physical
barriers at California theaters built after July 1982.
REF: http://www.pacdbtap.org/pr11.txt
4.37.
The
4.38.
The maximum penalty is $5000 for each day of noncompliance. (ref Title
28. Insurance, Part II. Texas Workers Compensation Commission, Chapter
165. Rejected Risk: Injury Prevention Services, paragraph 165.9 Report
of Follow-up Inspection) found on the Internet.
4.39.
4.40.
The OSHA proposed penalty for Samsung Guam totaled $8,260,000. The
final settlement amount Samsung Guam agreed to pay was $1,850,000. (ref
OSHA News Release USDL:96-525)
128,582 violations
Repeat:
Willful:
1,399 violations
288 violations
=
=
1399/128582
.01 or 1%
288/128582
Note that the NCM Database will not return total figures if * is used
in a "keyword search" because too many entries will be returned. The
Database will ask you to narrow your search.
4.42.
4.43.
$3496904/1243
approx $2813.
Answers will vary, depending upon which standards the student picks for
his/her sample to study. The author picked popular standards 1910.212,
1910.36 and 1910.151, with the following results returned from the NCM
Database:
*212*
Total violations:
5154
*36*
Total violations:
1037
*151*
Total violations:
1882
.002
8073
=
16
CHAPTER 5
5.1.
5.2.
5.3.
Pipes
5.4.
5.5.
5.6.
5.7.
Yes
5.8.
5.9.
5.10.
5.11.
5.12.
5.13.
5.14.
5.15.
5.16.
5.17.
5.18.
$850 billion
RESEARCH EXERCISES
5.19.
5.20.
As of this writing, the author found 100 hits using InfoSeek and the
keywords HAZWOPER | training
5.22.
5.23.
A search of the OSHA website reveals that the standard for Hazard
Communication is OSHA standard 29CFR1910.1200. Searching the NCM
Database by standard, with the query *1200* returns the following
totals:
Total citations: 15537
Number of serious citations: 5522
Computing the percentage:
5.24.
Percentage = 5522/15537
.355
= 36%
First, using the OSHA website, determine that the appropriate OSHA
standard is 29CFR1910.1200. This can be determined through a search of
the entire OSHA website for the term MSDS. Then in the 1910.1200
standard, use the Edit Find (in this document) feature to find the
appropriate provisions of 1910.1200 that contain the desired term.
First try MSDS, but this search turns up only a few references in the
definitions section of the standard. A more fruitful search results
from searching on the whole term written out as Material Safety Data
Sheet. One can accomplish as much with a search on Material Safety
because whenever Material Safety appears in 1910.1200 almost surely
the entire term Material Safety Data Sheet will appear. Upon using
Edit Find for the term Material Safety approximately 40 to 50
hits result. Ignoring the multiple hits within a single provision of
the standard, a total of 36 provisions were found to contain the term
Material Safety. After writing out this series of provisions, the NCM
Database can be opened to perform searches for Total Violation
Citations for each of the respective provisions of 1910.1200. Such a
search of the 36 provisions revealed the following frequencies of
citation, which were manually entered into an Excel spreadsheet:
Standard
provision
Standard
provision
Citation frequency
1200(e)(1)
(e)(1)(i)
(e)(2)(i)
(f)(2)(ii)
(g)
(g)(1)
(g)(2)
(g)(2)(vi)
(g)(2)(viii)
(g)(2)(ix)
(g)(2)(xi)
(g)(2)(xii)
(g)(3)
(g)(4)
(g)(5)
(g)(6)(i)
(g)(6)(ii)
(g)(6)(iii)
5134
859
28
0
0
1486
2
4
0
1
0
1
1
0
0
0
0
0
(g)(6)(iv)
(g)(7)(i)
(g)(7)(ii)
(g)(7)(iii)
(g)(7)(iv)
(g)(7)(v)
(g)(7)(vi)
(g)(7)(vii)
(g)(8)
(g)(9)
(g)(10)
(g)(11)
(h)(1)
(h)(2)(iii)
(h)(3)(iv)
(i)(1)
(i)(1)(ii)
(i)(1)(iii)
Total citations
Citation
frequenc
y
0
1
0
0
0
0
0
0
923
3
4
21
2121
62
51
0
0
1
7516
5.25. Using the NCM Database searches were performed on the following terms with the
total number of citation violations as shown in the following spreadsheet
manually entered from the NCM Database search results:
SEARCH TERM
"medical surveillance"
"medical"
"examination"
"medical examination"
"physical examination"
"medical record"
CITATIONS
183 citations (2 pages of
provisions)
4790 citations (5 pages of
provisions)
1775 citations (2 pages of
provisions)
58 citations
20 citations
320 citations
The total number of citations can not be added from the above table because
obviously there are duplications in the search hits. For instance, every search hit
in the search for medical surveillance will also be found in the more general
search for the term medical.
CHAPTER 6
6.1.
6.2.
6.3.
6.4.
Materials of construction
Piping diagrams
Instrument diagrams
Relief system design
Ventilation system
Design codes and standards
Material and energy balances
Safety interlocks
Detection systems
Suppression systems
6.5.
6.6.
6.7.
6.8.
6.9.
6.10.
6.11.
6.12.
6.13.
6.14.
6.15.
1.
2.
3.
4.
6.16.
The employees may lose or fail to carry the cards on their person.
the credibility of
employer. It costs
a measure of
the problem of
Initial training
Refresher training
Verification or testing
Documentation
6.17.
Employers who deal with highly hazardous chemicals subject to the OSHA
standard for Process Safety and who subcontract part of their process
operation or maintenance to a contractor are required to keep the OSHA
200 Log/Summary of Occupational Illnesses and Injuries on the
contractor personnel as well as on their own employees.
6.19.
6.20.
6.21.
6.22.
6.23.
6.24.
6.25.
RESEARCH EXERCISES
6.26.
6.27.
30 hits
From the OSHA web site it can be determined that the Process Safety
standard is OSHA standard 29CFR1910.119. A search of the NCM database
reveals that the Process Safety standard was cited a total of 932 times
during the Fiscal Year reporting period. Of these, 769 were designated
as alleged serious violations. From these data it can be calculated
that in excess of 82.5 % of the alleged violations were designated as
in the serious category.
6.29.
From the OSHA web site it can be determined that the Process Safety
standard is OSHA standard 29CFR1910.119. A word search on "training" on
the NCM database reveals the portion of the Process Safety standard
that pertains to training, 1910.199(g). By performing another query on
the NCM database it can be determined that there were a total of 79
alleged violations of the provisions of 1910.119(g). To get a picture
of the total alleged violations of 1910.119 a new query can be made on
the NCM database for *119* Also, one can check each of the
subparagraphs of 1910.119 for frequency. Following is a tabulation of
those frequencies in which the subject matter of the subparagraph was
obtained from the OSHA web site and the frequencies of citation from
the NCM database:
119(a)
119(b)
119(c)
119(d)
119(e)
119(f)
119(g)
119(h)
119(i)
119(j)
119(k)
119(l)
119(m)
119(n)
119(o)
119(p)
"Application"
"Definitions"
"Employee participation"
"Process Safety Information"
"Hazard Analysis"
"Operating Procedures"
"Training"
"Contractors"
"Pre-startup Review"
"Mechanical Integrity"
"Hot Work Permits"
"Management of Change"
"Incident Investigation"
"Emergency Planning and Response"
"Compliance Audits"
"Trade Secrets"
Total
0
0
46
120
46
183
79
39
15
135
7
70
28
27
37
0
732
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
citations
A search of the OSHA web site reveals that the appropriate section for
"employee participation" in the Process Safety standard is
29CFR1910.119(c). A search of the NCM database on this provision
(*119C*) reveals that 46 citations were written for the Fiscal Year on
this subject. Another search on this provision (*119C*), using the
"serious violations" option of the NCM database, reveals that 37 of
these 46 citations were classified as alleged "serious violations." The
citations in the "serious" category represent over 80% of the citations
for "employee participation."
CHAPTER 7
7.1.
7.2.
Standards:
7.4.
7.5.
Many people do not think about the difference between jumping and
falling from a 4 ft. height.
7.6.
7.7.
7.8.
7.9.
7.10.
Whenever it is a hazard.
removable cover.
7.11.
7.12.
Compare housekeeping goals with standards for the given industry. Keep
accurate records of accidents and take appropriate steps to remove
causes whether they be housekeeping or other causes.
7.13.
7.14.
7.15.
7.16.
7.17.
When a fixed ladder is more than 20 feet but less than 30 feet long.
Alternative devices may be used on tower, water tank, and chimney
ladders over 20 feet in unbroken length.
Advantages: inexpensive and effective in appropriate weather.
Disadvantages: responsibility for use is left to the worker, and icing
can cause problems.
7.18.
"Means of egress" are (1) the way of exit access, (2) the exit itself,
(3) the way of exit discharge.
7.19.
7.20.
7.21.
7.22.
7.23.
7.24.
7.25.
7.26.
Building codes include safety features that are appropriate for any new
construction, or perhaps remodeling, but may not be practical for
retrofit on existing buildings. Federal standards that relate to
buildings and facilities sometimes address issues of relative
permanence and have been interpreted as applicable to existing as well
as new facilities. The result has been costly renovation to comply
with rules that many believe should apply only to new facilities.
7.27.
7.28.
The Life Safety Code specifies a minimum exit access aisle width (28
inches), whereas the OSHA standards specify no minimum except in
performance language (sufficient safe clearances). The OSHA
Formerly the OSHA standard for aisle marking specified black or white
color. This strict specification was revoked by OSHA, which now
permits any color provided the function is maintained (performance
standard).
7.30.
7.31.
7.32.
RESEARCH EXERCISES
7.33.
7.34.
As of this writing, using INFOSEEK the author found 105 hits using the
keywords Triangle Shirtwaist. The Triangle Shirtwaist event was
historic and still is being described in current documents. A
particularly gripping and detailed account was found at the following
internet address:
http://www.tcr.org/triangle.html
7.36.
It takes some digging in the OSHA web site but by searching on the word
"Aisle" (be sure to capitalize the word "Aisle" in this case), one can
find that OSHA standard 1910.22(b) pertains to "Aisles and
Passageways". The appropriate provision for the maintenance of aisles
is 1910.22(b)(1). A query on the NCM database (*22B01*) reveals that
this provision was cited 221 times in the Fiscal Year. Also relevant to
the maintenance of aisles is the appropriate marking of aisles
(1910.22(b)(2). The NCM database shows 55 citations for a query of
*22B2*.
7.37.
A search of the OSHA web site reveals that General Industry OSHA
standard 1910.36(b)states that An exit door must be unlocked. This
provision contains three subparagraphs b(1), b(2) and b(3) that explain
further. Turning to the NCM database it can be found that two of these
subparagraphs have been cited. 36(b)(1) was cited 129 times in the
fiscal year reporting period, and 36(b)(2) was cited 139 times.
Searching the NCM database again, this time by total number of
CHAPTER 8
8.1.
Ergonomics is a broad field and draws upon many different sciences. The
relevant facets of the field as described in Chapter 8 of the text include the
following:
a. Ergonomic vehicle design for human performance
b. Designing safety features into workplace machines
c. Controlling the work environment, including:
1. Manual lifting
2. Accommodating individual worker characteristics
d. Workplace Musculoskeletal Disorders (WMSDs)
8.2.
8.3.
8.4.
8.5.
Both the ANSI and the OSHA standards for ergonomics were developed at the same
time (the decade of the 1990s). The OSHA standard was intended to be mandatory
and would be enforced with inspections and penalties. The ANSI standard was
developed using the traditional standards development framework used for all
ANSI voluntary standards. The two standards were very similar in content. Both
had provisions for management plans for ergonomics. However, the components
in the management plan in the provisions of the ANSI standard went beyond the
management plan requirements specified in the OSHA standard. The ANSI standard
specified job analysis and job design and intervention, emphasizing the
analysis and prevention of future hazards before the occurrence of the WMSD
cases.
8.6.
8.7.
No one questions the fact that taken on average the average male can lift a
heavier load than the average female. Despite this obvious fact, it is
incorrect to discriminate against females for jobs requiring manual lifting
based upon their gender. Some females can lift more than the average male can,
and some males can not lift as much as the average female can, so employers
should use care to test and qualify workers based upon their capabilities, not
upon their gender.
8.8.
NIOSH has conducted intensive studies of the effectiveness of back belts. The
studies showed no statistically significant improvements in decreased
frequency of worker compensation claims rates for employers who require the
use of back belts versus employers who do not. Studies also compared workers
who voluntarily use back belts every day versus those who do not use them or
use them only occasionally. There was no statistically significant difference
in workers compensation claim frequency. Besides studying workers compensation
claim frequency, NIOSH also studied "self-reported back pain" and again the
results showed no statistically significant difference between back belt users
and those who do not wear back belts.
8.9.
8.10.
8.11. One problem is that it is not clear that the rule prevents back injuries.
Manual lifting is one of the most studied subjects in ergonomics, but to date
the studies are still inconclusive. Injuries continue to be prevalent, even in
the industries that emphasize "proper" lifting techniques. Even NIOSH, the
federal agency charged with the mission of studying hazards and recommending
standards, has little respect for the benefits of training in proper lifting.
This is another reflection of the general distrust of the often-heard rule,
Lift with your legs, not with your back.
8.12.
8.13. The term MSDS is the abbreviation for Material Safety Data Sheet. The term MSD
is the abbreviation for Musculoskeletal Disorder. The term MSDs (note the use
of lower-case s) refers to the plural of Musculoskeletal Disorder(s).
Therefore, MSDS and MSDs, though similar in appearance, represent quite
different terms in the field of occupational safety and health.
8.14. After a decade-long promulgation process an OSHA standard for Ergonomics was
issued in the waning days of the Presidential administration of Bill Clinton
at the end of the year 2000. However, the politically-controversial standard
was immediately overturned by the new Congress when it reconvened in 2001
after the elections. The agency is prohibited by Congress from reintroducing a
slightly different version of the standard.
8.15. Back belts are very controversial, and there is little evidence that they
prevent back injuries. NIOSH has studied back belts to test the hypothesis
that they reduce workers compensation claim incidence and that they reduce
self-reported back pain. The study showed no significant difference between
the groups who used back belts, versus the groups who did not use them. The
studies were very comprehensive and collected data on 9,377 workers in 160
stores nationwide.
8.16. The chapter does not address this question directly. Certainly research
studies have cast doubt upon the utility of back belts in preventing injury or
in reducing back pain. Training and education of the worker is an important
part of any hazard prevention program, and certainly this is an important
aspect of a program for ergonomics and the prevention of WMSDs. It is
recognized that workers may simply like to wear back belts, and, accordingly,
it appears that they should be permitted this privilege. Recognizing
principles studied in earlier chapters of the text, the employer should
endeavor to adequately train employees so that they do not become misled by a
false sense of security arising from the use of back belts.
8.17. Punch presses often have covers over the foot pedal to prevent inadvertent
actuation of the pedal which would trigger an unwanted stroke of the press
ram. To use the pedal, the operator must deliberately extend the toe of
his/her shoe into the cavity under the cover and then depress the pedal.
Another feature of punch presses is two hand tripping or control mechanisms.
By requiring the concurrent actuation of the two pushbuttons, both of the
operators hands are protected from entry
8.18. Despite the emphasis that has been placed upon "proper lifting techniques"
there has been little evidence that such training prevents injuries. Employers
are reluctant to discontinue such training for fear of injuries and subsequent
claims of employer negligence for failure to provide adequate training. Even
NIOSH has shown little respect for the benefits of training in proper lifting
by referring to training of workers in safe methods of manual material
handling as a practice that "is likely to continue despite the lack of
evidence to support it."
8.19. Both the OSHA standard (that was rescinded) and the draft ANSI standard
contained requirements for a WMSD program. The ANSI wording was similar to the
OSHA wording but went a little further to specify job analysis and job design
and intervention, even if WMSDs had not yet been manifested in the workplace.
Program components required in the draft ANSI standard are as follows:
Management responsibilities
Training
Employee involvement
Surveillance
Evaluation and management of MSD cases
Job analysis
Job design and intervention
8.20. Once a WMSD problem has been identified, the responsibility is upon the
employer to do something about it. Once reported, the hazard becomes
recognized and steps must be taken to eliminate it. Personal protective
equipment is not generally accepted as appropriate. Engineering or work
practice controls must be instituted. Engineering controls are best because
they eliminate the hazard. The policy of ramp-in for new employees in new
jobs is considered an administrative or work practice control. Another
administrative control is job rotation.
8.21. Food manufacturing and processing; meat-packing, especially poultry; the
nursing home industry (especially nurses and healthcare providers). Another
concern is computer terminal operation, a job function that touches virtually
all industries.
8.22. Beverly Enterprises, Ft Smith, Arkansas, a provider of healthcare services
(especially nursing homes), and Pepperidge Farms, Downingtown, Pennsylvania, a
maker of biscuits.
8.23. Ramp-in gives new employees or existing employees on new jobs the
opportunity to practice and become accustomed to the requirements of the new
job. Ramp-in is considered an effective method of reducing unnecessary
discomfort for new employees who perform repetitive tasks. An added advantage
of ramp-in is that it permits the setting of high performance (productivity)
standards for the job. Even though the new worker to the job can not meet the
high standard, the standard is considered a norm for the new worker to work up
to after the ramp-in period is complete.
8.24. Since ramp-in involves a change in procedure or the pace of the job, it should
be considered an administrative, not engineering, control.
8.25. The classical three lines of defense are (1) Engineering controls, (2)
Administrative or work practice controls, and (3) Personal protective
equipment. The third line of defense is widely used in protecting workers from
noise and respiratory hazards, but, for WMSDs, the effectiveness of personal
protective equipment is not widely recognized. Engineering controls are
definitely preferred as a means of eliminating, not just mitigating, the
hazard of WMSDs.
8.26. The answer to this question is a moving target. As of this writing the ANSI
standard had still not been finalized. A search of the Internet yielded
thousands of hits for the search term ergonomics standard, but most of the
articles were several months old and referred primarily to the OSHA standard
that is now defunct. Future searches on this question may result in quite
different results.
8.27. Following are some distributors found on the Internet, along with quotations
of claims for their back belts:
Northern Tool and Equipment: Four flexible 7 1/2in. stays give you extra
lower back support. Tapered front panels make it easy for you to bend.
Breathable and machine washable.
Comfort House: orthopedically designed for maximum support unique
overlapping side-pulls provide added support and compression to your
abdomen and lower back. Encourages proper lifting technique
limits excessive lumbar movement during physical exertion.
TorsoSport: Real back support precisely molded to fit both the lower back
and abdominal muscles providing unprecedented comfort product that
will stand the test of time This source also used the following
language that did not amount to an actual product claim, but implies
one: There has been a dramatic increase in the number of individuals
who rely on back supports or weightlifting belts to help prevent
injuries during their daily exercise and leisure routines.
8.28. The following general comment was found on the Internet:
Ergonomics in the Automotive Industry
Virtually all automobile and component manufacturers already recognise ergonomics as
an important part of vehicle design. For example, the first phase of the design
process is to make sure that the driver can reach all of the controls, see and
understand the dashboard displays, and feel comfortable in the seat. Failure to
address ergonomics in vehicle design leads to poor driving performancewhether it is
Nigel Mansell not fitting into his Formula One driver's cab or your own sore back
after a long motorway journey. Customers value ergonomic design and they will pay
for it.
http://www.system-concepts.com/case/autohs.html
In this article the point was made that the auto industry pays close attention
to the ergonomics features of the products they sell to the public, but they
give less attention to the ergonomics principles in the design of work
stations for their own employees. Despite the claim that auto manufacturers
use ergonomics in the design of their products, use of the word ergonomics
is not commonly found in sales literature. This author did not find the word
in general use when searched within specific manufacturers websites for
marketing their products.
8.29. At the time of this writing, the OSHA website contained a link to ergonomics
as a category within the Safety/Health Topics listing in the contents
section. This linked revealed that though the general Ergonomics standard was
dead, OSHA remains active in the field of ergonomics. There were public
announcements of new ergonomics guidelines proposals in at least three
industries: poultry, retail grocery, and nursing homes. In addition, OSHA
announced a four-pronged comprehensive approach to dealing with ergonomics,
in particular with workplace musculoskeletal disorders. These four approaches
were listed as: Guidelines, Enforcement, Outreach/Assistance, and Research. In
the enforcement arena, OSHA made reference to the General Duty Clause and
stated that the elimination of recognized serious hazards includes ergonomics
hazards. This implies that OSHAs enforcement strategy for ergonomics makes
use of the General Duty Clause. At the same time, OSHA said that it will not
focus its enforcement efforts on employers who have implemented effective
ergonomic programs or who are making good-faith efforts to reduce ergonomic
hazards.
CHAPTER 9
9.1.
9.2.
The term "toxic substances" generally refers to agents that cause harm
to the body. Examples would be irritants, systemic poisons,
depressants, asphyxiants, carcinogens, teratogens, and mutagens.
"Hazardous materials" are more likely to be associated with safety
hazards, such as fire and explosion hazards. Admittedly, toxic
substances are also hazardous, but the terminology used by OSHA and
practicing professionals is to make the above-described distinction
between the two terms.
9.3.
9.4.
9.5.
9.6.
Dentistry
9.7.
For most toxic substances, OSHA has taken a general approach and has
published "national consensus" PELs, based upon existing TLVs published
by the American Conference of Governmental Industrial Hygienists
(ACGIH). However, for some substances OSHA has gone much further and
written "completed" standards, each addressing a particular substance.
Prominent examples of such substances are asbestos and lead. Other
prominent examples include benzene, vinyl chloride, cadmium, and
arsenic. (See Table 9.1 of the text).
9.8.
9.9.
9.10.
9.11.
9.12.
Em =
Carbon
Monoxide
50
Carbon
Dioxide
5,000
Ci
330
x
-- = ------- + ---- < 1
Li
5000
50
x
50
x
50
x <
< 1 -
<
330
5000
9670
5000
9670(50)
5000
9.13.
Concentration
.00001
.00015
Total
Length of Time
4 hr
4 hr
C x Ti
.00004
.00060
8 hr
.00064
CiTi
.00064
E = --------- = ------- = .00008
8
8
TWA
.00008 = ---106
TWA = 80 ppm
The PEL for methyl styrene (from Appendix A.1) is 100 ppm and is
preceded by the letter C, which identifies it as a "ceiling"
concentration, not a TWA. The AL, at one-half the PEL, would be 50
ppm, also a "ceiling" concentration. Since the afternoon
concentration, at .00015 = 150 ppm, exceeds both PEL and AL ceilings,
both PEL and AL are exceeded, even though the TWA at 80 ppm is lower
than the PEL.
9.14.
TWA
= .001 x 3
8
TWA
= .0005(8)
8
(trifluorobromomethane)
(propane)
8
Em =
Concentration
.001
.0005
1 x 10-6
trifluorobromomethane
propane
phosgene
Ci
LI
375
1000
500
1000
Duration
3 hrs
8 hrs
1/4 hr
(phosgene)
+ .03125
.1
= .375 + .5 + .3125
Em = 1.1875
Since Em > 1, the mixture exceeds the OSHA PEL (and the AL, too).
(b)
< .125
< .125
< .1 hr = 6 min
Therefore, to meet the OSHA PEL a total of 6 minutes exposure of
phosgene (at one part per million) is permissible given the other
contaminants. This represents a decrease in exposure of 9 minutes (15
min. - 6 min. = 9 min.).
9.15.
9.16.
CO
Conc. Length C x L
10
2
20
20
2
40
25
1
25
30
3
90
Total
175
Iron Oxide
Length C x L
2
2
2
8
1
2
3
9
21
Conc.
1
4
2
3
Total
Manganese
Conc. Length C x L
1
2
2
1
2
2
0
1
0
1
3
3
Total
7
PELs
50
5000
10
(C)5
Ci
Li
= 21.875
50
=
+
TWA
PEL
1000
5000
2.625
10
1
5
= .4375 + .2 + .2625 + .2
Em = 1.050
Since Em = 1.050 > 1, the mixture exceeds the PEL.
9.17.
9.18.
9.19.
9.20.
9.21.
At home, ingestion, skin contact, then inhalation are the order of most
frequent occurrences of poisoning. At work, the order is reversed.
9.22.
Vapors are gases that come from substances that are normally in a
liquid or solid state. Fumes are solid particles which are too fine to
be considered as dust. Fumes are usually formed by the
resolidification of vapors from very hot processes such as welding.
9.23.
(a)
(b)
(c)
(d)
9.24.
9.25.
9.26.
9.27.
8:00-10:00
10:00-11:00
11:00- 1:00
1:00- 4:00
Total
TWA
2
1
2
3
8
hrs
hr
hrs
hrs
hrs
50
150
100
200
1050/8 = 131.25
PEL
200
Ratio TWA/PEL
100
150
200
600
1050
5
10
5
10
60/8 = 7.5
25
Sulfur
Dioxide
C iT i
Ci
10
10
10
30
60
0
1
1
1
Total
(Mixture)
CiTi
0
1
2
3
6
6/8 = .75
5
131.25/200 = .65625
7.5/25 = .3
.75/5 = .15
1.10625 > 1.0; mixture exceeds the PEL.
9.29.
9.31.
(The AL is exceeded.)
With the hot oven adding an additional 25 ft3 of alcohol vapor to the
room, the total would be 5 ft3 + 25 ft3 = 30 ft3. Under these new
conditions, six times as much vapor has been introduced into the
apartment's air. If it is assumed that the initial and average
concentrations are also six times as great as in Exercise 9.30, then:
Concentration initial = 6 x 1042 ppm = 6252 ppm
Average concentration 6 x 771 ppm = 4626 ppm
Since 4626 ppm > 1000 ppm, PEL is exceeded.
9.32.
Percent
PPM
Tube 5H
Lower
Upper
.05%
8.0%
500
80000
Range
Lower
.002%
20
Tube 5M
Upper
.36%
3600
9.34.
From Table A.1 of the text, the PEL (TWA) for isopropyl acetate is 250
ppm. The
AL = 1/2 PEL = 125 ppm
Detector tube range: 0.05% to 0.75%
converted to ppm:
Detector tube range: 500 ppm to 7500 ppm
The detector tube is of insufficient sensitivity to be useful as a
detector of concentrations near the PEL or AL.
9.35.
9.36.
Contaminant
Conc
Isopropyl ether
Ethyl benzene
Chlorobenzene
Chlorobromomethane
200
50
PEL
40
25
500
200
AL
100
75
250
100
50
37.5
On the surface it appears that the new solvent will help matters by
reducing the solvent vapor release by 20%. However, 20% is only a
modest improvement, and a more knowledgeable assessment would include a
comparison of the PELs for the two solvents under consideration. The
old solvent, Stoddard solvent, is listed in the OSHA list for air
contaminant PELs as a TWA of 500 ppm (see Appendix A.1). The new
solvent, perchloroethylene is listed in Appendix A.1 with a reference
to Appendix A.2. Earlier editions of the Appendix have recognized
"perchloroehtylene" and "tetrachloroethylene" as synonyms.
Tetrachloroethylene is found in Appendix A.2 to have a TWA PEL of 100
ppm and a MAC of 200 ppm. Therefore perchloroethylene is much more
tightly controlled as a more hazardous substance than Stoddard solvent.
The advantage of the modest reduction in solvent vapors is more than
offset by the fact that the new solvent is much more dangerous, five
times as dangerous as indicated by the ratio of PELs. It would be more
difficult to control the new solvent to levels within the PEL and AL.
The consultant should point this out to the process engineer and
caution against making the process change.
9.38.
Substance
Morning
Exposure
(4 hrs)
Afternoon
Exposure
(4 hrs)
Ci
8-hr
TWA
Li
OSHA
PEL*
Ci/Li
Acetic anhydride
Sodium hydroxide
Ammonium sulfide
Calcium bisulfide
Carbon disulfide
Sodium sulfide
Sodium sulfite
.5 ppm
.2 mg/m3
3 ppm
5 ppm
4 ppm
.7 mg/m3
.5 mg/m3
1 ppm
.3 mg/m3
4 ppm
8 ppm
6 ppm
.8 mg/m3
.5 mg/m3
.75 ppm
.25 mg/m3
3.5 ppm
6.5 ppm
5 ppm
.75 mg/m3
.5 mg/m3
5 ppm
2 mg/m3
none
none
20 ppm
none
none
.15
.125
0
0
.25
0
0
.525
OSHA
PEL*
Ci/Li
Total Em =
i=1
9.39.
Ci
----- = .525
Li
Morning
Exposure
(4 hrs)
Substance
Ci
8-hr
TWA
Li
1 ppm
.525
1 ppm
1 ppm
3 ppm .333*
*Appendix A.2
Total Em =
i=1
.858
Ci
----- = .858
Li
The accident occurred on January 30, 1995. The Arkhangelsk Pulp and
Paper Combine of Novodvinsk, Russia emitted up to 16 tons of mercury
compounds into the Svernaya Dvina River. The emission of toxic mercury
compounds into the river were, and still are, a health threat to the
people of the area, and are a threat to the ecological health of the
river itself. The contamination of the Svernaya Dvina River at this
point was as high as 740 and 640 critical contamination concentrations
(cac), on each side of the river. In laymens terms, this represents a
contamination 20 times greater than the acceptable level for the
Svernaya Dvina River at this geographical point. There is danger that
the accidental release and the continued release of mercury compounds
into the river will result in the death of the river. The Svernaya
Dvina River empties into the White Sea and ultimately into the Arctic
Ocean. While the much larger body of water represented by the Arctic
Ocean will disperse the concentration rather quickly, the Arctic Ocean,
because of the low water temperatures is a much more fragile
environment than the waters of more temperate oceans. The Arctic
Region is much more sensitive to this type of pollution due to the lack
of microscopic organisms that help to neutralize this type of
contamination in more temperate regions. Source: Internet
http://gurukul.ucc.american.edu/TED.MERCURY.HTM
9.41.
(a) 1910.1052
(b) April 10, 1997
(c) The rate of implementation of the start-up phase depends upon the
size of the company and upon the section of the standard, as
follows:
COMPANY SIZE:
<20 employees
Initial monitoring
Engineering controls
All other requirements
20<employees<99
300 days
210 days
3 years
2 years
1 year
270 days
>99 employees
120 days
1 year
180 days
By searching the OSHA website for the keyword "methylene chloride" the
Internet surfer can be directed to the preamble to the standard that
appeared in the Federal Register when the methylene chloride standard
was promulgated (January 10, 1997). The summary to the preamble claimed
that the standard would result in a savings of 31 cancer deaths per
year plus 3 deaths per year from central nervous system disorders and
carboxyhemoglobinemic effects (carbon monoxide poisoning
complications). The cost of compliance was estimated to be $101
million/year. Searching the archived News Releases on the OSHA
website, OSHA News Release 97-06, dated January 9, 1997, can be found.
In this release, then OSHA Director Joseph Dear stated that a total of
34 lives per year would be saved, 31 from long-term effects and 3 from
short-term effects. The news release also reported an estimated
237,500 workers are exposed to methylene chloride.
9.43.
On the OSHA website, going to the archived news releases, search for
the term "butadiene." This will display OSHA News Release 96-147, dated
October 24, 1996. According to the News Release, the PEL was reduced
from 1,000 ppm to 1 ppm. (This represents a thousand-fold reduction.)
The estimated cost of compliance with the standard was $2.9 million per
year. The more stringent standard is expected to prevent at least 79
cancer deaths over a 45-year working lifetime.
9.44.
The top on the list of frequently cited standards among the standards
completion project substances was Lead, which accounted for
approximately one-third of all citations for standards completion
project substances. Following is a listing of the top three, with
frequency of citation for each:
29CFR1910.1025 Lead: 1137 citations
29CFR1910.1052 Methylene Chloride: 769 citations
29CFR1910.1048 Formaldehyde: 308 citations
9.45.
From the OSHA website it can be determined that the general OSHA
standard for air contaminants is 29CFR1910.1000. The specific
provisions that require air contaminants to be held within their
respective PELs are presented with their respective enforcement
statistics, as determined from the NCM database:
Standard Provision
Coverage
Citation
Frequenc
y
Total
Average
$ Penalty
$ Penalty
1000(a)
1000(b)
1000(c)
All of the above
Table Z.1
Table Z.2
Table Z.3
150
21
97
268
$168,000
$79,425
$145,950
$393,375
$1,123
$3,782
$1,505
$1,468
Source NCM database
9.46.
CHAPTER 10
10.1
10.2.
10.3
10.4.
10.5.
10.6.
Solution method 1: Design and install systems to filter and purify the
contaminated air so that it can be recycled back into the plant
atmosphere.
Solution method 2: Introduce the makeup air for the exhaust system
adjacent to the point of origin for the contaminant. The makeup air
introduced at the point of operation may not need any heating or
cooling, as it will be immediately removed by the exhaust ventilation
system.
Solution method 3: Use a heat exchanger to warm (or cool) makeup air by
passing it through the heat exchanger in close proximity to the heated
(or cooled) exhaust air.
10.7.
10.8.
Pitch and pressure intensity of the sound wave. Of the two, pressure
intensity is the more dangerous characteristic of sound. Even though
the peaks of pressure intensity can be dangerous, the human ear can
withstand, without damage, sound pressures 10,000,000 times as great as
the faintest sound it can hear.
10.9.
10.10.
10.11.
In this problem we are given the SLM readings and must work backwards
to infer the sound output of either of the two identical generators.
(a) One generator on: SLM reading
= 83.6 dBA
dBA
= 2.6 dB
PEL = 90 dBA
Since 85.16 < 90, PEL is not exceeded.
AL = 85 dBA
Since 85.16 > 85, AL is (barely) exceeded.
(c) From Table 10.2 and using linear interpolation (as in part [a]):
dBA
Hrs.
Ref. Duration
83.6
4
19.48
85.16
4
15.664
D =
Cn
Tn
= 100
10.12.
19.48
15.664
(d)
(a)
machine 1
machine 2
machine 3
86 dB
-80 dB
6 dB
86
+ 1.0
87.0 dB
93.0
6 dB
dB = 1.0
machine 4
dB = 1.0
93
+ 1.0
94.0 dB
70.0 dB
24.0 dB
dB = negl.
d2 = 52 x 4 = 25 x 4 = 100
d = 10 feet
Note that we have doubled the distance from 5 feet to 10 feet and the
resultant sound is thus reduced by a factor of 4.
10.13.
10.14.
system.
10.15.
Since the difference between 99dB and 65dB is so great, the background
noise can be considered as negligible. So we have
99 dB for 10 machines
-3
96 dB for 5 machines
-3
93 dB for 2.5 machines
-3
90 dB for 1.25 machines
Therefore, 9 machines would have to be shut down to meet the 90 dB
standard.
10.16.
10.17.
36000 lbs
Vapor released =
PEL (chlorine) =
Vapor released
Room volume
103 lbs/ft3
1 ppm
(Appendix A.1)
10-6
157,282 ft3
Vol
>
Vol
Vol
10-6
Volume
Ceiling Height
= 1.57 x 1011
30 x 52802
= .523 x 1010 = 188 square miles
5.282 x 106
[ 1 mile]2
[5280 ft]2
10.18.
(a)
dB
86
84
81
101
75
hrs
1
2
1
1
3
8
1
2
1
1
----- + ----- + ----- + ---- = 80.47%
13.9
18.4
27.9
1.7
2
Enclose the noise source with a barrier that reduces the noise
level by 50%.
1
Position the operator at a distance twice as far from the source
of the noise.
3
Rotate personnel so that each worker is exposed to the noise
source for only one-half shift.
4
Provide ear protection that cuts the noise level by one half.
Moving the operator away (twice as far) from the noise is best because
this change will reduce the noise exposure by a factor of 4 (6 db),
whereas the other three alternatives only reduce the noise exposure by
a factor of 2 (3 db reduction reduces the absolute sound pressure by a
factor of 2). Second in priority is the barrier because it would be
considered an engineering control. Third in priority would be rotating
personnel, an administrative or "work practice" control. Last in
priority would be ear protectors, which would represent personal
protective equipment.
10.20.
PEL
---106
liberated
--------- =
exhaust
5
--E
5(106)
5(106)
E = -------- = ------- = 5,000 ft3/hr
PEL
1000
10.21.
10.22.
Often operating personnel ignore such alarms as red lights. Even when
the alarm is an audible type, operators and/or maintenance personnel
may ignore the signals or even deliberately disconnect the wiring to
the alarms as an expediency.
10.23.
10.25.
X-rays
10.26.
3.2%
240/3.2
75 ft3/hr
(b) To deal with the health hazard the ventilation system must keep the
concentration of ethylene glycol at least below the PEL and should be
designed to keep it below the action level. The PEL for ethylene
glycol is shown in the problem statement to be 50 ppm (ceiling)1, so the
AL at 50% of the PEL is 25 ppm. Therefore,
2.4 ft3
vent
vent
=
=
25 ppm
2400000/25
0.000025
=
96000 ft3/hr
(c) Although the room volume of the plant would not affect the design
of the general dilution ventilation system to deal with the ethylene
glycol hazard, it would determine how many room changes per hour the
ventilation system would effect, as follows:
Room changes/hr
=
10.27.
0.5
result in a
old absolute
reduction by
6 = 90 dB
The two plans are equally effective in that each reduces the noise
level to 90 dB. If both plans were employed at the same time, each
plan would reduce the absolute sound pressure by a factor of 4,
resulting in a 16-fold overall reduction. Note that a 16-fold
reduction is a halving of the sound pressure four times (24 = 16). Each
time absolute sound pressure is halved, sound level is reduced by 3 dB.
The sound level is thus reduced by 12 dB (4x3dB = 12dB). New dB
reading = 96-12 = 84 dBA.
RESEARCH EXERCISES
10.28.
Note to Instructor: Although the PEL for ethylene glycol is listed in the problem statement for Exercise
10.26 to be 50 ppm, OSHA lists the substance as 2-Methoxyethyl acetate and currently lists its PEL as 25 ppm (TWA)
as shown in Appendix A.1 of the text. For purposes of this exercise the solution assumes a ceiling PEL of 50 ppm
for this substance, as stated in the problem statement.
10.30.
Industries
Target Initiative
40
35
40 micrograms
Both of the above targets were scheduled for a 5-year phase-in with the
relocation target to decrease at the rate of 2 micrograms per year and
the return-to-work target to decrease at the rate of 1 microgram per
year until the 5-year targets are reached.
10.31.
From the OSHA website, the general industry industrial noise standard
is found to be OSHA standard 1910.95. This standard contains provisions
for exposure to excessive noise plus provisions for monitoring, hearing
conservation programs, and personal protective equipment. The NCM
database shows that OSHA standard 29CFR1910.95 was cited 2265 times for
the fiscal year, and that 1283 of these citations were designated as in
the serious category. Thus, the percentage of serious violations is
1283/2265 = approximately 57%. The total dollar amount of the penalties
proposed for the alleged violations was $1,548,498, for an average
penalty per citation of approximately $684.
10.32.
10.33.
Using the OSHA website, the relevant provisions of the OSHA noise
standard are listed along with the total number of citations and the
number of serious citations for Fiscal Year 2002, as determined from
the NCM database:
Serious
citations
Total citations
Audiometric testing
1910.95(g)
1910.95(h)
1910.95(m)(2)
1910.95(m)(3)(ii)
1910.95(n)(1)
Hearing conservation
programs
1910.95c
1910.95c1
Totals
General ventilation standard
1910.94
502
2
53
1
1
294
0
15
1
0
5
500
1064
3
303
616
201
159
= approximately 79 percent
OSHA cites the noise standard more frequently, but the ventilation
standard generates a higher percentage of serious citations.
CHAPTER 11
11.1.
A floating roof is used on many petroleum tanks. The roof rises and
falls with the level of the liquid, so that the tank does not require
venting. This saves vapor losses and also enhances safety.
11.2.
11.3.
11.4.
11.5.
Flammable range:
Gasoline
1.4 to 7.6% vapors
Ethyl Alcohol
4 to 20% vapors
A drum of alcohol would have a much greater hazard potential than one
containing gasoline because a much wider range of alcohol
concentrations in air are burnable.
11.6.
82 ft3 vapor
hr.
11.8.
11.9.
Dip tank covers are required to be "kept closed when tanks are not in
use." Automatic closure is not required.
11.10.
11.11.
11.12.
Using the paint spray area as a drying area can raise the temperature
level of the paint residues and also the level of flammable vapors in
the air, increasing the fire hazard. The standards prohibit the use of
a paint spray area as a drying area unless the arrangement does not
"cause a material increase in the surface temperature of the spray
booth, room, or enclosure.
11.13.
(a)
For dealing with safety hazards the objective is to keep carbon
disulfide levels below the lower flammable limit, which was stated in
the problem statement to be 1.3%
Let x = the required ventilation level:
3 ft3/hr
x
x
0.013
3/0.013
231 ft3/hr
(b)
For dealing with health hazards the objective is to keep carbon
disulfide levels below the 8-hr TWA PEL: 20 ppm
Let y = the required ventilation level:
3 ft3/hr
y
y
0.000020
3/0.000020
150,000 ft3/hr
(c)
The flashpoint of carbon disulfide is shown in the problem
statement to be -22 oF, and the boiling point is 46.5oC. The flashpoint
identifies the liquid as Class I. The boiling point is converted to
Fahrenheit as follows:
B.P. (Fahrenheit) = 46.5
C x 9/5 + 32
= 115.7
No difference.
liquids.
11.15.
The danger of the empty gasoline drum is that the vapors have thinned
to the point that they may be within the burnable range, i.e., less
than the UEL but still greater than the LEL. In a full tank of
gasoline the vapors are virtually certain to be in greater
concentration than the UEL. For carbon disulfide, however, the range
of burnable concentrations is much greater. The LEL for carbon
disulfide is 1.3% and the UEL is 50%, a range of 48.7%. For gasoline
the range is much narrower at 6.2% (7.6% UEL - 1.4% LEL = 6.2%).
11.16.
The hazard is that the vapor density of gasoline is greater than that
of air. The heavier gasoline vapors will tend to displace the air and
collect in the basements of service stations, creating dangerous
concentrations.
11.17.
11.18.
11.19.
Its OK to refuel forklift trucks with the engine still running, if the
forklift is LPG-powered. This is despite the fact that federal
standards prohibit refueling of forklift trucks while the engine is
still running if the fueling operation involves venting to the
atmosphere. LPG refueling does not require venting to the atmosphere.
RESEARCH EXERCISES
11.20.
http://www.micro-blaze.com
11.21.
11.22.
11.23.
also,
Grounding of containers:
1910.107(e)(9) 94 citations
also,
1910.107(i)(6) (general grounding, incl containers) 4 citations
for a total of 98 citations
NO SMOKING signs:
1910.107(g)(7)
1910.107(m)(2)
93 citations
3 citations
11.25.
The OSHA website shows that the principal standard for LPG is OSHA
standard 29CFR1910.110 Storage and handling of liquefied petroleum
gases. The NCM database shows that for the fiscal year 1910.110 was
cited 558 times, of which 292 citations were listed as serious. Of
these 558 citations, the most frequently cited provisions were:
1910.110(f)(2)(i) 128 citations
(location of LPG containers in storage)
1910.110(d)(10) 69 citations
(precautions to prevent damage from vehicular traffic)
1910.110(f)(2)(ii) 63 citations
(inside storage of LPG near exits)
1910.110(e)(4)(iii) 58 citations
12.2.
12.3.
12.4.
12.5.
12.6.
12.7.
The employee needs to learn that PPE is limited to a finite useful life
even under proper care and maintenance.
12.8.
12.9.
12.10.
12.11.
12.12.
12.13.
12.14.
12.15.
12.16.
12.17.
12.18.
Also any
12.19.
12.20.
12.21.
The need for personal protective equipment implies that the hazard has
not been eliminated or controlled.
12.22.
The employee may have inadequate equipment, yet the employer still is
responsible to provide adequate protection to its workers. Also,
employee-owned inadequate equipment can create a dangerous, false sense
of security.
12.23.
The undersized manholes prevent entry of personnel wearing selfcontained breathing apparatus.
12.24.
In an actual fall the shock load applied to the fall protection system
would be much greater than the static load of the wearers body weight.
12.25.
12.26.
12.27.
1.
2.
3.
4.
5.
6.
12.28.
12.29.
12.30.
12.31.
12.32.
Substitute
Change the
In
12.33.
Close all valves that govern piping that might lead dangerous liquids,
gases, or even solids into the confined space. Use a double-block-andbleed procedure that closes two valves in series in a pipe leading into
the space, and in addition opens a small bleed valve in the pipe in the
space between the two major valves. The bleed valve allows the escape
of any fluids that might accumulate due to high pressure differential
on the primary major valve. The secondary major valve thus has little
or no pressure differential across it and can achieve a positive
closure. Another procedure for positive isolation is blanking or
blinding, in which a solid plate is installed in the line completely
covering the cross-sectional area of the pipe and absolutely blocking
flow. Another procedure is to physically sever the line and detach and
separate the two remaining lengths of pipe.
12.34.
12.35.
12.36.
12.37.
RESEARCH EXERCISES
12.38.
At least one accident has been reported in the area of working in the
confined space of a service pit for a display waterfall (fountain) in a
shopping mall. An employee lost consciousness when he descended seven
feet to the bottom of a service pit to adjust valves for the fountain.
A companion worker entered the pit to rescue the first worker and also
lost consciousness. A security guard and a passerby tried to assist
but became dizzy. The fire department was summoned to the scene and
both employees were revived and were treated and released. OSHA
investigated four such service pits in this shopping mall and found
three of the four had oxygen concentrations of less than the minimum
acceptable 19.5 percent. In addition, carbon dioxide readings were
more than double the OSHA PEL. Similar problems have been studied by
NIOSH.
References: This story was first found on the Internet at the UniHoist Newsletter. Uni-Hoist is a manufacturer of confined space entry
equipment. The URL used to find this data on the Internet was:
http://www.cdnsafety.com/unihoist.html This
URL may no longer be available. Other articles describing confined
space hazards may be found at http://www.cdnsafety.com/articles.htm
Data on this accident may also be available on the OSHA website. OSHA
changes the organization of the website from time to time. At the time
of this printing in 2003, a description of this accident was found in a
Hazard Information Bulletin, dated June 13, 1996, by doing a search on
the term waterfall in the OSHA website search facility entitled Find
it! In DOL
12.39.
have shown that oxygen levels can be depleted inside the suit to a
dangerous 16 percent in only 40 seconds! The situation can deteriorate
into a life-threatening situation very quickly. Besides escape
situations, simple donning and doffing of air-supplied suits during
training exercises without turning on the supplied air can result in
dangerous oxygen-deficiency. Especially because of the escape hazard,
the Department of Energy (DoE) has issued directives that workers
should be trained to give precedence to preventing oxygen-deficient
atmosphere inside the suit at the expense of sacrificing contamination
control.
Original reference for this information: Potential Oxygen Deficiency
While Wearing Air-Supplied Suits, DOE/EH-0414, Issue No. 96-1, April,
1996.
12.40.
12.41.
12.42.
The best source for finding the requested background information on any
promulgated standard is in the preamble to the standard published in
the Federal Register by OSHA at the time of promulgation. The
following is quoted from the Preamble to the Permit-Required Confined
Space Entry standard, found in the Federal Register and the OSHA
website:
From the OSHA website it can be determined that the general standard
for confined space entry is OSHA standard 29CFR1910.146 PermitRequired Confined Space Entry. Section a. (Scope and application)
specifically excludes agriculture, construction, and shipyard
employment from coverage under the standard. The preamble to the
standard explains that these areas are covered under other standards.
The preamble also contains discussion and arguments over the scope of
the standard. The telecommunications industry argued that it should be
excluded, but an exclusion for the telecommunications industry does not
appear in the Section a. Scope and application paragraph of the
standard.
12.44.
The NCM database can be used to perform a keyword search on the term
*respiratory protection*. Such a search returns a long list of
citations, the vast majority of which are in the general respiratory
protection standard, OSHA standard 29CFR1910.134. Some other
respiratory provisions of specialized standards are also included in
the list, especially in the standards included in the standards
completion project (refer to Table 9.1 in the text, page 187). The
total number of citations listed in the NCM database for the term
respiratory protection is 9101. The corresponding search using the
serious violations search capability reveals a total of 4206
citations, or 4206/9101 = 46 % of the total. A search of the database
can be focused on general personal protective equipment by using the
keyword search term *personal protective equipment*. Such a search,
using the NCM database, shows a total of 4927 citations. Doing a
similar search by serious violations a total of 3285 is shown, or
3285/4927 = 67 % of the total. So, comparing the terms respiratory
protection and personal protective equipment as they appear in
standards cited by OSHA during the fiscal year reported in the NCM
database, standards containing the term respiratory protection have
resulted more citations, but a greater percentage of the standards
containing the term personal protective equipment have been in the
serious violation category. Both terms are involved in frequent
citation activity, and a large percentage of citations for both of
these terms are designated as serious.
12.46.
Using the NCM database keyword searching capability, a search for the
term *medical services and first aid* results in a printout of several
standards containing this word group. The most heavily cited standard
is OSHA standard 29CFR1910.151(c). The OSHA website reveals that this
standard is the general requirement for medical services and first aid.
If all provisions containing the word group medical services and first
aid are included, the NCM database shows a total of 1887 citations for
the fiscal year. Another search for the same word group, using the
serious violations option of the NCM database keyword search
capability, a total of 1283 citations is shown. Thus the percentage of
total alleged violations that are in the serious category is
1283/1887 = approximately 68 %. Apparently, OSHA takes the subject of
medical services and first aid quite seriously.
CHAPTER 13
13.1.
13.2.
13.3.
13.4.
Workplace violence
13.5.
13.6.
Residential
13.7.
13.8.
(a)
(b)
(c)
(d)
(e)
13.9.
13.10.
Audible alarms are obviously ineffective for deaf employees. But even
worse is the complacency which is sometimes created by a wide variety
of audible alarms or signals for conditions of various degrees of
urgency.
13.11.
No
13.12.
The employee may not want to alarm other workers, thinking that the
fire is being taken care of.
13.13.
13.14.
13.15.
13.16.
Class
A
B
C
D
Description
Paper, wood, cloth, etc
Flamm/combust liquids, gases,
etc.
Energized electrical equipment
Combustible metals
13.17.
13.18.
13.19.
Dry chemical extinguishers may be approved for more than one class of
fire; however, the chemical may foul or ruin expensive equipment
(computers, for example); and they may be more expensive than foam and
water extinguishers. Also, dry chemical powders may be subject to
caking, which would make them ineffective when deployed.
13.20.
13.21.
No, the employer may select any convenient mounting scheme, provided
that the extinguishers are readily accessible without subjecting
employees to possible injury.
13.22.
13.23.
(1)
(2)
(3)
(4)
13.24.
Direct city water supplies usually cannot meet the flow requirement of
100 gpm for 30 minutes (insufficient dynamic pressure).
13.25.
13.26.
The paper bag will prevent the sprinkler head from becoming fouled by
paint spray residues. The bag will be burned away or washed away by
the water spray when the sprinkler is activated.
13.27.
13.28.
By weight
13.29.
13.30.
13.31.
13.32.
13.33.
13.34.
13.35.
13.36.
Shut-off-type nozzles
Lining for hose
Dynamic pressure minimums at the nozzle
Hydrostatic testing upon installation
13.37.
Not anymore; tags were once required and OSHA heavily cited this
standard throughout industry; now alternative procedures are permitted
such as maintaining the inspection status in a filing system. However,
many companies still use the tags so that the record of the inspection
status is readily available right on the fire extinguisher, instead of
tucked away in a file that might be difficult to find during an
inspection.
13.38.
Up to one year after the last entry or the life of the shell, whichever
is less.
13.39.
13.40.
13.41.
1.
2.
13.42.
13.43.
Corrosion
Mechanical damage
RESEARCH EXERCISES
13.44.
Answers to this exercise will vary somewhat from year to year. The
data shown below were taken from the 2002 edition of the National
Safety Councils Injury Facts. The data reflect overall totals and
averages for industries of all types nationwide for the nine year
period 1992-2000:
Number of
Fatality cause
fatalities
Percent
Total, all causes
Falls
Electrocutions
Oxygen deficiency
Exposure to harmful substance
Transportation accidents
Assault, violent act
Fires, explosions
(not included in the above categories)
55919
5880
not listed
not listed
5123
23372
10287
1760
9497
100.0%
10.5
N/A
N/A
9.2
41.8
18.4
3.1
17%
13.45.
13.46.
13.47.
CHAPTER 14
14.1.
Three legs of the four may be supporting the full weight at any given
time, with the fourth leg being slack.
14.2.
Put all u-bolt clips on ropes with the saddle assembly on the live
portion of the rope, instead of vice versa.
14.3.
14.4.
Warehouse space
14.5.
(b); the angle of the sling legs are closer to vertical. Orientation
(a) would place more stress on the sling legs because the sling legs
would be more horizontal to reach around the horizontal orientation of
the load.
14.6.
14.7.
14.8.
Mechanical advantage = 4
Rated load = number of parts of rope x (20%) x nominal breaking
strength
RL = 4 x 20% x 5000
RL = 4000 lbs
4000 - 200 = 3800 lbs (allowing for load block)
14.9.
14.10.
14.11.
So that the ladder will not be moved to another location while the
crane is in use, thereby removing the operator's means of dismounting.
14.12.
Tampering with the design or altering the truck may invalidate the
approval classification of the truck.
14.13.
Refer to the OSHA website to check OSHA standards under the general
heading Material Handling and Storage. Following are two example
performance standards:
1910.176(a)
Use of mechanical equipment. Where mechanical handling equipment is used, sufficient safe
clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or
passage must be made. Aisles and passageways shall be kept clear and in good repair, with no
obstruction across or in aisles that could create a hazard. Permanent aisles and passageways shall
be appropriately marked.
Note that the above wording does not specify exactly how wide an aisle
should be to achieve sufficient safe clearances. Also note that the
standard calls for aisles to be appropriately marked. The standard
does not specify what constitutes appropriately marked.
1910.176(b)
Secure storage. Storage of material shall not create a hazard. Bags, containers, bundles, etc.,
stored in tiers shall be stacked, blocked, interlocked and limited in height so that they are stable
and secure against sliding or collapse.
Note that the above wording does not specify a maximum height for
stacking materials. The decision is left to the employer to keep height
14.15.
14.16.
14.17.
Gross load
14.18.
Gross load
Mech. adv.
2100
3
= 700 lbs.
Eqn. 14.5
Gross load
The problem states that the wire rope is "rated" at 2,000 lbs. The
term "rated" implies that the safety factor of 5 has been applied and
that
Nominal breaking strength = 5 x "rating"
= 5 x 2000 = 10,000 lbs
Applying Eqn. 14.1:
rated load
nbr. of parts of rope
14.21.
= 1/3 x 1000 lb
= 333 lb.
When a sling leg is 30 from horizontal, the tensile stress in the sling
leg is twice the vertical component of force.
Therefore, stress on each leg = 2 x 333 lb = 667 lb
14.22.
Let W represent the maximum total load the sling is rated to pick up.
The problem is to find W.
Weight borne by each sling leg = W/3
(This is the vertical component of force on each sling leg.)
The tensile stress on each leg in the sling is limited to the rated
load of the chain used in the sling, which was given in the problem as
equal to 6 tons. Then:
W/3
3(.866 x 6 tons)
15.6 tons
If the trolley rides on top of the rail, the device is a crane and the
safety standard for overhead and gantry cranes applies. If the trolley
hangs from the lower flange, the device is an underhung crane or
monorail, and the standard for monorails applies.
14.24.
14.25.
The hoist is the part of the lifting mechanism that lifts the sling and
the payload. The sling is the flexible chain, wire rope, and other
attachment that is used to wrap around or attach to the load so that
the hoist can lift it.
14.26.
The more severe (acute) the leg angle is from the horizontal, the
greater will be the stress on each leg of the sling. In quantitative
terms, using trigonometry,
Ts
Ts
=
V s / sin L
Where,
=
tensile force on a leg of a sling
Vs
A sling that is too short will necessitate a very acute leg angle and
thus will cause a severe stress upon the legs of the sling.
14.28.
will cause an unusually high force on the straps, usually much greater
than the entire weight of the load. The straps are likely to break,
dropping the load.
14.29.
1.
2.
14.30.
Design a box or other enclosure around the conveyor intake. The box or
enclosure must have openings in order for the conveyor to operate, but
the openings can usually be made large enough for the conveyor to
function, but small enough that a worker's hand, foot, or other body
part will not intrude into the danger zone.
14.31.
14.32
14.33
The greater the horizontal distance of the load from the lifter's body,
the more difficult it will be for the lifter to manage the lift.
Therefore, the maximum load the lifter can pick up is reduced (greatly)
by this horizontal distance. The geometry of the load can greatly
affect this distance.
14.34
When lifters lift with their legs, they are lifting not only the load
but their entire body as well. In addition, it can be very awkward or
difficult to position the load to lift it with the lifter's legs.
14.35
20,15 0
20% x nominal breaking strength of the rope
n
where n = the number of parts of rope
20,150
n
Try n = 2:
Try n = 3:
Try n = 4:
14.36.
8000 = 4r2
r = 25.23 feet
x2 + 202
25.232
15.38
The proposal to place a toggle switch control box on the wall raises
some safety considerations that should be communicated to the design
team. One concern would be the toggle switches. Crane controls should
be of the deadman type, which, if released, will stop crane movement.
Another consideration is the placement of the control in a fixed
position on the wall. An overhead bridge crane will travel some
distance away from the control box on the wall. A better design would
be a pendant control on a flexible cord that will travel with the
bridge and trolley, placing the crane operator in closer proximity to
the hoist. Another consideration would be the capability to lock out
the control for maintenance. No mention was made of lock-out
capability in the proposed toggle switch box to be mounted on the wall.
The hazards from failure to lock out a crane during maintenance are
aggravated by the distances which a crane can travel away from a fixed,
wall-mounted control.
14.38.
The answer to this question will vary depending upon the level of
current research in this area at the time of search on the Internet. As
of this writing (mid-2003) 16 hits were returned for a search of the
following keyword phrase: NIOSH lifting limits simulation virtual
reality
CHAPTER 15
15.1.
That part of the machine where the tool engages the work.
15.2.
15.3.
(1) Where belts contact pulleys, (2) Where gears mesh, (3) Where mating
rollers make contact
15.4.
15.5.
15.6.
The nylon is more susceptible than metal to the buildup of oil and lint
which decreases the efficiency of the fan.
Any fan guard (including nylon mesh) will decrease fan efficiency.
15.7.
15.8.
S.D. =
15.9.
The holes are for the purpose of anchoring a machine (1) for ease of
shipping, (2) for security purposes, or (3) because the machine is
designed for use in a "fixed location."
15.10.
15.11.
15.12.
15.13.
Type A gates close before the press stroke is initiated and remain
closed until all motion of the ram has ceased. Type B gates close
before the press stroke is initiated but open after completion of the
downward stroke, allowing the operator to reach in before motion has
ceased.
The Type A gate is the safer of the two.
15.14.
15.15.
15.16.
15.17.
60/90[1/2 + 1/14] x 63 = 24 in
15.18.
15.19.
Galvanized wire mesh is more durable because the junctures of the wire
crossing each other are held together by the fused galvanizing metal.
Thus, personnel are less likely to penetrate or distort the guard mesh
and encounter the danger zone.
15.20.
15.21.
"Pullbacks" pull the operator's hands out of the danger area as the ram
makes its downward stroke.
"Restraints" do not allow the operator's hands to enter the danger zone
at any time.
15.22.
15.23.
15.24.
Safety distance
= 60/rpm(1/2 + 1/N) x 63
= 60/60(1/2 +1/4) x 63
= 47.25 inches
15.25.
No, the machine has a full revolution clutch and the ram cannot be
stopped by the two-hand control.
Presence-sensing devices are illegal for full-revolution presses.
15.26.
(1) Failure to keep the workrest in close adjustment (within 1/8 inch)
to the wheel on offhand grinding machines.
(2) Failure to keep the tongue guard adjusted to within 1/4 inch.
(3) Failure to guard the wheel (including bolt end and flange)
sufficiently.
All three of these rules are aimed at protecting the worker in the
event of a breakup of the wheel or preventing the breakup of the wheel.
Grinding wheel breakup can result in worker fatality.
15.27.
If the die opening is less than inch, then the die itself meets the
guard opening dimensions specified in the OSHA standard (see Table
15.1). By this same reasoning, the OSHA standard explicitly exempts all
mechanical power presses having less than inch maximum die opening
from the point-of-operation safeguarding requirements.
15.28.
Kickback is more likely and is a greater hazard for ripsaws than for
crosscut saws.
15.29.
15.30.
15.31.
Shaft couplings need no guards when bolts, nuts, and setscrews are
countersunk so that no hazardous projections are present. It is
further desired that such fasteners be used parallel to the shafting.
15.32.
15.33.
15.34.
15.35.
15.36.
15.37.
15.38.
15.39.
15.40.
The best color is usually black. The point of operation is where the
machine does the work, and an operator often must be able to see into
the machine at this point. If the guard is painted orange or some
other bright color, it inhibits the operator's ability to see into the
point of operation.
15.41.
15.42.
15.43.
Die enclosure guards have the advantage of being small and close to the
operation of the machine, making them efficient and convenient. They
can be specially designed to fit the particular die's operation. Fixed
barrier guards must accommodate all die configurations that might be
mounted on the machine at various times or for various setups. They
are necessarily large and, for some operations, awkward. The advantage
of the fixed barrier guard, however, is that one guard is suitable for
all operations and setups.
15.44.
15.45.
Holdouts or restraints
15.46.
15.47.
15.48.
15.49.
15.50.
This design case study uses the principle of the safety distance
formula to set design parameters for the design of the engagement
mechanism for the flywheel.
Using Eqn 15.2, let D represent safety distance:
D = 60/rpm [1/2 = 1/N] x 63
[1/2 + 1/N] =
[ Dx rpm]
[60 x 63]
[D x rpm]
[60 x 63]
1/N =
1
2
20 x 100
60 x 63
1/N =
.529
.029
=
1
2
.500
34 engagement points
15.51.
15.52.
15.53.
15.54.
Tripping of the top-stop overtravel limit switch means that the brake
has deteriorated beyond limits. Therefore, the brake monitor provides
an indication to that effect. In addition, the brake monitor signals
the control system to disable the press such that it will cease to
operate. However, the control system will not disable the brake system
of the press.
15.55.
15.56.
On a handheld saw, the blade is very dangerous if the saw is set down
or dropped either before or after the cut. Before the cut, the blade is
brought up to rotational speed, and after the cut, the blade will
continue to rotate for a time after the trigger is released. Without
the retractable guard, the handheld saw would be very hazardous at
these times. Particularly AFTER the cut the operator would be tempted
to set the saw down somewhere before waiting for friction to slow the
blade to a complete stop.
15.57.
15.58.
Fixed barrier guards encompass the entire die area and accommodate
various size dies. Therefore, they are more distant from the point of
operation and permit larger openings through the guard, provided that
OSHA requirements are met with regard to the distance to the danger
zone and the maximum opening size of the guard mesh.
15.59.
A power hacksaw and a bandsaw are used for similar purposes. Both have
a thin, narrow (band-type) blade. However, the hacksaw uses a
reciprocating motion, and the bandsaw uses a continuous motion with a
blade that is a continuous loop. The hacksaw is more difficult to guard
because the guard must continually adjust back and forth to the work
during every stroke of the blade.
15.60.
15.61.
15.62.
Type A gates keep the gate closed until all motion of the ram ceases.
Type B gates permit the gate to open during the less hazardous upward
portion of the stroke, which speeds up the operation and improves
efficiency. Muting is a design feature of presence-sensing devices
that permits the sensing device to be ignored during the less hazardous
upward portion stroke with production advantages identical to those of
the Type B gate.
15.63.
15.64.
15.65.
15.66.
This design case study requires the application of the principle of the
safety distance formula to design the system to accommodate safe ranges
of operation of the flywheel to facilitate the safe operation of the
safeguarding system. From Eqn 15.2, let D represent safety distance:
D =
D =
D =
rpm
accidental repeat stroke, the Type B gate increases the hazard somewhat
and should be avoided if possible.
Alternative design #2: Convert the press to a part-revolution design
by equipping it with a clutch and brake. Although more expensive than
alternative #1, the clutch and brake would promote safety and permit
the use of two-hand control systems that are safely positioned closer
to the point of operation. The close placement would facilitate
feeding and speed up production while safety is preserved by the
superior control of the ram stroke afforded by the clutch and brake.
Alternative design #3: (Most expensive) Same as alternative #2 above,
only replace the two-hand control with a presence-sensing device for
safety and use a footswitch tripping mechanism. The presence sensing
device could be muted on the upward stroke for maximum efficiency.
Alternative #3 would maintain safety using the clutch and brake system
to stop the press in the event the danger zone is violated. Maximum
safe access to the danger zone for feeding, made possible by the
footswitch freeing the hands from the responsibility for tripping,
would make this arrangement the most efficient.
15.68.
60 x 63 x [1/2 + 1/14] / 20
=
108
Another solution (the best solution) to the problem from the safety
perspective would be to retrofit the press by equipping it with a
clutch and brake so that it would operate as a part revolution press.
Fully equipped with a brake monitoring and control system the remodeled
part revolution setup would permit an entirely different formula for
safety distance that would be based upon the stopping time of the
press.
STANDARDS RESEARCH QUESTIONS
15.69.
2675
21
2883
187 citations
Source: NCM database
15.71.
CHAPTER 16
16.1.
16.2.
Welding occurs when the material that melts is either the material to
be joined or a like material.
Brazing and soldering are done by melting some other material with a
lower melting temperature than would be required for melting the metals
to be joined.
16.3.
When the melting material has a melting point above 800F, the process
is brazing; below 800F, the process is soldering.
16.4.
16.5.
16.6.
16.7.
16.8.
Workers often hold their hands over the valve opening when first
opening the valve to test the cylinder. If a greasy glove is on that
hand, the presence of pure oxygen causes the grease to become
explosively combustible.
16.9.
16.10.
Valve protection caps protect the valve from damage. The slots in the
cap allow escaping gas to escape in a manner which will prevent the
cylinder from becoming a missile. The slots are misused by workers who
insert pry bars into the slots for extra leverage in handling the
cylinders.
16.11.
16.12.
16.13.
16.14.
Many of the small arc welding machines weld at higher voltage than do
the industrial type welding machines. These smaller machines achieve
power by making up in voltage what they lack in current flow. These
larger voltages can overcome electrical resistance to produce dangerous
electrical shock when careless use causes exposure to the welder.
16.15.
16.16.
If the metal tank contains compressed gas, the high amperage of the
welding circuit could cause the heat buildup in the tank, possibly
causing the pressure limit of the tank to be exceeded.
16.17.
16.18.
16.19.
(1) Short duration of the hazard, (2) People do not realize the
ignition potential of welding. (The ignition potential is unfamiliar
to most because they are not accustomed to watching welding operations
because of the eye hazards.)
16.20.
16.21.
16.22.
Leather
16.23.
16.24.
There are so many variables to measure. The welding fume contains tiny,
transitory concentrations of trace compounds that are difficult to
capture and analyze, both quantitatively and qualitatively.
16.25.
16.26.
16.27.
HAZARD 1:
Acetylene cylinders should be stored valve end up. The
liquid acetone inside the tank could be passed through the valve if the
cylinder is lying on the floor.
HAZARD 2:
together.
HAZARD 3:
Manifold pressure for acetylene is too high.
unstable at pressures greater than 30 psig.
Acetylene is
HAZARD 4:
The nail-polish remover odor is obviously due to leaking
acetone, a very flammable and hazardous substance.
HAZARD 5:
The greasy gloves are an explosion hazard in the vicinity
of oxygen, especially when the oxygen valve is opened by the welder
wearing the greasy gloves.
HAZARD 6:
The welder should not use his torch tip to chip slag from
the finished weld. The tip could be damaged, resulting in flashback.
HAZARD 7:
The welding hose should not be completely wrapped with
tape, possibly concealing breaks or defects in the flexible hose.
16.28.
The term "gas welding" implies that the source of heat is from burning
a gaseous fuel. Nitrogen is not a fuel gas and has a different
function in the welding process in that it acts as an inerting agent.
16.29.
PPM
percent x 10,000
78%
10000
780,000 ppm
16.31.
16.32.
MAPP gas and natural gas can sometimes be used as alternative fuels for
acetylene. The disadvantage is that these fuels do not burn at
temperatures as hot as does acetylene.
16.33.
16.34.
Phosgene
16.35.
16.36.
RESEARCH EXERCISES
16.37.
Nitrogen and oxygen are very complex in the ways the atoms form bonds
to make compounds. Four different compounds make up the classification
NOx. They are:
N2O
Nitrous oxide, commonly called laughing gas and formerly used
as dental anesthetic. N2O is associated with the mildest hazards among
the compounds of the NOx family. It is listed as slightly dangerous
by Sax (see reference below) and has both health and safety hazard
implications.
NO
Nitric oxide.
NO2
Nitrogen dioxide.
N2O5
Nitrogen pentoxide.
Except for N2O, the hazards of NOX are quite serious and even insidious
in their nature. The term insidious is used because of the mechanism
of their attack on the body. NOx is only slightly soluble in water, so
the acid they produce (nitric and nitrous acid) does not irritate the
mucous membranes as much as they would if the solubilities were
greater. This would seem to be good, but unfortunately, the warning
property of the irritation is reduced in effect and the exposure goes
unnoticed. Without serious irritation, exposure continues and acids
form deep within the respiratory system, sometimes with disastrous
effects. An excellent source for reviewing these effects are the
various editions of the classic reference by Sax. The version used by
this author is:
Sax, N. Irving. Dangerous Properties of Industrial Materials, 5th
edition, New York: Van Nostrand Reinhold Company, 1979.
All four of the oxides of nitrogen are both health and safety hazards,
to varying degrees. The safety hazards are explosion, fire, and
violent reactions with common materials. The health hazards are highly
toxic gases formed during decomposition from heating and reaction with
common materials, even water.
16.38.
16.39.
This research question could evolve into a term paper project for a
student. On the Internet try either of the following sites for
starters:
http://www.amweld.org
http://www.aws.org
Example types of information available include: book titles, visual
aids, welding products buyers guides, manufacturer names, journal
subscription information, information on welding inspection,
scholarship opportunities, certification information, conference and
convention calendars, membership information, welding schools
information, career advertisements, welding standards information,
government affairs, answers to technical questions, and local chapter
information.
16.40.
The reader should go to the OSHA website on the internet and activate
the link to standards under Laws and Regulations. Then select the
link to Part 1910. A text search capability is then displayed, and an
excellent search term for this exercise is the term noncombustible
barrier. This search term will zero in on the general industry
standard 1910.253 and the corresponding construction industry standard
1926.350. Select the general industry standard, 1910.253. Upon display
of the full text of the standard, use edit to perform a search within
the text of the standard, again using the search term noncombustible
barrier. The search will jump immediately to the standard in question,
1910.253(b)(4)(iii). The NCM database can then be searched for this
particular provision of the general industry welding standard to
determine the frequency of citation of this provision. For the Fiscal
Year this provision of the standard was cited 621 times.
16.41.
From searching the OSHA website within the OSHA Part 1910 General
Industry standards, it can be determined that the principal standard
for gas welding is 29CFR1910.253 and the principal standard for arc
welding is 29CFR1910.254. The NCM database can be used to gather
summary data on the citation of all of the provisions of each of these
standards. For frequency of citation the comparison is as follows:
1910.253
1910.254
It is apparent that OSHA finds many more citations of the gas welding
standard than it does for the arc welding standard.
CHAPTER 17
17.1.
17.2.
17.3.
17.4.
17.5.
17.6.
The "hot" wire provides contact between the power source and the load
using electricity. The "neutral" wire is the normal completion of the
circuit providing a path for the current to ground. The "ground" wire
is a safety device which is the ground wire in case of a short from the
hot wire to the casing (or other conductive part of the load being
used). This low resistance circuit will "blow" a fuse or "trip" a
breaker to open the circuit.
17.7.
17.8.
17.9.
17.10.
17.11.
Class I, II, and III locations describe the type of hazardous material
present: Class I--gases and vapors; Class II--ignitable dusts; Class
III--ignitable fibers or flyings.
17.12.
17.13.
17.14.
(1)
(2)
(3)
(4)
(5)
17.15.
Starting with the given that the bulbs each consume 5 watts of power,
whether the Christmas tree lights are connected in series or in
parallel is irrelevant because the answer to the problem is the same
either way. Most Christmas tree lights are connected in parallel, but
for illustration, both solutions are demonstrated here. It is
recognized that the RESISTANCES of the bulbs are vastly different,
depending upon whether you assume that the bulbs are connected in
series or in parallel.
Method I: Assume a parallel circuit
In a parallel circuit, each resistance sees the full voltage.
If W = V x I and I = V/R, then W = V2/R or
R = V2/W for each branch
R = (110)2/5 = 2420 ohms
1/RT = 1/R1 + 1/R2 + 1/R3 ... etc.
1/RT = 8/2420
RT = 302.5 ohms
I = V/R = 110/302.5 = 0.364 amps
Method II: Assume a series circuit
In a series circuit, the voltage drop is divided among the components
in relation to their resistance. In this case, all are equal.
110V/8 = 13.75 volts per bulb
R = V2/W = (13.75)2/5 = 37.81 ohms
RT = R1 + R2 + R3... etc.
RT = (37.81)8
= 302.5 ohms
I = V/R = 110/302.5 = 0.364 amps
Method III: Assume it doesn't matter.
I = W/V = (5 x 8)/110 = 40/110 = 0.364 amps
The current in the hot wire and the neutral wire are equal.
17.16.
17.17.
The worker will probably be shocked since his/her body will likely
provide the ground to complete the circuit.
If the worker is "moist" enough or otherwise provides good contact and
the current passes through his/her chest, the mishap will probably be
fatal.
17.18.
17.19.
17.20.
17.21.
17.22.
17.23.
17.24.
The broken ground plug removed the chance of a short circuit which
would have tripped the breaker.
17.25.
17.26.
17.27.
(a) The resistance of the pantleg material would likely prevent shock.
If skin contact did occur, the proximity of the neutral contacts would
likely prevent the passage of current through the worker's torso.
Electrocution would be highly unlikely.
(b)
17.28.
17.29
17.30
17.31
Peak voltage
17.32
17.33
240v x 1.414
339.4 volts
Effective voltage
=
80v x 0.707
56.6 volts
Effective voltage
=
170v x 0.707
120 volts
W = VI and I = W/V
Effective current
Peak current flow =
.5 amp x 1.414
0.707 amp
17.34
17.35
17.36
17.37
17.38.
17.39.
17.40.
RESEARCH EXERCISES
17.41.
17.42.
17.43.
Rank
1
2
3
4
5
6
7
8
9
10
Std cited
305(b)(1)
305(b)(2)
304(f)(4)
305(g)(1)(iii)
303(g)(2)(i)
305(g)(2)(iii)
303(f)
303(g)(1)(ii)
304(a)(2)
303(g)(1)(i)
Description
Elect boxes: unused openings or unprotected conductors entering boxes
Open electrical boxes without covers
Grounding path broken or not continuous
Misuse of flexible elec cords (subst for fixed wiring or run thru holes in wall)
Exposed live parts
Electric cord plugs: missing or inadequate pull protection (strain relief)
Inadequate marking of electrical disconnects
Access space around electrical equipment blocked (i.e., by other eqpmt)
Reversed polarity
Inadequate clearance for access around electrical equipment (for maint)
Citations
2159
1729
1430
1429
1378
1346
1158
757
455
363
The above list can be seen to approximately match the list of frequent
violations discussed in Chapter 17 of the text. The rank shifts
somewhat from year to year, but the same, familiar problems continue
over the years to generate the most OSHA citations. There is some
variation in the way various OSHA inspectors choose to write a
citation. The pattern of citation sometimes follows current OSHA
inspector practices. For instance, the familiar standard covering
exposed live parts has been used by some OSHA inspectors to cite open
electrical boxes as well.
17.44.
CHAPTER 18
18.1.
18.2.
Lasers may be used as tools for checking steel girder alignment and
deflection in bridges and buildings.
18.3.
18.4.
18.5.
18.6.
Hydraulic tools operate with higher pressure than pneumatic tools which
causes a higher degree of hazard. Hydraulic pressure is supplied by a
liquid which can have an electrical conductivity or fire hazard
associated with the chosen liquid.
Hydraulic tools are quieter than pneumatic tools.
18.7.
The rear of
crane. The
rear of the
rear of the
18.8.
18.9.
18.10.
18.11.
18.12.
A trench jack placed too high can be damaged as shown in Figure 18.16.
18.13.
18.14.
18.15.
18.16.
18.17.
Yes, a fire that has started in an area other than the explosives
compartment could be extinguished, saving a disastrous explosion.
18.18.
many cranes has a swing radius that exceeds the base of the
poor visibility of the crane operator plus the extended
crane present a hazard of crushing personnel between the
crane and some other object.
=
=
=
=
18.19.
18.20.
18.22.
No; the platform is 27 feet from the ground, so the worker's safety
belt would normally be at his or her waist, approximately at 30 feet
(27 + 3). If the worker fell off the platform the maximum fall
distance would be
30 ft - [40 ft - 12 ft] = 2 ft
Such a fall distance is well within the 6 foot limit specified in
standards for lanyards.
18.23.
18.24.
Mushroomed heads on chisels may release tiny metal fragments when the
chisel head is struck. These metal fragments are a hazard to the eyes
and other body parts.
18.25
1.
2.
3.
18.26
There are 12 power levels. The 12 levels are divided into two groups
of 6 each, the group being designated by the color of the case as
follows;
Brass: lighter (less powerful) group
Nickel: heavier (more powerful) group
Within the two groups there are six levels each, the levels being
designated by the color of the load. The load color code sequence is
as follows from lightest to heaviest:
Gray, Brown, Green, Yellow, Red, Purple
18.27
Every shift
18.28
18.29
Flammable liquids
18.30
The hose flies about dangerously, propelled by the rapidly escaping air
under pressure. Federal standards require in-line automatic shut-off
valves that close whenever a line break causes a sudden
depressurization in the line. The problem is that under heavy usage
with large airflows, the shut-off valves may close during normal
operation causing a nuisance.
18.31
The obvious way to two-block a crane is to hoist the load block too
high to the point at which it contacts the boom tip. Less obvious are
the ways that the geometry can be changed by moving the boon while the
hoist is held fixed. When the boom is lowered, the load block will
slowly creep closer to the boom point even with the hoist fixed. This
is due to the positioning of the hoist drum behind the pivot point of
the boom. Another way to two-block the crane is to extend a
telescoping boon while the hoist is held fixed.
18.32.
fluids are fire and electrical shock through contact with high-voltage
utility lines. For general hydraulic tool applications, the fire
resistance characteristic of the hydraulic fluid takes priority.
However, when working in construction and alteration of electric
utility transmission and distribution systems, the hazard of electrical
conductivity takes precedence over the fire hazard. Therefore, the
hydraulic fluids used for insulated sections of derrick trucks, aerial
lifts, and hydraulic tools that are used on or around energized lines
and equipment for power transmission and distribution are required to
be of the insulating type.
18.33.
18.34
Due to the sensitivity of the GFCI device it can sometimes trip due to
small, perhaps harmless, leaks to ground in a typical construction site
outdoors. This is called "nuisance tripping" .
18.35
18.36
18.37
18.35
The crane likely two-blocked. While the boom was lowered, the hoist
was held fixed and the load block and headache ball slowly creeped up
to the boom point. See diagram. The accident could have been
prevented by motoring out the hoist while lowering the boom or
automatically by an anti-two-block device.
Position 1.
Therefore,
c2 >
c1
Position 2.
Boom lowered.
18.39
18.40.
18.41.
Two-blocking occurs when the load hook or hook block is drawn up too
close to the boom point of a crane or to the upper block in a reeving
arrangement. When the lower block and the upper block (or crane boom
point) make contact, any further winching of the hoist rope imparts a
severe tensile stress to the wire rope. Two-blocking often results in
breaking the wire rope and the fall of the load and load block. Many
fatalities have resulted from two-blocking. ANSI requires two-blocking
damage prevention features on mobile hydraulic cranes if the crane is
of the telescoping boom type with less than 60 feet of extended boom.
18.42.
18.43.
18.44.
18.45.
18.46.
18.47.
18.48.
Helicopter crane hooks must not only be reliable in holding the load
without releasing it at the wrong time; they must ALSO release the load
reliably at the right time. For safety, a mechanical override is
required that can be used in an emergency to release the load in case
the electrical release fails. (Incidentally, this is an example of the
Fail-Safe Principle of Redundancy discussed in Chapter 3.)
18.49.
Material hoists and personnel hoists are different in design and safety
factor. It is a violation of standards to use a material hoist for
personnel; however, it is OK to use a personnel hoist to lift material
provided that rated capacities are not exceeded.
18.50.
18.51.
18.52.
18.53.
18.54.
Earlier editions of the text listed the following as the top five
causes of construction fatalities:
Falls
Electrocutions
Vehicle rollovers
Personnel runover by vehicle
Excavation cave-ins
Current editions do not list these causes because of the paucity of
current data on the causes of construction fatalities. It is probably
unfair to ask students to find conclusive answers to this question, but
it is a good question for student research.
RESEARCH EXERCISES
18.55.
The National Safety Council publication Injury Facts reveals that farm
hazards are very similar to construction hazards, listing such examples
as transportation accidents, falls, and especially machinery hazards.
Tractor fatalities from rollovers has been targeted as a very frequent
cause of fatalities. The National Safety Council publication Accident
Facts, the predecessor publication to Injury Facts, reported that in
1995, overturns accounted for 55% of all on-the-farm fatalities
reported to the National Safety Council, with an annual rate of 5.5
deaths per 100,000 tractors. For all tractor deaths combined the
estimated number of tractor deaths nationwide for the year was shown as
431 in the 1997 edition of Accident Facts. Formerly the largest source
of farm fatalities, there were only 100 fatal tractor accidents in all
of 2001, as reported by the National Safety Council in the 2002 Edition
of Injury Facts. When all farm fatalities are counted (not just those
that occur while actually on the farm), transportation ranks as the
number one exposure to fatalities. The number of transportation
fatalities reported for the agriculture, forestry, and fishing
industry was reported as 3744 for the period 1992-2000 (ref. Injury
Facts, 2002 Ed). Averaged over the nine year period, the yearly average
total would be approximately 416.
18.56.
18.57.
The case study states that the workers lifeline was attached to an
attachment line that was in turn attached to the beam on which the
worker was standing. Since the lanyard was attached to the workers
body harness, the attachment at that point was considerably higher than
the beam on which the worker was standing, perhaps an estimated four
feet higher than the soles of his shoes. Therefore, the worker fell
this estimated four feet PLUS the six-foot length of the lanyard PLUS
the five-foot effective length of the looped, 10 foot attachment line.
This adds up to 4+6+5 = 15 feet. At the 15-foot point in the fall,
then, the lanyard would become taut, and the workers body would swing
below the attachment point of the lanyard. This accident points to the
fact that in ANY FALL the fall distance depends not only upon the
length of the lanyard but also on where the worker is standing when the
fall begins. In this accident it also depended upon the additional fall
distance created by the 10-foot, looped attachment line.