Cultivating a Relationship with OSHA Part 3

The value of a safety and health program.

This is the third in a series of blogs designed to help introduce your rope access company to OSHA and improve your company safety culture, or if there is none currently, then it’s time to get you started on the correct path to safety. (Check out the first and second blogs.)

It has always been my passion to promote safe work at height and help small business employers in the work at height industry understand the “cost” of safety.

The first question that I ask owners and management is, “How is your company’s safety and health program?” The responses that I receive range from the ignorant to the absurd.  I have heard everything from, “We’re good for now. We’re safe,” to “I’ve been in business for X years and haven’t had a problem.” The fact is most small business owners have been lucky by not having a serious injury, illness or worse a work-related death. For this reason, they don’t understand the importance of proper Safety and Health Management.

The fact is, safety and health programs add value and savings to a business by:

  • Reducing medical costs
  • Lowering insurance rates
  • Lowering EMR’s (Experience Modification Rate) the ability to secure more work
  • Increasing productivity
  • Increasing Morale
  • Reducing turnover

Employees and their families also benefit from Safety and Health because:

  • Their income is protected
  • Their lives are not hampered by an injury
  • Their stress level is not increased

Investing in a safety and health program now will set your company on the course to avoid possible losses in the future. The time, energy and minimal fiscal output to create a culture of safety in your company yields an obvious and extreme ROI.

THE BASIS OF A PLAN:  A FOUR POINT WORKPLACE PROGRAM

  1. Management Commitment and Employee Involvement. The owner, manager or management team leads the way, by setting policy, assigning and supporting responsibility, setting an example and involving employees.
  2. Worksite Analysis. The worksite is continually analyzed to identify all existing and potential hazards. This is where a mobile workforce such as a rope access company sets itself apart from a manufacturer. For example, a rope access company performing an inspection on the side of a building would analyze all hazards from the roof deck down to the ground.
  3. Hazard Prevention and Control. Methods to prevent or control existing or potential hazards are created, utilized and maintained.
  4. Training for Employees, Supervisors and Managers. Managers, supervisors and employees are trained to understand and deal with worksite hazards.

Regardless of business size, these four basic elements make up a Safety and Health Program.  The key to the success of a Safety and Health Management System is to make it part of your day to day operations so it becomes second nature.

Q & A’s for Small Business Employers

Q. What is a Job Hazard Analysis?

A. A preparation technique that focuses on job tasks as a way to identify and correct hazards.

Cultivating a Relationship with OSHA Part 2

Cultivating a Relationship with OSHA

This is the second in a series of blogs designed to help introduce you and your rope access company to OSHA, improve the safety culture of your company, and to help you get started creating that culture if one is absent. (You can check out the first blog here.)

Think of this series as an investment in safety. You have invested in equipment, PPE, insurance, employees and so much more. It’s time to invest in safety. Can you afford not to?

What you first need to know is that there are two types of coverage under OSHA: Federal and State. State Plans are OSHA-approved job safety and health programs operated by individual states instead of Federal OSHA. Section 18 of the OSH Act encouraged states to develop and operate their own job safety and health programs and precludes state enforcement of OSHA standards unless the state has an OSHA-approved State Plan.

So, where do you start?

  1. Educate yourself on your OSHA coverage. First, learn what kind of OSHA coverage will apply to your company: State or Federal. State Plans are OSHA-approved job safety and health programs operated by individual states instead of Federal OSHA. Section 18 of the OSH Act encouraged states to develop and operate their own job safety and health programs and precludes state enforcement of OSHA standards unless the state has an OSHA-approved State Plan. 22 states/territories have OSHA approved State Plans. If your state doesn’t fall under the State approved plan, it will fall under the federal plan. You can check your state on the State Plan homepage.
  2. Take your business to OSHA’s front door. Call your local OSHA office to introduce yourself and your company to the OSHA representative. I called several times and stopped by the local office. Personally, I don’t like phone conversations for first time introductions. I would much rather meet someone face to face so that they better understand my needs. What I try to accomplish is to help them understand my company, SPRAT and our mission of promoting safety in the work-at-height industry. It’s that easy – a telephone call, a letter or a knock at their door will get the process moving in the right direction.
  3. Apply for a consultation. Ask about OSHA’s On Site Consultation Program. The (free!) on-site safety and health consultation provides surveys for small and medium sized Construction and General Industry businesses. The On Site Consultation Program is completely separate from OSHA inspections and there is no concern of enforcement or fear of citation. Because consultation is a voluntary activity, you must request it (see OSHA’s Consultation Directory)  fill out the form and email it to your state OSHA office.
  4. Prepare for, and learn from, your consultation. Schedule a Consultation meeting with your OSHA Consultant, who will then walk you through specific needs of an employer and set up a visit based on the priority assigned to your request. Due to the nature of rope access, we were considered a “mobile workforce,” so we had our consultant visit us at one of our work sites. OSHA encourages a complete review of your company’s safety and health situation in order to determine the correct path forward to safety. The consultant will start with an opening conference with you before beginning the company walk-through. The consultant will study your entire workplace, pointing out safety or health risks. After the walk-through, the consultant will review the findings with you before leaving. Finally, the consultant will send you a detailed written report explaining the findings and confirming any abatement periods agreed upon. They may also contact you from time to time to check your progress.

The costs associated with improving your company safety culture should be thought of as an investment. This investment is free and the payoff will continue for years to come.

Q & A’s for Small Business Employers

Q: What will an OSHA Citation or penalty cost my business?

A: Maximum penalties are set to increase for the first time since 1990. OSHA’s new penalty levels will take effect after August 1, 2016 when the maximum penalty for serious violations will rise from $7,000 to $12,471. The maximum penalty for willful or repeat violations will increase from $70,000 to $124,709, which does not include the cost of an attorney to represent you and your company.

Cultivating a Relationship with OSHA

 

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It is one of the questions that I get asked most often as a business owner: “How do I approach my state OSHA office?” Companies want to operate as safely as possible to avoid fines, while their local OSHA office many not even know what rope access is. The problem is wide spread, and it’s up to the company to take the first step to remedy the situation.

Many rope access employers and employees avoid the acronym OSHA at all costs, but it doesn’t have to be that way. By sharing my experience with OSHA, my hope is to change your misconceptions with this organization and help answer some of the questions you may have regarding your first steps towards introducing your rope access company to OSHA.

My journey with OSHA started out in an unorthodox manner, yet it ultimately changed my perception of safety and OSHA itself. My first official rope access project was a very challenging condominium complex where I encountered a disgruntled window cleaner whose services had just been replaced by my rope access company; this person threatened to report my company to OSHA for what he believed were willful safety violations. He regularly photographed and reported my work to the property manager and shouted that four letter word OSHA as if it were an obscenity.

I can tell you that it became my worst fear that I could potentially be facing a compliance officer based on this person calling OSHA. I certainly did not want anything to do with OSHA nor did I need a citation at that time. Thankfully, the hands of fate intervened and my destiny with OSHA became an invaluable learning experience. Thinking back, if I could meet that window cleaner today, I would shake his hand and thank him for all that he has done for me and my company.

It begins with your employees; building a small company and hiring employees changes the game significantly, since you now inherit the title of ‘Employer’. This title comes hand in hand with another: Employer Responsibilities. Under the General Duty Clause, Section 5(a)(1) of the Occupational Safety and Health Act of 1970, employers are required to provide their employees with a place of employment that is “free from recognizable hazards that are causing or likely to cause death or serious harm to employees. 

In simpler terms, employers have a responsibility to provide a safe workplace. (The full list of key employer responsibilities can be found here: https://www.osha.gov/as/opa/worker/employer-responsibility.html.)

It’s key to understand the importance of safety and health management so that your rope access company is not on the wrong end of an OSHA inspection or worse, a work-related injury or fatality at your company.

So, what’s at stake if you are the employer?

In short: your company, your livelihood, or someone’s life. A work-related injury or fatality will put your company in the cross-hairs of OSHA and also Civil Litigation, at which point it is all but too late. By the time a trial comes around, a lawyer will have a carefully prepared case against you and your company. If this happened to you tomorrow, how prepared would you be?

No one will ever be prepared for a work-related fine, injury or fatality, but you can make sure you are arming your company against the occurrence of all three by being prepared, knowledgeable, above all, genuinely friendly with your local OSHA office.

Q & A’s for Small Business Employers

Q: Can an OSHA Compliance Officer (CSHO) show up unannounced at your site without an appointment for a surprise inspection? Do they need to call ahead, email or send notice of an inspection?

A: Notice of intended inspection shall not be given to an employer prior to the time of actual entry upon the workplace. Compliance Officers will present credentials, and shall be permitted to inspect places of employment, Question employees, and investigate conditions, practices or matter connection with employees.

Top 5 Benefits of Working in Rope Access

Top 5 benefits of working in rope access

  1. Physical Fitness: Due to how physically demanding the work is, rope access leaves technicians little option other than to be physically fit. In most cases, just performing the work itself goes a long way in helping to cultivate a higher level of physical fitness. Being a rope access technician is not dissimilar to working out for forty hours a week; the exercise is built into the job.
  2. Unbeatable Views: One of the awesome benefits of being hired to access an area no one else can get to is that you get to see what no one else gets to see. There are views technicians see that only a handful of people in the world have or will see, places they will access that they would never be able to access if they weren’t performing rope access. The underside of the Skywalk at the Grand Canyon, government buildings with top level security, rooftops on New York City skyscrapers, the space shuttle Atlantis: without rope access, we wouldn’t have seen any of them.
  3. Patience & Focus: Two traits that can easily make or break technicians, and those technicians also take home with them and see the benefits of in their personal lives. Patience and focus are paramount when performing rope access; ascending 200 feet, performing an edge start on a 50 story building, tying knots necessitate a serious level of patience and focus because it could be the difference between life and death. Learning to have both of these qualities while on line brings with it the benefit of these qualities in the technician’s daily life, lending to an often times calmer, thorough and more focused thought process.
  4. Coordination: We could have included this with number three, but it’s significant enough to warrant its own spot. There is a very real necessity for coordination in rope access; to put it simply, you can’t accomplish anything on ropes if you resemble a fish out of water. Technicians need to be coordinated enough to perform, hold and maintain multiple physical tasks simultaneously which is an incredibly useful trait to have carry over into one’s personal life.
  5. Career Path: Rope access holds the potential for countless career paths. There are countless windows of opportunity, whether a technician is interested in being an instructor, evaluator, supervisor, project manager, operations manager or even the director of a safety division, all are possibilities that are open to technicians in the rope access community. Many enter into rope access in the early stages of their career development, and with dedication and proper planning they can take their career within the industry in nearly any direction, up to and including retirement. Rope access appears on the surface to be a limited potential occupation for young climbers, when in reality it is the perfect way to begin laying the foundations of an enduring and self-sustaining career.

Top 5 Misconceptions about Rope Access

Top 5 misconceptions about rope access

  1. “Rope access is a trade.” Rope access is not, in itself, a trade. Rope access is the vehicle that gets a technician from point A to point B in order to perform a trade or skill. There’s a huge difference, and it is consistently and nearly universally overlooked. Becoming a level 1 rope tech isn’t going to get one anywhere other than to the physical spot on the tower/building/structure/rig where the actual work needs to be done. It should go without saying that the probability of someone hiring a rope tech for the sole purpose of ascending or descending a line only is pretty low. Be prepared to accept the fact that rope access needs to be paired with a skill or a trade.
  2. “Starting pay is $X per hour.” Rope access is like any other industry when it comes to pay; different companies have different budgets, pay scales and projects requiring technicians. An international or publicly traded company with large scale funding will absolutely pay a technician more per hour than a small business that works one project at a time. In addition to this, misconception number one comes into play again: if a technician has no trade to perform on rope, s/he’s going to make less per hour than a technician who is also a welder, NDE inspector, or even one who simply has experience performing a certain skill, like lighted sign maintenance.
  3. “Being certified is going to guarantee me work.” We see it constantly: technicians have a brand new certification, zero logged hours of rope access work, and are genuinely surprised by the fact that they do not have a large number of jobs to choose from. Rope access is an industry filled with highly competitive, hardworking technicians who are constantly trying to bulk up their resume in order to acquire better projects and positions. Being certified is not enough to get a technician work; rope access professionals must also be hungry for knowledge, experience and self-improvement because while the industry is small, there is still not a never-ending supply of work.
  4. “My employer is legally required to provide me with my rope access kit.” We are still fighting this battle, always. Many people in the industry think that OSHA’s requirements for supplying employees with PPE applies to rope access, which it does not. “On May 15, 2008, a new OSHA rule about employer payment for PPE went into effect. With few exceptions, OSHA now requires employers to pay for personal protective equipment used to comply with OSHA standards.” There are currently no OSHA standards in place for rope access, meaning this OSHA standard does not apply to rope access. Some employers with more financial backing may be able to provide kits to their employees, however it is not required by OSHA or any other governing party.
  5. “Rope access is an industry of men only.” Like many professions, it’s a common assumption and misconception that the work force is entirely comprised of men. Industries like construction, welding, engineering, nearly anything involving athletics, and even computer programming are all erroneously assumed to be men-only. Rope access is a field of work that clearly has more male technicians than women, but that should not deter any women from entering the field. One of the founding members of SPRAT (Society of Professional Rope Access Technicians) was Loui McCurley, who is a widely renowned industry leader, and who is currently the CEO of one of the most esteemed manufacturers of rope and equipment in the industry (PMI). Our academy has had incredibly successful female students, who have gone on to have rewarding careers in the industry, and that is not as uncommon in rope access as you might think.

Top Five Most Overlooked Must Haves for Rope Access

When performing rope access, there are few things more frustrating than positioning yourself to perform your work only to realize you forgot something and need to get off line. It’s rare you’ll ever forget anything in your rope access kit, but there are a few things that are necessary and easily forgotten if you aren’t prepared.

  1. Hydration & Snacks

Hydration seems like an obvious necessity on the job site, but we notice (especially in our desert environment) that it is often underestimated just how much water a person needs to stay hydrated. It’s safe to assume that if you’re performing hard labor or working in heat that you should be consuming at least sixteen ounces of water per hour.

We tend to work ten hour days, and we don’t like breaks.  Sometimes that means eating when you can grab a second. We keep protein bars on hand, and bananas to keep up our potassium. It’s important to eat nutritious, clean foods while working on ropes to keep yourself physically well and capable of performing your duties. As a rope access technician, your body is your most valuable and important tool on the job.

  1. The Unexpected

Performing rope access during the day? Bring head lamps. You brought your ASAP? Bring your Red, too. You already gave a copy of your JHA to the property manager? Bring another. Performing an inspection that requires photos? Bring an extra battery and memory card. Rope grabs. So many rope grabs. Think Boy Scout. Be so prepared that it’s comical, and make it a habit. You can never be too prepared, because the alternative is unacceptable (and unprofessional).

  1. A Knife

It may seem like a bad idea to have an item that’s sharp while performing rope access, but just like anything else; if you take the right precautions it’s perfectly safe. Keep it tethered, keep it facing away from your body and keep it away from your ropes. I cannot tell you how many times a knife has come in handy when I was performing work at height. There’s nothing more annoying that having to get off line to go track a knife down just so you can complete your work.

  1. Clothing & Steel toe shoes

You already know the clothing you should be wearing when working at height, and your necessary PPE. This isn’t about that. This is about working within the constraints of your required PPE to be as comfortable and efficient as possible while performing rope access. If my clothes don’t breathe, especially in 120 degree weather, I can’t perform the physical actions required of rope access. The game changer is going to be the first time you wear sweat-wicking/breathable and/or UV protecting clothes. They’ll change your entire outlook on work attire, and you’ll never go back. I got a pair of these pants a few months ago and wore them into the ground, and now I’ve stocked up and they’re all I wear. (Not an exaggeration, I wear them to every job site.)Wearing TrueWerk T2 pants for rope access work

My other must have, which is still pretty well debated among rope access technicians, is steel toed boots. I’ve spoken to many rope techs who say they don’t feel the need to wear them because they aren’t always performing rope access work on a construction site. Construction or not, they’re incredibly convenient and bring an extra level of safety to your PPE, while giving you the ability to hold yourself in place easily and without injury to your feet. Wearing steel toed shoes while performing rope access work gives me the ability to utilize a unique and effective tool every day with minimal effort.

  1. Gloves

Sometimes you’ll need different kinds of gloves, but my go-to are baseball gloves. They protect your hands, prevent sweat from interfering with your work, and are thin enough to be able to perform tasks requiring a more delicate touch. Obviously, rigging gloves are great for rigging and more general or hard labor, but thinner gloves give you the ability to keep a strong grip while also maintaining the ability to perform precision tasks.

To Move From Mediocrity to Greatness, We Must Venture Out

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TO MOVE FROM MEDIOCRITY TO GREATNESS,
WE MUST VENTURE OUT

The responses received from the last blog were remarkable; listening to the stories behind the messages from all who took the time to communicate their thoughts and ideas was genuinely inspiring. The result left us with one of the most precious resources: optimism, the optimism that together we can make a difference.

Making a difference in this industry is absolutely possible and within our grasp, and as simple as one important thing: listening.

Now is the time to listen to the opinions, concerns and input of peers within the industry. The last article granted us this ability, and it has been invaluable.

The point of An Uncontrolled Descent: The Free-Fall of the Rope Access Industry was to question the current system of the 40 hour course and gather the thoughts and ideas of those within the industry so that together there is a path forward for the betterment of the industry.

http://www.abseilon.com/an-uncontrolled-descent-the-free-fall-of-the-rope-access-industry/

Those who commented and voiced their opinions about the article produced opportunities to explore different approaches to solve the issues we are facing as an industry. Although there was an array of ideas, we did notice a trend in the comments we received. The majority of responses, from a cross-section of the rope access community, shared the idea of an apprenticeship as a path forward and a need for additional training provided to those individuals entering the industry.

Why Apprenticeship is Right for Rope Access Certification

According to the US Department of Labor, Registered Apprenticeship is a tried and true approach for preparing workers for jobs, and meeting the business needs for a highly skilled workforce. This reason alone makes sense for Rope Access certification; it works for the industry and develops a skilled workforce. Feedback from the most recent blog recommended raising the bar for skill requirements and properly enforcing those requirements, followed by a sponsorship with a contract. In essence, this defines an apprenticeship, and we could not agree more that this is the most appropriate path to take.

Here are the Components of a Registered Rope Access Apprenticeship

  1. Business Involvement. In short, employers need to be a part of the apprenticeship design process. In order for the program to be a success, businesses, business owners and hiring managers must play an active role about their wants and needs for future employees.
  2. Structured, On the Job Training. Every sanctioned apprenticeship revolves around this concept, and a rope access apprenticeship should be no different.
  3. Related Training and Instruction. Rope access in itself is not a trade, but a means of physical access to perform a trade. An apprenticeship in rope access would require education partners to assist in training apprentices in trades to perform while on line.
  4. Reward for Skills Gained. Apprentices receive increases in pay as skills and knowledge increase. Progressive wage increases reward and motivate apprentices as they advance through training.
  5. National Occupational Credential. Every graduate of a registered apprenticeship program receives a nationally recognized credential.

It’s time to make a difference. Encourage a discussion on the subject with your peers and above all, listen.

An Uncontrolled Descent: The Free Fall of the Rope Access Industry

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AN UNCONTROLLED DESCENT
THE FREE FALL OF THE ROPE ACCESS INDUSTRY

As an employer in the Rope Access Industry our company receives many calls and emails regarding employment from recently Certified SPRAT and IRATA Level I Technicians. Over time, we have noticed a startling trend among prospective employees; a misconception about what working in the industry actually entails. This led us to ask ourselves the question:

“Are rope access training companies properly preparing new technicians for the workplace?”

For Level I grads, the perception is that by attending a standard forty hour course and obtaining SPRAT / IRATA Level I Certification, they are going to walk away with an hourly wage of $20 – $40 per hour with no prior experience, expect that their employer is going to train them to advance in their careers, and also provide them with all of the equipment and gear necessary in order to perform their job. They leave their course under the impression that their certification card and empty log book guarantee them forty to eighty thousand dollars a year and unlimited on the job training.

But Where is the disconnect? There are striking gaps between the expectations of newly certified level I technicians when it comes to experience, salary, and equipment. As with any other industry, these three factors partly rely on the size of the company. A multimillion dollar outfit will be able to supply employees with equipment more easily than a small business with less than ten employees, for example. Employers and prospective newcomers to the industry experience a disconnect when a belief is instilled that all companies have the same amount of resources.

The second problem lies in unrealistic expectations for instant gratification. How do new technicians form these attitudes and assumptions?

Where does the problem start?  Wondering where these future technicians are getting such inflated ideas about their desirability to employers? The internet is the first place to start, performing a simple Google Search on ‘Level – I Rope Access Technician Wages’ and you’re on your way.  To exacerbate the problem further, some Rope Access Training Companies utilize subtle marketing tactics on their websites alluring students with the general expectation of earnings somewhere between $20 – $40 per hour. The false promises of high starting wages and a target audience of 18 – 35 year olds paired with society’s attitude of instant gratification makes this an enticing offer to all those who choose this field of work. As an employer we believe this can be damaging to our workforce and organizations such as SPRAT and IRATA. Nothing can take the place of experience, too fast, too quick, too soon is a recipe for disaster in our industry.

The truth regarding a 40 – Hour Course?  There is no standard from SPRAT that requires a 40 hour course. The SPRAT certification process is intended to establish a minimum baseline of knowledge and skill directly related to industrial rope access. The certification does not test industry-specific skills. Additional evaluation may be required by the employer to verify the rope access technician’s suitability to a specific job. The keyword in this paragraph is minimum, the least or smallest amount attainable. With the growing body of certified level I technicians in the USA the demand for additional training of newly certified technicians is critical. Critical to employers and critical to ensure SPRAT’s future in terms of safety.

Adverse Effects of the 40 Hour Course:   Most employers are reluctant to hire newly certified SPRAT Level I Technicians due to lack of industry experience. When newly certified technicians become unemployed or underemployed for long periods of time the result is the effect of progressive knowledge or skill deterioration. Skill Decay is particularly problematic in 40-hour courses where individuals receive initial training on knowledge and skills that they have not used for an extended period of time.  In the rope access industry you need to maintain a regular regiment of skills or you will lose that knowledge and skill set.

After Training Courses The Real World Shock:   All Rope Access Training Courses are ‘controlled environments’ and not ‘real-world’ applications. The average height of many training facilities is approximately 20 – 30 feet and certainly not a real world experience. The real world shock for the new grad comes the moment they have to negotiate a height more than the average training facility and perform as a Level I Technician. For some there is no problem, however for others the real world shock of a 200 ft drop brings the nerves out immediately.

Implementing a Solution to the Problem:   Problem solving is one of the most essential skills in life; to solve this problem is as easy as thinking differently. Nothing great has ever been achieved by doing things the way they have always been done. As an employer in the Rope Access Industry how can our company change the current method of educating the future rope access technicians?

The answer is simple; create an internship or apprenticeship program in addition to the 40 hour certification program that currently exists. A system of on-the-job training and related technical instruction. An intern receives supervised, structured, on-the-job work experience combined with related technical instruction under the supervision of a SPRAT L-III or L-II Technician assigned to oversee and train the intern. The intern is a regular part of the workforce and earns while acquiring important skills for rope access.

It’s up to us to change the industry for the better by instituting a system of additional training and education. Rope access is the vehicle that takes a technician or tradesman from point A to point B; let’s make sure we are sending them on their journey with more than a learner’s permit.

Abseilon Rope Access Training Academy’s Anniversary!

abseilon training academy

 

It’s been a year since our Academy doors opened last August and we’re celebrating our anniversary in a big way with our August SPRAT Rope Access Training Course.

$1500 Tuition includes:
Free: Kindle Fire loaded with curriculum and training videos, breakfast and lunch, giveaways from rope access equipment manufacturers like CMC Rescue and Kask, and we will cover  your SPRAT fee.

We only have a few spots left, don’t miss out!

Email questions or application requests to info@abseilon.com.