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January-February 2021

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PalletCentral • January-February 2021 35 OSHA penalties for violation of these rules can reach $134,937 per affected worker in instances of repeat or willful citations. Inspections and Responsibilities OSHA's STF standard requires inspection of walking/working surface (WWS) conditions regularly, although a specific timetable for such inspections is not provided nor is there a documentation provision. However, without documented inspections, it is difficult to prove to OSHA that the inspections have been conducted, particularly if the inspector observes a dangerous condition that should have been captured in an adequate examination. When checking walking/working surface conditions in the workplace, remember that OSHA expects the employer to: • Keep clean, orderly, sanitary • Keep free of hazards such as sharp or protruding objects, spills, snow and ice • Ensure that walking/working surfaces (such as catwalks, storage lofts, etc.) can support maximum intended load – if the rating is unknown, this may require retaining an engineer to determine and post the load rating • Provide and ensure use of safe means of access and egress to/from each WWS • Inspect WWS "regularly and as necessary" and maintain in safe condition • Correct or repair hazardous conditions on WWS before any employee uses it again, or else guard the area to prevent use until it is fixed OSHA also specifies that when a correction/repair involves structural integrity of the WWS, a qualified person must perform or supervise the correction/ repair. Under 29 CFR 1910.21 ("definitions" in the WWS rule), "Qualified" means a: "Person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work or the project." The employer must also use a "Qualified Person" as the trainer for other workers, and he or she must be able to identify and minimize fall hazards, know how to use personal fall protection systems and rope descent systems, and train others on proper techniques. A qualified or "competent" person must also be in charge of inspecting fall protection equipment before use. Personal fall arrest system (PFAS) components, such as lanyards, cannot be used for any purpose other than personal protection, so if a line is used for hoisting material, it may no longer be used as part of a PFAS. In a 2017 Letter of Interpretation (LOI) issued by OSHA, the agency clarified that it will consider a designated competent person who meets the criteria of ANSI/ASSE Z359.2 and Z490.1 to meet the criteria in 1910.21(b) and 1910.30(a)(2) for a qualified person: • ANSI/ASSE Z359.2 requires trainers must meet qualifications in Z490.1-2016, including subject matter expertise, training experience and delivery skills … and "appropriate level of technical knowledge, skills or abilities in the subjects they teach;" • ANSI 490.1 includes training qualifications beyond those in the final OSHA rule (participation in continuing education, competency in adult learning methods, etc.); and, • ANSI Z359.2 also sets out responsibilities for competent person in terms of supervising, implementing, and monitoring fall protection program. Pallet Hazards In addition to basic fall protection practices, it is critical to instruct workers that they should never use pallets as a work platform or stack them as a make-shift ladder, nor should persons stand on pallets that are affixed to forklifts (despite what they might see on YouTube prank videos). Those types of hazardous work practices are almost certain to trigger a serious or willful OSHA citation, particularly if management was aware of and tolerated the unsafe activity. Similarly, NWPCA's Uniform Standard for Wood Pallets stresses that pallets are manufactured, recycled and repaired for the sole purpose of storing and/or transporting material. Pallets should be inspected for damage before use and only used where the pallet design is appropriate for the particular unit load application. All pallets should be removed from service, if they are determined to be unsafe or dangerous to persons or goods. This applies both in the pallet industry workplace and for downstream users, who should be reminded of fall and other potential hazards arising from misuse of pallets. Fall protection violations are now OSHA's most-cited standard, and because there are a lot of specific requirements, an employer can get cited for gaps in workplace inspections, in worker training, provision of personal fall arrest systems, or the improper use/storage of personal protective equipment (PPE).

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