By Owen McLean
Maintenance pits are necessary for servicing your vehicles; however, there are many dangers associated with them that could pose a severe threat to the safety of your employees. Understanding the laws and regulations of OSHA can protect your employees and prevent costly accidents.
According to OSHA Standard 1910.21(a)(2), a “floor opening” is “an opening measuring 12 inches or more at its least dimension, in any floor, platform, pavement or yard through which persons may fall; such as a hatchway, stair or ladder opening, pit, or large manhole.” OSHA continues to state in Standard 1910.23(a)(5): “Every pit and trapdoor floor opening, infrequently used, shall be guarded by a floor opening cover of standard strength and construction. While the cover is not in place, the pit or trap opening shall be constantly attended by someone or shall be protected on all exposed sides by removable standard railings.”
An inquiry to an OSHA official resulted in a reference to a Federal Register published on May 2, 2003. This Federal Register specifically discusses the unique problem associated with the use of guardrails for perimeter protection that would otherwise interfere with normal work operations. It references the fact that guardrails or similar fall protection devices may cause issues for employees when vehicles are moved over and/or away from the pit. The fact is also acknowledged that when a vehicle is parked over the pit, the primary hazard of falling to the surface below has been eliminated. Don’t breathe a sigh of relief just yet. While there is an understanding of issues, it does not mean employee safety is not the top priority in this situation.
The General Duty Clause, Section 5(a)(1) states: “Each employer shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees.” In other words, the employer has the responsibility to take whatever measures necessary, and with all means possible, to protect the safety and health their employees. At no time should the “easy” route or the “least expensive” route be taken when it comes to ensuring the protection of human life.
A letter of interpretation posted by OSHA reads: “Employees engaged in maintenance work at bus and rail car inspection and repair pits when the bus or rail car covers the pit are not in violation of 29 CFR 1910.23(a)(5). When the pit or pits are not covered, employees walking at least 6 feet from the pit would not be in violation of 29 CFR 1910.23(a)(5), provided the following actions are implemented by the employer:
1. The employee’s safety training program will instruct employees to maintain a 6 feet clear distance from the uncovered pits.
2. Highly visible contrasting lines will be installed 6 feet from the edge of pits.
3. Employer will install caution signs and ensure compliance by employees.”
So, are you in compliance if you train employees to maintain a clear distance of 6 feet from the pit, paint the floor 6 feet out from the edge with high visible contrasting lines and install signage to warn employees of the pit? The answer is maybe. While the precautions mentioned above may be acceptable, it does not mean that is all that is required. The best practice for this type of situation is to ensure there is a standard railing surrounding the pits to ensure no one can fall to the bottom. However, ask yourself the following questions.
o Is a standard railing a viable option? If yes, install the railing. If no:
o Are employees trained and alerted to the presence of the pits? If so, is the training documented?
o Are employees trained to only be in the vicinity of a pit when a vehicle is over the pit and being serviced? If so, is the training documented?
o Is there adequate signage posted warning employees to the presence of the pit?
o Is the floor surrounding the pit painted in a contrasting color to warn employees they are in the vicinity of an open pit?
o When the pit is not in use, is there some barrier erected such as stanchions and chains so an employee cannot accidently fall into the pit?
o Most importantly, have you taken every measure conceivably possible to protect employees from falling into an open pit?
One injury associated with falling into an open pit could more than eliminate any cost savings associated with them. It can also prove life-altering to the employee who suffers injuries resulting from the fall. Following the regulations and guidelines set forth by OSHA can greatly diminish your risk of a workplace accident occurring.
For more information, visit www.osha.gov.
Owen McLean serves as team lead in the Loss Prevention & Safety Services Department of Protective Insurance Company, Carmel, IN.