OSHA third party inspections

So it says follow the regulations in the current National Electric Code, so that's pretty good if you're in construction. Ifyou're in 1926, you are installing equipment, but if you were in general industry, maybe our equipment's already been installed. So if you're in general industry, you may want to take a look at the National Electrical Code, and determine was the equipment was installed properly, especially grounding and bonding. That's going to be very important for worker safety.

I should bring up to you now that we are currently on the 2014 National Electrical Code, but shortly we're going to be on the 2017 National Electrical Code. So that document will come out sometime around September or October, and we're going to have a brand new code book to follow, and sometimes it's tough to keep up on all those items.

 

Follow the manufacturer's installation guidelines. This is extremely important. You can see the document of the National Electric Code right there, in section 110.3B, it says that you have to install the equipment in accordance with the instructions that come with, from the manufacturer, and you also have to use that equipment in accordance with those instructions that come from the manufacturer. So it's very important that we just don't throw away all of this information that the manufacturer gave us.

 A good example of that is, I've been in many facilities, and I'll do a little walk through, I will see a two-wire heater underneath a desk. Somebody, their feet are cold, and they want to try and get a little bit warmer down there. Well if we look at the instructions that come from the manufacturer on that little two wire heater, it says "residential use only." What would OSHA do with that? They would unplug that heater; they would cut that cord so it's only about a quarter of an inch long so you couldn't use it again, and issue you a $7000 citation.

So, we can never go wrong by following what the manufacturer gives us for their guidelines. This is another pet peeve of mine here. If I am going to do installation in accordance with the National Electrical Code. If I could have a third party come and inspect that, now this is an entity that has no vested interest in the installation. They're going to come and they're going to give us their best judgment if we did it correctly or not. But what else does that do? It gives us documentation that the work we did was correct. We file that, unfortunately if it ever did show up in there, with some type of incident there, we have documentation from a third party, not from us, that sure enough, we did that correctly.

Have qualified personnel performing the work. This is extremely important. So, it really doesn't matter much what the task is. But in OSHA's eyes, they want the employee to be qualified. What does that mean to the employer? Well, that means that the employer has to ensure that the worker has some skills and knowledge that are related to the equipment that they are working on, they have to know how that equipment operates, and they have to know how to keep themselves safe. OSHA wants a list of the qualified personnel. So if I was an OSHA inspector, I could walk into a facility, and I could say "Give me a list of all your qualified electrical workers," let's say. And I could walk up to one of those electrical workers and I could say, "Tell me the personnel protective equipment you wear for six calories per centimeter squared incident energy."

Well, if the worker could tell me what that personnel protective equipment was, everything would be all set. If they couldn't, we'll just probably going to dig a little bit deeper, and you have to remember, with qualified personnel, that I could be qualified for one piece of equipment, and not qualified for another. So you've really got to have that documented, that worker XYZ, he can work on this elevator, but worker ABC, he can't work on that elevator. So you got to make sure they're qualified and they're being qualified:

     - Skills and knowledge about how the equipment was installed

     - How the equipment operates

     - How to keep yourself safe around that equipment

Well, okay. We did mention that TPC Trainco is a little bit different than TPC Online, and here's another picture of me unfortunately, but there I am. I conduct a lot of these seminars. Just finished one in Boulder, Colorado this week. But we go out, and we train in the current regulations of the National Electric Code, and we do over 2,000 of these two-day public seminars, and many times, we will go to you. So we'll have what we call on-site courses, and we will tailor our material to whatever it is you need us to do. And we can help qualify your electrical workers.

Once we issue a certificate with certain CEUs, we could also have them demonstrate that they know the knowledge through written tests. We sometimes have hands on testing where they have to actually just demonstrate that they do know the equipment, and they do know how to keep themselves safe. So this is one way that TPC Trainco can help you with training.

So, forklifts, again, qualified. So we got to make sure that operator is competent. I've been in many facilities where the operators were actually outside contractors, so the facility themselves did not actually employ these forklift operators. So what you should understand about that, whether they are a contractor, or a permanent employee of your own, that you could be held liable for that, because they are operating your forklift, at your facility, on your property. So you can't just think that if you go ahead and say "Oh, we've got contractors doing that, that's up to them.” Oh, no.

It's on your property, it's your equipment, you've got to make sure that they are qualified also. So we can see that we want to make sure that we certify these operators. We want to make sure that we come out and document and evaluate that they are operating the forklift correctly. Give them some refresher training, and then of course, we want to make sure that the forklift has been maintained properly, so we're going to examine it. And if there is any damaged forklifts, we're going to take it out of service. This is true, I told you, also on the extension cord we're going to take it out of service, so that's true. But also, remember, that even PPE, if we have damaged or defective PPE, that also have to be taken out of service.

So ladders. So now we're back in to 1926, which is the construction industry. This is a pet peeve of mine, I have a neighbor that lives very close to me that was injured on a ladder, it was just very unfortunate. He was only about three feet high when it happened. So one, we've got to make sure we've got the right ladder. So we're going to use that ladder only for its designated purpose. Many different types of ladders out there. You can see this one down here is a blue color. That's going to be a certain weight requirement. Also, it's going to be, whether it is non-conductive or not, so the color of the ladder make a big difference.

 We want to make sure that we're not on that top step. And, I have a thing about ladders, I like to say this, I've got a belt buckle rule, that if my belt buckle gets outside of the rails of that ladder, then I've got a good chance of falling off that ladder. So we don't want to get very high and we want to make sure that we have three points on that ladder, either two feet in the hand or whatever we need, we always have three points of your body making contact with that ladder.

We want to make sure that there are no structural defects. So this is where the manufacturer can help us again, they give us a little guide on how to inspect that ladder, and if it is defective, we want to take it out of service, get rid of the ladder. So, very important. 

Also, they have to be on stable and level surfaces, unless we can secure them somehow, but you want to make sure that the ladder is going to be safe when we start to climbing up that ladder.