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Certified Remodeler

Module 7: Safety

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The contractor should be aware of possible hazardous conditions and


materials that may be encountered on the job and be able to plan for their
mitigation. He should be able to instruct his crews in proper work
procedures to minimize hazards to themselves and others. He should also
be aware of the OSHA requirements for safety in the workplace and the
EPA requirements regarding the disposal of hazardous materials
encountered. OSHA citations for rules violations can be very expensive.
A reference for self-study is Modern Carpentry by Willis H. Wagner and
Howard Bud Smith (2000), p. 51-100, 719-728. Another reference is the
OSHA issued booklet Selected Construction Regulations for the Home
Building Industry. The number of copies produced was limited, and it may
no longer be available in print. However, it is available for free download at
www.osha.gov/Publications/Homebuilders/Homebuilders.html. The
Wagner and Smith book emphasizes tool safety, ladders, and scaffolding.
Injuries from falls are a major part of injuries in the construction industry.
Because of the number of new safety hazards not covered in the Wagner
book, scaffolding and fall protection are covered extensively in this module.
Most of the safety questions on the exam will be based upon the
information in this module.
OSHA has indicated a willingness to go to a job site and make an
evaluation upon request without making any citations. Congress mandated
this, but check with your local OSHA office before doing so. They may not
be so cooperative. Each state has an OSHA office to provide information
to any business requesting it. The OSHA web site, http//www.osha.gov,
will have the latest regulations.

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Glossary

Accident – any suddenly occurring, unintentional event that causes injury


or property damage.
Bearer – a horizontal transverse scaffold member (which may be
supported by ledgers or runners) upon which the scaffold platform rests
and that joins scaffold uprights, posts, poles, and similar members.
Body Belt (safety belt) – a strap with means both for securing it about the
waist and for attaching it to a lanyard, lifeline, or deceleration device. No
longer acceptable.
Body Harness – a design of straps that can be secured around the body in
a manner to distribute the fall arrest forces over at least the thighs, pelvis,
waist, chest, and shoulders with a means of attaching it to other
components of a personal fall arrest system.
Brace – A rigid connection that holds one scaffold member in a fixed
position with respect to another member, a building, or structure.
Carpenters' Bracket Scaffold – a scaffold consisting of a platform
supported by brackets attached to a building or structural wall.
Cave-in – the separation of a mass of soil or rock from the side of an
excavation or the loss of soil from under a trench shield, and its sudden
movement into the excavation by falling or sliding in such a quantity that it
could entrap, bury, or otherwise injure or immobilize a person.
Cleat – a structural block used at the end of a platform to keep the platform
from slipping off its supports. Cleats are also used to provide footing on a
sloped surface.
Combustible – capable of exploding into flames.
Competent Person – one who is capable of identifying existing and
predictable hazards in the surroundings or working conditions that are
unsanitary, hazardous, or dangerous to employees and who has
authorization to take corrective measures to eliminate them.
Crawling Board (chicken ladder) – a supported plank with cleats spaced
and secured to provide footing; it is for use on sloped surfaces such as
roofs.

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Deceleration Device – any mechanism, such as a rope grab, rip-stitch


lanyard, specially-woven lanyard, tearing or deforming lanyard, or
automatic self-retracting lifeline lanyard that dissipates a substantial
amount of energy or limits the energy imposed on a person during a fall
arrest.
Deceleration Distance – the additional vertical distance a falling person
travels, excluding lifeline elongation and free fall distance, before stopping
from the point where the deceleration device begins to operate. Measured
as the distance between the location of the body harness attachment point
at the moment of activation (at the onset of the fall arrest forces) of the
deceleration device during a fall and the location of that point after the
person comes to a full stop.
Equivalent – alternate designs, materials, or methods to protect against a
hazard that the employer can demonstrate will provide an equal or greater
degree of safety than those specified in the standard.
Excavation – any man-made cut, cavity, trench, or depression in an earth
surface formed by earth removal.
Explosive – something tending to explode.
Extinguish – to cause to quit burning.
Fabricated Frame Scaffold (tubular welded frame scaffold) – a scaffold
consisting of a platform(s) supported on fabricated end frames with integral
posts, horizontal bearers, and intermediate members.
Failure – load refusal, breakage, or separation of component parts. Load
refusal is the point where the ultimate strength is exceeded.
First Aid – immediate, temporary care given to the victim of an accident or
sudden illness until the services of a physician can be obtained.
Flammable – capable of being easily ignited and burning with extreme
rapidity.
Ground-Fault Circuit Interrupter – an electrical device installed either in a
service entrance or in an outlet that compares the electrical flow to a device
and the amount returning and shuts off the circuit if there is a difference,
which is usually caused by an unintentional leakage to the ground.

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Guardrail System – a vertical barrier consisting of, but not limited to,
toprails, midrails, and posts erected to prevent people from falling off a
scaffold platform or walkway to lower levels.
Hazard – source of danger.
Hole – a gap or void 2" or more in its least dimension, in a floor, roof, or
other walking/working surface.
Ladder Jack Scaffold – a scaffold consisting of a platform resting on
brackets attached to ladders.
Lean-to Scaffold – a scaffold that is kept erect by tilting it toward and
resting it against a building or structure. Now prohibited.
Lifeline – a flexible line connected to an anchorage at one end to hang
vertically or connects to anchorages at both ends to stretch horizontally. It
serves as a means of connecting other components of a personal fall arrest
system to the anchorage.
Low-Slope Roof – a roof having a slope less than 4 in 12.
Maximum Intended Load – the total load of all persons, equipment, tools,
materials, transmitted loads, and other loads reasonably anticipated to be
applied to a scaffold or scaffold component at any one time.
Mobile Scaffold – a portable caster- or wheel-mounted supported scaffold.
Opening – a gap or void 30" or more high and 18" or more wide in a wall or
partition through which a person could fall to a lower level.
OSHA (Occupational Safety and Health Act) – federal legislation
designed to ensure safe and sanitary working conditions for employees.
Personal Fall Arrest System – a system used to halt a person's fall. It
consists of an anchorage, connectors, and a body harness, and it may
include a lanyard, deceleration device, lifeline, or combinations of these.
Platform – a work surface elevated above lower levels. It can be
constructed using individual wood planks, fabricated planks, fabricated
decks, and fabricated platforms.
Pneumatic – air-powered.
Powder-Actuated Tool – any tool that depends upon the combustion of a
gunpowder charge for its driving force.

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Pump Jack Scaffold – a scaffold consisting of a platform supported by


vertical poles and movable support brackets.
Qualified – one who, by possession of a recognized degree, certificate, or
professional standing, or who by extensive knowledge, training, and
experience, has successfully demonstrated his/her ability to solve or
resolve problems related to the subject matter, the work, or the project.
Rated Load – the manufacturer's specified maximum load to be lifted by a
hoist or to be applied to a scaffold or component.
Roof Bracket Scaffold – a rooftop scaffold consisting of a platform resting
on angular-shaped supports.
Rope Grab – a deceleration device that travels on a lifeline and
automatically, by friction, engages the lifeline and locks so as to arrest the
fall of a person. Usually uses the principle of inertial locking, cam/lever
locking, or both.
Safety – state or condition of being safe; freedom from danger, risk, or
injury.
Scaffold – any temporary elevated platform and its supporting structure
(including anchorage) used for supporting people, materials, or both.
Sheeting – members of a shoring system that retain the earth in position
and are supported by other members of the shoring system.
Shield – a structure that can withstand the forces from a cave-in and
thereby protect employees within the structure.
Shoring – bracing of an excavation or foundation to resist lateral pressure.
Stair Tower – a tower made with scaffold components containing internal
stairway units and rest platforms that are used to provide access to scaffold
platforms and other elevated points, such as floors and roofs.
Steep Roof – a roof having a slope steeper than 4 in 12.
Toeboard – a low protective barrier that will prevent the fall of materials
and equipment to lower levels and provide protection from falls for
personnel.
Top Plate Bracket Scaffold – a scaffold supported by brackets that hook
over or are attached to the top of a wall. It is used in residential
construction for setting trusses.

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Written Plan
Remember that OSHA is a bureaucratic organization. Nothing is as
important as having everything in writing. Every employer should have a
written Injury and Illness Prevention Plan (IIPP). While no plan can
guarantee an accident-free work place, following the safety procedures set
forth in such a plan will significantly reduce the risk of danger to you and
your employees. A little common sense and caution can prevent most
accidents from occurring.
State and federal law and company policy must make the safety and health
of your employees the first consideration in operating your business.
Safety and health must be a part of every operation and everyone's
responsibility at all levels. No employee can be required to work at a job
known to be unsafe or dangerous to his or her health. Employees cannot
be disciplined or suffer any retaliation for reporting a safety violation in
good faith.
A number of companies sell pre-written IIPPs that can be adapted to your
business. They should include safety rules, training programs, and record-
keeping requirements. Adopt only those parts of these suggested
programs that you are willing to actively pursue and enforce. Adopting
statements or policies you have no intention of enforcing may well discredit
your entire plan. Be sure it includes things you will try to do, not things you
intend to ignore.
Training
Training is one of the most important elements of any Injury and Illness
Prevention Program. Such training is designed to enable employees to
learn their jobs properly, bring new ideas to the workplace, reinforce
existing safety policies, and put the injury and illness prevention program
into action. Such a training program should include an indoctrination
program, written material for employees, and periodic “toolbox talks” on
safety (at least every three months). Be sure to keep outlines of the
material covered and attendance records at all these functions, preferably
signed by the attendees. All such meetings must be on paid time.
The employer must provide a training program for any employee who may
be exposed to any hazards and ensure that a competent person qualified

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to evaluate the hazards and the protection provided has trained each
employee. The employer must verify this training by preparing a written
certification record containing the name of the employee, the date(s) of the
training, and the signature of the person who conducted the training or of
the employer. If the employer relies on training by another employer, the
certification record shall indicate the date the employer determined the prior
training was adequate rather than the date of actual training.
Subcontractors
All subcontractors must be made aware of any potential hazards that may
exist on the job. Conversely, all subcontractors must make you aware of
any hazardous conditions that may result from their work or equipment.
All safety information and all safety rules should be printed and distributed
to all new hires and included in any employee handbooks. They must also
be distributed to all subcontractors, and subcontractors must be
contractually bound to observe the safety rules on the job.

Code of Safe Practices

Safe Work Conditions


• Floors and platforms shall be kept free of projections, obstructions,
holes, and loose boards.
• Exits shall never be blocked or obstructed.
• Fire extinguishers shall not be blocked or obstructed at any time.
• Safety devices and guards shall not be removed, and/or will be
replaced before operating any machine.
• All unsafe work conditions shall be reported to a supervisor or the
safety coordinator.
• Report all accidents, injuries, or illnesses to a supervisor or the safety
coordinator, regardless of how minor they may be.

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• Correct or report any safety device that is missing or inoperative.


• Return tools and equipment to a proper storage place after use.
• Qualified personnel shall perform maintenance of equipment. Do not
attempt to fix it yourself.
• No jewelry, long hair, or loose clothing is allowed around any
machinery while operating.
• Horseplay and running shall be forbidden.
• Smoking is allowed only in designated “smoking areas”.
• Proper hygiene shall be used when leaving or returning to work areas
for breaks and lunch (i.e. washing hands).
• Employees shall use proper lifting techniques as outlined in the Back
Injury Prevention Program to avoid overextension when lifting.

First Aid
Provisions shall be made before beginning a project for prompt medical
attention in case of serious injury. If an infirmary, clinic, hospital, or
physician is not reasonably accessible in terms of time and distance to treat
workers, a person who has a valid certificate in first-aid training from the
American Red Cross or equivalent should be available at the work site.
Your policy should offer to pay for any such training, including that done
outside regular work hours. It is best to have at least one person on every
job who has a Red Cross first aid card. First aid training should be a part of
the safety training of each employee. A first aid kit adequate for the
number of workers and the type of work being done should be present on
every job. The phone number of the nearest available ambulance service
or other source of medical attention should be prominently displayed at the
job site.

Hazardous Chemicals
OSHA has established a list of Permissible Exposure Levels (PELs), which
are air concentrations of certain chemicals that may not be exceeded on
average during an eight-hour shift or, in some cases, not at all. In most

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cases, if materials are used according to industry practice with reasonable


ventilation, PELS are not likely to be exceeded. A review of Material Safety
Data Sheets for these chemicals and an evaluation of how they are used is
usually sufficient to determine if there are any problems. The worker's
compensation insurance carrier or the OSHA Consultation Service can
assist employers in this evaluation.
The Material Safety Data Sheets for each hazardous substance used will
indicate the PEL for the substance or product's hazardous ingredients. An
MSDS for every hazardous substance must be maintained on the job site,
and is available from the manufacturer of the product. There is even an
MSDS for rock salt used to thaw ice on the project!
There are a number of chemicals that may be encountered in the
remodeling industry that pose significant hazards to workers.
One hazardous chemical is pentachlorophenol, which was used for years
as a wood preservative and was used in pressure-treating wood members
for public use until about 1985. Since that time, its use has been restricted
to treatment of telephone poles, railroad equipment, poles, and structural
members used for pole-frame construction. Pentachlorophenol may
contain traces of dioxin, which is one of the most hazardous chemicals in
the world. Workers handling penta-treated wood should wear gloves and
long sleeves. If the material is to be cut, safety goggles and breathing
masks should be used.
Many of the termiticides used in the past have also been banned, but they
may still persist in the soil or on the surface of materials. These include
chlordane, dieldrin, aldrin, and heptachlor. Their life in the soil may be as
long as 40 years. Again, workers must be protected according to their
exposure.
OSHA has effectively banned methylene chloride, which was an ingredient
in most paint strippers. The fumes from any of the volatile hydrocarbons
can be dangerous to workers and may cause long-term damage to kidneys
and other organs. Good ventilation, breathing masks with the appropriate
chemical-absorbing cartridges, and appropriate protective clothing are
required.
Material Safety Data Sheets must be available to all workers and

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subcontractors who are exposed to any hazardous materials, and safety


meetings should be conducted on a regular schedule to maintain
everyone's awareness of the hazards involved. Subcontractors also must
make an MSDS available on any chemical they use.
Lead
The numerous and significant adverse health effects from lead have been
known for over 200 years. Many governments had banned its use in
various products, including wine, food, food containers, household paint,
gasoline, pipes and wires, and children's toys and furniture. The presence
of lead in our environment is not a problem. Man has lived with the
presence of lead in the earth for thousands of years, but it did not cause a
problem until man started mining it. There is a significant area of science
that blames lead for the decline of the Roman Empire because they piped
water around Rome in lead pipes. When used properly, the presence of
lead in regular household products does not present a danger. Misused or
ignored, however, lead can and does cause serious health problems.
The primary victims of lead are the very young. As the brain and nerve
pathways are being developed in the child, the presence of lead can affect
or detour them. From the fetus until at least six years of age, lead can
have a devastating effect on the human mind. It can cause problems
throughout life, but it takes more and produces fewer problems than it does
in the very young.
For instance, the lead used in batteries presents no danger as long as the
battery is used and disposed of properly. The lead in the lower layers of
old paint in and on homes, schools, and other buildings presents no danger
to the occupants if the paint is properly maintained or handled. It is the
condition of the paint and the availability of the lead in the paint that
determines the safety, not the concentration. High-risk conditions exist in
many homes and apartments where the occupants and owners think
nothing about the paint when they sand, scrape, or repair their homes,
when they open and close their windows and doors, or when painted
surfaces are allowed to deteriorate.
Your training program should provide information to employees who are
subject to lead exposure at or above the action level that the possibility of

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skin or eye injury exists from this exposure. The site supervisors must be
trained to determine the presence and extent of any hazard. A specific
program should be presented to all employees before they enter the work
area to begin work.
Risk Assessment. Lead is dangerous only if it is ingested either by drinking
lead-contaminated water, inhaling vaporized lead, or eating lead-containing
dust or, rarely, paint chips.
There are relatively few lead water supply pipes still in existence and those
only in cities with very old water systems. Lead drain piping does not
present a hazard. Some houses have copper water pipes with joints made
using lead-based solder. Whether or not the lead is leached from solder
depends upon the chemical properties of the water. Nearly all potential
hazards from lead in water can be eliminated by running the water for 90
seconds before drawing drinking water in the morning or from pipes that
are seldom used.
Lead paint is mainly found in enamel paints manufactured before 1978. Its
use was substantially reduced after the 1940s because of the development
of better bonding materials. Most homes built since the 1960s do not
contain enough lead-based paint inside the house to be a hazard. Even
the amount found inside or outside houses from the 1960s and 1970s is
usually low. Both exterior and interior paints from the 1940s and earlier are
often in excess of acceptable levels.
The presence of lead-based paint in a home is not something that requires
its removal. The first step is determining the risk of problems, how easily it
can be damaged, and its potential for being inhaled or eaten by the people
living or working there. One factor is who is living in the house. Lead-
based paint is mainly a threat to children under six and to pregnant women.
A second factor, the condition of the paint, is important. Chipped paint is
potentially dangerous, not because it is likely to be eaten but because the
chips are easily ground into lead-containing dust. The third factor is where
the paint is located. Doors and windows are of more concern than walls or
trim because of the dust or chips that may be created by friction when they
are opened and closed.
Testing paint for lead should be done when specific areas of potentially

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hazardous levels of lead need to be known, such as when sanding painted


surfaces; replacing windows, doors, and trim; or major remodeling.
Finding the exact areas and concentrations of lead-based paint requires
extensive testing to be accurate. Concentrations can occur randomly
throughout the home or even on a single window, door, or wall. A typical
pre-1978 home should be tested in 70-100 different locations to provide
reliable results.
Testing should always be done by an EPA Certified Renovator or an EPA
Certified Dust Sampling Technician. The contractor should not be affiliated
with a painting, remodeling, or lead abatement company. The chances of a
conflict of interest are too high.
Lead Concentrations. When the problems with high lead levels became
widely known, Congress required HUD to eliminate childhood poisoning by
abating all known lead paint and lead pipes, whether the paint was in good
condition or widely used or not. The number of accidental poisonings has
not decreased but increased. This mandate forced HUD to remove paint,
creating lead-containing dust, its most dangerous form. When Congress
found that costs of abating paint containing any lead at all were
unacceptably high, they set regulatory levels high for the paint to be
considered lead. There are those who contend this was done without
scientific evidence basically to save millions of dollars in mitigation costs.
Unfortunately, that also established that paint with low levels of lead is safe.
There have been many cases of childhood lead poisoning when the
concentration of lead in the paint (if that indeed was the source) has been
below the regulatory limits. This created a dangerous situation. Hundreds
and thousands of homeowners, tenants, landlords, do-it-yourselfers, and
contractors, thinking that the old paint has been tested and is safe, are
exposing themselves, their children, and their workers to what may be
hazardous conditions.
A coat of paint is classified as containing lead when it contains 1 milligram
per square centimeter. Federal lead standards for risk assessments by
wipe sampling are:
♦ Floors (carpeted or uncarpeted) 100 micrograms per square foot
♦ Interior window sills, 500 micrograms per square foot

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♦ Window troughs, 800 micrograms per square foot


Window troughs (the space between a window and a storm window),
window sills, and floors under windows are the places most likely to harbor
lead. It is not unusual to find lead in window troughs at a level of 15,000
micrograms per square foot or more. If your proposed project involves
work in these areas, they should be tested for lead, and the appropriate
precautions taken.
Two-thirds of homes and half of the schools and day care centers in the
United States built prior to 1960 still have lead-based paint used in them,
according to the Environmental Protection Agency.
To further protect against the risk of lead poisoning due to remodeling, the
EPA revised its lead-safe rules in April 2008. And although the language of
the new rule is somewhat complicated, it can be boiled down to these
components: contractors and maintenance officials must be certified, their
employees must be trained and they must follow stringent lead-safe work
practice standards.

Timelines
Although the Renovation, Repair and Painting program rule was published
in 2008, it will not be fully implemented until April 2010. However, there are
some key dates to keep in mind.
December 22, 20099: If you’re working on a project that will disturb paint in
a space that’s the size of 6 square feet or more on the interior or 20 square
feet or more on the exterior in a home, school or child care facility built prior
to 1978, you must provide lead hazard information in the form of the EPA’s
new booklet, “Renovate Right: Important Lead Hazard Information for
Families, Child Care Providers and Schools.” This booklet can be
purchased in packets of 50 on the NARI store at WWW.NARI.ORG/STORE
April 2009: By this time, trainers will be able to apply for approval to certify
conduct the Certified Renovator and Certified Dust Sampling Technician
classes. This means you need to beware of companies that are touting the
ability to conduct certification training in lead-safe work practices. They

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cannot yet. It is expected that EPA will complete accreditation of training


providers by mid June or early July.
October 2009: Renovation businesses can apply for certification.
April 2010: All businesses must be certified, Certified Renovators trained,
workers trained, and the new work practices are required.

What is certification?

The EPA rule requires that at least one Certified Renovator be on the job
site to oversee the project during the following times:
• When warning signs are being posted alerted residents to the
work area.
• When the containment is being established
• While the work area is being cleaned.
• The certified staff person must regularly direct the work being
performed by other individuals.

The certified staff member will have to attend a one-day Lead Safe Work
Practices course. If someone on staff has already been trained in a
HUD/EPA-approved course with in the past 5 years, that person, more than
likely, will only have to sit through a four-hour bridge course. However,
double-check with your state and the EPA, as this hasn’t been fully
determined yet.
In addition to having a certified staff person, firms also will need to be
certified by the EPA, and firms will need to keep the following records for
three years:
• training certificates
• name of certified staff person
• lead safe work practice documentation

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• cleaning verification
• waste containment

You can download a copy of the full checklist at


www.epa.gov/lead/pubs/samplechecklist.pdf.

Lead safe practices

Inside the home, the EPA has outlined specific practices that must be
followed during the job, at the end of each day and after the job is
completed.
Inside the home, you must set up safe work areas by containing the area
with heavy plastic sheeting so that no dust or debris might escape, and you
must move all furniture and other belongings out of the room. For anything
that stays in the room, such as fixed surfaces or appliances, you must
cover those items with heavy plastic sheeting—this includes floors. Forced
air heating and air conditioning systems must be turned off and all vents in
the room must be closed and sealed. Signs must be posted to alert
residents as to the work area.
All workers must wear appropriate protective equipment, including
eyewear, clothing, disposable shoe covers, gloves and respiratory
equipment.
At the end of the day, trash and debris must be discarded in heavy duty
plastic bags. Waste building components, such as windows and doors,
must be wrapped in heavy-duty plastic sheeting and taped shut. Workers
and any tools used in the area must be completely free of dust before they
can leave the area, and a HEPA vacuum must be used on the area before
you leave.
Warn workers to change clothes and wash up before they go home, as
they do not want to be bringing any lead-based paint remains into their
home.

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When the job is completed, workers must carefully remove all plastic
sheeting, mist with water and fold dirty side shut before taping it up for
disposal. A HEPA vacuum must be used on all surfaces, including walls,
and then use a general purpose cleaner to wash all surfaces with in the
work area. Inspect the area carefully for miniscule dust residue. If there
are any particles, the area must be cleaned again.
Also before completing a job, you must wipe down all surfaces with a
disposable cloth and compare it to the EPA cleaning verification card and
your cleaning cloth must match the cleaning card. Call the National Lead
Information Center at (800) 424-LEAD (5223) to order a cleaning
verification card.

How to minimize dust

Mist any area you sand, scrap, drill or cut. Score any paint before you
separate any components. Don’t separate components with a hammer;
instead pry or pull them apart. If you use a power tool of any kind to sand,
grind, plane, needle gun or blast, you must use a HEPA vacuum
attachment. Never leave an open flame or torch burning in the work area.

Resources:
EPA’s Small Entity Compliance Guide to Renovate Right handbook
www.epa.gov/lead/pubs/sbcomplianceguide.pdf

Office of Pollution, Prevention and Toxics


www.epa.gov/lead or (202) 260-3810

HUD’s Office of Healthy Homes and Lead Hazard Control


www.hud.gov/offices/lead or (202) 755-1785 ext. 104

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OSHA’s publication “Lead in Construction”


www.osha.gov/publications/osha3142.pdf

Fire Extinguishers
There are four classes of fires, and an appropriate extinguisher should be
available for combating any of the classes that may be encountered on the
specific job. The classifications are:
♦ Class A-wood, paper, rags, and similar flammable materials.
♦ Class B-flammable liquids or gases, such as gasoline, natural or LP
gas, paint thinners, etc.
♦ Class C-fires that occur in or near electrical equipment, such as
motors, switchboards, and electrical wiring.
♦ Class D-flammable metals, such as magnesium (rare in the building
industry).
A currently inspected fire extinguisher rated not less than 2A must be
available within 100 feet on each job involving 3000 square feet or less,
with an additional extinguisher for each additional 3000 square feet or
fraction thereof. A more practical recommendation would be an
extinguisher rated at least 5ABC for each such area. If 5 gallons or more of
combustible liquids or 5 pounds of combustible gas, not including fuel in the
tanks of equipment, are present, an extinguisher rated at not less than 10B
must be present within 50 feet of the site of use. Propane tanks or
kerosene supplies for temporary space heating are common sources of
flammable liquids or gases on the job.

Housekeeping
During the course of construction, alteration, or repairs, form and scrap
lumber with protruding nails and all other debris must be kept cleared from
work areas, passageways, and stairs in and around the building. Materials
stored within buildings under construction shall not be stored less than 6
feet from any inside floor opening or 10 feet from any exterior wall that

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does not extend above the stored material. Citations for sloppy
housekeeping are among the most common violations issued against
building contractors. Subcontractors may also be a source of
housekeeping violations. Contracts should include requirements that the
work area of each contractor be broom-clean at the end of the work shift.

Personal Safety Equipment


The contractor is responsible for providing, or being sure the workers have
provided, the required safety equipment and for enforcement of rules
requiring its use. The requirements for safety glasses, hard hats, and
steel-toed shoes are the most common in residential construction. Hearing
protection may be required for the operation of some power tools and for
jack-hammers and other air-powered tools. The presence of poorly muffled
engines may also cause a noise level high enough to require protection.
Safety glasses, face shields, or goggles should be required for the use of
most power tools and the use of any hardened steel tools or nails. Those
personnel working with pressure-treated wood should always wear eye
protection and gloves to prevent contact dermatitis. Hard hats should be
required for nearly all phases of construction, with the possible exception of
roof work where there is no danger of material falling on workers' heads. In
the case of roofers, they must wear hard hats while climbing to the roof.
Steel-toed shoes should be required on all construction sites. Likewise, the
shoes should have soles providing reasonable protection against
penetration by nails or other sharp objects. The common rubber-soled
canvas shoe should never be permitted on the site. Roofers should use
good work boots with soles that grip.
Personal clothing should be free from any loose material that may become
entangled in machinery. The wearing of rings, chains, and similar jewelry
should be discouraged.
The contractor himself should always provide the required example by
wearing a hard hat and eye protection when he visits the site in a
supervisory capacity.
Personal fall protection must be provided where a worker may be able to
fall 6’ or more to a lower level. Body belts can be used when the free-fall

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distance is less than 2’; otherwise a body harness must be used. The
deceleration distance must be no more than 3 ½’.
If conventional fall protection equipment is infeasible or would present a
greater hazard in residential construction, a fall protection plan may be
implemented. The plan should be prepared by a qualified person and
developed specifically for the site. The plan must be maintained up-to-date
and a copy be maintained at the job site. It must document the reasons
why conventional systems are infeasible and the other measures that will
be taken to reduce or eliminate the fall hazard. For example, it should
discuss the extent to which scaffolds, ladders, or vehicle-mounted work
platforms can be used to provide a safer working surface.
Ladders
Improper use of ladders is one of the most prevalent causes of construction
accidents and major sources of OSHA citations. Portable ladders in use
should be tied, blocked, or otherwise secured in position. The base of a
straight or extension ladder should be about ¼ of the height away from the
wall or support against which it is being rested. The side rails should
extend at least 36" above the landing. The sections of extension ladders
should overlap at least three feet for lengths up to 36 feet and four feet for
longer ladders. Portable ladder feet should be placed on a substantial
base, and the area around the top and bottom of the ladder should be kept
clear. Non-slip bases (safety feet) should be used on portable ladders.
Rails and rungs of wood ladders should never be painted because paint
may hide cracks or splits. If a weather-resistant finish is desired, it should
be a clear finish. Ladders with missing or broken rungs or broken or split
side rails must not be used. The exception to this is a ladder with the top
rungs removed above the landing level to permit stepping through the
ladder. Metal ladders must not be used within four feet of electrical wiring.
Fiberglass or wood ladders should be used. All unsafe ladders must be
destroyed or removed from the job site. If they are there, someone will use
them, even if they have a red tag. The same rules must apply to
subcontractors.
Stepladders must be used fully open with the spreader fully extended.
Never stand on the top, pail rest, or rear section of a stepladder. Never

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erect any type of ladder in front of a door without taking precautions to


prevent the door from being opened.
Job-made ladders must have the cleats inset into the side rails at least ¼”
or filler blocks used on the rails between the cleats. The cleats should be
secured to each rail with at least three 10d nails or equivalent fasteners.
The cleats shall be uniformly spaced at 12" top to top.
Particular care must be taken when working on a job where children may
be present. Their urge to climb is almost irresistible. Ladders should be
taken down any time they are not in use.
Scaffolding
Scaffolding is a significant area of concern for OSHA. Falls are the
greatest source of job-related injuries. Meeting the safety requirements for
ladders and scaffolding will greatly reduce the chances of a safety citation.
Since standards seem to change almost on a monthly basis, check with
your local OSHA office regarding the current requirements.
OSHA established standards for scaffolding in the construction industry,
effective November 29, 1996. The following material is based upon those
standards. They cover fabricated frame scaffolds (also known as tubular
welded frame scaffolds), mobile frame scaffolds, pump jack scaffolds,
ladder jack scaffolds, crawling boards, and roof brackets. Each employee
who performs work while on a scaffold must be trained by a person
qualified in the subject matter to recognize the hazards associated with the
type of scaffolding being used and to understand the procedures to control
or minimize those hazards. This should include electrical hazards;
erecting, maintaining and disassembling; the fall protection and falling
object protections being used; and proper handling of materials on the
scaffold.
A competent person must determine the feasibility and safety of providing
fall protection for workers erecting or dismantling scaffolding. Employers
are required to provide fall protection where the installation and use of such
protection is feasible and does not create a greater hazard. Note that a
safety belt is not permitted; a full body harness must be used.
Scaffolding must be built to safely carry the weight of men and materials
required for construction. The platform should be not less than 18" wide for

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light construction and 48" wide for bricklayers. Ladder jack scaffolds, roof
bracket scaffolds, top plate bracket scaffolds, and pump jack scaffolds must
be a minimum of 12" wide. A bricklayer’s scaffold should extend to within
five inches of the wall. A light scaffold must be designed to hold at least 25
pounds per square foot. A bricklayer’s scaffold should be designed for 75
pounds per square foot. Use adjusting screws, not blocks, to adjust to
uneven grading conditions. Metal scaffold legs must be supported on mud
sills at least 10x10x2”.
All wood scaffolds should be built with clear, straight-grained lumber. Both
ends of the planks should be cleated to prevent them from sliding off the
supports. All wood scaffolding must be cross-braced. Cross braces should
never be climbed; access to the scaffold platform must be by ladder or
stair. No material or tools should be thrown up to or down from a scaffold.
No makeshift devices, such as boxes or barrels, can be used to increase
the working level height of employees. Ladders must not be used on
scaffolds except large area scaffolds where special requirements have
been met.
Any scaffold from four to ten feet high must be equipped with guard rails on
the ends and open side. Scaffolds more than ten feet high must have both
guard rails and toe boards.
A catch platform should be erected below the working area of roofs more
than 6 feet above the ground at the eaves and having a slope greater than
4 in 12 without a parapet, unless each worker on the roof is protected by a
safety harness and lifeline. The catch platform should extend at least two
feet past the eaves and be provided with a guardrail, midrail, and toe
boards.

Fabricated Frame Scaffolds


A fabricated frame scaffold is required to support its own weight and four
times its maximum intended load without failure. One of the more critical
factors is the base that supports it. The scaffold must have a steel base
plate at least 5" square that must rest on a mudsill. The latter must be at
least 10” square and be of scaffold plank or similar material. Cinder blocks,
bricks, and other unstable materials are specifically prohibited. Any

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settlement of the mudsill indicates the need for a larger mudsill to distribute
the weight of the scaffold and its contents. A mudsill is not required on
concrete, but is a good idea.

The base plates must be secured to the mudsills (if used) by at least two
nails through diagonally opposite holes in the base plate. The scaffold
frames may have screw jacks in the bottom to permit leveling. The cross-
braces must have a working positive locking mechanism to prevent the
cross bracing from coming off the frames.
Manufactured work platforms are suggested on a scaffold having only a
single tower. If larger scaffolds are needed, the work platform may logically
be made of planks. The planks spanning between the end frames must be
scaffold-grade and marked accordingly. They must not be painted. They
should be checked for splits at the ends. Planks spanning 6-8' must not
have splits longer than 12", and those spanning 10-12' must not have splits
longer than 18". OSHA no longer specifies minimum plank dimensions but
requires that the deflection not exceed 1/60th of the span. A 5' plank can

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deflect 1", and a 7' plank can deflect 1.4". The planks must extend a
minimum of 6" and a maximum of 12" past the end frame. If the plank
extends more or less than this, it must be secured from movement by
cleats on the bottom or tied to the frames with wire or something similar.
The entire work area must be planked (no more than 1" between planks
unless the scaffold does not permit), and guardrails and fall arrest systems
must be provided if the work area is more than 10' above the surrounding
grade. If the scaffold is more than 14 ½” from the working face, fall
protection must be supplied. Many scaffolds are not designed to hold
guardrails except on the top deck, so it may not be possible to install
guardrails during erection of lower stages.
If the scaffold is 3' or less in width, it must be braced at least every 20 feet.
If greater than 3' wide, the bracing must be at least every 26 feet. The
scaffold must be tied, braced to a solid structure (not the block wall which is
being erected), or guyed to prevent tipping if the scaffold height is more
than 4 times its width. If it exceeds the 4:1 ratio of height to width and is
more than 30’ long, it must be braced or tied at least every 30’.
Access ladders to the scaffolding must have steps at least 8" wide, spaced
not more than 16 ¾” from one another. The steps built into the end frames
of the scaffolding may be used if they meet these requirements. Ladders
can be hooked onto the scaffolding or stair towers used.
The typical fall protection on fabricated frame scaffolds is guardrails. The
top rails must be between 38” and 45” above the work platform. The top
rail must be able to withstand 200 lbs. of force in any direction. This can be
met with 2x4 rails supported by 2x4 posts no more than 8' apart. The mid-
rail must be able to withstand 150 lbs. of force in any direction. This can be
done with a 1x6 attached to 2x4 posts no more than 8' apart. If there is any
danger of objects falling from the scaffold striking employees or others
below, barricades, canopies, or debris nets can be used, but toeboards are
the usual solution. The toeboard must be able to withstand a force of 50
lbs. A 1x4 piece of lumber secured around the platform will meet this
requirement. No work areas should be located below the scaffold, and
access to the area below the scaffold should be restricted.

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Mobile Scaffolds
Mobile scaffolds made with fabricated frames must meet the same
standards as described above. The system must be fully braced, level,
square, and plumb. The platform must be fully decked. The scaffold must
rest on a firm, level surface and be equipped with casters or wheels
capable of supporting the loads off and on the scaffold. The wheels must
be able to be locked or chocked. If the scaffolds must be moved with
employees on them, they must meet the stability requirements of ANSI and
the Scaffold Industry Institute. The surface on which the scaffold will travel
must be free of pits, holes, and debris and be within 3 degrees of level.
Front-end loaders and similar pieces of equipment must not be used to
support scaffold platforms unless they have been specifically designed by
the manufacturer for that use. Fork-lifts must not be used unless the entire
platform is attached to the fork and the fork-lift is not moved horizontally
while the platform is occupied.

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Pump Jack Scaffolds


Pump jack scaffolds are often used in roofing and siding applications. The
work platform can be raised or lowered from the platform without adding
sections to the scaffold. As noted above, the scaffold must be designed by
a qualified person and be able to support 4 times the maximum intended
load. No more than two workers can occupy the work platform between the
poles, and the maximum load should not exceed 500 lbs., including
materials and tools.
The scaffold must be secured at the top and bottom of the poles using rigid
triangular bracing or equivalent. Additional bracing can be added for
stability. Each pump jack must be equipped with two positive locking
devices that will prevent slippage and failure.
Metal poles manufactured for the purpose are recommended. If wood
poles are used, they must be free from large knots or defects. The lumber
should be straight-grained and be no more than 30’ in height. If two 2x4s
are fastened together to form the pole, mending plates must be used to join
the wood. Only uniformly staggered 10d common nails spaced not more
than 12” from the opposite outside edges must be used. If wood poles are
constructed of two continuous lengths, they must be joined with the seam
parallel to the bracket.
Workbenches are often
attached to pump jack
scaffolds. The workbench can
be used as the toprail if it is
between 36” and 45” above the
platform and can withstand 200
lbs. force in any direction. The
workbench must never be used
as a work platform.
Ladder Jacks
Ladders used with ladder jack
scaffolds must meet the
requirements of “Subpart X,
Stairways and Ladders.” The

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ladders must be capable of being secured. Job-built ladders are not


allowed.
The ladder jack must be designed by a qualified person to support a
maximum intended load of 25 lbs. per square foot. The maximum spacing
between ladders is 8’. No more than two persons may be on the platform
at the same time. The maximum height of the work platform is 20’, and
platforms are not allowed to be bridged from one to another. When the
platform height exceeds 10’, personal fall arrest systems must be supplied.
The brackets should be designed to bear on both the side rails and rungs.
If they bear only on the rungs, the bearing area must be at least 10” long.
Crawling Boards
Crawling boards are used in steep roofing applications. They are intended
to provide a solid foothold for the workers. The crawling board must extend
from the peak to the eaves during construction, repair, and maintenance.
The board must be secured at the ridge with ridge hooks. The board must
be at least 10” wide and 1” thick. The cleats must be evenly spaced no
more than 24” apart. The cleats must be a minimum of 1” high and 1½”
wide and extend the full width of the board.
Fall protection can be provided in any of three ways: a personal fall-arrest
system, a guardrail system with a 200 lbs. toprail capacity, or a ¾” grab line
on each side of the board.
Roof Brackets
Roof brackets are one of the more common means of support used on
steep roofs. The scaffold standard requires that the roof bracket scaffolds
be at least 12 inches wide. Because roof brackets typically accept nominal
board dimensions of 6-10” and the 12” requirement conflicts with the
interim rule for fall protection in the residential roofing industry, this
requirement has not been enforced.
This material summarizes the OSHA scaffold standard: 29 CFR 1926.450-
454, Subpart 1. It is not a substitute for a review and understanding of the
regulation. These regulations may change with time after publication of the
Study Guide.

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Other Areas

Trenching
Any trench or excavation deeper than 5 feet should be supported by
substantial and adequate sheeting, sheet piling, bracing, shoring, etc. or
the sides sloped to the angle of repose of the soil involved. Trenches in
partly saturated, filled, or unstable soils should always be suitably braced.
Excavated or other material should not be stored closer than 2 feet from
the edge of the trench. The safe storage distance is in proportion of the
depth of the trench; the deeper the trench, the farther away the material
should be stored. Men working in deep trenches should wear hard hats.
Access to excavations more than 4 feet deep should be by ladders,
stairways, or ramps located no more than 25 feet from where the
employees are working. Jumping into the trench should not be permitted.
Extra care should be used when excavating in the area of communications
cables, gas mains, oil tanks, etc. Workmen should erect barricades and
warning lights around any excavation at the end of each work shift for the
safety of people moving about in that area after dark, even trespassers.

Power Tools
All personnel should be carefully instructed in the safe use of the power
tools they are required to operate. Electrocution or electrical shock is the
second leading cause of job-site injuries.
All electrical tools should be either double-insulated or grounded through a
three-wire plug. There must be a traceable ground to all outlets on the job
site. Three-prong to two-prong grounding adapters should not be
permitted. All outlets on the construction site should be protected with
ground-fault circuit interrupters that have been approved by Factory Mutual
or another certified testing laboratory. The common GFCI of the type
ordinarily installed within the house is not approved by OSHA for job-site
use.
The condition of electrical cords and plugs must be monitored carefully.
Any frayed, cut, spliced, or damaged cord or tool with a damaged cord

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should be removed from the job site immediately until it is repaired. Cutting
the ground prong off the plug on an electrical tool renders it unsafe, and it
must not be allowed on the job. OSHA citations for electrical violations are
common and expensive. These restrictions must also be applied to all
subcontractors and the tools they use.
All belts, gears, shafts, pulleys, sprockets, spindles, drums, flywheels,
chains, and other rotating or moving parts must be equipped with guards.
While there are some operations, such as a blind cut with a table saw, that
require the removal of guards, they must be in place and used whenever
possible.
Perhaps the most dangerous power tool is the powder-actuated stud
(fastener) gun. It is as lethal as a deer rifle and must be handled with the
same care. Because a hardened steel "bullet" is being fired into concrete
or steel, any variation in the density of the material can cause the fastener
to deflect. If a particularly hard piece of aggregate is encountered, the
fastener may split off the edge of a concrete surface, or the fastener may
bend and chip off a piece of concrete with explosive force. There have
been instances of a powder overload being used to attach a stud to a
concrete block wall, with the fastener passing completely through the block
and killing a workman on the other side. Powder-actuated equipment
should be entrusted only to the most careful and safety-minded member of
any crew. Special training should be provided to the operator. Some
states require a formal training program and a state certification of
competency.
Pressurized Cylinders
Cylinders containing any gases, such as oxygen, acetylene, or LP-gas
should always be stored upright on firm foundations and strapped or
chained in place or otherwise secured. This is often ignored when using
propane cylinders to supply temporary heaters. This is considered a major
safety violation. The protective cap should be on the valve of any cylinder
not in use. If a cylinder containing gas under pressure should fall over and
knock the valve off, the effect is equal to that of a rocket engine running
amok. Such cylinders have been known to blast their way through
concrete block buildings and can cause extreme damage as well as
present a severe danger to anyone on the job.

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Asbestos
The inhalation of asbestos fibers has been determined to increase the
incidence of several types of cancer and other lung ailments. Asbestos has
been quite commonly used in building construction in the past and may well
be encountered within the remodeling industry. It was used as a
fireproofing material, usually over structural steel. It was used in insulation
for pipes and boilers and in insulating sheets covering ducts or sealing tape
for ductwork in warm air heating systems. Cement-asbestos board was
commonly used as a lining for furnace rooms or closets. Cement-asbestos
shingles were often used on roofs and sidewalls. Asbestos was often used
as filler in drywall taping compounds during the 1950s and 60s. Vinyl-
asbestos floor tiles were also quite popular.
If any asbestos is present, special precautions must be taken to avoid
health risks to your workers and to avoid future claims from the building
owners or occupants that your work has caused asbestos contamination of
the building, requiring extremely expensive decontamination. Asbestos
fibers are so small that if friable (crumbly) asbestos is disturbed, it may take
as long as two days for the fibers to settle out. Some of the most
dangerous particle sizes are so small that they can be accurately counted
only with an electron microscope. An ordinary vacuum cleaner will not
capture the asbestos fibers. It will just grind them finer and discharge them
through the dust bag into the room. A special HEPA vacuum cleaner is
necessary to remove the particles.
If asbestos insulation is encountered on pipes and boilers, the best course
of action is to have it removed by a professional asbestos abatement
contractor. If the amount of asbestos is minimal and in good condition,
such as asbestos-containing tape used to seal warm air ducts, it may be
able to be encapsulated by covering it with duct tape or fully enclosing the
area containing it. There are also approved encapsulating coatings that
can be applied by brush, roller, or airless spray that will form a hard coating
over the asbestos to prevent fiber escape.
If asbestos fireproofing is encountered, removal by a certified contractor is
virtually the only solution. Vinyl-asbestos flooring should NEVER be
sanded; that can result in contamination of the entire building.

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Cement-asbestos board and cement-asbestos shingles seldom present


problems while they are in place, but if they are cut or broken, asbestos
fibers will be released. The surface of cement-asbestos board can be
painted to further bind the fibers. Because of the breakage that occurs
when cement-asbestos roof and siding shingles are removed, workers
should be fully protected. In addition, it may be necessary to bag and
dispose of the removed shingles as though they were asbestos insulation.
Your state Environmental Protection Agency will be able to provide the
local regulations pertaining to disposal. Usually, special heavy plastic
asbestos burial bags are required, and they must be taken to an approved
landfill.

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Discussion Questions
1. What are the hazardous substances that might be found in the
normal course of remodeling?
2. Where might asbestos be found in remodeling?
3. Where might lead be found?
4. Which pieces of power equipment used on your jobs require special
training for the operators?
5. What equipment on your jobs might require hearing protection for
your workers?
6. Do all of your portable power tools have grounding-type plugs with
the grounding prong intact, or are they double-insulated? Do your
plug boxes have ground-fault circuit interrupters? Are the grounds
traceable?

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Sample Questions
1. The minimum width of a light construction scaffold platform should be
_____.
a. 12 inches
b. 18 inches
c. 20 inches
d. 24 inches
2. What is the minimum length portable ladder that can be used to
provide safe access to a flat roof whose edge is 20 feet above the
ground?
a. 20 feet
b. 24 feet
c. 28 feet
d. 30 feet
3. Shoring should be used to protect workers in any trench that is more
than ____ feet deep.
a. 3
b. 4
c. 5
d. 6
4. A fire in wood scrap or sawdust would be classified as a Class ____
fire.
a. A
b. B
c. C
d. D

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