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Module 7: Safety
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Glossary
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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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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.
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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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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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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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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
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.
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
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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.
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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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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.
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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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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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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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