Ironworkers on the Safe Side Safety Bulletins

On the Safe Side: Avoiding Hazards Working Over or Near Water

Working over or near water has contributed to fatalities and serious injuries to our members throughout the United States and Canada. This article highlights important standards and clarifications pertaining to work activities over or near water. The International Associations’ “2014 ZERO Fatality” campaign targets the “deadly dozen hazards” including hazards associated with working over or near water. The Occupational Safety and Health Administration (OSHA) have established specific safety standards and clarifications for any construction work activities “performed over or near water.” There has been some confusion regarding these requirements because they are not contained in the OSHA 29 CFR 1926.750 Subpart R – Steel Erection standard that are commonly referenced. 

There are always unique jobsite situations and safety issues that must be recognized and addressed prior to working over or near water. The following are OSHA standards and clarifications pertaining to lifesaving skiffs, buoyant work vests, and fall protection that our members must recognize to avoid drowning hazards when working over or near water. Note: there may be a variation or more stringent safety requirements in Canada or state-approved OSHA plans in the United States. Additionally, there may be project owner specifications or contractor safety policies that must be identified prior to the commencement of any work over or near water.

Requirement for buoyant life jackets
The OSHA 1926.106(a)&(b) states: “Employees working over or near water, where the danger of drowning exists, shall be provided with U.S. Coast Guard-approved life jacket or buoyant work vests and, prior to and after each use, the buoyant work vests or life preservers shall be inspected for defects which would alter their strength or buoyancy. Defective units shall not be used.”

Limited exception for use of buoyant life jacket 
OSHA has determined by letter clarification that, “In general, when continuous fall protection is used (without exception) to prevent employees from falling into the water, the employer has effectively removed the drowning hazard, and life jackets or buoyant work vest are not needed.”

OSHA clarification on fall protection and the use of nets
As stated above, OSHA has determined that “when continuous fall protection is used (without exception) to prevent employees from falling into the water, the employer has effectively removed the drowning hazard, and life jackets or buoyant work vest are not needed.”
However, OSHA has determined by letter of clarification that “the use of safety nets as fall protection during marine construction activities usually will not eliminate the drowning hazard. In many cases (such as in bridge construction), there is a risk that materials heavy enough to damage the nets may fall. In such cases the personal flotation device and the other applicable requirements of §1926.106 apply.”

Requirement for ring buoys
The OSHA 1926.106(c) states: “Ring buoys with at least 90 feet of line shall be provided and readily available for emergency rescue operations. Distance between ring buoys shall not exceed 200 feet.”

Requirements for a lifesaving skiff
The OSHA 1926.106(d) states: “At least one lifesaving skiff shall be immediately available at locations where employees are working over or adjacent to water.” OSHA has determined by letter clarification that “immediately available” must include the following provisions.

• The skiff must be in the water or capable of being quickly launched by one person.
• At least one person must be present and specifically designated to respond to water emergencies and operate the skiff at all times when there are employees above water.
• When the operator is on break another operator must be designated to provide requisite coverage when there are employees above water.
• The designated operator must either man the skiff at all times or remain in the immediate area such that the operator can quickly reach the skiff and get underway.
• The skiff operator maybe assigned other tasks provided the tasks do not interfere with the operator’s ability to quickly reach the skiff. 
• A communication system, such as a walkie-talkie, must be used to inform the skiff operator of an emergency and to inform the skiff operator where the skiff is needed.
• The skiff must be equipped with both a motor and oars.

With regard to the number of skiffs required and the appropriate maximum response time, the following factors must be evaluated:

• The number of work locations where there is a danger of falling into water;
• The distance to each of those locations;
• Water temperature and currents;
• Other hazards such as, but not limited to, rapids, dams, and water intakes;
• The fact that, in the event a personal flotation device is not worn or malfunctions, permanent brain damage can occur in a drowning victim within three to four minutes of oxygen deprivation.

The International Association will continue our “2014 ZERO FATALITY CAMPAIGN” to prevent workplace fatalities in the field and shop. This goal challenges all members to “See Something – Say Something,” to help recognize and avoid workplace hazards when working over or near water.