Finishing Trades Institute Of New England Challenges by Eric Redding
Saying 2020 did not get off to a good start is a bit of an understatement; COVID-19 hit us hard, but, as usual, DC 35 and your training department hit back. First, we had to postpone all existing classes, both apprentice and health & safety. We needed to figure out how to exist with this new normal. We completely shut down everything for a few weeks while conducting business remotely and slowly returning to the office on a somewhat skeleton crew. I am pleased to announce our office has returned to normal hours while still respecting social distancing and other necessary protocols. Apprentice classes were hit hard when we shut them down: almost every apprentice class had at least one week left on their academic calendar. With the Building Trades Training Directors Association, we petitioned the Massachusetts State Apprenticeship office for some relief, but the office is under new leadership and refused to give us any credit. Starting in June our Craft Directors began to bring the students back in to complete their training, and by the end of August, that will be complete. Health & Safety classes started back up almost immediately with an online COVID-19 Preparedness class that was assigned to every IUPAT member. It was followed shortly after with virtual classroom training via the Zoom platform which included an extremely successful Labor History class developed by our FTINE team and a sexual harassment course. We are now very close to starting the new school year, and like most, we are searching all viable options open to us for the best way to accomplish this.
Your training department is continuing to embrace the challenges we have already faced as well as what that lies ahead. Another of those challenges started a while back with the American National Standards Institute (ANSI). ANSI is a private, not-for-profit organization dedicated to supporting the US voluntary standards and conformity assessment system and strengthening its impact, both domestically and internationally. Originally slated to take effect in December of 2019, the revised ANSI A92 standard for aerial lifts was delayed until March 2020. These changes included definitions, aerial lifts and scissor lifts will now be referred to as MEWP (Mobile Elevating Work Platforms). They will be divided into two classifications (Group A Group B) and then three categories (Type 1, Type 2 and Type 3).
Training Changes Group
A will be defined as MEWP “in which the vertical projection of the center of the platform area” always stays within the tipping lines (i.e. scissor lifts).
Group B is characterized as “MEWP isn’t in Group A”. These are vehicles were the platform can extend out past the tipping point (i.e. aerial lifts, boom lifts).
Some of the biggest changes will be in the training and certification process. Those that are not the operators of the MEWP are now described as “occupants” and will need to be trained on the hazards of working on an MEWP and what to do in case of an emergency.
Supervisors will also need training to ensure that the operator and occupants are acting safely while working on the MEWP. They will be required to understand the rules and regulations of this new standard as well as become familiar with the operator’s manual and the importance of ensuring that it is stored on the MEWP.
Operators will need to be able to demonstrate the ability to perform a worksite inspection and well as a pre-start inspection on the MEWP.
Risk Assessment/Rescue Plan
A qualified person must now perform a risk assessment prior to the use of an MEWP. This should include a description of the job, location and time frame for the job. Hazards and risks should be evaluated and a description of safe work practices and what safety precautions will be taken.
A rescue plan must also be in place prior to beginning work in the event of a fall. The plan must be written and reviewed by all workers on the job site. The plan may include self-rescue, assisted rescue (by other trained workers) or an emergency services rescue.
MEWP Equipment Design Changes
There are new design changes rolling out for new MEWP being made. Some models may have reduced speeds or reduced lift. A sensor will be added to sound an alarm when the safe load limit is exceeded and will prevent normal operations of the vehicle. Another new sensor will disable boom functions if the slope limit is exceeded, or, if outdoors and the wind speed is exceeded.
Chains will no longer be allowed as a means to block off the entrance; new MEWP will have a gated entrance. If the vehicle will be used outdoors or in rough terrain, it will need to have foam-filled or solid tires. Exceptions can be made for an indoor-only MEWP.
All the information in this article is accurate, and there was one word in my opening paragraph that has great importance: that word is voluntary. “ANSI is a private, not-for-profit organization dedicated to supporting the U.S. voluntary standards and conformity.” This now begs the question – does OSHA require me to comply with the new A92.20, A92.22 and A92.24?
The answer is NO–this would have to be done through rulemaking. Compliance is voluntary with this new consensus standard. However, as a general rule, OSHA may reference industry standards for establishing industry recognition of a hazard and existence of feasible abatement measures to support violations of the general duty clause where an OSHA standard is not applicable. For the purpose of utilizing A92, OSHA is limited to using the Incorporation by Reference (IBR) for aerial lifts contained in A92.2 (1969).
The problem we’re having here in the North East is someone is telling the general contractors they need to comply with the new rules and in turn the GC’s are telling the sub-contractors (our contractors) they must comply and train their employees to the new standard, and it doesn’t matter that you’d be compliant under existing OSHA standards because, remember, OSHA is the minimum standard. Your contractor can always increase the safety factor, and that’s what they’re doing now.
So once again I tell you that your training department is ready for the challenge. In January, Director of Health & Safety Mike Moreschi and Instructor Rich Cabral joined ten other trainers from the IUPAT at JLG University in McConnellsburg Pennsylvania for a 4-day course covering all the new material. Our next step is to bring these classes to you, our members, so you will have all the same work opportunities you always had without missing a beat. The rollout of the first class was impacted by COVID-19, luckily Mike and the H&S team completed the classroom portion of the training however the hands-on had to be put on hold till we figured out our protocols for working in the pandemic. That class has now been finished; the team now delivers the classroom through the Zoom platform while the hands-on is structured to keep everyone safe. That means we stagger the participants’ time slots for their time on the different machines and keep everyone socially distanced.
It’s no secret that the opioid epidemic has had crushing effects across America and so too has the suicide rate in construction. With the support of our Business Manager Jeff Sullivan, we have been able to embrace this disaster head-on. Working as a team, Business Representative Chris Brennan, Director of Health & Safety Mike Moreschi and Instructor Jim McCann have launched a campaign with an awareness course called Changing the Culture in Construction.
The course itself is designed to inform and empower the construction industry by separating fact from fiction and encouraging our workforce to choose proactivity when it comes to behavioral health issues and addictions. Our goal is to educate individuals, in turn promoting a healthy, safe, and substance-free working environment. Starting in September 2019, the team has attended every apprentice class twice to bring the message and to listen to the conversation that has been started. We hope our message of compassion reaches every DC 35 member and your family; remember that there is someone always listening, and we are here to help in any way we can.