Code Compliance vs. Risk Reduction 

  
Meeting Code

In the safety and risk field, something you hear often is “It met code so it’s fine, right?” Implying that building codes are sufficient by themselves to determine whether a condition is reasonably safe. Codes are most certainly important and useful, but when evaluating risks you must be careful to look beyond codes to broader risk analysis principles. 
An Example

The example above is a railing at the new recreation center in our town. The issue at hand something known as “ladder effect” where horizontal elements of the guard rail present facilitated climbing for young children. This is something that was previously part of model building codes in the U.S. (The base documents that local building codes are based on.) These requirements were phased out of building codes several years ago. The rationale was given to provide more flexibility for architects and designers to create more varied buildings, and support for this was offered in the negligible reduction in emergency room visits related to this issue during a trial period where the regulation was removed. 

They removed the requirements, aren’t we fine?

There are several concerns with this.

 First, nothing in the code or supporting materials suggest that this design is safe for all applications, there is now just more responsibility on the architect or building managers parts to decide when to employ different types of handrails.  

Secondly using emergency room data was a very limited way to support this change,  as the number of railings already existing and the relative number different configurations installed didn’t change much during the relatively bread period examined. When the regulation was dropped many many facilities had compliant railings under the old standard and it was very hard to discern how different the environment really was when it came to handrail composition.

What to Do

There are other elements to this issue but I wanted to focus on the general concern of code compliance not equaling safety per se. The location depicted is the second level of a recreation center and the railing protected area adjacent to a toddler and small children play area. During the time I was there with my daughter I noticed many many children with various levels of supervision in and around that area. And the location and use of that area indicates that a handrail guard rail without climb ability would be a better choice.

We can’t remove every risk from the world we can’t remove every hazard that we and our children face but we do need to have a prudent approach to figuring out what risks are excessive and what risks are unnecessary. Code compliance is one factor to consider when determining relative safety, is should not be the only factor.

Slips and Falls: Are You Taking The Risks Seriously?

A jury verdict came in this week in a slip and fall case at a Popeyes restaurant. Looking at the published details of the case, it was interesting how much of the contesting of the case focused on the level of damages. This highlights a few things that restaurant operators need to keep in mind when planning their prevention efforts:

1. Any given slip and fall can result in a wide range of outcomes. The level of injuries isn’t always predictable by the nature of the fall itself. 

2. Minor falls can be just as instructive to hazard recognition and prevention efforts as major ones. We need good systems to use the information that comes our way.

3. It’s a combination of the way a facility is designed, the way it’s managed,and  how issues are identified and addressed that makes up the risk picture someone using a given walkway faces.

When was the last time you reviewed your procedures and practices?

Falls From Elevation or More than That?

Traditionally, falls from elevation are grouped differently in risk categorization than same-level falls. There are several good reasons for this, but there is something important to keep in mind…

 …that most falls from elevation are initiated by similar factors as same level falls.  Look at the debris on this scissor lift platform for example.  If you have exposures at height, are you considering fall initiation, not just fall protection and fall arrest? 

Protecting Buildings From Vehicle-Into-Building Crashes: How and Why

California 2015 AB 764

This week marks a milestone in the issue of vehicle-into-building crashes (otherwise know as storefront crashes). The California State Assembly just passed a bill sponsored by Assemblyman Bill Quirk, which provides for consideration for protection of buildings from accidental vehicle incursions at state facilities. This bill also includes two other very significant provisions. One is that the building codes in the state may now include provisions for protection from vehicle-into-building crashes, and the other is that insurance comanies insuring commerical facilities may offer discounts to their insured entities that have put storefront crash protection in place. There are severl states where legislation of this type is pending, but this puts California in the lead when it comes to addressing this risk. 

Why Address Vehicle-into-Building Crashes?

The question of why that operators of commercial, retail, and restaurant (to name a few, there are other categories of at-risk facility as well) should plan to include protection to new facilities and add protection to existing ones now goes beyond the likelihood/severity relationship that is a key to risk assessment (and likely to indicate a need for protection at many of these facilities) and into the realm of direct regulatory compliance, and also into the realm of insurance cost as well. At the very least, any operation with nose-in parking facing a building that is open to the public should evaluate and assess their risks and consider what risk controls are in place and what may be needed.

How Do You Protect Your Storefront?

Very simply, some means of relaibly protecting both the building entrance and interior from vehicles must be sought. There is some discussion about strengthening buildings themselves, versus placing an engineered barrier (such as a bollard) away from the building. 

Selecting Slip-Resistant Footwear for General Purpose Use

Slip and Fall Risks Get Personal

A former colleague of mine who is a commercial real estate appraiser related to me that he slipped and fell a couple of weeks ago as he was on a high-rise condominium tower walk-through. He related that the steel diamond plate decking on one of the exit stairways was damp, and his shoes were very worn. He went out the exit hallway door, took two steps onto the landing, and experienced a heel-slip leading to a fall.  He went down hard on his tailbone, and also hit his elbow on the ground as he fell. Thankfully, he was not seriously hurt. He called me today, recounting his incident and speculating that his poor footwear was the primary cause of his slip and fall. He asked me for advice on how to select shoes that would give him more confidence in the varied environments where he walked on the job.

Shoes that Help Keep You on Your Feet

I have done a lot of slip and fall prevention work with restaurant, hotel, manufacturing, and construction operations, all environments where there is generally  an understanding that footwear needs to perform for the job. My friend’s request, though opens up some broader considerations.  What about professionals who need to walk in varied environments and conditions, but need a business-casual look and a high degree of comfort as well. Here are some of the characteristics I told him to look for:

1. A good sole tread pattern. One of the most important things for good footwear traction on wet, contaminated, or loose surfaces is a good tread pattern. Look for mid-size tread blocks with many leading edges, with channels between the blocks wide enough to channel away liquids. Avoid smooth soles, lightly textured or patterned soles, or protruding ridges that run lengthwise along the sole.

2. A good sole compound. This is harder to discern when you are shopping, but an important factor that affects the ability of the shoe to provide good traction when wet or greasy. This is one area where some less reputable shoe brands have copied the tread pattern of industry-leading soles but have much harder sole material that exhibits poor slip resistance. A soft sole isn’t automatically going to have good slip resistance, but hard soles seldom do.

3. Good sole geometry. You want to make sure that there is a slight rise at the front of the shoe (known as “toe spring”) to prevent tripping over small changes in level, as well as good relationship between the angle of the sole and heel. Any shoe that angles the foot downward excessively may make it hard to maintain your balance in some situations.

Here are some examples from real-world shoe soles:

This sole has very good channels, both wide and narrow, that make for great performance on wet and greasy surfaces.

This sole has some large flat areas with a fairly shallow pattern, which are not great for slip resistance, but does have some good tread blocks on the perimeter of the sole. A good sole compound helps this shoe perform fairly well given its limitations.

This shoe has some good tread blocks and a good sole material, but lacks smaller channels for optimized performance on wet surfaces.  This particular shoe does have a very good sole material which makes for solid performance. 

This sole has a good lug design with good performance both on smooth surfaces and on loose dirt and gravel. It can be difficult to find a shoe sole well for both outdoor and indoor environments, but this one is very good in both environments.

This sole has very good cylindrical tread elements integral smaller channels, but has a relatively smooth surface on the critical heel-strike zone at the rear of the shoe. Balancing that out, though, is a good sole material compound, and the good grooves in the rear section. Also noteworthy is the consideration for wear patterns built into the sole, with extra material along the quick-wearing heel area, and a flexible section in the forefoot.

An example of a great all-around shoe for my colleague’s application. Good sole geometry, great tread pattern and material, and a stylistic fit for the application in question. If he was going to be walking on a lot of dirt and gravel, another choice would be better, but for his travels in and around various properties, these fit the bill nicely.

Every occupation and application has its own challenges and constraints, but hopefully these examples will provide some guidance about general factors.

Snow and Ice Removal: The Details Matter

Snow Season Isn’t Over

In the realm of slip and fall prevention, attending to snow and ice control is a given in regions where cold winter temperatures are the norm. At the moment, with spring officially here and warm temperatures in many places, some operators have put snow and ice out of their minds. Yet the season is not fully over; for example, much of the Metro Denver area experienced 3-5 inches of snow this morning and it’s not likely the last snow of the season. I encountered a spot in a parking area this morning that is instructive for those charged with maintaining the safety of parking areas and exterior walkways. Here are two photos of the spot in question. I’ll outline the issues below.

Metal Walkway Plate with Snow and Ice

Metal Walkway Plate with Snow and Ice

Walkway metal plate

Side View Showing Drainage Channel

Why Does This Condition Exist?

First, you’ll notice the strip of snow across the walkway, in a localized spot, surrounded by clear sidewalk. The strip of snow if there because the walkway has a drainage channel across that spot, covered by a steel diamond plate cover. Because the steel cover is exposed to air on the bottom, it freezes much sooner than the regular walkway. This phenomenon is the same as what occurs on highway bridges and overpasses. Takeaway: Have you identified spots of special concern in your walking areas and do you know the factors in play?

What About the Cone?

Next, notice that there is a cone in place. It turns out this was placed there a few hours before the photos above were taken. The maintenance person who placed it there put it in place because the steel cover underneath was slippery due a layer of ice on its surface, under the snow. When the cone was placed, the whole walkway was covered with snow. This cone is beneficial because it helps alert pedestrians to the hazard. It is also not ideal because there are several preventative measures that could have been put in place, perhaps removing the need for a cone. Takeaway: Eliminate or reduce hazards first, then deploy warnings.

Possible Corrective Actions

Here is a round-up of possible preventative measures that could have been employed here:

  • Use a different material for the cover that would not function as a heat sink and be as prone to freezing.
  • Put a textured coating or finish on the cover so it would have better traction when wet or covered in snow.
  • Remove the snow from this cover after any snow accumulation, not just after the trigger level of 2-3 inches that prompts full-scale parking lot snow removal.

There may be other solutions as well, but this should give you a good glimpse of how effective risk control requires specific attention to the real-world details of your situation. The sidewalk and cover in question met building code requirements, which is a good start, but in this case prudent risk control takes more than that.

Auto Repair Shop Carbon Monoxide Control: A False Sense of Security?

Car dealer service department

Large auto repair operations often have vehicles running inside.

That was the reading on the handheld carbon monoxide detector brought along on a follow-up safety consultation visit to the service department of a large automobile dealership. The conditions were typical for the the early part of their service day – several vehicles running at once inside their 20,000 square foot service area, with one of the six large overhead doors fully open to the outside and the others closed. A discussion with the service manager revealed that this was typical in the morning, when cars would be brought in to be checked out and run briefly for diagnosis.

Exposure With Consequences

The spot reading of 400ppm of CO does not tell the whole story related to exposure in the garage. Just a few minutes before, the shop was closed and the reading was effectively zero. And a few minutes later the reading began dropping from the peak. But the 400ppm number was definitely cause for concern. That level is enough to approach short-term exposure issues (see the CDC data on that risk) with exposed workers, and if it is sustained for long it could cause serious issues.

Why Was This Occurring

Even though the facility was equipped with good means of ventilation and a dedicated exhaust removal system, neither of these controls were helping much. The early spring moderate temperatures meant that the ventilation system wasn’t running in the morning, and not one of the running vehicles were hooked up to the exhaust removal system. When asked about this, one of the mechanics said that they will use the system if running a car for a while. When he and others were queried further as to just how long that meant, the answer was far from definite. “More than five minutes.”  “Any extended time.” “Ten minutes or more…” It was clear that this wasn’t well defined, and also was not based on any actual determination of what level was an issue. It was much more about convenience, an informal determination on each technician’s part about if it was worth the trouble of hooking a car or truck up.

Learning from Other Environments

Some of the work I’ve done recently that centers on parking lot and parking garage safety has highlighted the usefulness of carbon monoxide monitoring systems. Though I was focusing on pedestrian safety and vehicle-into-building crashes, many elements of parking safety were looked at to some degree. It became clear that the issue of carbon monoxide in parking structures had been given a lot of attention and had subsequently become the focus of regulatory activity. This set the stage for some great technological options for reduction, monitoring, and exhaust of carbon monoxide that could be applied. In the case of the auto dealership service department, it was monitoring that was a glaring omission from their arrangement.

Industrial Carbon Monoxide Detector

Industrial Carbon Monoxide Detector

Appropriate Detection

A survey of some other auto repair environments showed that some were employing consumer/household style carbon monoxide detectors. The rise of UL standard 2034 and its inclusion in many building codes has led to good availability of simple consumer style detectors. Many more homes are protected today than just a few years ago, but the problem with using a UL2034 detector in a commercial setting such as a garage is that the standard for these residential detectors places a great deal of importance on avoiding false alarms, which means that these detectors are not nearly as sensitive as  most commercial models. The right solution for a garage environment typically requires some analysis by an industrial hygienist, and would include an appropriate advanced detector along with both alerts and possibly automatic activation of  ventilation.

What About Procedures?

Note that the engineered solution is the right place to begin controlling this hazard. The service manager’s suggestion that they begin with a procedural response, including a shorter timeframe to attach the exhaust removal system, and more overhead doors open was not a sufficient solution. The way the shop operated, the longstanding practices employed, and the difficulty in determining action triggers in the existing environment all pointed toward not accepting an administrative-only solution. Naturally, every situation is different, and this case does not indicate that all similar operations should employ the same controls, but it does show that the right factors need to be considered, and any controls employed should have a good expectation of actually being effective!