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Here we are for the second panel which covers the OSHA RFI, let’s get to it.
OSHA has released the initial version of the “Communication Tower Best Practices” document coauthored by OSHA and the FCC. Click here to download the PDF. For those of you that don’t know OSHA has a website for the Communication Tower industry here.
This panel covered the RFI that OSHA put out last year to the tower climbing community, the people on the front lines, for Information on Tower Climber Safety, OSHA-2014-0018, and click here to learn more about it.
I will be at the NATE Unite conference February 23rd and 24th, will you be there? Let’s talk if you are! So who is going? The exhibit floor, map found here, where I will be the 24th to meet and greet as many people as I can! The schedule, found here. See you at NATE Unite! Remember that the TFF will auction off a professional drone package, details here.
Thank you FCC and DoL/OSHA for putting this together, for taking the time to show you care about making this a better industry.
- Michael Janson, Associate Chief, CIPD, WTB, FCC
- Erin Patterson, Regulatory Analyst, OSHA
- Michael and Erin opened the session by asking Nick to explain a picture, an overloaded tower with about 8 dishes all at one level making it impossible to climb around, that he had put up on the monitors.
- Nick explained how many towers are overloaded and not conducive for a tower climber to manage the climb. Then Nick showed how you may rely on a safety climb only to see it spliced farther up the tower. Then he showed a crooked tower, literally, and how it’s not used but still standing and left there by the owner.
- Erin asked how the panelist felt about the RFI response. She did day they were pleased with the response regardless.
- Craig said that the RFI was successful because the FCC and DOL allowed the climbers to respond freely. Craig pointed out how that Regulations.gov was not the best way to respond and Wireless Estimator was fortunate that they could serve as a portal for the climbers to use them and submit it into Regulations.gov openly.
- Nick thought that social media really helped to get the word out. Making the link to comment readily available to the climbers to know about the RFI and reminding them to do it. They also were able to submit anonymously was something that really helped. The ease of participation made it a success.
- Dr Hester thought that the responses were well thought out and pointed out how the schedules and pressures were brought to light in the RFI. She was happy that company owners were pointing out many of the same problems as the climbers were talking about. She thought that RF would be more of an issue since it is a health risk over the long-term. There are many studies that prove this and a hazard that needs more attention.
- Then Michael asked the board to comment on some RFI feedback they got, first one, “The biggest problem is the rush carriers put on the GCs. We have a couple of weeks where we might not have any work. Then all of a sudden. We get four sites in and the companies expect these sites to be completed within a matter of days. We have to push our guys to the limits sometimes working two weeks straight 10-12 hours a day.”
- Nick said that it is a great comment that sums up one of the main problems in the industry. You have timelines that in the contracts it states that you shouldn’t be fatigued and yet you need to get it done or they can’t go home or the don’t get paid. Even if they ask for another week they may not get future work.
- Richard then pointed out that because of all the delays up front, mainly permitting, causes the tower workers to do more work in less time. If the tower structural fails then there are even more delays to make it safe. The decision process often creates more problems. Sometimes a new tower is not an option due to the local zoning ordinances, so you spend more money to make the existing tower better.
- Michael had the next comment, “Most safety issues are directly a result of pressure from the wireless carriers to get the projects done in a very short time frame. Even though the field crews go through all the OSHA training like ComTrain, and other safety training, they feel they need to take short cuts to get the job done by the due dates specified by carriers. This means that they do not always adhere to the safety regulations purposely or are too exhausted and overlook steps to insure their safety and others safe working conditions on job sites.”
- Dr Hester told us that she hears this from the field quite often. They say it comes from the carriers from the top down. But many climbers feel forced to do this by the sub that hired them to do it. They are often told to get it done no matter what. They still free climb and take short cuts so that they can get done and get paid. She brought up that it might not be complacency but acceptance that you need to get it done. She mentions that to change the safety culture is a good idea but how do you do it quickly, if you can.
- Craig responded by not totally agreeing with Dr Hester that the pressures are causing fatalities but instead fatalities in 2014 were more about not knowing how to do the job or following the standards out there. These guys didn’t’ know where to get the information. He brought up the West Virginia incident where 2 climbers dies and a fireman died. He mentioned that maybe the solution should be better training, inspections, and enforce it.
- Michael brought up that we all have a responsibility to make this industry safer, how we all are a part of the solution.
- Michael then brought up the next slide, Erin read it, “The placement and positioning of equipment on the tower, however, probably has the greatest impact on climber’s ability to safely navigate the natural hazards of our work. Obstructions of tower integrated safety components is certainly one of the more common examples of this. Mounts themselves are often heavily crowded with equipment and cabling configuration that can require climbers to take greater risks simply to access the equipment they need to work on.” “T-Boom style mounts, for example, often greatly increase the difficulty of accessing the equipment by requiring the climber to execute the balancing act along one, often round, steel member to reach the equipment – then to hang six feet below the mount in order to access cabling and connections. Finding a means of creating greater ease of access to the equipment once on the tower would mitigate some of the risk inherent in working these structures, further allowing the workers to focus their attentions on less controllable hazardous elements.” Erin then asked for comments.
- Richard responded with the options to improve the safety of the employees like getting a man lift or another options.
- Nick brought up that some towers do have a sign pointing this out. He mentioned that it’s not enough.
- Richard said that it’s up to the contractor to figure it out. He said that if it’s a construction project that the contractor is fully responsible, not the tower owner.
- Michael then transitioned into the next note from the RFI. “The issue is the use of a copier to make everyone a certification. Every employee that I hired would submit a certification that was copied from someone else’s certification and their name added. I had 8 companies tell me that they had one person to the class and everyone is certified in their company with the use of a copier.”
- Craig believes that the NWSA will resolve the certification problems that we see today.
- Nick thought that NWSA was also a great thing. He verified that it is a common problem in the industry.
- Michael then brought up another comment which Erin read. “I was sent to test a [company’s] site with 2 climbers and when he got there he was working with 2 climbers. When we got to the site, one of the two climbers had two weeks of experience but had only climbed one time and the other climber had been hired the day before. Climber B, (the one hired the day before) decided he didn’t want to do this job any more and quit on site and climber A with 2 weeks experience belted up, and started climbing but had trouble with his safety climb about 60’ up the tower. Climber B exhausted himself trying to figure out how to get his safety climb sleeve past the bracket and I had to go up and rescue Climber A from 60’. In order to finish the job, I had to let the company rep use the site master to test while I climbed the tower to 160’, changed the TMA and completed the tower side of the sweep process. This was a regular occurrence.”
- Dr Hester said that she gets this call all time from the field that many climbers are so poorly trained or they are not trained at all. Many complain that they are not trained and thrown into situations that they are not trained for. She would like to see TIRAP correct problems like these.
- Richard said that he also sees things like that in the field where many times they send the untrained climber up because the older climbers feel they have done their time.
- Nick says that he sees it often. Many times these new guys could be the problem and as it gets worse it could cause more fatalities.
- Dr Hester said that they are often just passed to another company and the problems is not resolved.
- The next issue brought up was weather. 2 comments – “We work in conditions that other construction workers with “safer” jobs don’t. Everyone climbs in the rain even if its policy not to. Refuse to climb in harsh weather and you will never go anywhere in this business” “Weather is also a major contributor to safely working on towers. Contractors in the north deal with every weather condition out there during the year. There doesn’t seem to be any standard available out there as to the limits to temperatures, wind, or snow/ice accumulation on the towers. It is basically up to the field employees and their managers to decide when the employees should be climbing or not.”
- Nick said that weather is an issue, but it would be hard to have a standard because of the variations in temperature across the US. Florida weather and North Dakota weather are very different.
- Richard said that it should be up to the competent person who is on site to make the call.
- Dr Hester said that many people try to cancel the work but it still needs to be done and the manager requires them to do it.
- Craig said that weather can’t stop you from working, the environment will not be perfect. You can do it safely.
- Erin then read a question from the audience, “What do you believe will be able to help with those timelines?”
- Richard said that the process the permitting issue should be streamlined. The consultants add a lot of delays because they often question the safety of the tower. He pointed out that while the tower is inspected by the tower owner, they do not do safety inspections because he said that is the responsibility of the contractor, not the tower owner. The tower owner often needs to correct tower issues. He said that often the restrictions put on them by the consultants adds delays to deployment.
- An audience member asked about the oversight of training, does it need to be escalated to a higher level?
- Nick said that the level of training is critical and the lack of consistency is a problem in the industry. There will be a formal approach to the certifications and training will be great for the industry.
- Craig talked about TIRAP and NWSA working together to provide standards in training and certifications to move forward. He said that this industry is moving quickly with the standardization of training.
- Michael’s next question stated that there isn’t one contractor here today where they haven’t worked a 2 week straight 10-12 hour day. He said that this industry has few limits on work schedules. He brought up the trucking industry and how they limit the number of hours they drive.
- Dr Hester said that management has full control and they have them work the long hours anyway. She said that some of it is the climber mentality, it’s a need to change the safety culture.
- Michael responded asking what the safeguard could be put in or implemented to make this change. (I think that a logbook system needs to be implemented)
- Then Richard said that its employer is responsible and pointed out that Dave Anthony stays close to home to work. That travel is a problem. He said he used to be gone 3 weeks and home one.
- Craig then said that he understood the dilemma but he stated that a truck driver on the road could kill many other people but a tower climber will really injury only himself. He pointed out that everyone works long hours, its part of life. He said that every industry works hard and long hours, but not use how to manage that in a safe way.
- Richard said when his crew worked long hours they took other breaks to do other things.
- Dr Hester mentioned that there is more issues on the climbers that affect mental health that could cause bad decision-making. She feels the employers don’t take the time to do a mental check to make sure the climbers are healthy.
- Then Erin asked another audience question, she asked about who pays to make the tower safer if there is an obstruction, like if you mean you need a man lift or a crane or if there is already a T arm on the tower? If one company will climb on them then the contractor will not pay for a crane to do the work. The carriers need to make the crane a mandatory requirement to use a crane.
- Nick said that to go in there with a crane or a man basket then someone will have to pay for it and it will cost more money. There are other ways to do it but it may be cost prohibitive for the carrier to do hire the qualified crew to do it right.
- The Craig said that it would be wonderful if the carriers could get together to come up with joint standards of any project to put rules around it to get a fair bidding process. He also said that you can rig and do it safely but it needs to be done right.
- The Michael asked another question, 2013 and 2014 were busy, 2015 was not. Fatality injuries go directly with carrier expenditures meaning there are unqualified workers doing the work. Do you think better vetting and putting more qualifications in place would reduce injuries? I have never in 17 years seen a safety line item on a bid.” The second question goes like this, “The tower owner states that the contractor is responsible to know the tower is safe. How can a third-party do this when they may not be qualified to know the structure or they may not know that the safety climb is broken 200 feet up the tower. Should there be a federal mandate stating that the tower owner should inspect the tower every 5 years?”
- Richard responded by stating that the TIS states it as they have to inspect their towers and structures aver 5 or 7 years. Are responsible for the problems like the safety climb is not connected 200 foot up? They also hire contractors to do the work. If a contractor does not do the safety climb properly then they should be criminally negligent. Why would a contractor do that? They do all that they can to be TIA compliant. They allow tie off point and they advocate to use tie off anchorage of step bolts. But what if someone rigs to it and stretches it out and the next time someone uses it and it break causing an accident? How can tower owners know that?
- Nick thinks there needs to be a better way to vet the contractors doing the work. Maybe their lowest bid because they cut corners. Maybe there should be a third-party audit to make sure it’s done right.
- Craig mentioned that the person asking was well versed but he said that the question is answered in TIA-222 and 1019A and that contractors need to read these documents and spend the money to buy them. He says that the document costs around $700 but they need to buy that document and it is where they should start. He said he was talking to Scott Kisting from TIRAP and a lot of people will contact him and ask him how to rig it. The answers are in those standards documents and also in OSHA regulations. People need to take the time an effort to read this.
- Nick said the answered are there but the everyday tower dog is not going to take time to read hundreds of pages to look how to rig. The ones in the field need to know it.
- Craig says that reading is required. (He is implying that all climbers or crew owners should purchase and read the required documents like TIA-222G)
- The closing statements:
- Craig said he likes enforcement but it is necessary. The FCC and OSHA need to keep enforcing the rules.
- Richard followed up with agreement o Craig saying that action matters. He went on to thank the leadership of Crown Castle for being an advocate for safety in the industry.
- Nick said he doesn’t see enforcement as being feasible because of how spread out the work and the towers are. It will be too late until they get there. It is up to the company to train each individual properly.
- Dr Hester agrees that we need great training and also that if we could have a third-party track problems, now with big data we could track everything is we took the time to create the system to do it. Follow who is at every tower to work. Follow all the potential avenues available to improve this industry.
Remember that the FCC and OSHA are your friends! They are working hard to help you become better at your job and safe!
You need to download the Wireless Deployment Handbook eBook that covers professional carrier end to end deployment of LTE small cells, CRAN, and DAS to show you the proper way to plan for deployment then execute, planning and action without the mistakes.
Be smart, be safe, and pay attention.
I am asking the carriers to provide numbers for workers to call to report payment issues and contractor issues. I didn’t hear from any of them yet, If you know it let me know at firstname.lastname@example.org, but for now, call OSHA!
OSHA cares, don’t be afraid to call the number below and explain to them what is wrong at the site when you feel the work site is not safe! CALL OSHA to report unsafe work conditions!
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OSHA is asking for public comment on Safety and Management, click here..
Give to the Hubble Foundation because if you don’t help these families, who will? Who supports Hubble? The wireless workers and the tower climbers, that’s who! So it’s up to you! What if it were you? Would you want help? Who would help you if you were hurt? Who would help your family, your spouse, your children if something happened to you? Do you see the people who are hurt?