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Update on the RFI response: Let me start by saying thank you to the 929 people that got on Wireless Estimator to respond to the OSHA Tower climber RFI and the 29 people who uploaded their RFI response directly to OSHA as of May 28^th, 2015. Thank you. Apparently there are less than 1,000 people in the US that really want to direct OSHA. From the feedback I am getting the rest of you think it’s all up to the climber. That’s fine, it just does not align with what many of you told me earlier. I just needed to know where we stand, that’s all. Many of you complained prior to the RFI, so I guess that was the 958 people that responded with input. Many of you were afraid of your companies, maybe they would fire you, and so you did it anonymously, which is great, because you responded. Thank you all! I guess the rest of you are fine with the way things are, great! I can see where it is such an inconvenience to take 30 minutes out of your life to help OSHA improve the rules for safety specifically for tower climbing and tower safety, it’s a real burden. After all, many of you think we were better off before OSHA and the DOL existed, probably even feel that way about the FCC.

Here is my full response in a PDF. Go ahead and download it to look it over. This is what I sent to the FCC.

To update the RFI click here to go to Wireless Estimator or click here to go to the FCC site. You can submit anonymously if you want to. Deadline is June 15^th, 2015!

Hazards and Incidents

15. Falls: Falls are currently the leading cause of fatalities among communication tower workers. OSHA believes that many falls result from the improper use of fall protection equipment or the failure to use any fall protection equipment at all.
16. How are employers addressing fall hazards?
    • 100% Tie off.

1. Are employers providing appropriate fall protection equipment to employees? Is it maintained and replaced when necessary?

• Many are and most of them do maintain it. It varies from company to company and many make that decision based on budget.

1. What factors contribute to employees failing to use fall protection while climbing or working?

• Common sense and safety. If someone is not using it then they are not trained properly or the company did not provide it or they are stupid. Probably a combination of all 3.

1. Are there situations in which conventional fall protection (safety nets or personal fall arrest systems) is infeasible? What alternatives can employees use for fall protection in those situations?

• There can be situations like that and each one should be treated as a one-off. They should always be able to use some type of fall protection. If there is a situation like that at a tower site then the owner should put something in to make sure the worker is safe. It would be a hazard once but then safe for every worker after that.

1. What are the ways in which fall protection systems or anchorage points on communication towers can fail? How can these failures be prevented?

• Often times they are not installed. If there is a cable grab, they need to maintained and inspected. Preferable annually but every 3 years would be good. Anchor points, if installed, should also be inspected every 3 years. Climbing pegs should be inspected and replaced as needed.

1. Should OSHA require built-in fall protection measures on new towers? Existing towers? Would such a requirement enhance worker safety?

• Definitely on new towers, there is no reason not to. On existing tower I believe so, but it would be an expensive venture. Perhaps on all towers built over the last 5 or 10 years would be reasonable.

16. Structural issues: When new equipment is added to communication towers, the additional loading of the tower has the potential to overload or destabilize the structure. Older towers may need additional reinforcements to maintain their structural integrity as new equipment is added to them. Communication tower collapses have resulted in numerous fatalities in the past two years. Which contractual party bears responsibility for ensuring that any structural work on the tower—such as modification or demolition—is done safely from a structural perspective? What steps are employers currently taking to prevent collapses?

• Responsibility: That lies with the team, the tower owner, the structural engineer, the customer, and the crew doing the work. The customer needs to require that the structural engineer not only provides the loading requirements and the upgrades, but also a procedure to do the upgrade. The tower owner needs to approve the plan, and the tower crew needs to understand and sign off that they can do the work properly.
• Steps taken – Most companies are reviewing the upgrade plans and verifying their steps with their given experiences. The crews and structural engineers need to be on the same page.

17. Hoisting materials and personnel: Base-mounted drum hoists are often used to hoist materials and personnel to working heights on communication towers. Hazards arise if hoists that are not rated for lifting personnel are used for that purpose. OSHA is aware of incidents in which hoists have failed under such conditions. Also, overloading material hoists and improper rigging procedures can result in loads striking the tower structure or workers located on the tower. OSHA knows of several deaths in the past two years that have resulted from these types of incidents.
18. When are personnel hoists used?

• In my experience, rarely.

1. What types of hazards are associated with personnel and material hoists? What are the best practices for safely managing those hazards?

• You need to have the proper winch and a good operator.

1. How are capstan hoists used in tower work? In what types of operations can they be used safely?

• In my experience, to raise equipment, and I have never had a problem with one as long as the operator is qualified and paying attention. They can be used safely if inspected and the operator is qualified.

1. What are the most common types of rigging hazards that occur on communication tower work sites? What can employers do to eliminate or minimize those hazards?

• Often, people don’t know the load rating of the block or they choose a poor termination point for the block. Also, rope needs to be inspected. I have seen rope failures due to crappy rope. It needs to be inspected and replaced. There should always be spare rope available for any job. Winch failures happen, although I have never had that problem because we maintained our winches, but they do fail and usually at the worst of times. One more thing, all the workers need to pay attention. If one worker rigs the tower for a light load and then the ground crew tries to pull a heavy load, bad things happen.

1. Are there methods, other than the use of a hoist or a crane that can be used to lift material and personnel at a communication tower? Which methods and procedures are the safest?

• If you can’t pull it up by hand or carry it, I don’t see another way to get it up there. Maybe someday drones will be strong enough to carry payloads.

1. What are the roles of different levels of the contracting chain in managing rigging and hoisting activities?

• Not sure I understand the question, contracting chain confuses me. However, on site I can explain the on site work. Guys on the tower choose the anchor point, knowing what they expect to pull up. They also anchor it based on load, obstructions, mounting location on the tower, and access. Then the block is attached to the tower using straps, steel cable, or carabiners. Then, depending on the weight of the load the ground crew will operate the winch or pull it up. The ground team is responsible for attaching the load to the rope/cable properly not only so it can be held on the way up but also so it can be positioned properly for the attachment of the item to the tower. They need to plan out how to rig it so that the equipment can swing into the tower with the attachment points where they need to go, or at least very close. Then there is a tag line on the ground. A rope is attached to the load to make sure that the load is swinging out from the tower and does not hit anything on the way up. The tag line is there to ensure that the load flies in the direction that you need it to go. It is also there so control the load in the wind. Wind is a huge factor. You do not want to destroy anything that belongs to someone else nor do you want to destroy your load.

18. Radio Frequency Hazards: Much research has been done on the health effects of overexposure to radio frequencies. General health effects reviews have found that high levels of exposure to radio frequencies may result in burns. In addition, the link between exposure to radio frequencies and cancer, reproductive diseases, and neurological effects has not been thoroughly explored.
19. What methods are employers using to protect workers from overexposure to radio frequency?

• Several things, site and tower inspections looking for dangers like Sirius/XM and antennas and broadcast. This should be part of the hazard assessments and a requirement. Also, RF exposure meters, like the NARDA.

1. Is there a need for employers to institute comprehensive radio frequency monitoring programs on communication tower work sites? What would a good program look like?

• Yes, it would be simple, add it to the hazard assessment, require RF safety training, and assign each climber a RF exposure meter with the requirement that they have it on their body at all times. They would need to be trained to use the meter properly and they would need to keep the batteries charged. It should be a require part of all climbers PPE.

19. Weather: Communication tower workers work outside during all seasons, and in all climates. They can be exposed to heat, cold, wind, snow, and ice. Storm conditions can quickly arise when workers are at elevation, and it can be difficult to descend the tower quickly.
20. What are the specific weather-related hazards to which communication tower workers are exposed?

• Hot – Heat exhaustion, sun stroke, dehydration, severe sun burn.
• Cold – frostbite, hypothermia, numbness and stiffness causing climbing difficulties.
• Lightning, always a risk, most climbers are usually off the tower or safely attached to the tower during a storm, but still a risk.
• Ice – Falling ice is a risk, could fall on the ground people. Climbing an icy tower should never be done but some people break the ice off as they go up.

1. How does a crew monitor and respond to changing weather conditions, including storms?

• Weather report, smart phone apps, and simply look at the sky.

20. Fatigue: OSHA believes that fatigue can affect communication tower workers in several says. Climbing a communication tower is physically demanding, and OSHA is concerned that fatigue due to exertion can be hazardous for tower workers. Accelerated work timelines can also result in tower workers working very long hours. And OSHA understands that communication tower workers may travel long distances to reach remote work sites, which can result in workers being fatigued before they even begin work.
21. What hazards are faced by a worker who finds it physically challenging to perform expected tasks, such as climbing a tower or performing a self-rescue? What impact can this have on other crew members?

• Falling is the biggest risk for everyone. If a climber is getting tired to the point where they can’t get down, then they need to be rescued. Many times the climber can tie off, drink some water, and rest. The workmates should be aware of the condition of the climber but if they are not paying attention then they will be responsible for the rescue. IF the climber is too tired to climb, he probably shouldn’t attempt self rescue, but controlled descent is easier than climbing so it may be a viable alternative.

1. What are the common causes of worker fatigue at communication tower work sites?

• Long days, heavy lifting, extreme weather.

1. What are the effects of fatigue on tower worker safety, and what types of incidents occur as a result of worker fatigue?

• If a worker gets too tired they make mistakes, not only the obvious physical mistakes like falling or dropping things, but mental mistakes and miscalculations. Not only for that day but they will be hurting for the next day or 2 and should be grounded so they don’t continue to be at risk. This puts more work on the workmates to perform. If all 4 crew members are climbers, then they should shuffle the work on those long days even if they alternate climbing duties daily. They should log their high time to make sure this happens.

21. Other common hazards:
22. What other hazards are present in communication tower work, and what types of incidents are resulting from those hazards? What can be done to protect employees from those hazards?

• Bee stings, allergies, snake bites, spider bites, over exertion, crushed limbs, broken bones, Carpal tunnel, long-term RF exposure, auto accidents, stress due to being away from home causing depression, stress of working a high rick job, bird poop, chemicals, long-term sun exposure.

1. What are some health and safety considerations involved in working with communications equipment installed on non-dedicated tower structures, such as water towers, buildings, silos, electrical transmission towers, etc.?

• Each structure has a dedicated risk, there are too many to mention and each structure should be looked into individually. I will list a few here.
• Water Towers – many people don’t realize how the water tower slopes off so they should be tied off 100% of the time when working there. Also, climbing up some of them you are in a confined space which could have problems.
• Electrical tower – must be certified to work on these, the risk of shock is too great.
• Buildings – safety issues, poorly maintain rooftops, should have a wall or rail or the climber should be tied off, bird poop piles up in many of these, trip hazards, low overhead in some areas, hi RF areas.
• Silos – usually remote, not always structurally sound, environmental issues, animal and insect issues

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