It seems we, as a profession, struggle to get a consensus on those three words/phrase. For me, it is crystal clear, but for many others I find they wish to have some “room to work” in how they understand these terms to be used. I am often told I read the OSHA (i.e. barebones MINIMUM requirements) too literal and that I should be more flexible and help management work to keep employees safe. The fact that it is insulting to hear those words, but to hear them from the “safety person” is just-downright sad.
OSHA standards are just sad, even for merely establishing a floor of minimum safety standards… most are over 40 years old and have little relevance in today’s workplace. Thus why our profession should have surpassed their use years/decades ago. We should be so far above the “bottom of the barrel” at this stage of industrial safety; yet we find ourselves, our profession, failing to be able to agree on three simple words/phrase. Let’s look at how OSHA has used these words in their standards and maybe, just maybe I can win one or two of you over, to the “literal” side of safety…
Completely
com·plete·ly
/kəmˈplētlē/
adverb
totally; utterly.
“the fire completely destroyed the building”
synonyms: totally, entirely, wholly, thoroughly, fully, utterly, absolutely, perfectly, unreservedly, unconditionally, quite, altogether, downright; in every way, in every respect, in all respects, one hundred percent, every inch, to the hilt, to the core, all the way;
“he had always been completely honest with her”
1910.219(c)(2)(i) All exposed parts of horizontal shafting seven (7) feet or less from floor or working platform, excepting runways used exclusively for oiling, or running adjustments, shall be protected by a stationary casing enclosing shafting COMPLETELY or by a trough enclosing sides and top or sides and bottom of shafting as location requires.
1910.219(e)(2)(iii) Where the upper and lower runs of horizontal belts are so located that passage of persons between them would be possible, the passage shall be either:
1910.219(e)(2)(iii)(a) COMPLETELY BARRED by a guardrail or other barrier in accordance with paragraphs (m) and (o) of this section; or
1910.219(f) Gears, sprockets, and chains –
1910.219(f)(1) Gears. Gears shall be guarded in accordance with one of the following methods:
1910.219(f)(1)(i) By a COMPLETE enclosure; or
…
1910.219(f)(1)(iii) By a band guard covering the face of gear and having flanges extended inward beyond the root of the teeth on the exposed side or sides. Where any portion of the train of gears guarded by a band guard is less than six (6) feet from the floor a disk guard or a COMPLETE ENCLOSURE to the height of six (6) feet shall be required.
Can we agree there is a clear pattern in OSHA’s use of the word COMPLETELY when it comes to guarding power transmission devices?
Fully
ful·ly
/ˈfo͝olē/
adverb
1. completely or entirely; to the furthest extent.
“I fully understand the fears of the workers”
synonyms: completely, entirely, wholly, totally, thoroughly, quite, utterly, perfectly, altogether, exhaustively, extensively, intimately, in all respects, in every respect, without reservation, without exception, lock, stock, and barrel, from first to last, to the hilt;
“the panel are fully aware of the law”
2. no less or fewer than (used to emphasize an amount).
“fully 65 percent of all funerals are by cremation”
synonyms: at least, without exaggeration, easily, quite; informal without a word of a lie
“fully two minutes must have passed”
1910.219(e)(1)(i) Where both runs of horizontal belts are seven (7) feet or less from the floor level, the guard shall extend to at least fifteen (15) inches above the belt or to a standard height, except that where both runs of a horizontal belt are 42 inches or less from the floor, the belt shall be FULLY ENCLOSED in accordance with paragraphs (m) and (o) of this section.
So if there was a belt/shaft and it was “FULLY ENCLOSED” or “COMPLETELY ENCLOSED” would there be any portion of the belt or shaft exposed? If the guard we used was solid sheet metal, should we be able to see the belt or shaft? Has OSHA provided a metric/measurement of a gap in a belt/shaft guard that they find is an acceptable gap? Not that I am aware of; if anyone can provide that acceptable gap metric (even if it is in an ANSI standard) please share with me and I will update this post.
“Absolutely certain”
This last one is the one that just blows me away, no pun intended, as this one causes us to get the strangest looks and it is one that I learned within my first week of working as a safety professional. It has been “on the books” since 1974 and still today we will kill about a dozen workers this year for failure to meet this “absolute” requirement…
1910.252(a)(3)(i) Used containers. No welding, cutting, or other hot work shall be performed on used drums, barrels, tanks or other containers until they have been cleaned so thoroughly as to make ABSOLUTELY CERTAIN that there are no flammable materials present or any substances such as greases, tars, acids, or other materials which when subjected to heat, might produce flammable or toxic vapors. Any pipe lines or connections to the drum or vessel shall be disconnected or blanked.
I have shared hundreds of bad accidents over the years in the incident alerts because this fundamental practice was not followed. And when we see it happening without own eyes you better bet we are going to inquire and if not done right we WILL EXERCISE our Stop Work Authority (even when the facility has no such program). When we intervene, we ask one simple question… are you absolutely certain that there are no flammable materials present in that container?
Now for someone to be “absolutely certain” about anything is a pretty high bar. I would suggest there are few things in live that are “absolute certain” and of those things we find are “absolutely certain” you most likely did not arrive at that point without exerting some efforts to convince yourself of that fact. So although OSHA makes no mention in how one becomes “absolutely certain that there are no flammable materials present”, how would you be convinced? For me it is simple… checking the atmosphere inside the container with a CALIBRATED Direct-Read instrument AND understanding the limitations of the LEL indicator for that meter. With that said, does anyone think that “absolutely certain that there are no flammable materials present” equates to an LEL less than 10%, 5%, 2%? How about ZERO/0%!!!!
When we as a profession begin to dice up the MINIMUM Safety standards established by a government agency we are messing with our safety foundation! These requirements are ABSOLUTES – no wiggle room – ABSOLUTES and they have been established as the MINIMUM safety standards that our employees deserve. Maybe some in our profession would do better if they read the OSHA minimums as LITERAL REQUIREMENTS and not guidelines.