PART 4: GENERAL CONDITIONS

Transcription

1 PART 4: GENERAL CONDITIONS STORING AND HANDLING MATERIALS Stacking materials 4.43 (1) Material and equipment must be placed, stacked or stored in a stable and secure manner. (2) Stacked material or containers must be stabilized as necessary by interlocking, strapping or other effective means of restraint to protect the safety of workers. Storage racks (1) In this section, storage rack means a combination of steel frames, beams and associated accessories used, once assembled into a structure, to support materials and products, including, for example, a pallet rack or cantilever rack, but excludes shelving and display fixtures used for retail purposes. (2) This section applies in respect of a storage rack that is (a) 2.4 m (8 ft) or taller in height, as measured from the floor to the top of the highest shelf level of the storage rack, or (b) under 2.4 m (8 ft) in height, if the materials and products are loaded on or unloaded off the storage rack by other than manual means. (3) The employer must ensure that a storage rack in the workplace is (a) capable of safely supporting the items stored on it, (b) designed and constructed in accordance with good engineering practice, and (c) used in accordance with the specifications and instructions of the manufacturer or a professional engineer. (4) The employer must ensure that a qualified person installs and uninstalls the storage rack, in whole or in part, in accordance with the instructions of the manufacturer or a professional engineer. (5) The employer must ensure that the instructions of the manufacturer or a professional engineer for safely loading, unloading and maintaining the storage rack are readily available in the workplace to workers. (6) The employer must ensure that the rated capacity of the storage rack is clearly posted near the storage rack and readily visible to workers. (7) The employer must ensure that any structural modification, including reconfiguration, of the storage rack is carried out in accordance with the specifications of the manufacturer or a professional engineer. March 2017 Page 1 of 12

2 (8) The employer must ensure that a qualified person (a) (b) (c) inspects the storage rack (i) for wear, corrosion, damage, missing or incompatible parts, and signs of fatigue, and (ii) at regular intervals that will prevent the development of unsafe working conditions, makes a record of the results of each inspection, and provides the record to the employer. (9) The employer must ensure that, with respect to the storage rack, (a) regular maintenance is done, and (b) wear, corrosion, damage, missing or incompatible parts, and signs of fatigue are repaired or replaced in accordance with the specifications and instructions of the manufacturer or a professional engineer. EXPLANATORY NOTES TO THE AMENDMENTS: Steel storage racks, such as the common industrial pallet racks, are ubiquitous equipment found in many workplaces. There are inherent hazards associated with the steel storage racks because they are often used to store large quantities of materials or items in workplaces like distribution warehouses or storage areas of retail stores. If the racks are not properly installed, maintained and repaired, catastrophic failures of racks can cause serious injuries and fatalities. In most workplaces, steel storage racks are loaded and unloaded with powered mobile equipment which increases the potential for rack damage. There have been serious injuries reported to WorkSafeBC resulting from storage rack failures. In other jurisdictions, there have been instances where unsafe storage racks have caused fatalities. Currently, the Occupational Health and Safety Regulation ( OHSR ) does not contain specific safety requirements for steel storage racks. Without clearly defined requirements in the OHSR for its proper installation, inspection and maintenance, employers and WorkSafeBC officers may not consistently apply the various requirements in the existing OHSR to ensure storage racks are installed and used in a safe manner. WorkSafeBC officers have predominantly issued orders under sections 4.2 (Safe building and structures), 4.3 (Safe machinery and equipment), 4.8 (Rated capacity), and 4.43 (stacking materials) of the OHSR, as well as the general duty clauses of the Workers Compensation Act, to require employers to rectify unsafe rack conditions. However, these sections are not specific to storage racks. The primary objective of these amendments is to outline the safety requirements for steel storage racks in workplaces to ensure stakeholders understand the hazards associated with these common workplace equipment. WorkSafeBC officers will have consistent standards for enforcing safe storage rack requirements. March 2017 Page 2 of 12

3 The CSA Standard A , User guide for steel storage racks; Standard for the design and construction of steel storage racks, and the ANSI MH Design, Testing and Utilization of Industrial Steel Storage Racks, were reviewed to incorporate some of the elements of the standards into the requirements. However, these standards cannot be directly referenced in the OHSR because the standard uses non-mandatory language, such as may and should, whereas enforceable regulations use words like must and shall. Also, the standards do not clearly state obligations using familiar terms of the OHSR like employer, but uses other undefined terms like vendor, operator and user. Subsection (1): The new requirements apply to steel storage racks of various sizes and shapes (except where subsection (2) applies). The most common types of storage racks that these amendments apply are pallet racks and cantilever racks. There are other types of steel storage racks the amendments will also apply to, such as the drive-in rack, drive-through rack, and the push-back rack. The new requirements do not apply to storage racks made out of wood, plastic or materials other than steel, but the safety requirements in the existing sections of the OHSR will continue to apply to ensure all materials are stored in a safe manner. Based on stakeholder feedback, the definition of storage rack was revised to use similar wording as the CSA Standard and to clarify the new requirements do not apply to display fixtures and shelving typically found in retail areas of businesses. Existing sections of the OHSR will continue to apply to these shelving and fixtures to ensure they remain in safe condition. The new requirements apply to steel storage racks on retail floor of some businesses, such as Costco warehouses, Rona, Home Depot, and other similar stores selling tiles and carpets, where customers are selecting items off pallets on or around the storage racks. Subsection (2): Based on stakeholder feedback during public hearings, the scope was further clarified for the new requirements to apply to steel storage racks 2.4 metres (8 feet) or taller in height. Also, the new requirements apply to storage racks under 2.4 metres (8 feet) in height if materials and products are loaded on or unloaded off the storage rack by other than manual means, such as forklifts and other mechanical material handling devices. The clarification is in keeping with the objectives of the amendments to ensure industrial racking used to store significant quantities of materials remain safe for workers. Many municipalities require storage rack permits if the storage rack is 2.4 metres (8 ft) or taller in height. The new regulations also apply to storage racks under 2.4 metres (8 ft) where items are loaded and unloaded by methods other than manually, such as mobile equipment, conveyors, automated systems, mechanical lifts, or other mechanical equipment, due to the increased risk to workers. Existing sections of the OHSR will continue to apply to storage racks less than 8 ft in height where items are manually loaded and unloaded to ensure these racks are safe. March 2017 Page 3 of 12

4 Subsection (3): Subsection (3) requires employers to ensure a storage rack in their workplace is appropriate for the intended purpose. The storage rack could be designed and constructed with good engineering practices, but the storage rack must also safely support the items. The storage rack must be used in accordance with the specifications and instructions provided by the manufacturer of the storage rack or a professional engineer. The subsections specifically reference both the storage rack s design specifications and instructions (generally found in rack user guides or manuals) because there are differences between them: Specifications of a storage rack design include detailed technical information regarding the specific storage rack s configuration and rated capacity, such as the maximum allowable product load per storage level, number of storage levels, vertical spacing between storage levels, component details, etc. Instructions usually found in user guides or manuals for a storage rack consist of a set of installation, operational and maintenance instructions outlining how to properly and safely assemble (install and uninstall), use (load and unload), and maintain (inspect and repair) a specific storage rack system. Various types of storage racks will have specifications and instructions intended for the particular storage system based on its unique characteristics and the manufacturer of the rack. The new regulations do not directly state storage racks must meet CSA or ANSI/RMI Standards because of the language issues explained earlier. However, the storage rack must be designed and constructed in accordance with good engineering practice. One way to adhere to this requirement is for the storage rack to be designed and constructed to a specific engineering design standard for steel storage racks, like the CSA or the ANSI/RMI standards. The new regulations do not state requirements from other sources such as municipal bylaws, building codes, seismic provisions because employers are already required to comply with them, if applicable. Also, WorkSafeBC officers do not have jurisdictional mandate to enforce requirements of other agencies, unless there is prior legal agreement to do so. In circumstances where the manufacturer of the storage rack is not known or cannot be contacted, a professional engineer could provide specification and instructions to the employer for the storage rack. Subsection (4): Subsection (4) states for the employer to ensure a qualified person installs and uninstalls storage racks in accordance with the instructions of the manufacturer of the storage rack or a professional engineer. Steel storage racks are engineered structures constructed by a network of bracings and framework designed to withstand specified loads. Proper installation and dismantling of storage racks are critical for the safe use of the storage racks. If installed March 2017 Page 4 of 12

5 incorrectly, storage racks could have catastrophic consequences. Similarly, if a storage rack is dissembled incorrectly, racks could collapse prematurely and endanger workers. The employer must ensure the person installing or uninstalling the storage rack is qualified as someone who is knowledgeable of installing and uninstalling the storage rack in the workplace, the hazards involved with the work and the means to control the hazards, by reason of education, training, experience or a combination thereof. During the last public consultation, stakeholders provided feedback they will like more detail in determining whether a person is qualified to install and uninstall storage racks. To address this point, WorkSafeBC has conducted a series of stakeholder workshops to outline the competencies of a qualified person for installing and uninstalling storage racks. A number of subject matter experts, including storage rack manufacturers, employers and workers, participated in the workshops. From the information obtained from the workshops, a draft Occupational Analysis for the qualified person installing/uninstalling storage racks was compiled (see attached). WorkSafeBC will be obtaining further feedback on the draft document from the external stakeholders who participated in the workshops. Once finalized, the document will be referenced as part of the OHS Guideline for the new regulations. Subsection (4) obligates the employer to ensure a qualified person follows the instructions of the manufacturer or engineer to install/uninstall storage racks. The employer could fulfill their responsibility by ensuring the qualified person has the instructions prior to the installation or uninstallation. Subsection (5): Subsection (5) requires the employer to obtain instructions for safely loading, unloading and maintaining the storage rack from either the manufacturer of the storage rack or a professional engineer and these instructions must be readily available in the workplace to workers. Maintenance instructions of storage racks will include any necessary regular maintenance and also any repair or replacement of components. Subsection (6): Subsection (6) ensures the rated capacity of the storage rack is clearly posted and is readily visible to workers. The rated capacity does not have to be posted on each of the rack unit itself, but it must be posted in the general vicinity of the storage racks and the workers must know where it is posted so it can be referenced as needed. Subsection (7): Steel storage racks are engineered to a specified configuration and rated capacity. The employer must ensure any structural modifications, including re-configuration, affecting the strength or stability of the storage rack are carried out in accordance with the specifications of the manufacturer or a professional engineer. Unauthorized modifications and customization, such as adding or removing levels or relocation, could compromise the structural integrity of the storage rack and endanger workers. March 2017 Page 5 of 12

6 Typically, the installation of storage rack accessories are permitted by manufacturers since they are not part of the design specifications, but its use should be confirmed with the manufacturer. It is recommended stakeholders discuss these issues with the manufacturer of the storage racks. Subsection (8): Steel storage racks, just like other industrial equipment, endure wear and tear with usage. Also, storage racks are often damaged by mobile equipment moving items to and from the storage racks. In subsection (8), regular inspections of the storage rack need to be conducted by a qualified person to ensure wear, corrosion, damage, missing or incompatible parts, and signs of fatigue are promptly identified to prevent the development of unsafe working conditions. The amendments do not stipulate a minimum frequency of inspections because, according to the CSA Standard, the frequency should be governed by the nature of the environment in which the storage rack is situated and incidence of damage found. For example, it may depend on the type of storage rack, high and low usage areas, use of mobile equipment, and the size (area) of storage rack systems, available resources, etc. The employer is responsible for determining the frequency to prevent the development of unsafe rack condition. During public consultation, stakeholders provided feedback they will like more detail in determining whether a person is qualified to perform inspections of storage racks. To address these points, WorkSafeBC has conducted a series of stakeholder workshops to outline the competencies of a qualified person for inspecting storage racks. A number of subject matter experts, including storage rack manufacturers, employers and workers, participated in the workshops. From the information obtained from the workshops, a draft Occupational Analysis for the qualified person inspecting storage racks was compiled (see attached). WorkSafeBC will be obtaining further feedback on the draft document from external stakeholders who participated in the workshops. Once finalized, the document will be referred as part of the OHS Guideline for the new regulations. Subsection (8) requires the employer to ensure a qualified person inspects the storage rack at intervals that will prevent the development of unsafe working conditions. The employer could fulfill their responsibility for this subsection by reviewing various aspects of their operations and work environment to determine the appropriate inspection interval. For example, the following risk factors should be considered in determining the inspection frequency: 1. Environment Nature of the environment in which the storage rack is located (i.e. indoors, outdoors, temperatures, vibration, chemical exposures, etc.); Size of the facility; 2. Workers Competency and training of the lift truck operators; Safety culture and procedures for reporting of damage; 3. Vulnerability of Storage Rack Prior incidents of damage; Level of vulnerability to damage and failure; March 2017 Page 6 of 12

7 4. Operations Nature of the operations including equipment used around the storage racks; Level of activity (i.e. seasonal fluctuations); Number of hours of work per week (e.g. shifts); and Methods used to store and retrieve items on the racks. The inspection interval may change over time depending on the results of subsequent inspections, activity level, and any noticeable pattern of re-occurring problems. A basic storage rack inspection form (draft inspection form attached) and accompanying material will be developed to provide further guidance to employers about inspection frequencies and what to inspect in the OHS Guideline. Subsection (9): In subsection (9), employers must ensure storage racks are regularly maintained and storage rack parts with wear, corrosion, damage, missing or incompatible parts, and signs or fatigue are repaired or replaced in accordance with the specifications and instructions of the manufacturer or a professional engineer. The amendments do not specify the type or extent of damage to the rack to be repaired or replaced since the design and the rated capacity of storage racks and their tolerances for damage could vary. The manufacturer of the storage rack or a professional engineer is qualified to provide specific instructions about repairs or replacement of certain parts of the storage rack based on their assessment. Typically, during an inspection by a WorkSafeBC officer, an employer may be asked whether the observed damage on the storage rack has been inspected by a qualified person and whether any specifications or instructions have been obtained from the manufacturer or a professional engineer to repair or replace the damaged part. Section 3.9 of the OHSR will apply to employers to remedy unsafe conditions found in an inspection without delay. March 2017 Page 7 of 12

8 Occupational Analysis Occupation Description: Qualified Person for Installation/Uninstallation of Storage Racks General Areas of Competence 1. Planning for installation or uninstallation of storage racks Knowledge of requirements to participate in location specific orientation (i.e. site employer); Demonstrated ability to review layout drawings to support install/uninstall processes; Knowledge of storage rack specific hazards; Demonstrated ability to review site specific procedures to support install/uninstall processes; Knowledge of how site specific scheduling that may impact install/uninstall; Knowledge of how to assess existing storage racks for compatibility; Demonstrated ability to review slab report to support install/uninstall processes; Knowledge of when special or additional temporary support is required to safely install or uninstall; Demonstrated ability to use the materials list to confirm adequate storage rack components for installation; Knowledge of when additional assistance is required for install/uninstall; and Knowledge of when special or additional temporary support is required to safely install or uninstall 2. Installation and Uninstallation Demonstrated ability to conduct a visual inspection of storage racks; Demonstrated ability to take measurements; Knowledge of how to identify start point from engineering drawings; Demonstrated ability to stand and install storage racks; Demonstrated ability to square the storage rack system; Demonstrated ability to inspect and assess anchors; Demonstrated ability to apply order of disassembly/knowledge of load path; Demonstrated ability to conduct a final inspection (post install); Demonstrated ability to conduct a final inspection (post uninstall); and Demonstrated ability to disassemble storage racks. 3. General Knowledge Knowledge of when to refer to a professional engineer and/or manufacturer; Knowledge of applicable legislative obligations (i.e. permits, electrical and fire codes); and Demonstrated ability to calculate lean and deflection. 4. Equipment Demonstrated ability to operate mobile equipment and work platforms as required; Demonstrated ability to select and use appropriate tools and equipment to install or uninstall storage racks; and Demonstrated ability to direct the use of mobile equipment and work platforms for the purposes of install/uninstall. March 2017 Page 8 of 12

9 Occupational Analysis Occupation Description: Qualified Person for the Inspection of Storage Racks General Areas of Competence 1. Planning the Inspection of storage racks Demonstrated ability to determine scope and purpose of inspections; Demonstrated ability to review past inspection reports to support inspection processes; Demonstrated ability to review engineering drawings and/or manufacturer s specifications to support inspection processes; Demonstrated ability to apply safe operating procedures (SOP) for general use of storage racks; and Demonstrated ability to identify hazards in the inspectional area. 2. Conducting Inspections Knowledge of when the load should be removed; Demonstrated ability to determine actual load against rated capacity; Demonstrated ability to perform systematic walk-around; Demonstrated ability to identify damage; Demonstrated ability to categorize and document observations; and Knowledge of appropriate load size based on storage rack type. 3. General Knowledge Knowledge of hazards associated with products/load; Knowledge of when to escalate to an expert, such as a professional engineer or manufacturer; and Demonstrated ability to calculate lean and deflection. 4. Equipment Demonstrated ability to select and use appropriate personal protective equipment (PPE); and Demonstrated ability to select and use appropriate tools and equipment to conduct the inspection. March 2017 Page 9 of 12

10 Storage Rack Inspection Form Rack Information Location of Rack Rack Manufacturer Inspection Date Inspected By Items YES NO Observations and Corrective Actions Drawings and Specifications Current storage rack configuration, including modifications, are permitted, as indicated in the drawings or specifications provided by the manufacturer or engineer Rated Capacity Rated capacity of the storage rack is posted nearby and readily visible to workers Estimated products/loads on the storage rack are within the rated capacity of the storage rack Load Placement Products/loads are placed, stacked or stored in a stable and secure manner Products/loads are placed in accordance with manufacturer or engineer s instructions Clearance Structural clearance between the top of the loads and the ceiling or sprinkler system is within the allowable distance as indicated on the drawings 1 Storage Rack Inspection Form 2016

11 Items YES NO Observations and Corrective Actions Storage Rack Stability (Base Plates and Shims) Storage rack is plumb with no signs of deflection or lean All base plates are secured in accordance with the drawings Leveling pads are well seated Leveling pads are equal in size to the base plates Leveling pads are well secured to the base plates Storage Rack Condition (a) Columns and frames No damage from impact (e.g., dents, cracks, bulges, etc.). No signs of corrosion damage (b) Horizontal and diagonal bracing Present and have no damage from impact (e.g., dents, cracks, bulges, etc.) No signs of corrosion damage (c) Beams No signs of permanent deflection when unloaded (if applicable) No damage due to impact (e.g., deformations, cracks in the welds, etc.) No signs of corrosion damage Beam positions conforms with the drawings and specifications of the manufacturer or an engineer Lock pins/bolts are secured at each end of the beams, if used Frames and beams are compatible in accordance with manufacturer s or engineer s specifications 2 Storage Rack Inspection Form 2016

12 Items YES NO Observations and Corrective Actions (d) Repairs and replacement Repairs and replacements were made according to the manufacturer s or engineer s recommendation. (e) Protective devices (if used) Column guards and row end protectors are in good condition. (f) Other associated components (e.g. accessories) Other associated components of the storage rack are in place and in good condition. Housekeeping Work areas around the storage racks, such as aisles and hallways, are clear of debris and other obstacles. Pallets (if used) In good condition Appropriate type Proper size for the storage rack Not overloaded Other comments or observations: 3 Storage Rack Inspection Form 2016