New OSHA Requirements Include Snow and Ice Removal
Hopefully by now you have read or have heard about the OSHA updated Walking and Working Surfaces standard. Did you notice the newly added comments on snow and ice removal? 1910.22(a)(3) states that walking-working surfaces are to be maintained free of hazards such as sharp or protruding objects, loose boards, corrosion, leaks, spills, snow, and ice. As an employer, you are responsible for keeping walking and working surfaces clear of snow and ice. This includes the parking lot, sidewalks, outside mezzanines, or anywhere in the building your employees may track in snow on their shoes. Furthermore, 1926.451(f)(8) prohibits employees working on scaffolds with snow or ice or other slippery material. If you utilize scaffolds in your facility and require employees to gain access, incorporate into your removal plan how a hazard-free walking working surface will be ensured.
Winter is here, so no time to waste.
Develop a Written Snow and Ice Removal Program
Now may be a good time to develop a Snow and Ice Removal Plan if you don’t already have one. “But how?” you ask. First things first: designate someone to be in charge of snow and ice removal and then select one or two additional employees to serve as backup. Establish communication between the designated person and the backups in the event a backup needs to fill in on short notice. “What are their responsibilities?” is usually the next question. They monitor the weather forecast, walking surface conditions, and determine when and how the snow/ice will be removed. Once you identify those responsible for monitoring a snow/ice event, and prior to the event, identify and prioritize potential areas that will need snow and ice removal. You will now need to decide if the task of snow/ice removal will be contracted out or if it will be accomplished in-house by assigned personnel.
If you choose to hire a contractor, determine upfront your organization’s priority on their response list. Be sure a written contract and certificates of worker compensation and liability insurance are obtained from the contractor. Also, determine their ability to react quickly in the event of a storm, the adequacy of their equipment, their ability to meet your needs, their experience, and reputation. If you have a large area from which to remove snow/ice, it would be a good idea to have a second contractor on standby.
Several factors come in to play should you decide to keep the task of snow/ice removal in-house. The number of employees assigned to this task depends mostly on the size of your facility and the number of walking surfaces impacted. Determine how these employees will be notified and mobilized during both operational and non-operational hours. Keeping it in house may require additional equipment such as shovels, salt/sand/ice melt, scrapers, snow blowers/throwers, plows, or whatever is needed to remove the snow and/or ice. Keep in mind the use of blowers/throwers/plows may require additional employee training. A Snow/Ice Removal Job Hazard Analysis (JHA) will need to be developed or absent that, a Non-Routine Task Form will need to be generated. When storing your snow removal equipment and materials, remember they must be accessible when a winter storm moves into your area. It is a good idea to pre-stage equipment prior to an impending event.
During the storm, inspections of problematic areas should be made on a regular basis. After the snow or ice has been removed, applying salt, sand, or ice melt will help keep the areas clear and provide traction on ice. Do not wait until the last minute to try to remove the snow and ice. While removal should be done before your employees arrive, there may be times you will have to provide a path for them until it can be cleared. If the storm continues to accumulate throughout the day, the removal must also continue throughout the day.
To help prevent the slippery floors inside, weather mats can be placed at entry ways. Set up “wet floor” signs and mop/squeegee the water up to keep the floor hazard-free. The wearing of slip-resistant footwear should be encouraged during inclement weather. Employees should also utilize handrails or stair rails whenever possible to maintain their balance.
A key component to your Snow and Ice Removal Program is documentation, documentation, documentation. A log of when/how the snow/ice was removed should be maintained. Note the date, time, who performed the removal, and how it was removed (i.e., ice melt, shovel, snow blower, etc.). Because not every storm is the same, periodically review the log and process to determine if your plan needs improvement.
As always, encourage employees to report hazardous conditions as soon as possible so they may remedied.
Here is an article on snow shoveling safety: