“The Critical Aspects of Tower Site Safety” Webinar: Unanswered Questions
1. Who is responsible for doing a wind load test on the tower, the contractor or owner?
I believe you are referring to a structural analysis. If that is the case, then the Owner is responsible. A structural analysis is performed to confirm that the current equipment loading on the tower still meets the design specifications for maximum wind and ice loading. I would try to determine who manufactured the tower and then contact them to confirm when the last analysis or tower study was performed. If needed, a new analysis and or inspection can be performed to verify the condition of the tower.
2. For tower painting, when there is not a problem with over-spray, what are the current best practices for applying paint? Also, is there a current type of paint that provides greater protection and color fastness?
In this situation, it is usually up to a contractor's preference. Spray application is the preferred method for all painting needs, except diagonal tension rods, which given their size, usually wastes paint. Hand mitting can be an effective application method, though somewhat harder to apply in an uniform manner. The most widely used paint products are those that are 100% acrylic latex with UV inhibitors. The most important element in tower painting is surface preparation. The surface must be cleaned of all dirt and foreign matter for any paint product to properly adhere. Good surface preparation with a poor paint will always perform better than poor surface preparation and good paint product. For extreme life use an epoxy based product in conjunction with a multi-step surface preparation.
3. Why, after so many years, is it no longer legal to ride a Molly Hogan - it must be a wedge socket now - and what incidents caused this new rule?
Molly Hogan or Flemished eyes have been the cause of many fatalities and significant property loss. Relatively few people know how to properly make and maintain a handmade eye termination in this manner. Given the widely available alternatives, there is no reason to accept something that has among the highest load de-rating end terminations compared to other end terminations.
4. How much power per dipole is considered safe for RF workers near FM antennas?
As you know, the amount of power per dipole is dependent upon many factors, including: distance from the RF source (dipole), power, parasitic elements, frequency, other RF sources and more. FM antennas are particularly "hot" given the frequency is relatively close to a man's height. As a starting point, I would suggest you reduce power to 500 watts per bay and take field readings 10 feet away from the antenna. If the readings are within the safe zone for un-protected workers, you could try to increase power gradually until the ambient RF energy starts to approach un-safe limits. This way you can create a RF safety policy for this tower for future use. You should perform this at each site, since other environmental factors come into play. You should also refer to FCC OET Bulletin 65 for Broadcasters requirements for worker safety.
5. What are the requirements for fencing around towers?
This is primarily a safety and liability issue and not a regulation that I am aware of. Of course, local zoning and building regulations might have site-specific requirements. I would consult with your insurance agent and find out if there are special requirements under your existing policy for site and building security. At a minimum, a perimeter fence should be maintained enclosing your facility and around the base of the tower. Safety first, safety always. Leaving a site unprotected is an invitation for vandalism.
6. If a tower site ceases to be used and is not removed, who ensures that these sites are maintained safely?
The tower and or property owner is responsible for making sure the sites are maintained safely.
7. What is the OSHA regulation number for providing tower rescue on site?
OSHA 29 CFR 1926.500 is the regulation number for providing tower rescue on site.
8. If local tower owners and contractors have not contacted the local rescue team to learn of their capabilities, can the rescue team's organization require proof that tower workers within their jurisdiction do have the proper training and written safety programs in place?
You might check the language within your jurisdiction to see if you can "require" proof of availability or capability. Lacking the jurisdiction, I would recommend you advise all tower owners in your jurisdiction that before the next round of tower work and services is performed, you want to advise the tower owners that to properly respond to an emergency situation, you request their commitment to only employing crews that can and will demonstrate the ability to perform rescue and retrieval. Perhaps, even inviting them to discuss the situation at your station. Some companies will attend and some will not. Failing that, you could contact your local or state representatives to alert them to the special conditions that must be addressed for tower rescue and retrieval and ask that the issue is addressed in local zoning and building ordinances.
9. In your opinion, do you think all towers should be equipped with up-to-date safety devices such as safety climbs? Etc?
In my opinion, yes, but there are some exceptions. AM towers, for example, cannot employ permanent ladder safety systems. In addition, broadcast television antennas and some FM support structures cannot have permanently installed safety climb systems.
10. For occasional tower climbs--is the old climbing belt and tie-off acceptable, or is the full-body harness, etc. required?
No, full body harness and 100% tie off is the law.
11. What are your thoughts on the use of fully automated self-descenders for emergency rescue duties?
When properly designed and tested there are installations where this may be an acceptable solution, as long as the employees are properly trained to use the equipment. But, you must have a fully functioning back-up safety system, like a lifeline.
12. What kind of decline in deaths and injuries have you seen since NATE was formed?
It is difficult to find accurate statistics for the tower industry, given the vast changes in the industry. Since NATE's founding more workers have entered the industry, and that number continues to grow as new technology demands more tower build-outs or upgrading. What we can confirm is, through NATE's efforts, thousands of workers have been trained and industry specific tools, equipment and training are now available. NATE efforts to reach out to those not part of NATE has met wide acclaim, even if not substantiated by numbers. I personally believe that without NATE, there would have been many more fatalities than there have been.
13. Do you need to have your shock absorbing lanyard hook to the tower to be considered tied-off?
If you are stationary and secured to the tower with a properly designed positioning device, then no. But to get to any work station you must have utilized both a positioning lanyard and back lanyard. To move from point to point, you cannot disconnect your positioning device without being secured with your back lanyard first. The shock absorbing lanyard must be secured to the back D ring and then connected to the tower some distance above you. In short, just leave your back lanyard attached when your positioning device is your primary fall protection.
14. My background is from a government controlled RF facility where safety is of utmost importance. We utilized Job Hazards Analysis (JHA) on site when performing task to evaluate and outline all aspects before doing a given job, its simple to use and is used in industry as I'm sure your aware of. I would love to see this implemented in the Broadcast Sector. It is a must! Are there any procedures, forms, etc for contractors and engineers?
I have the utmost respect for government run RF facilities. Among others, I worked on the NAVY Radio facility at Annapolis and witnessed first hand the extensive policies and procedures that had been written for virtually every task required on the NAVY towers. A Pre-job Hazard survey is part of NATE Members Safety and Health Program, It is an essential part of a safe company's requirements. Also NATE members use daily tool box meetings to review the work planned that day and address any safety concerns before work begins.
15. When you mention RF PPE, are you referring to RF Monitors or are you referring to Protective Suites as well? If so, does NATE recommend the us of RF Suits?
RF PPE represents a number of personal protective equipment that is available. RF monitors, Measuring meters, pre-written RF safety plans and RF protective clothing. RF suits have limitations and very exacting criteria for use. When properly designed and used in conjunction with proper training makes RF protective suits useful additions to a safety program. Again, site specific conditions must be fully evaluated before any work is done.
16. Our 1054' guyed tower has a climbing ladder but doesn't have a safety climbing cable system. Is this a violation of any regulation?
It is not a violation if you don't have employees that climb the tower. However, every crew that you hire must be made aware of this hazard and they must bring temporary lifelines or expect to double hook when climbing the entire height of the tower to gain access to the work level. The benefits outweigh the costs to fit this tower with a ladder safety climb cable. If you have more than two or three days work to do on this tower it will pay for itself. Plus a ladder safety device will remove one element of potential liability by providing safe access for the work crew to use. Going forward, be certain it is inspected each time before use.
17. If a tower does not have a safety climb device on it is it in violation of OSHA, or is it the climber's responsibility to ensure that all safety measures are followed while climbing?
It is not a violation if you don't have employees that climb the tower. Yes, it is the responsibility of employer of the workers who will climb this tower to provide 100% fall protection. However, every crew that you hire must be made aware of this hazard and they must bring temporary lifelines or expect to double hook when climbing the entire height of the tower to gain access to the work level. The benefits outweigh the costs to fit this tower with a ladder safety climb cable. If you have more than two or three days work to do on this tower it will pay for itself. Plus a ladder safety device will remove one element of potential liability by providing safe access for the work crew to use. Going forward, be certain it is inspected each time before use.
18. How can we drive rogue climbers (those that willfully free-climb) out of the industry?
That's a very good question. I wish all tower owners shared your frustration and obvious commitment to tower safety. Greater effort for safety is needed. We must collectively stop allowing sub-par performance regarding tower safety. It's not hard to argue that price is an important consideration in what we do, but it is not the only consideration. Too often the criteria for crew selection comes down to availability and price. Free-climbing is perceived by some as faster than double hooking or setting up and using the proper fall protection safety systems. To the untrained eye, it is hard to recognize a bad actor from the real thing. It's ironic, that by accepting the lowest bid, the contractors that are cutting the most corners are rewarded with the project. Inversely, the contractor unwilling to cut corners is put at a competitive disadvantage and is more likely to not be the lowest bidder. This puts added pressures on the best contractors to educate customers so qualified decisions are made. Yes, it will take a collective effort to turn these tables. But NATE is committed to doing just that.
19. What is your opinion of the topic of tower climbers and "the industry" being highlighted as a reality TV show?
NATE believes the Dateline piece inadvertently highlighted some of the most critical issues that must be addressed by the tower industry including:
• The need for adequate training of all members of the crew. When evaluating a subcontractor it is important to ensure that all members of the team are properly trained so that the team isn’t hampered if one person becomes unavailable.
• The impact that unrealistic timelines and budgets have on the safety. There is an inherent pressure in our industry to work to the clock rather than to the safety needs of the task at hand. It is our hope that this opens a dialogue with tower owner and operators to show the worth of an investment of safety and the importance of taking the time needed to complete the job properly the first time.
• The importance of hiring qualified contractors with the proper equipment and skills to accomplish the task at hand safely. Safety audits are critical to ensure that the work is done in the safest way possible. The need for adequate training of all members of the crew. When evaluating a subcontractor it is important to ensure that all members of the team are properly trained so that the team isn’t hampered if one person becomes unavailable.
20. "Isn't it unrealistic to expect self-compliance given the competitiveness of the contractor sector? Isn't a watchdog needed? Who could play such a role? OSHA?"
I do not believe so. In this case, OSHA is the law and the enforcer. The majority of erectors and tower companies that perform work on towers are utilizing safety in every aspect of their work. Responsible erectors figured out long ago that safety doesn't cost money, it saves money. Shouldn't we instead ask how to we as an industry stop hiring unqualified contractors simply to meet budget constraints? To maintain good insurance coverage, contractors must demonstrate a comprehensive safety and health program. On your next RFP, set the limits at something besides minimal coverage and ask for a work history and references.
21. You discuss training and experience as the number one fault for injuries. How can we explain that two third of the falls this year were from very seasoned people with multiple years in the industry?
The industry has made great strides in bringing safety to the forefront of awareness. But safety training and specialized equipment is only a beginning. Addressing personal behavior is the next level of emphasis for safety programs. In reality, the most seasoned workers are the ones who have never experienced an accident and still feel immortal. Behavior modification will be the toughest challenge.
22. An older TV tower from the late 50's has no bottom-to-top anti-fall cable system. Is one required now or is the tower grandfathered? (The tower has a ladder and elevator).
It is not a violation if you don't have employees that climb the tower. However, every crew that you hire must be made aware of this hazard and they must bring temporary lifelines or expect to double hook when climbing the entire height of the tower to gain access to the work level. The benefits outweigh the costs to fit this tower with a ladder safety climb cable. If you have more than two or three days work to do on this tower it will pay for itself. Plus a ladder safety device will remove one element of liability by providing one for the work crew to use. Going forward, be certain it is inspected each time before use.
23. In the new labor market, what is your advice on how to approach non-English speaking tower workers?
There is no OSHA requirement stating that it is mandatory to post required OSHA notices in any language other than English. That being said, OSHA does encourage organizations to accommodate bilingual or non-English speaking employees in the workplace. OSHA maintains a Spanish-language webpage at: www.osha.gov/as/opa/spanish/index.html
24. Why do the majority of cell service providers use separate towers?
Mostly competition and location, but sometimes interference is a factor.
25. What level of interaction is required with local emergency response rescue teams in case workers are not able to "self rescue?"
Rescue and retrieval are important elements of a tower erectors safety and health program. Tower owners and crews should check with local rescue teams to find out their capabilities and plan accordingly. No one wants to have an accident, it would be worse if planning didn't include the possibility of having to call local EMS and not have them available.
26. Can I assume that a tower erector is automatically qualified to DISASSEMBLE and take down an 800ft tower?
No. Tower dismantling is seldom done. Few are experienced in de-stacking a tower. Plus, OSHA requires a demolition plan prior to any parts being removed. This is where experience and reputation must be closely reviewed and verified.
27. Is having unobstructed tower climbing access an OSHA requirement?If so where can I find it?
You could start with 1926.268 (h) (6) which describers the spacing and clearance. Then you could look in Subpart D working and walking surfaces for more details of what type of clearances are required around the ladder or climbing device.
28. What are the requirements for using personnel hoists for existing towers? Can they only be used to lift employees on the line during new construction?
CPL 3.126 is written for new construction. But we know that the industry and OSHA also uses the CPL and its requirements for maintenance too.
29. What kind of signage has to be posted on the fencing that encloses a television tower/transmitter site? What about guy anchors enclosed by fencing?
Signage should be posted to warn unsuspecting people and the general population of hazards. RF, falling objects, high voltage are just a few examples. Plus, there are liability issues to remember, including signs such as : private property, no trespassing etc. The site should be fenced, locked and secured.
30. Do you see licensing of tower climbers coming in the near future?
No, I personally don't think that having a piece of paper makes you safe. Just like with a driver's license, obtaining a drivers license doesn't make you a safe driver. Adding bureaucracy does not necessarily add benefit.
31. Is there a site listing tower accidents and investigation results on root causes?
Not at this time. But this is a goal of NATE to provide a process for disseminating accident details to key on areas of concern to focus attention for training and education.
32. We have a 1050' guyed tower with both red lights for night use and strobes for day and twilight use. We have experienced several strobe failures over the past 3 years costing us over $50,000.00 in maintenance cost. The model of the strobe lights is EGG 125's. The question is, is this a normal expense?
The above cost is over the past 4 years. I suggest you contact one of the premier tower lighting manufacturer's to obtain a state of art system. NATE has several has members. After 10 years even the best systems will develop increased maintenance issues. Think of strobe lights in terms of home air conditioning or other appliances. If you've gone 10 years with minimal maintenance, consider yourself fortunate. Sounds like it's time for new system.
33. Why does OSHA not file the good inspections with as much diligence and information as they do with a bad inspection?
Mainly because if you are doing everything correctly, there is not need to waste government resources on reporting is. OSHA has budget requirements and they spend their capital on investigations and educations and training.
34. Are there any courses that deal with the rescue of tower employees?
Yes, many of the training companies offer rescue and retrieval training.
35. How do I know a tower crew meets all the safety guidelines?
Use the NATE Qualified Contractor Checklist and ask questions. A crew doing it the right way loves to talk about and show you their processes. A bad actor wants to avoid answering too many questions or providing details. The NATE Qualified Contractor Checklist is available online at www.natehome.com. Qualified Contractors Evaluation Checklist