There’s a variety of dangers associated with working at water and wastewater treatment plants, and one of the most deadly hazards is falls from elevated surfaces like clarifiers, walkways, buildings and equipment.

Many municipalities aren’t regulated by the federal Occupational Safety and Health Administration (OSHA), leaving safety decisions to each individual workplace. This article aims to help readers understand the issue and offers some recommendation for safe work practices.

Falls to lower levels were attributed to 14 percent of all fatalities for workers in fiscal year 2014 per the Bureau of Labor Statistics. When you add fatalities from falls, slips and trips, that figure climbs to 17 percent. OSHA recorded falls as the No. 1 cause of death in the construction industry, accounting for 359 out of 899 (or 39.9 percent) in calendar year 2014.

Though OSHA doesn’t regulate local governments, the issue of fall protection is a universal problem. Some states give OSHA jurisdiction over local governments, and in those cases OSHA provides consultation and training services.

In local governments, the total recordable cases and days away from work, job transfer or restriction cases are consistently higher than the private sector or state government. Utility management should institute the appropriate protection for workers to avoid these deaths and injuries.

Fall hazards for utilities

On a water and wastewater facility, there are a variety of storage tanks, elevated surfaces, vehicles and roofs that workers routinely use as a working or walking surface. Recently, in Sheepshead Bay, New York, a 31-year-old wastewater worker fell into a process tank and drowned. In 2014, a 48-year-old wastewater operator fell into a process tank through a walkway grate and drowned. In both incidents, the workers were conducting routine tasks for a treatment plant.

Some of the identified fall hazards in treatment plants include walking/working surfaces, elevated surfaces, ladders, roofs and skylights.

Walking and working surfaces: Workers who walk on grates at a treatment facility, especially in wastewater, trust that the tracks and grating have been checked for any structural damage or decay. Sulfides, chemicals and environmental stressors can weaken the walking structure to create a fall hazard.

Trip hazards also are a problem in treatment facilities due to standing water or hoses that are commonly in walking paths. Some algae can build on wet surfaces to create a more dangerous slip hazard. Stairways with damage or missing components (handrails, tread, chipped concrete) can also be a source for slips, trips, and falls.

Elevated surfaces: Routinely, workers must walk on digesters, clarifiers and other tanks to do tasks such as cleaning and taking process samples. Many operators will walk the circumference of the clarifiers with brooms or water hoses to break up the algae on the inside wall of the tank. In most cases, there are no guardrails or walkways around the tank walls. Treatment plants often have hoses on the ground to transfer water or left lying around after cleaning jobs.

At a treatment plant, consider anything above 4 feet to be an elevated surface. That covers vehicles, tanks and platforms. In the field or during maintenance activities, be aware of open pits, excavations and equipment. As an example, operators cleaning a belt press after a dewatering job have to climb on the equipment to hose from the top down, and it’s slippery, often with residual polymer on the surface.

Ladders: Accidents often happen due to damaged ladders or risky behaviors on ladders. While most workers say they’re aware of ladder hazards, it’s commonplace for them to misuse extension ladders by standing on the top two rungs, or to lean a closed step ladder against a wall without putting down the support structure and locking the spreader bars.

Another commonly seen hazard is workers using bent or otherwise damaged ladders instead of disposing of them.

Scaffolds and lifts: Scaffolds are used in the utility field by workers doing maintenance and building activities. OSHA has recorded scaffold-related accidents to be 4,500 per year causing an average of 50 deaths. Scaffolds are used for larger projects such as changing the rake arms in a clarifier. Lifts can be used in tasks a minor as changing a windsock or lights.

The improper set up of a scaffold or the lack of fall protection can be deadly. Fall protection is necessary at 10 feet when on a scaffold. Scaffolds and lifts must be used as recommended by the manufacturer, and it’s imperative that employees receive training on their proper use.

Roof and skylights: Workers at a treatment facility often find themselves on roofs to check leaks, HVAC equipment or to replace windsocks. A fall can happen by slipping or tripping over an edge of the walls. In some cases, a skylight may be unguarded and the worker can fall through the skylight if there is a trip hazard. Many plants use in-house maintenance staff to be the first line of defense with mechanical repairs. As a last resort, contract companies are hired to perform tasks that cannot be done in-house.

Fall protection options

OSHA has identified three direct options for fall protection and several indirect or administrative ways to protect workers from falls. The hierarchy of any hazard control plan is:

1. Engineering Controls: a physical device or barrier;
2. Administrative Controls: work rule, policies and procedures; and
3. Personal Protective Equipment (PPE): something the worker wears to protect them from the hazard

The three options for fall protection are guardrails, personal fall arrest/restraint systems or safety nets. If it is infeasible to use any of these options, OSHA requires that a fall protection plan be written for the protection of workers in the construction field.

Guardrails: A guardrail should be at least 42 inches high from the upper surface of the rail to the platform or elevated surface. The rails should be smooth without rough edges and have an intermediate rail between the top rail and upper surface area. The railing should be able to withstand 200 pounds of force in any direction. The toeboard should have a 1/4-inch clearance above the floor level and be at least 4 inches high.

Personal fall arrest/restraint system: A personal fall arrest system (PFAS) is designed as a way to protect workers from falling to hazards below. The system is made up of three key components: a full-body harness, lifeline and anchor point.

All three components must be used as the manufacturer recommends, and operators should be trained to properly use the gear. Workers also may use a fall restraint system that is a short lifeline allowing the worker to come close enough to the edge of a platform or elevated surface to fall. Anchor points must be able to provide 5,000 pounds of protection per each employee.

Safety Nets: Safety nets are a practical use for the water and wastewater plants, but they should be installed per manufacturer recommendations and tested. A drop test must be done with a 400-pound bag of sand 28 to 32 inches in diameter dropped into the net from the highest surface from which an employee can fall. This test should be done in various intervals to check integrity and it should be able to hold a minimum of 5,000 pounds before breaking.

Ladders safety: When working on a ladder, workers should check ladders before each use to identify any defects. Ladder training is an essential part of protecting the operator from falls. OSHA has some recommendations for ladder safety on their website. 

Fall protection for utility workers has many facets and moving components. However, if the workplace has good housekeeping practices, safety training, policies and procedures for safe work conditions, it becomes easier to keep workers safe.

In states with OSHA jurisdiction, there are regulations to help utilities stay on target with safe work practices. Those without a state plan or federal OSHA must prioritize safety to protect workers from slips, trips and falls.

About the author
Sheldon Primus is a Class A licensed wastewater operator with more than 18 years of industry experience. He is a Certified Occupational Safety Specialist, authorized OSHA outreach instructor, and holds master’s degrees in public administration and environmental policies. He has held positions as a laboratory operator, chief operator, plant superintendent, safety and compliance officer, and industrial pretreatment coordinator.

Primus is CEO of Utility Compliance Inc. based in Port St. Lucie, Florida, which helps utilities in industrial pretreatment and risk management program compliance, water and wastewater CEU training, as well as occupational safety program development and OSHA outreach training for general industry and construction. He is also an online adjunct instructor for the Environmental Science Department at Florida Gateway College. He can be reached at sheldon@utilitycompliance.net or 888/398-0120.