Lift Station Safety and a Common Question

 “Are we required to have safety nets over our pump access hatch openings?”

This is a question I have heard several times in my short tenure with the League of Minnesota Cities. It may be phrased in several ways. 

“Really, I’m supposed to have nets over my inspections hatches?!”

Or

“Are nets required or can I use my temporary manhole guards?”

The answer to all these questions is “YES.”

According to MNOSHA standard 29 CFR1926.502(c) any opening into which a person could walk (or fall) must be guarded. The specific requirements of the guard system can be found clearly and understandably within the language of the standard. In general industry the fall height of 4 feet or more requires guarding, in construction that height (or depth) is 6 feet.

So, what constitutes “guarded”? The short answer is permanent railings, temporary railing systems, mesh net systems, or expanded steel type grates. Once again, a web search of the standard will provide details you need to be compliant.

“How about fall arrest systems? A lanyard or retractable device?” The answer is “maybe.” In this case the first thing to remember is that the pit you are guarding is a confined space, so the primary goal is to keep people out of the area, not dangling safely above it. So, if you are following the two-person method of confined space entry and you have the proper rescue equipment and an attendant, then a lanyard may meet OSHA’s standard. However, consider the risk associated. What if the lanyard is longer than the distance to the surface of the wastewater? How about air quality for the entrapped person while the attendant retrieves them? Suddenly lanyards are not an acceptable option. Preventing a person from toppling into the hole should be the goal.

So in the end, take a look at your access hatches. Are there guard rails or safety nets installed? If not, consider applying for an OSHA safety grant to update your facilities today before you or a coworker is in up to their necks!

Samples of acceptable systems:

Photos courtesy of  Hillsborough County Water Resources Department

Resources:

OSHA fall protection standard

MNOSHA Safety Grant online application

Hillsborough County Wet Well Dilemma
Article from the Florida Water Resource Journal 

Submitted by: Marc Dunker, Loss Control Consultant

Time to get your playgrounds ready for spring

As the snow melts and the puddles dry, your parks and playgrounds will become popular places once again. The League of Minnesota Insurance Trust (LMCIT) has a few tips to help you prepare for the change in seasonal use.

Safety reminders for staff   
As your employees begin clean-up duties, remind them to work safely. Consider the personal protection equipment (PPE) needs of the job. Certainly, gloves are a must to prevent hand injuries such as cuts or puncture wounds. High-visibility vests or clothing should also be worn. Talk to your folks about situational awareness on the job: oncoming vehicles, changes in walking conditions, etc. It’s also a good time to review your city’s policy on earbuds and headphones.

Make a list as you go
As employees are out and about cleaning and picking up trash, have them make a physical list of items that need attention. Using a Playground Inspection Checklist can assist in documenting your inspection and can be used by management to create a “to-do” list. High-hazard issues should be addressed and documented right away.

Focus on landing surfaces
Keep in mind that about 70% of all playground injuries are a result of ineffective or insufficient soft landing surface materials. The League of Minnesota Cities has several resources available to help you determine if your playground meets general safety and ADA standards.

ADA compliance depends on proper surface materials. Acceptable surfaces include poured-in-place rubber, tiles, engineered wood fiber, or hybrid surface systems. More information on these surfaces can be found in the U.S. Access Board’s ADA play surface guidelines (pdf). 

LMCIT endorses the use of ADA-compliant materials for playground surfaces. However, we also understand that some playgrounds are still waiting to update for various reasons. In cases where you are relying on other forms of loose fill materials, be sure that substrates are where they belong and have an adequate effective thickness (generally 12”, but this may vary depending on your equipment).

Playground and park safety should be a priority for your staff. Using the suggestions in this article and some basic best practices, you can provide safe and enjoyable recreation to your community. Your League of Minnesota Cities staff can help! Contact your loss control consultant, or call (800) 925-1122 to be connected with the loss control consultant in your area.

Additional resources:

Consumer Product Safety Commission Handbook for Public Playground Safety (pdf) 

Institute for Human Centered Design ADA Checklist for Existing Facilities (doc)  

Safe 2 Play Playground Safety Inspection Checklist (pdf)

League of Minnesota Cities Parks and Recreation Loss Control Guide

Submitted by: Marc Dunker, Loss Control Consultant

FMCSA phishing scam alert

Important message from the Federal Motor Carrier Safety Administration (FMCSA)

FMCSA has been notified of a phishing scam that you may receive from the FMCSA “Assistant of Administration” claiming you need to “complete your most recent up-to-date membership License certificate.” If you receive any suspicious email from info@fmcsa.dot.gov or any other entity that you are not expecting or looks suspicious, please delete the email from your inbox. Once the email has been deleted, go into your deleted mail and delete it from your deleted mailbox. Doing this will limit the exposure of the phishing email.

Note that the only legitimate way to log in to the Training Provider Registry is via login.gov. Never enter your email address and password into a third-party website claiming to give you access to the Training Provider Registry. 

How can I tell if a website is an official government website? 

The .gov means it’s official.
Federal government websites often end in .gov or .mil. Before sharing sensitive information, make sure you’re on a federal government site.

Check the URL for https://
The https:// ensures that you are connecting to the official website and that any information you provide is encrypted and transmitted securely.

If you believe your city has already experienced a data breach or other cyber/privacy liability, contact LMCIT claims staff immediately at (800) 925-1122.

Can your city afford to skip a spring roof inspection?

Ahh, that sweet smell of spring! Spring brings beautiful flowers, warm weather, and potential problems with the roofs on your city buildings. The Minnesota winters of snow, rain, wind, and ice can take a toll on roofs, and you’ll want to make sure they keep you dry during summer storms. The warmer weather makes it easier and safer to inspect your roof and gutters and determine what needs to be done to get them back in good condition. Read below to find out what you should include in your spring roof maintenance.

Clean gutters and inspect downspouts

The first thing in your spring roofing inspection checklist is to get to work on your gutters and downspouts. Harsh winter weather can fill your gutter system with leaves, tree limbs, moss, and garbage. A blocked drainage system leads to overflows and structural damage, so it’s vital to clean it out each spring. Additionally, loose sections of the gutter should be secured, and damaged sections should be replaced right away.

Damaged downspouts can cause water leaks around your building. Make sure that you check your downspouts for damage from tree branches or ice dams and prune the tree branches hanging over your roof.

Inspect roof exteriors

A thorough inspection of the roof during the spring is a must. Your spring roofing inspection checklist must cover the following aspects:

• Damaged/missing shingles, cracks, tears, leaks.
  Take a note of missing, damaged, or worn-out shingles and ensure that you replace them immediately. A missing or damaged shingle can cause a water leak and, if not fixed, can damage the interiors of your building. For flat roofs, inspect scuppers, drains, penetrations, HVAC unit doors, and edge metal. Repair cracks, tears, and leaks. Make repairs to damaged portions of the roof as soon as possible to prevent them from causing even greater damage to your building.
• Mold growth.
  While doing a roofing inspection, actively look for signs of mold. If caught early, this can keep mold from seeping into the foundation of your building and save you from major issues. If you notice mold has spread over a large area, call your roofing professional for a thorough inspection.
• Damaged skylights.
  Inspect the seals around your skylights closely and make sure there is no damage to the roofing surface. If the seals are falling apart the chances of water leaks increase over time.
• General wear and tear.
  Look out for general wear and tear on your roof like loose or exposed nails, missing or damaged flashings, missing caulk, rusty metal flashings, and sagging areas. If you notice any of these conditions, make sure you get necessary repairs and replacements done so that your roof continues to protect your buildings.

Inspect roof interiors

Once you have thoroughly examined the exteriors of your roof, it is time to check the interiors for any damage, especially in the attic area. Grab a flashlight, or any other light, and inspect all the spaces in your attic for signs of water leaks or ventilation issues. In addition, look for water stains, cracks, and settling of foundation on interior walls and ceilings.

Protect your city investment by performing routine roofing maintenance and inspections. When you catch potential problems early, you prevent some bigger roof repairs and costly interior damage. You can even push roof replacements further into the future. It also gives you the opportunity to budget for big repairs or replacements early on, buying you time to save up for them.

Submitted by: Julie Jelen, Loss Control Consultant

Snow loading and roof collapse preparation

We’re in the middle of winter and snowstorms in Minnesota, so let’s talk about preventing snow
loading and roof collapses.  Adverse weather conditions can affect the structural integrity of buildings and can cause a partial or complete collapse.  You can minimize the risk of snow loading and roof collapse by planning, preparing, and taking prompt action to remove accumulated snow. 

The following safeguards can help prevent roof collapse:

• Continuously monitor winter storms and remove snow off roofs as soon as possible after each snowfall.
• Keep all drains clear and unblock debris (leaves, dirt, etc.) year round. The downspouts should also be clear.
• Keep the roof well maintained and do repairs/replacements as soon as required. 
• Keep workers trained and the proper equipment available for snow removal. 
• Keep an updated winter emergency response plan in effect, especially for snow removal. 
• Have a fall prevention plan that is compliant with local agency requirements before engaging in roof preparation activities.
• Confirm generators are in good condition and their fuel tanks are full. 
• Ensure fire hydrants and fire protection system control valves are visibly marked to avoid damage from snow removal equipment. 

After a snowfall

During a winter storm, it can be dangerous to be on the roofs. It is best to be prepared to take action after a snowfall.

• Do not allow unauthorized workers/persons on to roofs. All workers should be properly trained on snow removal and equipment use.
• Remove the snow systematically to maintain the balance of the structure. Use shovels and wheelbarrows. If using a snowblower, ensure that the auger is set to the highest level to prevent damage to the roof. 
• Do not create snow drifts by moving snow from one area on another.
• Verify all drains are clear of ice and snow to allow melting and runoff. If the roof is pitched and without drains, open paths to the eaves to ensure drainage and prevent ponding. 
• Inspect for any other roof damage and make necessary repairs when it is safe to do so. 

It is important to continue monitoring for winter storms and removing the snow off roofs as soon as possible, before the next storm comes in. When you protect your roof, you protect everything beneath it. 

Submitted by: Kate Connell, Loss Control Consultant

UPDATE Reminder: Changes to Federal CDL training coming Feb. 2022

Update to Oct 28, 2021 blog

Some cities may have concerns about the budget for this training. Consider that under the American Rescue Plan final rule, cities may elect a standard allowance of up to $10 million under the revenue loss category. These funds may then be spent on the general provision of government services (things we normally spending money on to provide services).  Cities will want to keep copies of the invoices to enable proper reporting of the use of ARPA funds and have until December 31, 2024 to spend these funds.

On Feb. 7, 2022 the updated Federal Motor Carrier Safety Administration (FMCSA) commercial drivers license (CDL) training standards will go into effect. These revised standards are required for anyone pursuing a new CDL license or endorsement. Training must come from a certified trainer registered in the FMCSA Training Provider Registry. As a result, most in-house training will no longer qualify.

The revised standards focused on entry-level driver training (ELDT), setting a baseline for anyone new to the commercial driving space. This includes those applying to: 

• Obtain a Class A or Class B CDL for the first time.
• Upgrade an existing Class B CDL to Class A.
• Obtain a school bus (S), passenger (P), or hazardous material (H) endorsement for first time.

Two exceptions in the FMCSA to be aware of are:

• If an applicant who obtains a commercial learner’s permit (CLP) prior to Feb. 7, 2022, obtains a CDL before the CLP or renewed CLP expires, the applicant is not subject to the ELDT requirements. 
• Any individual who meets one of the exceptions for taking a skills test in 49 CFR Part 383 is also exempt from the ELDT requirements. 

The registry’s purpose is to ensure entry-level drivers are proficient in both driver theory training and behind the wheel training. The registry will always contain the official list of qualified trainers and the records of drivers who have successfully completed their ELDT, and states will have access to that information. After a driver has completed the required training, the training provider must electronically submit the certification into the training provider registry. 

Looking for more information? Explore these additional resources:

Training Provider Registry

CDL regulation PDF 

FMCSA Website for ELDT 

49 CFR Pt. 383 Guidance Q&A

Where can I get certified as a playground safety inspector?

On average, over 200,000 children a year require emergency room care due to a playground-related injury. Of these, public playgrounds account for 74% of injuries.

At the League of Minnesota Cities, we frequently get asked where staff can go to get certified as a playground safety inspector. The National Recreation and Park Association (NRPA) offers the industry-leading certification program in playground safety, the Certified Playground Safety Inspector (CPSI) certification program. The CPSI certification program provides the most comprehensive and up-to-date training on playground safety issues including hazard identification, equipment specifications, surfacing requirements and risk management methods.

In-person options:

The Minnesota Recreation and Park Association (MRPA) offers the NRPA Certified Playground Inspector Course and Exam at 2 Minnesota locations in Spring of 2022.

Online options:

If you don't see a course in your area, the NRPA offers virtual courses.

If you’re looking to hire a local CPSI to inspect your playground equipment, you can find a list in the CPSI registry.

Additional resources:
IPEMA International Playground Equipment ManufacturerAssociation

Submitted by: Julie Jelen, Loss Control Consultant