In the communication tower industry, workers are at risk of falls and structural collapse—a risk that is increased by the chances that, at some point, safety will fall through a gap in the multiple layers of cellular service providers (carriers), tower owners, turf vendors, contractors, and subcontractors arrayed over them.
It’s not a unique setup—multiple layers of contractors are becoming more common generally. So, the new guidance document jointly released by the Occupational Safety and Health Administration (OSHA) and the Federal Communications Commission (FCC), Communication Tower Best Practices, could be useful to more than just employers in that industry. The guidance document identifies the safety-related responsibilities of each employer in the communication tower industry.
Carriers and Tower Owners
Carriers and tower owners tend to be the top-level employers in the communication tower industry, contracting work to smaller employers in many different locations. In addition to their responsibility to vet contractors and require their compliance with established health and safety practices, carriers and tower owners are responsible for:
- Establishing an incident reporting system and managing all reported incidents from a central location
- Investigating all serious injuries and fatalities
- Performing random audits of safety-related work practices
- Taking steps to ensure that employee training at all levels is of adequate quality, and to verify individual employee training and certifications
- Keeping records of all contractors performing work for them
- Maintaining an electronic inventory of all towers and antennas
- Freely sharing information that pertains to work on communication towers
In addition to the above, carriers are responsible for allowing sufficient time and flexibility in project timelines for work to be completed safely. This includes making sufficient allowances for travel time to prevent employee fatigue.
Tower owners are responsible for making sure that their towers are properly maintained, safely accessible, and equipped with engineered anchorage points. Drone technology can be employed to minimize the amount of climbing needed. Owners should use photographs of completed work to manage work assignments and minimize climbing.
Turf vendors are contracted intermediaries between carriers and the tower-climbing contractors that install and maintain their equipment. Their safety-related responsibilities include:
- Ensuring that all contractor employees are properly trained and that their training is properly documented
- Establishing an expectation of zero tolerance toward unsafe work practices, including free climbing
- Ensuring an open flow of communication between carriers, tower owners, and contractors, and creating the capability to respond immediately to hazard reports and safety-related inquiries coming in from the field
- Placing representatives on-site while tower work is being performed, to ensure that safe work practices are followed
- Ensuring that a job hazard analysis and orientation session are performed by each contractor on-site, and retaining the documentation of these activities.
Tower Construction and Maintenance Contractors
Contractors who are hired to perform tower construction and maintenance are responsible for:
- Promptly reporting all serious injuries and fatalities to local emergency responders and OSHA, as required.
- Investigating all safety-related incidents on-site.
- Identifying workers whose training appears to have been inadequate.
- Conducting daily tailgate meetings.
- Completing a job hazard analysis before beginning any job.
- Identifying specific safety equipment and safety-related work practices that will be needed for the job.
- Providing adequate supervision to ensure that safe work practices are being followed.
- Enforcing a zero-tolerance policy against unsafe work practices, especially free climbing.
- Tracking work schedules, including travel and driving time, to ensure that workers do not climb when they are fatigued.
- Maintaining records of employee training and certifications, and making them available to carriers, tower owners, and turf vendors upon request.
- Obtaining up-to-date technical and engineering specifications for towers that are necessary to perform job hazard analyses and establish safe work practices.
- Ensuring that all climbers and ground crew have received proper training and timely retraining, and pairing new climbers with experienced climbers. Employees responsible for rigging and hoisting should receive specialized training.
Tower Climbers and Ground Crew Employees
The safety responsibilities of tower climbers and ground crew employees include:
- Identifying and reporting unsafe conditions
- Using their safety equipment
- Committing to being 100% tied off at all times
- Being weather-aware, and not climbing in unsafe conditions
- Being aware of conditions that could affect their ability to climb safely, like health conditions and medications
- Conducting regular equipment inspections
Overlap and Redundancy
There is a great deal of overlap and redundancy in the responsibilities of various parties. A gap in responsibility for ensuring training, safe work practices, or scheduling can lead to a worker’s death just as surely as a gap in fall protection. When multiple levels of contracting are involved in a project, it’s important that each party does what it can to ensure the safety of all workers, especially those who are at greatest risk.