OSHA, Cycling, and You

OSHA, Cycling, and You

Thanks to that anon commenter who first woke me up to the the ccwonderful world of PPE (personal protective equipment)! πŸ™‚

For the last two days, I’ve been trolling the OSHA and CDC websites, and I can see that there has been a LOT of work put into the study of safety.

However, in world of cycling, we re-invent the wheel, badly.

Check this out:

http://www.google.com/url?sa=t&rct=j&q=&esrc=s&source=web&cd=9&ved=0CG8QFjAI&url=http%3A%2F%2Forosha.org%2Feducate%2Fonlinecourses%2F1241%2F1241FinalPDF.pdf&ei=M4yxUISuL8ebqwH0p4DADg&usg=AFQjCNE29nX9cqJLfqBT3IoIDT50GxBiMg&sig2=zjgAJll4QB3JXWK1uzsM5g

First of all, we will assume that in this case, the state is the employer because the state has created our transportation system, and thus, like a good citizen, should be perILEsonally responsible for the risks that it creates.

How is the state doing?

Not so well.

First of all, is this post a submarine part of my anti-helmet crusade? No! It’s openly anti-helmet.

Second, let’s rehash that the good nation of Australia has proven that many, many, many people can die while wearing PPE. How tragic!

However, maybe pro-helmet people should at least THINK of STFU of their blame and shame of those who hurt ourselves while NOT wearing a helmet.

If we have to eat the deaths of those of us without helmets then helmet promoters must take equal blame for promoting useless safety equipment when people die.

What does OSHA have to say about injuries while wearing PPE?

“For example, one study indicated that 70% of the workers experiencing hand injuries were not wearing gloves.
Hand injuries to the remaining 30% of the workers who were wearing gloves were caused by the gloves being
either inadequate, damaged, or the wrong type for the type of hazard present.”

All caps for the skimmer commenters:

“ACCORDING TO OSHA, IF YOU ARE HURT WHILE WEARING A HELMET,THE HELMET IS INADEQUETE FOR THE TYPE OF HAZARD PRESENT.”

Thus, if you admit that a helmet will not protect you from all road injuries, you are pushing an inadequate solutions. From the other day, we learned that bottom of the safety barrel interventions are ONLY to be used as a last resort unless they are totally adequate. Thus, the employer, the state has created unsafe working conditions (cycling conditions) and suggesting a useless band-aid for this is not recommended by the safety experts.

“Personal protective equipment will be provided, used, and maintained when it has been determined that its use is required and that such use will lessen the likelihood of occupational injury and/or illness.”

But most normal people have all ready agreed that a helmet will not save you in the most common way to die which is getting hit by a high speed car. Thus helmet advocates are pushing INADEQUATE equipment which is not recommended.

Not only that, but a poor cyclist, by OSHA standards, is NOT obligated to buy a useful helmet:

“Although employers may at times arrange for employees to provide their own protective equipment, it’s important to understand that in such circumstances the employer remains responsible and accountable to assure its adequacy, ie helmet does not meet standards, the state should be liable for injury and death. I don’t recall anyone suing the state for a defective helmet thus, I feel that the roads don’t meet minimum OSHA standards.

“Remember, PPE that is defective…is not PPE.”

This is why I say that cycling helmets are useless.

“(1) The employer shall assess the workplace to determine if hazards are present, or are likely to be present, which necessitate the use of personal protective equipment (PPE). If such hazards are present, or likely to be present, the employer shall:

(i) Select, and have each affected employee use, the types of PPE that will protect the affected employee from the hazards identified in the hazard assessment;”

For cyclists, high speed cars are the biggest hazard that they would identify on their quaint walk through, of the high speed roads that I ride on.

There is no cycling helmet that will protect for this hazard. Thus, I suggest other means on the pyramid such as engineering controls and GASP elimination of the hazards.

As OSHA says:

“PPE devices alone should not be relied on to provide protection against hazards, but should be used in conjunction with engineering controls and other management controls.”

When one reads engineering controls, for the most part, in cycling, this is infrastructure:

“Engineering controls are the “first line of defense” against injury/illness, because they have the potential to completely eliminate a hazard, and do not
rely on human behavior to be effecti ve.”

I skimmed through the walk though, and I’ll circle back to another post.

For now, here’s a chestnut:

“Select the protective equipment which ensures a level of protection greater than the minimum required to protect employees from the hazards;”

Note that this means that if you claim it will protect against head injury on a VC road–I mean on a road where traffic if 50 MPH, the PPE should be rated for 60 MPH. I wonder who will sell me this helmet. Do I hear a Nut CaseTM. πŸ™‚

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