| By Randy E. Newcomer, CMSP COHC “We can lick gravity, but sometimes the paperwork is overwhelming.”
- Werner von Braun. Returning to MSHA’s list of Rules to Live By I’m forced to confront the difference between talking about safety and talking about compliance. The last column we discussed common sense and I have to admit it probably applies more often to safety than it does compliance. Of course I’m talking about safety as attending to issues that will keep you from getting injured or killed and compliance as dealing with things that keep you from getting a citation from an inspector. In a perfect world the two would be the same if the purpose of rules and regulations accurately is to keep workers safe. Needless to say we don’t live in that perfect world. It seems a simple thing to park a vehicle or piece of equipment. Even the regulation, at first glance seems fairly simple. It says: 30 CFR § 56.14207 Parking procedures for unattended equipment. Mobile equipment shall not be left unattended unless the controls are placed in the park position and the parking brake, if provided, is set. When parked on a grade, the wheels or tracks of mobile equipment shall be either chocked or turned into a bank. There are three different actions here: 1. Placing the vehicle in park, 2. Setting the parking brake and 3. Chocking the wheels or turning them into a bank. For the most part, people commonly do the first and 99.9 percent or more of the time it’s sufficient. I mean I don’t commonly walk around parking lots afraid that parked vehicles are going to suddenly begin rolling toward me even when there’s a substantial grade. From a quick survey of mostly guys at least the parking brake seems to be an option they wouldn’t need on their vehicle because it’s rarely used. Now maybe I have a circle of friends and acquaintances that is radically anti-parking brake, but it seems that most people are satisfied their vehicle will stay put with just the first option. I don’t know anyone who carries a chock around and uses it when forced to park where it’s not perfectly level. On a mine site failing to use the parking brake, even on the level is a violation. That’s beyond argument. Whether it’s a serious one or not may depend upon the situation, but it’s still a violation. I’m not sure more needs said than that. If you don’t use it it’s a violation even if you can convince me that your vehicle isn’t going anywhere. It’s at the very least a compliance issue. I’ll agree it’s unlikely, but I’d have to say there’s some chance at least of it being a safety issue as well. I know I could spend several articles on chocking. Many facilities enforce a rule of always chocking whether on a grade or not and even though the rules only require it on a grade it can also be a compliance issue with the inspector who does not agree with your idea of what constitutes a grade sufficient to require chocking. I’m not a fan of it from the aspect that it’s overkill and people will tend to think it and therefore all other safety rules are stupid and only to be followed when someone’s watching. On the other hand I’ve been to Gravity Hill in Pennsylvania. There are phenomena like these around the world. I found the one near Bedford as advertised on billboards along the PA Turnpike. I did as instructed and pulled up the hill and stopped on the line painted across the road. I took my car out of gear, released the brake, and was still surprised when my car began to roll forward UP the hill! Now I know there was nothing supernatural involved and the only thing going on was that my perception was being tricked by the lay of the land. Still, it’s a good lesson to tell us that it’s difficult for us to truly know what is level and where our vehicle needs extra help to stay put. On this point I’ll argue that it may seem like overkill, but I’ll shoot for compliance anyway. After all, enough miners thought their equipment would stay put and wound up getting run over to put this on the Rules to Live By list. Just a Minute: Whether you’re on mine property or not next time you park use the parking brake. Then use it the next time. Can it become a habit for you? What’s the true cost of using it? Avoid the surprise of a grade where you think it’s level. There’s one way to truly be certain. Follow the rules. To comment on this story or for additional details click on related button above. |