June 1, 2017–Following nearly three years of deliberations, the FCC and the Labor Department’s Occupational Safety and Health Administration today issued a set of voluntary guidelines that communications tower companies and contractors should follow to help improve safety conditions at tower sites. “The guide is a result of the long-standing commitment of both agencies to ensuring the safety of tower workers,” FCC Chairman Ajit Pai and Deputy Assistant Secretary of Labor for Occupational Safety and Health Dorothy Dougherty said in a joint statement, adding: “The guide is an important step to reduce the tragic number of fatalities involved in communications tower work.”
The FCC and OHSA noted they held a workshop in October 2014 (TR Daily, Oct. 14, 2014) and another in February 2016 (TR Daily, Feb. 11, 2016) during which industry stakeholders, employee safety advocates, and others discussed “best practices that could reduce injuries and fatalities among tower employees.” The first workshop was held in the wake of an expanded focus by OSHA on communications tower safety as tower worker deaths rose.
The new guidelines are the result of those workshops and additional discussions, they said. “These best practices are focused on the ways in which each level in the contracting chain can build a positive culture of safety and accountability,” the FCC and OSHA said.
The Wireless Infrastructure Association said it “applauds” the final product the FCC and OSHA released. The guidelines are a “valuable set of best practices aimed at promoting improved safety within the communications tower sector,” WIA President and Chief Executive Officer Jonathan Adelstein said in a statement.
“The safety of all workers in the wireless telecommunications industry is extremely important to WIA members and critical to the continued growth and evolution of our mobile networks,” he said.
The National Association of Tower Erectors also hailed the “Communication Tower Best Practices” document. The guidelines will serve as a “valuable resource for the wireless and communications tower industry to reference and utilize to ensure that work is conducted in a safe and quality manner,” NATE Executive Director Todd Schlekeway said in a statement. In addition, he said, NATE believes it is “paramount” that the FCC and OSHA “continue to collaborate to host additional workshops and stay engaged with all layers of the wireless infrastructure chain to ensure that workforce safety and quality remain the top priorities.”
CTIA also praised the new guidelines. “We welcome the FCC and OSHA’s focus on communications tower worker safety and continue to partner with government and other stakeholders to ensure a safe working environment,” a spokesperson for the group said.
Competitive Carriers Association President and CEO Steve Berry said, “Competitive carriers depend on consistent and safe siting and infrastructure maintenance policies to provide their customers with robust mobile broadband services; yet many network providers face substantial challenges trying to deploy, and upgrade their physical networks. Competitive carriers experience these challenges first-hand, and I am very pleased that the Commission and OSHA took CCA and its members’ input and recommendations into consideration when creating the best practices guide.” Mr. Berry added, “With the post-incentive auction repacking process in the immediate future, and competitive carriers’ focus on investment and deployment of next-generation services, it is more important than ever to prioritize safety for tower climbers and to promote expansion of mobile broadband services with sound infrastructure policies. The FCC and OSHA’s Guide is an important step to ensuring the safest environment possible for the tower climbing community, and I commend OSHA and the FCC for working together on tower safety issues, which is a key catalyst in changing the hazard landscape. CCA looks forward to continued work with policymakers to foster enhanced safety and broadband deployment opportunities.”
The guidelines note that many tower companies use outside contractors, or “turfing vendors,” to build and maintain structures. Presenting further logistical and accountability issues, those vendors often sub-contract work to others. “As a result, carriers and tower owners may not know who is performing work for them, or when work is being performed,” the guidelines state. “Thus, responsibility for employee safety is fractured into many layers. … In light of these circumstances, ensuring employee safety requires accountability and diligence throughout the contracting process, all the way from the carrier to the individual employee performing the work.”
The guidelines call on “all entities” involved with tower construction and operation to “establish a comprehensive safety and health program” that “should address all of the hazards associated with communication tower work.”
That program should ensure managers “continually demonstrate” a commitment to improving safety and health” of tower workers. Employees should also be involved “in all aspects” of the program, the guidelines state. The program should also include procedures to identify and assess tower hazards, and processes for inventing and controlling them, OSHA and the FCC said.
All managers and employees should be trained to understand how to prevent and control tower safety issues, they suggested. The program should also be regularly evaluated to determine any deficiencies and potential areas that could be improved, the agencies said.
To ensure “maximum effectiveness,” all safety and health programs “along the contracting chain” for any tower site should be managed by a single person, the guidelines state. That person should “ideally” have experience climbing and working on towers, or have a “close supervisor” that does.
Safety and health programs should also establish “concrete consequences” for contractors that do not follow procedures put in place, the guidelines say. The guidelines also “strongly” recommend that contractor safety and health programs be evaluated on “at least” an annual basis.
The FCC and OSHA also laid out details for verifying that subcontractors have implemented their own safety programs. There should be “clear criteria for vetting and approving all contractors,” including subcontractors.
Among other things, the FCC and OSHA said there should be procedures for obtaining certification and training records for each climber at a tower site. There should also be criteria established for awarding future contracts based on a contractor’s safety record, as well as provisions for conducting independent audits of job sites.
The guidelines also specify that tower climbers and ground crew employees should be aware of how to report unsafe working conditions. All work crews should have access to proper safety equipment and no climbing work should be done on sites without a comprehensive safety plan.
For employees, the guidelines direct that no member of a work crew should work on a tower if his or her “physical or mental health is impaired.” In addition, work crews should immediately cease operation if any safety device malfunctions. There should also be frequent inspections of safety equipment at tower sites.
Carriers and tower owners should also establish an incident reporting system “with a clearly defined, streamlined process for responding to incidents in a timely manner,” the guidelines state, adding: “Carriers and tower owners can foster a culture where everyone is encouraged to report safety issues by making it easy to anonymously report unsafe towers to a telephone hotline, or via a mobile phone application.” Carriers and tower owners should establish a central location that would manage repair and maintenance requests, which would then be tracked until they are completed. Carriers and tower owners should also “automatically launch an investigation” into the cause of “all serious injuries and fatalities,” the agencies said.
The FCC and OSHA called upon carriers and tower owners to support the development of training standards that would be used industry-wide, including by subcontractors. The guidelines also include recommendations for maintaining records of projects and the contractors working on them, as well as a “comprehensive electronic inventory system of all towers and antennas.”
According to the guidelines, carriers should also take “proactive steps” to guard against employees becoming fatigued on job sites. Among other things, carriers should try to minimize “long drives” to and from tower sites, and take travel time into consideration when establishing project schedules.
Turfing vendors also should follow various protocols, such as establishing a “command center” staffed by employees who can respond to inquiries about safety issues. Turfing vendors should also always have a representative on site to ensure safe practices are being observed.
When injuries or fatalities occur on a tower site, the guidelines state, they should be reported to OSHA, local emergency services, and any other appropriate authorities.
Contractors should also have their own policies for investigating any tower site safety incidents. If an incident results from the action of an employee, the contractor should examine its training procedures to determine if there are any deficiencies.
The guidelines also recommend that a “tailgate meeting” take place each day at work sites to go over safety procedures. Contractors should also make sure employees follow those procedures throughout the day.
The guidelines also recommend that tower climbers be tied-off to towers rather than “free climbing” without being tethered. —Jeff Williams