OSHA RFI Response for Contracting, Oversight, and Economics

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Update on the RFI response: Thank you everyone who responded to OSHA tower climber RFI. Less than 500 people in the US that really want to help OSHA recognize the importance of tower safety in the wireless community. Congrats! For the rest of you, don’t worry, I realize I am beating a dead horse with no hope of getting him to move. So I will let it rest for a while. I was just so shocked that so many of you complained about safety but so many of you refuse to let OSHA know what their problems are. I just don’t understand, that’s all. I should have remembered my dad’s old saying, “You can lead a horse to water but you can’t make him drink”. In this case I can’t help those who won’t help themselves, even if they spend their spare time complaining about this very problem.

Here is my full response in a PDF. Click here to download it and look it over. This is what I sent to the FCC.

To update the RFI with your answers click here to go to Wireless Estimator or click here to go to the FCC site. You can submit anonymously if you want to. Deadline is June 15th, 2015!

Special thanks to Tower Safety for their sponsorship! Tower Safety, where the best get better.

Contracting and Work Oversight

  1. Describe your role in the contract chain and the key safety-related provisions typically included in your contracts. How do contracting parties oversee or enforce those provisions?
    • Currently I help put together large offers that will require contractors to deploy large communication systems. Usually with larger companies a project manager will manage the contractor and follow through the work with them from inception to close out.

What are the consequences if a party fails to fulfill those contractual requirements?

  • If they do not present the certifications and safety plans they do not get the work. If they send uncertified people out to the site and the contractor hears about it they are not paid.
  1. What characteristics of past safety performance does your company use in selecting potential contractors and subcontractors?
  • Review contractor’s safety record as well as the required material.

What safety-related criteria does your company use in this selection process?

  • Ask for certifications up front but that is it. We should be asking for the safety and rescue plan as well.
  1. Are safety-related factors considered in determining whether to remove a contractor/subcontractor from an ongoing project or from future selection processes? If so, what specific factors are considered?
  • Yes, safety record and feedback from the end customer, landlord/tower owner and the PM. The subs employees are usually very honest and their feedback is also taken. If the feedback is very negative, then they are removed.
  1. What are the ways in which the multi-leveled contracting environment (i.e., where entities such as the carrier, tower owner, turfing vendor, subcontractor, and contractors hired by the subcontractor all have some role in the project) impacts employee safety at communication tower work sites?
  • As margins are added, the price that the actual crew doing the work is very low. It takes money to provide training and PPE to employees. It also adds delays to the schedules because the work required passes through many hands before it is released to the company doing the work. Compressed schedules cause the installers to rush increasing the chances of making mistakes.
  1. What practices might companies in the contracting chain adopt to encourage communication and coordination among employers at tower work sites? What obstacles stand in the way of communication and coordination between different parties in the contracting chain?
  • Many contractors are afraid to let the end customer or master contractor talk to the end worker but this should not be the case. There should be NDAs in place that allow the turf vendor or contractor to act as a placement company and open communication showing the certifications from the people on the field to the end customer. The obstacles are fear that the other contractors will steal the sub contractors. The other fear is that there could be confusion with all of the information being shared. There needs to be a way to streamline the information from the end customer to the work crew. Then, streamline the information from the field back to the end customer. It all comes down to program management.

Economic Issues

  1. The Agency seeks information on the number and size of firms that are engaged in communication tower work and on the number of employees employed by those firms.
  • The companies that I deal with are mostly 30 to 50 employee companies.
  1. The Agency seeks information about wage and turnover rates for employees who work on communication towers. The Agency is also interested in information about the experience possessed by workers currently doing communication tower work. Are they usually experienced in this type of work? Are there many new or inexperienced employees working on communication towers?
  • Experience – From what I see the experienced crews are doing the tower building and structural upgrades. The tower crews doing antenna and line installations are usually the less qualified people. These crews are usually less experienced and paid less. There are many inexperienced crews doing cell deployments and there will be again when the work picks up.
  • Payment – for carrier deployments they usually get paid from $15 to $30 an hour. For heavier tower work they generally get paid over $35/hour depending on experience.
  • General – I have personally talked to many tower techs that have worked in the business for less than 2 years, they are just learning the job and the issue is that they often are on a crew with the same experience and that is not the structure that we should have in the field.
  1. What types of equipment are used in tower work and how often is this equipment repaired and/or replaced?
  • Tools, winches, PPE, rope, cranes, vehicles, so much more.
  • It should all be maintained, repaired, and replaced as needed.
  1. The Agency seeks information from all employers in the contracting chain about the extent to which employees directly engaged in tower work are covered by workers’ compensation and/or an employer liability insurance policy.
  • I have worked on all sides. Insurance is handled by HR or finance. I do not have the best insight into this issue.

Tell me what you think!

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