A Reference Guide for Safety Professionals
This reference guide is written with safety professionals in mind. The focus of this guide is safety and OSHA compliance responsibility within organizations as it relates to various commercial overhead door systems.
Summary
Even though overhead door systems are very common, they are almost always overlooked as safety hazards, even in organizations with excellent safety programs. Despite how common overhead door systems are, they are often overlooked as potential safety hazards. Even companies with exceptional safety programs and practices fail to keep up with proper safety precautions for their overhead door systems.
This oversight, while seemingly harmless, can have catastrophic consequences. Commercial overhead doors are often weighty, high hanging, forceful, and often operate where there is pedestrian traffic, making potential accidents highly dangerous.
Each year, there are far too many examples of people being struck or crushed by overhead doors in incidents that would have been easily avoided with regularly scheduled door maintenance and inspections. Additionally, the inclusion of the recommended safety entrapment devices can help avoid harmful accidents.
OSHA Compliance Requirements
Overhead doors systems are subject to OSHA compliance standards, specifically Section 5(a)(1) of the Occupational Safety & Health Act of 1970, which has been used many times as the basis for overhead door-related citations and penalties.
State OHS Plans may impose additional, more strict standards.
Federal OSHA Standards
Main types of commercial overhead doors:
Overhead door systems are not specifically referenced in the Occupational Safety & Health Act of 19704 ; however, they are subject to the standards of Section 5(a)(1) of the Act, the General Duty Clause:
Section 5. Duties
(a) Each employer —
(1) shall furnish to each of his employees employment and a place of employment which are free from recognized hazards that are causing or are likely to cause death or serious physical harm to his employees;
Section 5(a)(1) has been used as the basis for overhead door-related OSHA citations and penalties, and OSHA enforcement has cited improperly maintained and/or installed door systems as well as the absence of entrapment devices as causing unacceptable exposure to “Crushing” or “Struck-by” hazards. Below are several examples:
“… overhead garage doors did not have a safety device edge, door stop sensors and proper signage.”5 “… two 14 foot wide overhead garage doors did not have a safety device edge or door stop sensors.”6
“… employer failed to ensure that the overhead door in Bay #3 was adequately constructed and adjusted to prevent it from coming off the track.”7
“… garage doors #1 and #2 did not have a safety device edge or door stop sensors.”8
OSHA abatement typically instructs companies to “hire a professional to install the safety devices and conduct periodic inspections.”9, 10, 11
State OSH Plans
State OSH Plans must, by federal OSHA law, be at least as effective as federal OSHA standards, but after having satisfied that requirement, these plans are free to outline more specific overhead door safety standards and practices. For example, Minnesota’s Clarification of Minnesota Rules 5205.0675, subp. 212 aims to provide more specific instructions on acceptable overhead door safety options.
How to Properly Include Overhead Doors in Your Safety Program
To ensure compliance with OSHA regulations and minimize the safety risks associated with overhead door systems, a planned maintenance and safety compliance program should be implemented. To get you started, review the below standards and apply them to your system. Inspection, maintenance and repair work should be performed by a qualified overhead door service company, such as RCI Doors™.
Standard #1 – Maintenance Practices & Intervals
All door systems should be installed, inspected & maintained in accordance with the manufacturers’ specifications. This includes maintenance intervals, which can vary depending on daily cyclage and operating environment. If manufacturer’s specifications are not available, then the PM program should adhere to established industry standards/best practices (e.g., DASMA).
Standard #2 – Entrapment Devices
All motorized door systems should be equipped with entrapment devices to manufacturer’s specifications, such as photo-eyes or sensing edges. If there are door systems equipped with older devices not current with newer, improved safety standards, modernizing should be considered where reasonably practicable; for example, upgrading to monitored entrapment devices.
Standard #3 – Documentation & Reporting
Thorough, secure documentation should be maintained that details:
· Maintenance and service work performed
· Problems or deficiencies found, preferably documented with notes and photographs; corrective action recommended; and corrective action taken
· The practices and standards used to inspect and maintain doors (e.g. manufacturer’s operating/maintenance manuals, or similar documentation)
What Now? Next Steps …
Do not ignore your door systems. Neglected doors become less reliable and potentially more hazardous over time. Take action by having a qualified door dealer do an initial inspection and service to establish a baseline of door condition, performance and safety compliance. Then, take it from there work with them to establish your personalized planned maintenance program.
Ensure your door dealer can perform and document maintenance work to meet standards #1, #2, and #3, as these are the standards that matter for safety compliance and door reliability.
Footnotes
1 Garage door crushed worker at Vancouver works yard not properly maintained – The Province, Oct 2012
2 Jury awards $21.3 million to man injured in garage door incident – IndyStar, Oct 2014.
3 Man pinned under garage door asphyxiated – Star Tribune, Mar 2012
4 Letter published on the OSHA website, Richard E. Fairfax, Director, Directorate of Enforcement Programs, September 10, 2002. URL https://ww- w.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=24460
5 OSHA inspection #314223140, Shelburne Fire Department 6 OSHA inspection #314071929, Orland Dwelley & Sons, Inc. 7 OSHA inspection #313525404, Cema Corp.
8 OSHA inspection #314071838, Force Manufacturing, Inc.
9 OSHA inspection #313993313, Kelly Lumber Sales, Inc.
10 OSHA inspection #313993321, Timber Express, Inc.
11 Minnesota OSHA Fact Sheet, Clarification of Minnesota Rules 5205.0675, subp. 2—Overhead Doors 12 OSHA inspection #314365602, Employee dies when crushed beneath garage door.
13 OSHA inspection #316106731, Employee dies after being struck by door.
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Disclaimer
The information in this publication does not take the place of professional occupational health and safety advice and is not guaranteed to meet the requirements of applicable laws, regulations, and rules. Safedoor Planned Maintenance Ltd., and their respective employees, officers, directors or agents (collectively “Safedoor”) assumes no liability for or responsibility for any loss or damage suffered or incurred by any person arising from or in any way connected with the use of or reliance upon the information contained in this publication including, without limitation, any liability for loss or damage arising from the negligence or negligent misrepresentation of Safedoor in any way connected with the information contained herein. The information provided in this publication is on an “as is” basis. Safedoor does not guarantee, warrant, or make any representation as to the quality, accuracy, completeness, timeliness, appropriateness, or suitability of any of the information provided, and disclaims all statutory or other warranties, terms, or obligations of any kind arising from the use of or reliance upon the information provided, and assumes no obligation to update the information provided or advise on future developments concerning the topics mentioned.
