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SAFETY AGC 5 STAR SERVICE Don’t Get Nailed b y by the New Pneumatic Nailer Regulation! By Kevin D. Bland, Esq. SB 07-9 It has been nearly three years since the industry set out on a course to update the Nail Gun regulation after many of us were getting cited for “unattended” nailers and nailers “not in use.” Well, those days will be gone soon. The new Title 8, Construction Safety Orders Section 1704 became effective on November 30, 2007. The new regulation was a result of a consensus reached through the advisory meeting process, and as a result, we now have a regulation which more closely mirrors actual practice in the field and establishes a nexus with the regulatory requirements and actual hazards. One of the key components of the new regulation is training. Training is now required in three major areas: 1) prior to use; 2) when an employee is observed using a nailer in an unsafe manner (“refresher training”); and 3) when an employee has been involved in an accident. The training must be conducted by a qualified person and include a “hands-on” training component. At a minimum, the training should include discussion of your company’s Code of Safe practices relating to nailers, hazards related to each mode of actuation (bump fire and sequential), and basic operating instructions. Proof of this training should be documented in each employee’s personnel file and made part of your new-hire package. In addition to the training components, the new regulation prohibits the removing or altering of the operating controls and safety devices on the nailer. Although the regulation no longer includes “unattended” type language, it does require that the nailer be disconnected from the air supply when maintaining, repairing or clearing a jam from the nailer. Also, the new regulation requires that the air hose be secured at the roof level on roof slopes that are steeper than 7:12. However, the harness and safety belt requirement on 1/3 pitch roofs was deleted from the new standard to make fall protection requirements for nailing on roofs consistent with the Title 8 Section 1716.2 framing standard. (e) All pneumatic hoses exceeding 1/2-inch inside diameter shall have a safety device at the source of supply or branch line to reduce pressure in case of hose failure. Below is the standard in its entirety: Section 1704. Pneumatically-Driven Nailers and Staplers. (a) Definitions. (1) Light-Duty Nailers and Staplers: Tools designed to only drive fasteners meeting both of these requirements: (A) Fasteners 1-inch nominal length or shorter. (B) Fasteners made from wire with cross sectional area less than 18 ASWG. (2) Mode of actuation: The use of a trigger, work-piece contact and/or other operating control, separately or in some combination or sequence, to actuate the tool. Modes of actuation include “bump fire” and sequential modes. (f) The employer’s written Code of Safe Practices shall include provisions for the use of pneumatically-driven nailers and staplers where applicable. (g) Training. (1) The requirements of this Section shall apply in addition to training required by Construction Safety Orders, Section 1509, and General Industry Safety Orders, Section 3203(a)(7). (2) Safety training shall be conducted prior to initial assignment to operate pneumatically-driven nailers or staplers. (3) Refresher training shall be provided to the operator when: (A) The operator has been observed using the pneumatically-driven nailer or stapler in an unsafe manner; or (B) The operator has been involved in an accident. (4) Safety training shall include, but not be limited to, the following elements: (A) The employer’s Code of Safe Practices for pneumatically-driven nailers or staplers. (B) The hazards related to each mode of actuation for pneumatically-driven nailers and staplers. (C) Hands-on training to verify that the operator understands the operating and safety instructions. (5) Training shall be conducted by a qualified person. (b) General. (1) All pneumatically-driven nailers and staplers shall have a safety device on the muzzle to prevent the tool from operating unless the muzzle is in contact with the work surface, to prevent accidental discharge. Exception: Light-Duty Nailers and Staplers. (2) All pneumatically-driven nailers and staplers shall be operated and maintained in accordance with the manufacturer’s operating and safety instructions. (3) Personal protective equipment shall be utilized in accordance with Construction Safety Orders Section 1514. (4) Operating controls shall not be removed, tampered with, altered, or otherwise disabled. (5) Pneumatically-driven nailers and staplers shall be connected to the air supply with a safety disconnect that consists of a spring loaded shut-off valve and a positive locking mechanism to prevent the tool from becoming accidentally disconnected. (6) Tools shall be equipped with a fitting that will discharge all compressed air in the tool at the time the fitting or hose coupling is disconnected. If you have any questions, please feel free to contact Kevin Bland at (949) 861-4100 or email him at [email protected]. (c) Pneumatically-driven nailers and staplers shall be disconnected from the air supply at the tool when: (1) performing any maintenance or repair on the tool, or (2) clearing a jam. (d) On roofs sloped steeper than 7:12, the air hose shall be secured at roof level in such a manner as to provide ample, but not excessive, amounts of hose. -2-