OSHA Inspection: UNITED AIR LINES, INC.

Issued

Sep 15, 2011

Abate by

Oct 18, 2011

Penalty

Initial $7,000 · Current $7,000

General-duty citation text

Title 40.1-51.1(a) Code of Virginia.   At Washington Dulles International
Airport, the employer did not furnish
employment and a place of employment which were free from recognized
hazards that were causing or likely to
cause death or serious physical harm to employees in that employees were
exposed to fall hazards while using
the FMC Commander Container/Pallet Loader, serial CR96034, identification
number CL348, during opening
and closing operations of the cargo doors of a Boeing 777 airplane to
unload cargo from the airplane.
On April 1, 2011, an employee was fatally injured when he fell
approximately 8 4 off of the folding
wing/wing extension between the front of the loaders bridge platform and
the right rear cargo door of the
airplane.   Ground clearance data for the Boeing 777 reveals the ground
clearance can vary between
approximately 127 and 134 for the Aft Cargo Compartment.  Based on the
above measurements, the bridge
of the container/pallet loader was lowered between approximately 27 and 34
below the doorsill of the cargo
door at the time of the accident.
The loader is equipped with two large platforms, which are operated
independently by scissor lifts.  The
platform closest to the airplane cargo door is referred to as the bridge.
The bridge can be tilted to reach a cargo
door independently of the scissor lift mechanism.  The operator maneuvers
the loader from an operators station
which is provided with a guard rail.  The loader is equipped with a
folding wing/wing extension at the front of
the bridge, which is designed to line up with base of the cargo door so
that large containers and pallets can be
unloaded from the airplane.  Because different model airplanes can have
cargo doors of different widths, the
folding wing/wing extension is adjustable in either an up or down
position.  When in the  up position, the
folding wing/wing extension allows the loader to accommodate a wider cargo
door, and when the  down
position it accommodates a narrower cargo door.  When in the  up position,
the folding wing/wing extension
is held in place by a manual latch/lock bar that slides from the bridge
and is held in place by a spring-loaded
latch pin that fits into a detent located in the manual latch/lock  bar.
When the scissors supporting the bridge are fully lowered and the tilt
feature is fully lowered at the front, the
folding wing/wing extension comes to rest on a fixed roller stop.  The
roller stop holds the folding wing/wing
extension in the  up position, level with the bridge and allows the manual
latch/lock bar to freely move under
the folding wing/wing extension, because there is no downward pressure on
the manual latch/lock bar from the
tilt feature.  Adjustment of the manual latch/lock bar is completed from
the ground.
If the scissors supporting the bridge are not fully lowered or the tilt
feature is not fully lowered at the front, the
manual latch/lock bar may not freely move under the folding wing/wing
extension.  It is possible for the manual
latch/lock bar to be partially under the folding wing/wing extension, with
the spring-loaded latch pin not
engaged in the detent, and provide enough support to hold the folding
wing/wing extension up when the bridge
is lifted.  If this condition occurs, the folding wing/wing extension can
fall to the down position if the manual
latch/lock bar travels towards the rear position while the bridge is
elevated.
a.The investigation revealed that multiple near miss accidents have
occurred where operators
were exposed to a collapsed folding wing/wing extension.  A near miss
accident occurred on
April 24, 2010, when an operator stepped from an elevated bridge onto a
folding wing/wing
extension and it collapsed causing him to be caught between the folding
wing/extension wing
and the side of the plane, with his legs dangling in the air.  As a result
of the April 24, 2010,
accident, the employer added a yellow line on the manual latch/lock bar
and the frame to assist
operators in determining whether the manual latch/lock bar is fully under
the folding wing/wing
extension and the spring loaded latch pin is lined up with detent in the
manual latch/lock bar.
The investigation also revealed that the employer instructed operators to
avoid standing on the
wing extensions where possible, although it is apparently necessary to do
so to open certain
aircraft cargo doors.  Employees are exposed to serious fall hazards as a
result of the collapsing
folding wing/wing extension.
b.The investigation further revealed that the United Air Lines, Inc.,
Airport Operations ! AirportUniversity training program entitled  Ground
Equipment Training, Cargo Loader !
Movement, version 11.05.09, instructs cargo loader operators when
approaching and
positioning the loader next to the airplanes cargo door to  STOP Cargo
Loader no closer than 1
foot from the aircraft.    The  Structured On Site Training ! Performance
Checklist &
Qualification training documentation form, section 7, entitled  Operate
Command Container
Loader, the operator standard when positioning the loader at the aircraft
is to  4. Stop loader 1
to 2 feet from aircraft.  This practice leaves a horizontal gap between
the body of the plane
and the bridge and exposes operators to serious fall hazards during cargo
door opening and
closing operations due to the 1 to 2 foot gap between the bridge and the
airplane cargo door,
and between the airplane and the vertical guard rails next to the
operators station.
c.  The investigation further revealed that the training program entitled
Ground Equipment
Training, Cargo Loader ! Movement, version 11.05.09, cautions that
CAUTION.  The
Cargo Door  swings down (extends below the doorsill) during the initial
opening process.
The investigation revealed that it is a regular practice for operators to
lower the bridge up to 2
feet below the cargo doorsill in order to access the pallet locks/doorsill
locks when the cargo
doors are being opened and closed.  This practice leaves a vertical gap
between the body of the
plane and the bridge and exposes operators to serious fall hazards during
cargo door opening
and closing operations due to the 1 to 2 foot gap between the bridge and
doorsill of the cargo
door, and between the airplane and the vertical guard rails next to the
operators station.
One feasible and acceptable method, among others, to correct this hazard
is
for the employer to provide
and assure that operators are trained on and use a personal fall arrest
system consisting of a body
harness, lanyard, anchorage and connectors meeting the requirements of
1926.502(d).  Reference:
1926.502(d) of the Standards for the Construction industry.