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How to Know When You Need Fall Protection – A Complete Guide

How to Know When You Need Fall Protection – A Complete Guide


Fall protection regulations can be tricky.  Depending on what industry you are in, what task you are performing, or what piece of equipment you are using, your requirement to have and utilize fall protection can be anywhere from 0’ to 30’.  That’s a big difference without even counting all the various requirements at heights in between.  So, how are you to know when you need fall protection?

The simplest answer is, absent the presence of equipment, machinery, or some substance you can fall into, if you are working more than 4’ above a lower level and do not have some type of fall protection, you MAY be in violation.  If you are not 100% sure if you are in violation or not, you either need to do some research or reach out to somebody who does know the answer.  Simply proceeding with your work because you weren’t sure of the specifics, is not acceptable. 

Industry

Let’s start with the quick overview.  Each of the OSHA regulations has its own starting point.  Keep in mind that each of these starting points has a caveat:  If you are working over some equipment or substance into which you could fall and do harm to yourself, then you must be protected from doing so even if you are mere inches above it.  All other requirements get overridden. 

Otherwise, the simple breakdown is this:

General Industry (anyone governed by 29 CFR 1910) – 4 feet
Shipyards (anyone governed by 29 CFR 1915) – 5 feet
Construction (anyone governed by 29 CFR 1926) – 6 feet
Longshoring (anyone governed by 29 CFR 1918) – 8 feet

Be careful though, because these numbers are by no means definitive.  There are many exceptions to these rules, most notably in construction, which brings us to how heights differ by task.

Task

Breaking the rule up into industry helps to give you a general idea of when you need fall protection given your task – but only in a very broad sense.  For instance, if the work you are doing is considered maintenance, then you would have to abide by the general industry rule, whereas any work deemed construction or demolition would mean you’d have to abide by the construction rule.  However, within those industries there are specific tasks that are treated differently.

A few notable examples are roofing and steel erection.  Both are considered construction activities, so they fall into 29 CFR 1926 which in general requires fall protection at 6’. However, here are your actual requirements for each:
Steel Erection –

  • No fall protection is required for anybody involved in steel erection activities until they are 15’ feet in the air.
  • At 15’, all workers involved in steel erection activities MUST have and utilize fall protection EXCEPT connectors and deckers.
  • Connectors must have fall protection and the ability to use it from 15’ to 30’ (or two stories, whichever comes first), HOWEVER, they may opt to not use it.
  • Deckers may utilize a Controlled Decking Zone (CDZ) from 15’ to 30’ (or two stories, whichever comes first).  For details on CDZs, refer to 29 CFR 1926 Subpart R.
  • At 30’ or two stories (whichever comes first), ALL personnel involved in steel erection activities MUST have and utilize fall protection, no exceptions.

Roofing –

  • Roofers (and only roofers – other trades working on a roof do not receive the allowances given to roofers) may opt to utilize a warning line and safety monitor system instead of other fall protection.
  • In such cases, the warning line must be 6’ from the edge of the roof (or more) or 10’ if mechanical equipment is operating on the roof and travelling toward that warning line.
  • Safety monitors are not optional.  While there are situations where a safety monitor may be used without a warning line (i.e. – on a roof less than 50’ in width), there is no situation in which a warning line can be used without a monitor.
  • This applies to low-slope or flat roofs.  It also applies if you have an elevated section of roof within the edges of a lower roof, if the elevated section is 6’ or more above the lower section.
  • Good advice for a roofer is, if you’re on a roof and don’t see something between you and the edge, you might not be properly protected, so ask.

What should be fairly obvious from the above two examples is that when we start to discuss specific procedures, things get very…well…specific.  Suddenly a catch-all rule doesn’t always apply…or can’t always apply.  Therefore, things get broken down further.  Bit by bit by bit.  This is not something you would just know or something that you could assume, so, before beginning your work, make sure that you understand whether or not there are different rules for the task you are about to perform.

Equipment


Equipment can also play a factor in when fall protection is required.  For instance, you must be properly tied-off at all times when in an aerial lift.  This overrides the 15’ requirement in the steel erection regulation as it is a more specific requirement and because the manufacturer requires it.  Scaffolding has a requirement of 10’ that exists solely for being able to work on top of one bay of scaffolding (often greater than 6’ high) without having to concern yourself with railings or other means of protection.  Ladders even have their own rules, depending on whether you’re just climbing or working from them.  With the new Walking and Working Surface regulation in place, new fixed ladders over 24’ must now have fall protection devices in place as opposed to the old requirement for cages or wells.  In order to find out if your equipment has a special requirement, refer either to the operator’s manual or to the specific section in the OSHA regulations that governs your equipment.

Of course, each of these situations that we’ve already discussed has additional rules, requirements, and exceptions that cannot be completely detailed in an article without completely reproducing the regulations.  It is important for you to fully understand the situation in which you are working before you work.  This can be done through your own research (www.osha.gov has great information), but it can also be done – and should also be done – through training.  All employees who need to utilize personal fall arrest systems MUST be trained in their use, but it is a good idea to train anybody that is utilizing fall protection equipment, even if it’s just railings, because it will teach them how to recognize hazards and how to avoid putting themselves in dangerous situations. 

In the end, to answer the question, “How do I know when I need fall protection?” is simple.  You might not, so trust your gut and if something doesn’t feel right, ask.  If you’re over the basic height requirement listed above for your industry and have no fall protection, don’t worry about whether or not you might be an exception to the rule.  Ask.  If you’re not satisfied with the answer you’re given, seek out somebody who knows.  Whether it’s a safety group on LinkedIn or a friend you know in the industry, find somebody who knows the answer.  Don’t put your life at risk because somebody else doesn’t know what is required, because once you fall, there is no turning back.

Related Entries

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

.(JavaScript must be enabled to view this email address)

http://www.signaturesafety.net

John Braun has been in the EHS field for more than 14 years. He achieved his CHST in 2005 and his CSP in 2010. Though he focuses on construction, his background includes manufacturing, recycling, and warehousing facilities as well. John holds a Bachelor's degree in English from The College of NJ.

Follow John on Facebook, Twitter and Google+

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OSHA Provides a Deadline for Fall Protection Training

OSHA Provides a Deadline for Fall Protection Training

It seems like we’ve been talking about the “upcoming” and “recently passed” Walking/Working Surfaces rule for a long time and many people may remember that contained within the rule were some delayed effective dates.  This means that while most of the regulation was effective this past January, employers were given some extra time to come into compliance with certain aspects of the law.  Unfortunately, for those not paying close attention, these delayed dates have started rolling around, and they may have caught some employers completely off guard.  In fact, one key date just passed and, if you were not aware, you could find yourself in non-compliance.

As of May 17, OSHA requires that all workers are trained in both fall hazards and any equipment covered by the final rule.  Understand that this is not a new training requirement. Workers in fall protection situations should already be trained, however, you need to ensure that they have now received training on any new aspects of the regulation that apply to them.  This training includes what hazards they are exposed to and how you are protecting them, as well as how to utilize equipment such as Personal Fall Arrest Systems (PFAS – Harness, lanyard, anchor point).  If you’ve already done this, congratulations!  Keep on doing what you’re doing!

If you were putting off training employees, you no longer have that option.  Now that we’re past the deadline, here’s what OSHA requires you to do ASAP, to come into compliance:

1) Each employee must be trained by a qualified person, which, according to OSHA, is someone who “by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project.” It is important you ensure that the person delivering training meets this definition, not only so that your employees are receiving all the necessary information to keep them safe, but to ensure your compliance with the requirement should your training come under scrutiny.

2) Each employee must be trained on what fall hazards they are exposed to, how to recognize fall hazards, and what procedures they need to follow in order to keep themselves safe.

3) Employees must be trained on how to properly install, inspect, operate, maintain and disassemble fall protection systems that they use.

4) Each employee must be trained in the correct use of fall protection systems, including proper hook-up, anchoring, tie-off techniques, as well as methods of inspection and storage as specified by the manufacturer.

In addition, OSHA offers further specifics to which this deadline applies:

1) Employees must be trained in the proper care, inspection, storage and use of equipment.

2) Employees that use dockboards must be trained to properly place and secure it.

3) Employees who use rope descent systems must be trained in proper rigging and equipment use.

4) Employees who use a designated area must be trained in their proper setup.

OSHA also notes that retraining is necessary in certain situations, such as:

  • When an employee demonstrates that they don’t have the knowledge or skill they should have in regards to fall protection,
  • When workplace changes make the old training obsolete,
  • Or when new fall protection systems or equipment are being used.

Finally, OSHA requires that training must be understandable.  While this may sound like common sense, it is not unheard of for employers to have employees sit through a training session in a completely unfamiliar language just to make sure they receive documentation of training.  However, this caveat doesn’t just apply to which language a person understands.  If a person is illiterate, for example, this requirement could mean that they must be presented the information – and tested - orally.  As an employer, you will have the burden of proving that your employees understood the training, should OSHA audit your company.  This is often accomplished through some type of exam, whether written, oral, or practical.  Whichever way you choose, be prepared because OSHA will ask, “How did you know they understood it?”

If you are one of the companies that has not trained your people, get on it immediately.  A great number of incidents, injuries, and fatalities can be traced back to the fact that people were not properly trained for the work they do and the safe ways in which to perform that work.  Train your people now, before something happens.  Keep them safe by arming them with knowledge.

To find a fall protection training course near you, we recommend checking the following online calendars:

Finally, as a reminder, below are the remaining upcoming deadlines for the Walking/Working Surfaces rule:

  • *November 20, 2017 – Inspecting and certifying permanent anchorages for rope descent systems.
  • *November 19, 2018 – Installing personal fall arrest or ladder safety systems on new fixed ladders greater than 24’ in length and on replacement ladders, including on outdoor advertising structures.
  • *November 19, 2018 – Ensuring that all fixed ladders over 24’ including outdoor advertising structures, are equipped with a cage, well, personal fall arrest system, or ladder safety system.
  • *November 18, 2036 - Replacing all cages and wells used as fall protection with ladder safety devices or personal fall arrest systems.

Related Entries

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

.(JavaScript must be enabled to view this email address)

http://www.signaturesafety.net

John Braun has been in the EHS field for more than 14 years. He achieved his CHST in 2005 and his CSP in 2010. Though he focuses on construction, his background includes manufacturing, recycling, and warehousing facilities as well. John holds a Bachelor's degree in English from The College of NJ.

Follow John on Facebook, Twitter and Google+

comments powered by Disqus