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4 Things You Need To Know About the New OSHA Regulations

The end of last year marked a significant update to the OSHA Fall Protection Regulations. With this new update, OSHA produced a 513 page document as a final rule on Working-Walking Surfaces and Personal Protective Equipment. Knowing that reading this regulation would be a feat of its own, we did the work for you. Download this ebook to learn more about the 4 core changes that you will want to know.

What's Inside:

  • New terms introduced by OSHA
  • Learn where on your roof you need fall protection
  • Understand the new requirements for ladder safety
  • New fall protection training requirements from OSHA

How to Run an Effective Toolbox Talk

How to Run an Effective Toolbox Talk

Toolbox talks, tailgate meetings, pre-work safety meetings – whatever you want to call them, these brief safety sessions can be a valuable opportunity. They help focus your workforce on safety, prior to the beginning of their work shift, and they are an opportunity for you to ensure that all of your employees are fit for duty.

Or, they can be dreadfully boring, disorganized, snooze-fests.

Meetings for the sake of meetings are inefficient and often serve no purpose other than giving the workforce something to complain about.  Your toolbox talks need to be run properly to ensure that your workers are not just paying attention, but benefitting from the time spent.  They need to be run in a way that will remind your employees what they should be concentrating on or to impart brand new knowledge on them.  If your workforce is bored, distracted, or otherwise disengaged, you will achieve nothing other than keeping your people from working. 

So, how do you do it right?

Don't Read to Them

If you think grabbing the safety write-up that gets emailed to you weekly and reading it to the workforce is going to get the job done, think again.  Nothing is easier to tune out than somebody reading words off a page.  Unless you’re planning on doing impressions and cartoon voices, your employees will see this as nap time.  Doing it this way makes it harder for you to put any feeling into what you’re saying, difficult to make eye contact with the people you are addressing, and it puts the idea in the mind of your audience that maybe you don’t know anything about the material you’re trying to present to them.  Read those weekly mailings (if that’s what you’re using) ahead of time.  Familiarize yourself with the topic.  I know we’ve all got a love/hate relationship with the internet, but here’s an opportunity to take advantage of the “love” part of it.  Do some research.  Find news stories relevant to what you’re discussing and other supplemental information. Show your workers how your topic applies in the real world. If you need inspiration or ideas on what to discuss with your team, subscribe to the Simplified Safety newsletter. Just don’t read right off the page!

Engage your Audience

So, once you’re armed with all the information the internet can provide (from reputable sources, please!), what’s next? 

Have a conversation. 

Talk with your employees about the chosen safety topic, not at them.  Think back to your school days.  Which classes did you find more entertaining: the ones where your teachers engaged you and got you to participate, or the ones where the teacher stood in the front of the class and lectured at you…on and on and on?  I’m guessing the former.  And, make no mistake, entertainment is important.  No, you don’t have to tell jokes and juggle (though juggling would be cool…just not knives…or fire…these are safety meetings for Pete’s sake!), but you do need to give your audience a reason to want to pay attention.  Don’t speak in a monotone voice unless you want to lull your employees off to La-La-Land.  DO tell related stories from personal experience, ask questions of your audience, and have them tell their own personal anecdotes (but don’t let this run wildly off topic or take an inordinate amount of time - you still need to control the meeting).  Do all this and watch their attention grow.  The more they pay attention, the more they’ll learn.

Be Relevant

Does most of your work involve digging excavations?  Then don’t do a toolbox talk on steel erection.  Do you do a vast majority of your work at heights?  Then why are you discussing forklift safety?  If your topic doesn’t apply to the work you do, then why teach it?  Now, there are topics that don’t apply as much as other topics do or as frequently, but still apply.  You don’t need to eliminate those, though they may only serve more as backup topics once your main topics are exhausted. However, if the topic has nothing to do with what your people do then toss it.  Find a replacement.  Try and have a backlog of topics. The Simplified Safety blog archive is a great place to find inspiration.

There's a Time and Place

If my parents told me this once they told me a thousand times, “There’s a time and a place for everything.”  I’m sure many of you are nodding your heads in agreement.   And, most of the time it was followed by, “And this is neither the time nor the place!”  Well, luckily my judgment has improved over the years.  And you know what?  Mom and Dad were on to something.  When and where you hold your toolbox talks play a big part in how successful or unsuccessful they will be.  Holding a toolbox talk in the work area is a good idea because it may be easier to demonstrate something you’re teaching or it may just mean people are already focused on their work.  It can also be a terrible idea if the work place is loud, uncomfortable, or offers other distractions.  Immediately following lunch can be a great time to hold a meeting because you can find everybody in one place, but it could also be a terrible idea as everyone struggles to fight off their food-comas.  Make sure that the time and place you choose to hold your meeting is conducive to learning because that’s the ultimate goal.

Toolbox talks don’t have to be tricky.  Sure you might be a Pinterest-level demonstrator who’s got all kinds of fancy, outside the box ideas and visual aids, but you can hold a great toolbox talk without all that.  Just remember though, while it can be simple to have a great toolbox talk, it’s also fairly easy to turn a topic that had potential into a poor use of company time.  As the Boy Scouts say, “Be Prepared.”  Know your material, know your audience, know your environment, and make sure everything you plan works within those parameters.  If not, change it up.  Better to delay a toolbox talk and get it right, than to have your workers walk away from your meeting with nothing to show for it. 

What Does the New Recordkeeping Rule Mean to Me?

What Does the New Recordkeeping Rule Mean to Me?

By now, you may have heard: OSHA issued a new final rule in regards to electronic recordkeeping.  Great!  What the heck does that mean? 

Well, funny you should ask, because I’ve got answers!

Just the Facts

Let’s start with the basics.  The final rule was issued by OSHA on May 12, 2016 and will require certain employers to electronically submit their injury and illness data (300, 300a, and 301  forms) to the Agency annually (before these were only collected through an inspection, a survey, or when things like fatalities and hospitalizations required employers to notify OSHA).
Those required will be:

  • Companies with 250* or more employees who are otherwise already required to keep these records.
  • Companies with 20 to 249* employees in “certain industries”.  This is primarily industries OSHA deems highly hazardous such as utilities, construction, manufacturing, retail, transportation, and health care.
  • Other companies upon OSHA request.

*When determining your number of employees, you must include part time, seasonal, and temporary workers.

These requirements will phase-in beginning in July 2017 and will be fully implemented by March 2019.

In addition, the new rule includes new protections for employees against retaliation and will require OSHA to scrutinize incentive programs and post-accident drug/alcohol screening to ensure they don’t discourage reporting of illness and injuries.

In terms of anti-retaliation measures, employers must notify employees that they have a right to report work-related injuries and illnesses, that they will not be discharge or discriminate against for reporting them, and the employer is prohibited by law from discharging or discriminating against somebody for reporting a work-related illness or injury (effective August 16, 2016.  While OSHA has had this in their purview for some time, the new rule allows OSHA to bring action even without an employee complaint of retaliation, which was previously required in order to begin an investigation).

As for discouraging employees to report, incentive programs must not punish an employee in any way for reporting an injury/illness.  For example, if a monthly safety bonus is given, and an employee is not eligible if they have an OSHA recordable incident, OSHA may consider this retaliatory and/or a means to discourage an employee from reporting their illness or injury.  In addition, blanket post-incident drug/alcohol testing will not be possible.  While OSHA will still allow “for cause” testing and testing mandated by a government agency (i.e. – the DOT), the company is going to have to show that requiring drug/alcohol testing in any other instance was reasonable.  For instance, if somebody gets a splinter that gets infected, they may not consider testing reasonable while if an employee swerved and crashed a company vehicle, they may.

What are the Consequences?

One major concern is that the reason many companies instituted blanket post-incident drug/alcohol testing was to eliminate any possibility of a false discrimination claim.  The prohibition of this type of policy seems to open that back up.  In addition, the National Law Review cited four consequences of this rule in a recent article they published.  To paraphrase:

1 – Information will be used to identify new bad actors.  Those reporting higher than normal injury and illness rates can expect their chances of inspection to dramatically increase.

2 – Electronic submission opens the door for data breaches and hackers.  Personal information of injured employees could be vulnerable prior to the agency scrubbing that information from the files.

3 – This information will be made public, so companies could be negatively affected by this before they have a chance to defend themselves.

4 – The information will be made public, so may be used as a tool for unions to find companies whose workforce may be more interested in unionization.

5 – It’s a new weapon OSHA didn’t have before – the ability to cite any company reporting policy/procedure for being “unreasonable”.

This is now the law and, while it will take some time to fully implement, you can begin notifying and training your employees now.  In addition, it’s probably time to review your incentive programs and drug/alcohol testing policies.  Don’t let this catch you off guard.  You know it’s coming, so make sure you don’t leave your company vulnerable to non-compliance.

Click here for more OSHA information.

OSHA National Safety Stand-Down to Prevent Falls in Construction

National Safety Stand Down

With the coming of warmer temperatures in most of the country comes an increase in construction activity.  Unfortunately, if history teaches us anything, with increased construction activity comes increased worker injuries and fatalities.  Falls continue to top the list of fatalities in construction year after year, so OSHA has once again decided to roll out its “National Safety Stand-Down to Prevent Falls in Construction.”

For the past few years, OSHA has led this effort to get employers to talk to their workers about the hazards of falls and the administration’s desire to reach increasingly larger numbers of workers has been paying off.  The Stand-Down reached 2.5 million workers last year for the first time and now OSHA hopes to double that number.  If successful, they will be reaching half the construction workforce in the United States.  This year the National Safety Stand-Down runs from May 2nd to May 6th.

The event is voluntary and is whatever you make of it.  This is your opportunity as an employer to take time out from your busy
schedule and talk to your workers about falls.  Help them understand, through a tool-box talk, equipment inspections, a training class, or some other safety-related activity that falls kill – all too often. Make them understand how severe the consequences of one mistake can be, find actual incidents to relate to them to make it personal, let them know the cost – in life ­– that fall protection violations can incur.  In other words, make them understand – pun intended – the gravity of the situation.

We have a ton of safety resources and articles on this site to help your employees understand fall hazards.  Take advantage of them, you don’t need to reinvent the wheel.  Signup on the email list, and we’ll make sure you get them in your inbox on a weekly basis.

Don’t assume that your workforce knows and understands this just because you believe it to be common sense.  The idea of common sense is a fallacy.  Common sense is learned information, not something we’re born with, so if somebody has been learning something incorrectly his or her whole life then “common sense” could easily get them killed.  Taking the time to have this conversation will be well worth not having to find a body on the ground, to not have to look into the eyes of a grieving spouse and children, to not have to counsel your workforce on how to handle the traumatic death of a friend and co-worker.  Taking the time to have this conversation is well worth the value of saving somebody’s life.

There was a time where death was an accepted side-effect of construction.  That time is long gone.  Many companies now understand that their people are their greatest resource, but I say forget that.  You should be operating safely and training your workforce not because your people are a good resource for your company, but because your people are just that: people.  Human life is not an expendable commodity.  If you are in a position to protect it, then you should make every effort to do so.  If you’re not already making those efforts, then don’t wait for the Stand-Down.  You can start saving lives today. 

To find ways to participate, see what’s been done in the past, or share your story, go to https://www.osha.gov/StopFallsStandDown/.  Once complete, you will be able to download a certificate of participation.  And don’t stop at your own employees.  Spread the word on Social Media using the hashtag #StandDown4Safety.  Your voice could convince another employer to participate.  Your voice could save lives you never thought you could affect.

Have You Seen These?  We Have…and They’re Dangerous

Dangers of Accessing

We’ve said it before on this blog, and I’ll reiterate it now: the illusion of safety is often much more dangerous than no safety at all.  Of course, we’re not advocating for no safety, but when somebody is given a false sense of security, they’re bound to take risks they wouldn’t otherwise take.  However, if they believed there were no safety precautions at all in a situation, they would probably be much more careful about what they were doing (probably).

One good example of where we often tend to see a false sense of security is at the top of fixed ladders.  How often have you seen a good, solid safety system on a building’s roof?  Most often, there’s nothing at all except maybe a couple of handholds.  

Here are some of the biggest offenders we’ve seen:

Plastic Chain

Have You Seen These? We have...and they're dangerous

Remember the old adage: a chain is only as strong as its weakest link.  Obviously, when dealing with a plastic chain, that weak link is going to be much weaker than when you’re dealing with a steel chain.  Plastic may not only fail to hold you when it’s new, but over time it could be affected by weather, UV light from the sun, and physical abuse.  Even on steel chains, links stretch, twist, or otherwise lose integrity.  It’s no different with plastic, it just happens faster.  Remember, OSHA allows for chains at the top of ladderways in lieu of railings, but they must offer the same protection and be able to withstand 200 lbs. of force.  Do your plastic chains do that?

Chain Attached with an S-Hook

Have You Seen These? We have...and they're dangerous

There’s a reason why safety hooks exist: because somewhere along the line, S-Hooks and other less-safe products failed to do the intended job.  Not only is it easy for an S-Hook to get knocked free of its eye-bolt, it’s also easy for it to stretch and lose its shape.  Soon, your S-Hook is looking like a fancy cursive J-Hook on its way to a simple lower-case L hook.  But, let’s say it holds shape.  The very fact that it’s open ended on both ends, gives double the opportunity for a failure.  Now, let’s just say it holds its shape AND you never allow enough slack in the chain for it to come off, you’ve still got to remove the chain to pass through.  At this point, there is slack and the hook can come off falling to the ground.  How is that a problem?  Well, now, with no protection in place whatsoever, somebody is bending over at the top of the ladder to get the hook back.  Overall, S-Hooks are a bad option.

Unhooked Chain

Have You Seen These? We have...and they're dangerous

The very nature of a chain means that the worker has to unhook and re-hook the chain.  Often, that second part is left undone, thereby completely negating any protection you’d intended to have in the first place.  A protective system should be like a safety power button on a tool – it fails safe.  The reason you have to keep the trigger depressed on a drill is so that if you let go, the drill stops.  This is because you may not always be letting go intentionally.  If you had a heart attack, say, the last thing you need is to drop a running drill onto yourself.  Gates should operate the same way.  They fail safe.  You walk through and it closes behind you.  It opens outward so that nobody can back into or stumble their way into the ladderway.  A chain can’t do that.   The human factor now comes into play and whether that factor is error or laziness, it can create a very dangerous situation.

No Offsets

Have You Seen These? We have...and they're dangerous

We’re not saying gates are the best solution, we’re saying properly installed gates are the best solution.  And, unfortunately, gates are not always properly installed.  We’ve seen gates installed right at the top of a ladder so that in order to access the roof or platform you are climbing to, you need to manipulate the gate while holding onto the ladder.  This should never be the case.  There should always be an offset at the top of the ladder.  This way the climber can access the roof safely, then open the gate once they are away from the ladder.  Some installations will have an offset without a gate.  While this isn’t the perfect solution, it is still better than plastic chains, bad hooks, or no protection at all. 

Your facility needs to be safe, but offering a false sense of security is only inviting disaster.  Review your safety controls.  Were they put in place after careful thought and planning or was something just thrown up there to look like worker safety had been considered?  Was the money spent to buy the proper protection or did you go with something cheap that might not meet the necessary requirements?  Remember, your workers will take risks they otherwise wouldn’t have taken if they believe they are protected.  Don’t allow an employee to lose their life because somebody was unwilling to spend the extra money or because appearance was more important than effectiveness.  Gates require no training.  They are a simple and effective tool to provide your employees the actual protection they need – and deserve.

Beginner’s Guide: Work Platforms

Beginner's Guide: Work Platforms

There are many types of work platforms: aerial work platforms (such as scissor lifts), scaffolding, or prefabricated, permanently-installed platforms. Which one you choose to use depends on the type of work you plan on doing and the duration of that work.  A quick paint job, for instance might be done on scaffolding, while replacing light bulbs throughout a warehouse might be done on a scissor lift.  Jobs that require indefinite access to elevated work areas however, are probably better served by a permanently installed, customizable work platform (to be clear, some platforms that are “permanently installed” can still be adjusted to different heights or moved a little bit, while others will be unchangeable once in place).  These platforms provide safe, easy access as well as ergonomic positioning for the task at hand.  So, what do you need to know about them?

What is Required?

Information on work platforms is going to be found in multiple locations within 29 CFR 1910 Subpart D (Walking and Working Platforms), but there are a few general requirements that hold true:

  1. Because we are discussing General Industry situations, rails will be required at 4 feet.  This is the height at which fall protection is required in General Industry (Most likely permanent platforms would not be used in a dynamic construction situation. Instead, scaffolding or lifts would be, and each has their own set of fall protection requirements). 
  2. The rail must be 42” high, a mid-rail is needed as well as a 4” toe-board.
  3. If it takes four or more steps to access the platform, the steps must have rails as well.
  4. Access openings must be offset so that somebody cannot step directly into them or must be protected by gates.

While there are many more regulations that apply to a platform’s design and use, these four basics should at least get you going.

Different Platforms, Different Uses

Platforms are often designed, or customized, with a purpose in mind.  For instance, you may have installed a platform so that a machine operator could work with the controls at a proper height, rather than having to reach overhead.  You may also need to access higher sections of this same machine for maintenance purposes.  Just because you have a platform in place though, doesn’t mean that it can serve every purpose.  While the platform may be at a perfect height for operating the equipment, using it to access higher areas could cause you to have to climb rails or perform other unsafe actions.  Make sure that the platform you are using is designed for the purpose you are using it.

Be Aware of the Surface on Which You Are Working

If your work platform is a fixed, non-adjustable platform, then the only surface consideration you need to be concerned with is that it is clean, free of debris or spills, and is not broken or compromised in any way.  But, if your platform can be moved, you also need to consider the surface below your work platform.  Some platforms can be adjusted asymmetrically in order to account for uneven surfaces.  Others are provided with large wheels so that they can be rolled over grating or other holes in the floor.  Without the safeguards mentioned, uneven surfaces or floor openings can be disastrous.  Make sure your platform is equipped with whatever is necessary to keep it level and stable.


If you’re in the design stage of setting up a work platform, you’ve got a lot of opportunity to make the platform as versatile as possible.  Look to the future now, so that you can be prepared for possible changes.  Will the task always be done this way or in this location?  Will maintenance need to be performed that could require additional access?  Is the platform strong enough, not just for what I intend to place on it now, but what I will need to place on it in the future?  Being overly focused on one application could prove costly if you need to make modifications down the road. So take the time to consider any and all future applications.  Once you have, you can build the versatility right into your design.

Mobile scaffolding and aerial lifts exist because you may need a quick, short-term solution to a problem, especially in the dynamic world of construction. However, when you are designing a long-term work platform, don’t rush it.  Take the time to understand what is required, to design it for the present and the future, to train your employees in its use, and to fully understand not only its uses, but its limitations.  Done right, work platforms can save you quite a bit of money and countless injuries.


Hidden Hazards in Your Warehouse

Hidden Hazards in your Warehouse

I’ve been in many warehouses.  Many, many warehouses.  The difference in safety culture from one to the next is as varied as the products they store.  Some are in pristine, new buildings with clear lines painted on the floor, have only safe, certified forklift operators driving the machines, and have meticulously stacked products on their shelves.

Others…well, not so much.

Then there are those that fall in-between.  These are the ones that have some sort of safety program that kind of addresses their hazards.  In these situations, the obvious problems are the ones that are most likely addressed: operator training, safely stacking product, wheel-chocking of trucks, and things like that.  However, things that take a little more depth of knowledge might be missed.  What are some hidden hazards that might be looming over one of these warehouses, waiting to strike?

Fall Hazards

Because the vast majority of work in a warehouse takes place at ground level, fall protection sometimes fails to be a consideration, yet there is a potential for falls in many situations.  In many warehouses, forklifts place the product up high and retrieve it, but in some, pallets and cases need to be broken to fill orders.  Some of these are at heights and it is simpler to use a lift to put a person up there than it is to bring the pallet down, select what you need, and return the product to its original place.  In this situation, fall protection would be needed.  The employee being raised would not only need to be on something designed to lift a person (in other words, no standing on a pile of coffee bean sacks on a pallet on the forks of a forklift – I’m not saying this did actually happen…), but may also be required to be tied off, depending on the type of lift being used.

But your fall protection concerns don’t end there.  Do you have mezzanines?  Elevated walkways?  I’m sure you’ve already addressed the need for rails – but if you haven’t, now is the time.  The part that is more likely to get missed, though, is your loading area.  If you have a break in the rails with no way to close it up when a loaded forklift is not present, then you have a violation.  Mezzanine and pallet gates solve this problem.  Self-closing gates ensure that nobody leaves the gate open, exposing your employees to a fall you thought you’d protected against.

The same issue may exist at the top of fixed ladders.  Do you have any locations where there is a break in the railing to access the ladder?  Depending on the layout, you may want to – or need to – consider a self-closing safety gate as well.

Struck By Hazards

Hopefully, your forklift operators have been properly trained, so that they know the best practices to help avoid collisions with other forklifts or pedestrians.  Staying to the center of aisles, stopping at intersections, using provided mirrors, keeping a safe distance from other forklifts, travelling the proper speed, and ensuring any spills are immediately cleaned up definitely help prevent injury from direct collision, but there is always room for human error.  Certain safeguards can help further reduce the chance for human error, as well as injury from indirect contact (for example, a forklift bumps into a rack knocking product off onto a pedestrian).

Strategically placed bollards can help protect product, utilities, and personnel from your forklift traffic.  This forces your equipment to give a greater safety cushion when travelling.  You can use impact barriers or safety rails to line sections of your pedestrian walkways as well, eliminating any chance that somebody passing through your warehouse wanders into traffic or on the opposite side of a rack that is being loaded.

Hazardous Materials

Just because you don’t store product known to be hazardous materials, doesn’t mean you don’t have hazardous materials.  Even small amounts of flammable liquids need to be properly stored so they don’t present a hazard.  Your maintenance team could have materials that fall into this category.  Ensure that you have the proper flammable liquid storage cabinets as is required by OSHA for any products you are storing.  And, if you haven’t been diligent about the type of materials being stored in your warehouse, now’s the time to check.  Even materials just passing through need to be properly stored in a separate barricaded part of the warehouse to prevent accidental contact.  Signage needs to be posted as required to inform employees of the fact that this is indeed hazardous material and to prevent smoking near flammables.  Employees handling this material need to be properly trained and SDSs need to be available.  Finally, depending on the type and amount of material, can you legally store such material in your building and is your fire suppression system sufficient to fight a fire involving what you have on site? 

There are many regulations that apply to the handling, transfer and storage of hazardous materials.  Warehouses that deal specifically with this are usually well-equipped.  It’s those that only handle some here and there that often find themselves lacking the resources to properly handle compliance.  If you have hazardous materials, seek out the advice of somebody familiar with the regulations to ensure you are not opening yourself up to fines and your employees up to illness and injury.

In the end, full hazard assessments are the key to ensuring that you are properly prepared for any situation.  If you do not have somebody capable of doing this thoroughly, seek out the expertise of somebody who does.  Abating some hazards is never a satisfactory solution.  Don’t wait until you are experiencing employee injuries or a warehouse fire to perform the due diligence you should already be performing.  

Construction Site Fall Protection Guide

Construction Site Fall Protection Guide

For many years now, falls have been the leading cause of death on construction sites.  From small, residential projects to large commercial structures, people continue to add to the fatal fall statistic – regardless of the focus placed on this epidemic.  Sometimes this is the result of a well-trained and properly equipped worker not doing what they were supposed to do, but more often than not, it’s a result of a lack of planning.  For seasoned construction professionals, fall hazards should come as no surprise, but, just in case they do, let’s review where you may encounter them – from the ground up.

Excavations, Utilities and Foundations

Some fall hazards get missed early on simply because nobody has considered that anybody could be “working at heights” while the structure hasn’t yet risen from the ground.   Unfortunately, digging a big hole in the earth starts to turn “ground level” into “elevated”.  While there is no specific requirement to provide fall protection around an excavation unless the excavation is not readily visible, you still need to provide a safe working environment.  If you have a heavy foot-traffic area, consider barricades whether it be Jersey barriers, stand-alone railing, or another means.  If you’ve got vehicular traffic, you need to prevent those vehicles from accidentally rolling into your excavation (as you must also do with materials that could roll in such as pipe).  Consider some type of curb-stop or berm to keep this from happening.  And, if your excavation will be open overnight and there is any chance somebody could wander into it, barricade it thoroughly or cover it in accordance with the OSHA regulations (secured against movement, able to support 2x the maximum possible load, and clearly marked “Hole” or “Cover”).

While your excavations are being dug, your pipe and other materials usually begin to arrive on site.  Be aware of fall protection situations that arise during loading and unloading of this material.  Does somebody have to climb up on top of a flatbed and then up on top of pipe to rig it up so it can be picked off the truck?  If so, what are you doing to protect them?  Some of these activities are exempt from the 6’ fall protection rule, but you need to be aware which of them are and which aren’t, as well as if you’re willing to take the chance in allowing that to occur.  If you’re not, be prepared to attempt some creative solutions to the problem as an overhead anchor point is often not available. 

Heavy equipment can also be an issue.  While you’re not expected to have to have a personal fall arrest system on just to climb into some of these large machines, you do want to make sure that all of the safety components of the machine itself are in place.  Ensure that your operators are inspecting the machines, including all the necessary handrails, grab bars, and stair treads to safely access and exit the machine.  Also, where guardrails exist on equipment to protect mechanics and operators during maintenance and repairs, inspect those as well.

At some point, concrete pouring will begin.  Sometimes this is a blessing and eliminates the previously mentioned excavation fall issues.  Sometimes, it creates more.  Depending on the concrete pad being poured, you could have new fall hazards.  Most buildings aren’t going to have a six-foot thick slab, but some structures – such as certain power plant structures could.  Or, if they’re not six feet above grade, the combination of the slab and the surrounding excavation could give you a greater-than-6’ exposure.  Be prepared for this before it becomes an issue and protect the perimeter.

Steel Erection

One of the most confusing fall protection requirements belongs to Subpart R – Steel Erection.  In my experience, even the steel erectors themselves don’t fully understand what is required of them – or they use the confusion to their advantage and claim they are exempt from fall protection up to 30’.  This is only partially true.

Let’s attempt to simplify.  First, all personnel involved in steel erection are exempt from needing any fall protection up to fifteen feet if they are on a walking/working surface.  Not thirty.  Note the “walking/working surface” part.  This does not mean that workers in aerial lifts, for example, are exempt.  For that, the aerial lift section of Subpart L still applies (lifts are discussed later in this article).  This also does not mean that all people working on the construction site on the day that steel erection takes place are exempt (trust me, they will try this).  It means those involved in steel erection.

Great, now that that’s clear, let’s get to the confusing part.  At 15 feet, all those people who are not deckers or connectors must be protected.  Yes, you, the guy bolting up.  Yes, you, the guy welding.  Anybody that is not actively receiving steel or is not a decker (we’ll talk about deckers in a moment) must be tied off.  For connectors (the one or two guys actively receiving steel), they must be provided all aspects of a personal fall arrest system but they may choose not to tie off.  Don’t ask me the purpose of this, I didn’t write the rule, but they must have the ability to tie off if they want to, between 15 and 30 feet above the nearest level or 2 stories, whichever comes first.  That doesn’t mean that they wear a harness and all is good.  That means that they must wear a harness, have a lanyard, and have a proper anchor point available to them that they can tie off to at any point.  If you have to go get a beam clamp when you decide to tie off, you are not doing it properly.  It must all be there with you, ready to use.

Deckers are allowed up to 30 feet or 2 stories as well.  During this time they must establish a controlled decking zone (CDZ).  The rules for this are many, but they require a marking of the area, only certain personnel being allowed in there, maximum dimensions and other requirements. 

The final aspect of steel erection is that the steel erector is responsible for perimeter protection of the building, which is often accomplished with wire rope guard rails.  They are the ones responsible to install and maintain this protection for the entire time they are on site.  When they are finished on site, they must get written notification that somebody specific will be taking over maintenance of the rails.  If nobody is willing to take this on, the steel erector must REMOVE the wire rope rails from site.  This eliminates the false sense of security workers would get from seeing wire rope rails in place that may be sagging or loose from lack of maintenance. 

The Structure

If the steel erector is on site, or has gotten somebody to take over perimeter protection, than that’s one less concern for you, but as the building goes up, it is important to look for all possible fall exposures greater than 6 feet.  This could be the perimeter of the building, it could be window openings, balconies, elevator shafts or pits, and other floor openings.  Stairwells are also a concern as some will be installed without the proper rails.  Stairs should not be used until proper rails are in place and if they are the tray style stairs that get concrete poured into them, they should not be used unless those trays are temporarily filled with planks or permanently filled with concrete. 

Ladders also become more of a concern at this point.  First, proper ladder usage could prevent many falls that occur.  Ladders, whether A-frame or extension, need to be set-up and used in the proper manner.  This includes extending 4 feet above the level being climbed to, having a proper 4:1 ratio for extension ladders, securing the ladder near the top, maintaining three points of contact as you climb/descend, and keeping your center of gravity between the side rails.  This also includes setting up the ladder on a level, sturdy surface, keeping it clear of obstruction, and not standing on the top steps of an A-frame or straddling it (oh, and yes, it does need to be opened all the way and locked into place.

Scaffolds will begin to appear.  Remember, scaffold users have up to ten feet before fall protection is required.  This pretty much allows them to work on top of one bay of scaffolding without worrying about rails or personal fall arrest systems.  Even so, scaffold falls still occur.  Fully planking any level on which you are working, having all of the proper pins and braces in place, ensuring base plates are in place – and mud sills where necessary, and ensuring your scaffold is plum and level will help eliminate these falls.  Once fall protection is required, remember that all open edges, including the sides, must be guarded if you’re using rails.  Also, the cross braces can only be used as EITHER the top or mid rail, not both.  Measure the height at which the cross braces come together.  If this is closer to 42” then it is your top rail and you must install a mid-rail.  If this is closer to 21” then it is your mid-rail and you must install a top rail.  Finally, ensure proper access to your scaffold.  Properly secured ladders that extend high enough work as well as stair towers or access through the structure.  Some scaffolds are designed for the sides to be used as ladders, but the rungs must be evenly spaced, of equal width (no tapering), and continuous to the level you are climbing.  In no situation should anybody be climbing the cross braces.

Speaking of scaffolds, scissor lifts are covered by the scaffold regulation, so you don’t need to be tied-off (unless your site has a requirement to do so) as long as you are completely surrounded by rails.  This includes closing the gate or hooking the chain.  Fail to do so and you are out of compliance.  Aerial lifts get their own section in the scaffold regulation.  The long and short of it?  Tie-off.  From the moment you are in the basket until the moment you exit the basket, tie-off using the provided anchor points.  Do not wrap your lanyard around a rail or tie off to anything that is not designed to be an anchor.  Check your operator’s manual if you can’t find your anchors.  In fact, check your operator’s manual anyway…just because.

And, with all lifts, keep your feet on the surface of the work platform.  Do not climb the rails.  Do not use a step ladder.  Do not stand on your partner’s back (oh, come on, you don’t think they’d do this?) – keep your feet on the platform.  Both of them.

The Roof

We’re at the top.  The roof is being installed.  Roofing fall protection rules can be as confusing, if not more confusing, than steel erection rules.  Warning line and monitor systems may ONLY be used for roofers doing roofing work.  (See this article: When is a Warning Line Sufficient Fall Protection?) So, if you are the roofing contractor, be prepared to let the HVAC guy know that your flags do not make him compliant and your monitor is not responsible for his workers.  Remember that a roof monitor must be able to communicate with and see everyone he/she is responsible for and must have no responsibilities that take away from his/her duties.

But, it’s 2015.  Technology has improved vastly.  Standalone rails exist.  Parapet clamp rails exist.  Roof fall protection carts exist.  Using a warning line and monitor should be a last resort because it doesn’t actually stop anybody from falling or slow/stop a fall once it has occurred.  Invest in some equipment that will actually keep your employees safe.  They will be better off for it and, in the long run, so will your company.


Keep in mind that what is referenced here is the bare minimum required by OSHA.  I do not necessarily support these rules.  For example, I feel if a steel erector has to have all the components of a fall protection system available to him or her, then there’s no reason they shouldn’t be tied off.  On my jobs, there is no choice.  There is no additional cost to the erector for this because all of the equipment must be there anyway.  Some places will require 100% tie-off at 6 feet.  Make sure you know what your site requirements are because they may be above and beyond what you’ve read here.

There are a LOT of fall protection considerations in construction, but all the preparation in the world will mean nothing if your employees aren’t properly trained in fall protection.  From general knowledge of what makes something a fall hazard to how to properly use their fall protection equipment, your workers must be armed with knowledge.  Then they must be armed with the proper tools.  Then you must enforce your policies and the OSHA requirements.  Then, and only then, will the statistic begin to drop.  Then, and only then, will we begin to lose fewer people to falls.



What’s the Difference Between Class A and Class B Self-Retracting Lifelines?

What's the Difference Between Class A and Class B Self-Retracing Lifelines?

Way back in August of 2012, a new ANSI standard was released that addressed the use of retractable lifelines for personal fall arrest and in rescue situations.  These self-retracting lifelines had been in use for quite some time and, as they had gotten smaller, lighter, and more inexpensive, they had also become more commonly used.  ANSI’s standard – ANSI Z359.14-2012 – provided previously undeveloped guidance on performance, design, testing, markings, instructions, inspections, maintenance, storage, and remove from service of retractable lifelines.  In so doing, ANSI also created two classes of retractables, which they called A and B.

Now, for the uninitiated, ANSI – the American National Standards Institute – does not write law.  That is OSHA’s job.  What ANSI does do, is write guidance standards for various products.  From there, manufacturers tend to voluntarily adopt the standards for use in their testing (and, if a company has an incident as a result of their not meeting a published ANSI standard, OSHA will most likely want to know why they weren’t meeting the standard).  Many companies will voluntarily adopt ANSI standards as “best practices” and OSHA will, eventually, incorporate many ANSI standards into the regulations by reference.

So, as noted, one of the key provisions of the Z359.14 – 2012 was that self-retracting lifelines would be divided into two categories – A and B.  Which category a retractable fell into depended on the results of dynamic performance testing.


  • Maximum arrest distance not to exceed 24” (610mm).
  • Average arresting force not to exceed 1350 lbs (6kN) or maximum peak of 1800lbs (8kN).
  • After environmental conditioning (hot, cold, wet), average arresting force not to exceed 1575 lbs (7 kN) or a maximum peak of 1800 lbs (8kN).


  • Maximum arrest distance not to exceed 54” (1372 mm)
  • Average arresting force not to exceed 900 lbs (4kN) or a maximum peak of 1800 lbs (8 kN).
  • After environmental conditioning (hot, cold, wet), average arresting force not to exceed 1125 lbs (5 kN) or a maximum peak of 1800 lbs (8kN).

All in all, the two classes are divided by 2.5 feet of arresting distance and 450 lbs of arresting force. 

What does this mean to you, the user? 

The maximum arresting force probably won’t play into your planning very much.  When worn with a body harness, both of these classes meet the OSHA requirement of limiting the arresting force on the human body to 1800 lbs.  However, when planning your fall protection, the maximum arrest distance will figure into your fall distance calculation.  Knowing which class your retractable is will allow you to use the proper value (24” or 54”) in your calculation.  An extra two-and-a-half feet of stopping distance is significant.  Planning for a Class A retractable when you are actually using a Class B could easily mean the difference before a fall being arrested safely and serious injury to a worker.

To make it easy, ANSI suggests that these classes should be listed on all product labels (which should be able to endure the life of the component being marked).    While there’s much more to the Z359.14-2012 standard, don’t let the A and B classifications themselves confound you; they are important, but simple.  Now you know the difference.  And, as a certain real American hero/toy used to say, “Knowing is half the battle.”

Seeing the Big Picture: A Holistic Approach to Safety

Seeing the Big Picture: A Holistic Approach to Safety

Some say the concept of multi-tasking is an illusion – that our brains are not actually capable of doing two things at the same time.  Even the things we refer to as multi-tasking (i.e. – answering an email while writing a report and participating in a conference call) are actually short bursts of time focused on each of those tasks individually.  You are not typing your report AND typing your email at the same time, you are quickly and briefly going back and forth between the two.  As you do, your attention is diverted away from the conference call.  The human brain likes order; it likes focus; it likes one thing at a time.

Some safety professionals apply this to their work.  “We’re having a problem with compressed gas cylinders!  I’m going to go out and sweep the site for compressed gas cylinder violations!”  Meanwhile, because of their focus, they walk past improperly stored flammable liquids, three forklift drivers without licenses, a worker straddling an A-frame ladder, and a partridge in a pear tree (which, admittedly, is not a safety violation).  There is never just one problem happening.  Focusing on one at a time is like playing a game of Whack-a-Mole.  Sure you knocked one mole down, but while you did, two more popped up out of different holes.

This is why as safety professionals we need to broaden our vision.  We need to see sites as a whole and look at all of the hazards.  This could help save time and money when developing solutions because some solutions may solve multiple problems.  For instance, setting up a warning line and safety monitor may suffice when it comes to your roofers, but if that’s all you’ve done, what if you’ve got HVAC crews following them?  Now, you need a second solution because that warning line is not allowed for them.  However, had you provided rails or an anchor point for your roofers, your other workers would have been protected as well when it was their turn in the work area.

Another example might be having fall hazards and trip hazards as you access your work location near a roof edge.  You could worry about separate walkovers for the various obstacles and trip hazards, and rails or fall arrest systems to mitigate the fall hazard at the roof’s edge, or you could use a safety access platform that protects against both.  How?  Well, the platform can be customized to any shape or size you need so that one solution allows you to walk safely over all obstacles.  At the same time, this platform has attached rails that meet the OSHA requirements for fall protection in strength and height.  Safe access and fall protection solved in one fell swoop.  Added bonus?  This platform, depending on what your workers are doing, could allow for a more ergonomic working position by eliminating the need for stretching and reaching.

This type of thing happens constantly. No hazard exists on its own.  Spend a few minutes thinking about one and you are bound to notice a handful of other related hazards.  Looking at your roof or work surface with a customizable work access platform in mind may actually open your mind to solutions you had not previously considered.  Those things that seemed impossible or too costly before may be viewed in a whole different light.  In fact, it could save your company additional money by protecting the roof membrane from the wear and tear of constant foot traffic.

One aspect of looking at the bigger picture is to understand what is not only happening now, but also in the future in the same work location.  Many solutions are temporary – made to be stripped down and removed at the end of the project, but temporary access platforms can be permanent.  Chances are, if you’re working there now, you’ll have to work there again one day.  Your solution to multiple issues just solved many more by staying in place for all future work in that area.  One cost, one install, one solution.

Start broadening your vision.  Stop being in a rush to come up with the quickest solution because the quickest isn’t always the best.  Stop reacting to problems and start planning for them.  Look at all of the technology available today, such as customizable access platforms, and come up with the best solution possible.  Your workers will be safe and your employers will be happy.

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