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 such as Jersey barriers or a stand-alone railing. 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 a personal fall arrest system on hand purely 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.
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. They must also 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.
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. Keep both of your feet on the platform. Both of them.
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.