OSHA’S NATIONAL FALL PREVENTION SAFETY STAND DOWN

OSHA’s National Fall Prevention Safety Stand Down takes place from May 4-15, 2015.  This year OSHA is hoping to reach 3 million workers in order to better educate and protect workers who are or may be exposed to falls.   Below is an excerpt from OSHA’s new “Fall Protection In Construction Book” OSHA 3146, published in 2015.  I have attached a link at the end of the blog for your easy reference.

Historically, falls are the leading cause of fatalities in construction, accounting for about one-third of all fatalities in the industry. For example, the Bureau of Labor Statistics reported that there were 291 fatal falls to a lower level in construction in 2013, out of 828 total fatalities. OSHA recognizes that incidents involving falls are generally complex events, frequently involving a variety of factors. Consequently, the standard for fall protection deals with both the human and equipment-related issues in protecting workers from fall hazards. This publication is intended to help workers and employers better understand the Fall Protection in Construction standard’s requirements and the reasons behind them.

EXAMPLES OF FALL PROTECTION REQUIREMENTS FOR CERTAIN CONSTRUCTION ACTIVITIES

  • Leading Edges – 29 CFR 1926.501(b)(2)
  • Overhand Bricklaying and Related Work – 29 CFR 1926.501(b)(9)
  • Roofing Work on Low-Slope Roofs – 29 CFR 1926.501(b)(10)
  • Residential Construction – 29 CFR 1926.501(b)(13)
  • Other Walking or Working Surfaces – 29 CFR 1926.501(b)(15)

CONVENTIONAL FALL PROTECTION SYSTEMS

  • Guardrail Systems – 29 CFR 1926.502(b)
  • Safety Net Systems – 29 CFR 1926.502(c)
  • Personal Fall Arrest Systems – 29 CFR 1926.502(d)
    • Fall Restraint Systems While fall restraint systems are not mentioned in Subpart M, OSHA recognizes a fall restraint system as a means of prevention. The system, if properly used, tethers a worker in a manner that will not allow a fall of any distance. This system is comprised of a body belt or body harness, an anchorage, connectors, and other necessary equipment. Other components typically include a lanyard, a lifeline, and other devices. For a restraint system to work, the anchorage must be strong enough to prevent the worker from moving past the point where the system is fully extended, including an appropriate safety factor.

ADDITIONAL FALL PROTECTION SYSTEMS

  • Warning Line Systems – 29 CFR 1926.502(f)
  • Controlled Access Zones – 29 CFR 1926.502(g)
  • Safety Monitoring Systems – 29 CFR 1926.502(h)

OTHER HAZARDS THAT REQUIRE FALL PROTECTION

A construction environment poses many hazards requiring protection. Below are some fall hazards that cannot be overlooked.

  • Hoist Areas – 29 CFR 1926.501(b)(3)
  • Holes – 29 CFR 1926.501(b)(4)
  • Ramps, Runways, and Other Walkways – 29 CFR 1926.501(b)(6)
  • Excavations – 29 CFR 1926.501(b)(7)
  • Dangerous Equipment – 29 CFR 1926.501(b)(8)
  • Wall Openings – 29 CFR 1926.501(b)(14)

FALL PROTECTION PLANS

Presumption of Feasibility As a general matter, OSHA presumes that using conventional fall protection (that is, guardrails, personal fall arrest systems, or safety nets) is feasible and will not create a greater hazard to use. However, as outlined below, there are a few circumstances when an employer can use a site-specific fall protection plan instead of conventional fall protection.

When Can I Use a Fall Protection Plan? It is possible that during leading edge work (29 CFR 1926.501(b) (2)), precast concrete erection (29 CFR 1926.501(b)(12)), or residential construction (29 CFR 1926.501(b)(13)), it may be infeasible or may create a greater hazard to use conventional fall protection for a specific task. In those circumstances, employers may implement a fall protection plan that complies with 29 CFR 1926.502(k). IMPORTANT: The employer has the burden of establishing that it is appropriate to implement a fall protection plan instead of implementing conventional fall protection systems.

ELEMENTS OF A FALL PROTECTION PLAN – 29 CFR 1926.502(K)  

A fall protection plan must be prepared by a qualified person and developed specifically for the site where the work is being performed. 29 CFR 1926.502(k)(1).

    • The fall protection plan must be maintained and kept up to date. 29 CFR 1926.502(k)(1).
    • Any changes to the fall protection plan must be approved by a qualified person. 29 CFR 1926.502(k)(2).
    • A copy of the fall protection plan with all approved changes must be maintained at the job site. 29 CFR 1926.502(k)(3).
    • A competent person must supervise the implementation of the fall protection plan. 29 CFR 1926.502(k)(4).
    • The plan must document the reasons why the use of conventional fall protection is infeasible or would create a greater hazard. 29 CFR 1926.502(k)(5).
    • The plan must include a written discussion of other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided with protection using conventional fall protection systems. For example, the employer must discuss the extent to which scaffolds, ladders, or vehicle-mounted work platforms can be used to provide a safer working surface and thereby reduce the hazard of falling. 29 CFR 1926.502(k)(6).
    • The plan must identify each location where conventional fall protection methods cannot be used. These locations must then be classified as controlled access zones, and the employer must comply with the criteria in 29 CFR 1926.502(g) and 29 CFR 1926.502(k)(7).
    • Where no other alternative measure has been implemented, the employer must implement a safety monitoring system that complies with 29 CFR 1926.502(h) and 29 CFR 1926.502(k)(8).
    • The plan must include a statement which provides the name or other method of identification for each worker who is authorized to work in controlled access zones. No other workers may enter controlled access zones. 29 CFR 1926.502(k)(9).
    • In the event that a worker falls, or some other related, serious incident occurs (for example, a near miss), the employer must investigate the circumstances to determine if the fall protection plan needs to be changed. For example, the plan may need to add new practices, procedures, or training. The employer must implement the needed changes to prevent similar types of falls or incidents. 29 CFR 1926.502(k)(10).

FALL PROTECTION TRAINING

Requirements – 29 CFR 1926.503 Employers must provide a fall protection training program to workers who might be exposed to fall hazards. Training must include how to recognize fall hazards and how to minimize them. 29 CFR 1926.503(a)(1).

Verification of Training Employers must verify worker training by preparing a written certification record. The record must contain the name or other identity of the worker trained, the dates of the training, and the signature of either the person who conducted the training or the employer. 29 CFR 1926.503(b)(1).

For additional information please go to https://www.osha.gov/SLTC/fallprotection/

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