5 Fall Protection Myths and OSHA’s 3 Step Program For Fall Protection
5 fall protection myths• Myth #1: “Residential construction has an exemption from the fall protection rules.”This used to be true. However, in December 2010, OSHA rescinded thedirective that allowed for that exception and as of September 15,2011, all residential construction companies must comply with1926.501(b)(13). The employer still has the option to develop andimplement a fall protection plan that meets the requirements ofparagraph (k) of 1926.502 if the employer can demonstrate that fallprotection is infeasible or creates a greater hazard.The new directive STD 03-00-002, Compliance Guidance for ResidentialConstruction, rescinds STD 03-00-001, Interim Fall ProtectionCompliance Guidelines for Residential Construction, and provides thatOSHA will be enforcing 1926.501(b)(13) for all residential constructionwork.
29 CFR 1926.501(b)(13)• EFFECTIVE SEPTEMBER 15, 2012 - The new directive requires all residential builders to comply with 29 Code of Federal Regulations 1926.501(b)(13).• Under 29 CFR 1926.501(b)(13) workers engaged in residential construction six (6) feet or more above lower levels are to be protected by conventional fall protection. For roofers, the 25 foot, ground-to-eave height threshold no longer applies, nor do slide guards as an acceptable form of fall protection, regardless of the roof pitch or height of the roof eave.• These new requirements replace the Interim Fall Protection Compliance Guidelines for Residential Construction, Standard 03-00-001 that have been in effect since 1995 and allowed residential builders to bypass fall protection requirements.• OSHA has developed training and compliance assistance materials for small employers and will host a webinar for parties interested in learning more about complying with the standard.
5 fall protection myths• Myth #2: “I don’t need any fall protection; it’s only going to take me a couple minutes to install that equipment.”Fall protection must be provided when employees areperforming construction work on a walking/working surfacewith an unprotected side or edge that is six feet or moreabove a lower level. (Note: Construction work is “work forconstruction, alteration, and/or repair, including painting anddecorating.”)The length of time needed to perform that construction workhas no bearing on the employer’s duty to provide fallprotection. Be it one minute or one hour, OSHA requires fallprotection per 1926.501(b)(1).
5 fall protection myths• Exception To Myth #2:There is an exception: when employees are making an inspection,investigation or assessment of workplace conditions prior to the actualstart of construction work or after all construction work has beencompleted, no fall protection is needed.The following is from an OSHA Letter of Interpretation dated March 2,2010:“OSHA has set this exception because employees engaged in inspecting,investigating and assessing workplace conditions before the actual workbegins or after work has been completed are exposed to fall hazards forvery short durations, if at all, since they most likely would be able toaccomplish their work without going near the danger zone... [R]equiringthe installation of fall protection systems under such circumstanceswould expose the employee who installs those systems to fallinghazards for a longer time than the person performing an inspection orsimilar work.”
5 fall protection myths• Myth #3: “Training programs for fall protection aren’t really needed.”OSHA is clear about requiring training for eachemployee who might be exposed to fall hazards. Forexample, employees may be familiar with specifictypes of fall protection and have had propertraining. However, if a different type of fallprotection is to be used, employees using it must betrained by a competent person qualified in this areaof expertise.
5 fall protection myths• Myth #4: “I’m doing roofing on a low-sloped roof so I don’t need any fall protection.”• OSHA requires (per 1926.5010(b)(10)) each employee engaged in roofing activities on low-sloped roofs, with unprotected sides and edges six feet or more above lower levels be protected from falling by:• Guardrail systems,• Safety net systems, or• Personal fall arrest systems.• Other options include a combination of:• Warning line system and guardrail system,• Warning line system and safety net system,• Warning line system and personal fall arrest system, or• Warning line system and safety monitoring system.• On roofs 50 feet or less in width, the use of a safety monitoring system alone (i.e., without the warning line system) is permitted.
5 fall protection myths• Myth #5: “A warning line is all I need for fall protection when working on a steep roof.”According to 1926.501(b)(11), a warning line is notallowed as a form of fall protection when workingon a steeply pitched roof. OSHA requires that eachemployee on a steep roof with unprotected sidesand edges six feet or more above lower levels beprotected from falling by guardrail systems with toeboards, safety net systems or personal fall arrestsystems.
According to OSHA Statistics:• In 2010:• Myth #2: cost employers $1,344,612 in OSHA citations.• Myth #3: failure to provide the required fall protection training in 1926.503(a)(1) resulted in $649,006 in OSHA citations• Myth #4: OSHA issued $909,442 in citations to enforce the requirement in1926.5010(b)(10)• Myth #5: Training employees on the requirements of 1926.501(b)(11) would have saved employers $447,828 in citations
Myth: Six-Foot Rule• This myth involves the so-called 6-ft rule or “two-step rule” where distance alone is the protection. OSHA has never viewed as compliant the practice of remaining at least 6 feet away from the edge. The preamble to 29 CFR 1926, Subpart M, states the premise that “OSHA has determined that there is no safe distance from an unprotected side or edge that would render fall protection unnecessary.”• That interpretation was the rule until July 23, 1996, when a letter of interpretation was written that stipulated for a low-slope roof, “However, when employees working 50 to 100 feet away from the unprotected edge have been properly trained, then the situation can be considered a de minimis condition.”
Welcome to OSHAs Fall Prevention Campaign • FALLS ARE THE LEADING CAUSE OF DEATH IN CONSTRUCTION. In 2010, there were 264 fall fatalities (255 falls to lower level) out of 774 total fatalities in construction. These deaths are preventable. • Falls can be prevented and lives can be saved through three simple steps: • Plan • Provide • Train
FALLS FROM ROOFS CAN BE PREVENTED! Inspect all fall protection equipment before use Use guardrails or lifelines Wear a harness and always stay connected Make sure your harness fits Guard or cover all holes, openings, and skylights PLAN ahead to get the job done safely. PROVIDE the right roof equipment. TRAIN everyone to use the equipment safely.
PLAN ahead to get the job done safely.• When working from heights, such as ladders, scaffolds, and roofs, employers must Plan projects to ensure that the job is done safely. Begin by deciding how the job will be done, what tasks will be involved, and what safety equipment may be needed to complete each task.• When estimating the cost of a job, employers should include safety equipment, and Plan to have all the necessary equipment and tools available at the construction site. For example, in a roofing job, think about all of the different fall hazards, such as holes or skylights and leading edges, then Plan and select fall protection suitable to that work, such as personal fall arrest systems (PFAS).
PROVIDE the right roof equipment.• Workers who are six feet or more above lower levels are at risk for serious injury or death if they should fall. To protect these workers, employers must Provide fall protection and the right equipment for the job, including the right kinds of ladders, scaffolds, and safety gear.• Different ladders and scaffolds are appropriate for different jobs. Always Provide workers with the kind they need to get the job done safely. For roof work, there are many ways to prevent falls. If workers use personal fall arrest systems (PFAS), Provide a harness for each worker who needs to tie off to the anchor. Make sure the PFAS fits, and regularly inspect all fall protection equipment to ensure its still in good condition and safe to use.
TRAIN everyone to use the equipment safely• Falls can be prevented when workers understand proper set-up and safe use of equipment, so they need training on the specific equipment they will use to complete the job. Employers must train workers in hazard recognition and in the care and safe use ladders, scaffolds, fall protection . systems, and other equipment theyll be using on the job.• OSHA has provided numerous materials and resources that employers can use during toolbox talks to train workers on safe practices to avoid falls in construction. Falls from ladders, scaffolds and roofs can be prevented and lives can be saved through three simple steps: Plan, Provide and Train.
PREVENTIONDON’T Disconnect From The DON’T Work Around DON’T Use DefectiveLifeline Unprotected Openings or Equipment Skylights