Sometimes, when questions seem like they should have obvious answers, we need to dig a little deeper to make sure we’re not making assumptions. When it comes to what OSHA considers a hole in the roof, it would be easy to say, “A hole is a hole.” I mean, we all know what holes look like, right?

The trick to questions like this is figuring out what less obvious things might fall into this category. Or, what could be even more challenging, what does OSHA not consider a hole?

Let’s start with OSHA’s definition of a hole. In the construction fall protection standard, as well as in the general industry walking/working surface standard, it states:

“A gap or void, 2 or more inches in its least dimension in a floor, roof, or other walking/working surface.”

So, any opening in the roof in which the smaller side is greater than 2" we have a hole. This is important because many people assume a hole is something you at least have to be able to fit a foot into. But, if that were the case, why would OSHA make the requirement for the least dimension so small?

OSHA isn’t just concerned with somebody falling through a hole, they are also concerned with somebody tripping because of a small hole, or kicking/dropping something through a hole that could potentially injure somebody below. Small holes could also pose problems for ladder stability, forklifts, man lifts, scaffolds, and a wide array of other equipment used on a job site by making them even slightly unstable. So, many larger, more obvious holes get protected in the work area, but many of these smaller holes get overlooked or intentionally ignored because people feel that they don’t pose a real hazard or because it would be too time-consuming to bother covering them all.

As a reminder, all holes need to be covered, if not with a permanent cover, with something that would support at least 2x the maximum intended load, is prevented from movement, and is marked with the word “HOLE” or “COVER”.

Skylights are “holes” in Your Roof

Still, even knowing that smaller holes are included in the mix, this doesn’t seem like a very complicated answer. So, what about holes that aren’t actually holes? The key to this one is realizing that hole covers, regardless of type, don’t always meet the necessary requirements for protecting human life. The biggest culprit in this category would be skylights – and I don’t just mean skylights that are left open during construction. Finished, covered skylights can very well be considered holes.

Most skylight domes are not strong enough to keep a person from falling through. In fact, many of the cages you see covering domed skylights are also not capable of supporting the force of a falling person. These cages, as well as the domes, are usually designed for preventing water, small animals, and debris from entering the building. Yet, many people assume they are protected while working around them. Rooftop work is often performed without the slightest consideration for fall protection around these skylights, despite there being countless stories of workers falling through to their deaths, or at the very least, debilitating injuries.

Skylights come in other forms as well, such as fiberglass panels. These panels are weaker and more translucent than other panels on the roof in order to allow light into the building. Most will not hold a person’s weight and are difficult to differentiate from the regular panels when looking down into a dark building. They have become a concern for firefighters for this very reason.

Protecting Your Workers from Falling Through a Skylight

While personal fall arrest systems can be used to protect your workers, there are also products on the market specifically designed for skylight protection. Skylight screens and skylight guardrail systems are a compliant and cost effective way to protect your workers.

These products are a form of passive fall protection, meaning they don’t require special training or for a worker to do anything in order to be protected. When possible, passive fall protection should be preferred over active fall protection.

Recognizing Weak Spots

One other problem that is fairly unique to roofs, is the fact that the surface on which you are working is almost always covered by a membrane which prevents you from seeing the condition of the roof itself. Holes can exist that you simply cannot see. It is important to do a walkthrough of a roof before beginning work to see if you find any weak spots. Inspections from underneath, if possible, are a good practice as well. Knowing what a hole is, technically, will not help you if you don’t even know the hole is there.

Holes are not difficult to wrap your mind around but are probably also nowhere near as simple as you may have thought. Next opportunity you have, inspect your work area to see if you may have missed things that meet the definition of a hole, now that you know exactly what OSHA is looking at. And, as they say, “Knowing is half the battle.”

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

As we venture into a new year, it’s a good time to take stock of where we are and where we’re headed. It’s no secret that falls have been the leading killer in construction for more years than we care to remember and that fall protection (training or otherwise) has led OSHA’s Top Ten list of violations for way too long. Some way, somehow, we’re just not getting this right. As 2018 begins to pick up speed, here are ten things to consider that can help you do your part to prevent falls.

Plan Ahead for Fall Protection

In my experience, failure to provide employees proper fall protection stems greatly from a lack of planning. When we evaluate the upcoming work, look at plans, develop a safe, compliant method of fall protection, purchase the equipment, train our workers, and implement our plans properly, our people tend to be safe. However, when we leave fall protection to be last-minute field decisions, it’s rare that the proper equipment is available or that the site employees aren’t already feeling the pressure of schedule so that when they don’t have a compliant solution, they just get to work anyway. In some instances, site workers have usable equipment and want to do the right thing, but aren’t trained in what, exactly, that “right thing” is. Selecting proper anchor points and determining fall clearances are not things an untrained person will know how to do properly. All of this is eliminated when we plan.

Know What is New

Perhaps we can manage to be safe, but we certainly can’t be compliant if we don’t know what the latest regulatory requirements are. Last year, OSHA released its new Walking/Working Surfaces rule. This rule contained specific fall protection information for General Industry that had previously been found in the Construction regulations. Until the release of this rule, the General Industry standards did not address such things as Personal Fall Arrest Systems (PFAS). Also, other fall protection changes were made, such as the allowance for a Desginated Area for work on roofs and new standards for what qualifies as fall protection on fixed ladders. Those in manufacturing, warehousing, and other industries governed by 29 CFR 1910 should familiarize themselves with these rules if they are working at heights.

Know What Applies

Speaking of General Industry and Construction regulations, it is extremely important to understand which standards apply to you and to know that it is possible that your operations span more than one set of regulations. It is not uncommon to see a company who follows construction regulations the majority of the time have to comply with general industry regulations at other times. An example might be a mechanical company that does new HVAC installations but also services these installations down the road. New installations would be under 29 CFR 1926 and maintenance services under 29 CFR 1910. Knowing this is especially important in fall protection where something as simple as the height at which you need to be protected changes between the two sets of regulations. Still, knowing what applies to you can go much deeper than construction vs. general industry. Some companies understand which standards apply, but ignore or misunderstand the applicability defined within. For instance, I have dealt with many steel erection companies that try to tell me, or my employees, that nobody on their crew is required to have fall protection until 30’, this couldn’t be further from the truth. That rule actually states that Connectors, specifically defined in the regulation but often a team of 2 people, do not need to be tied off between 15’ and 30’ – or 2 stories, whichever comes first – but must be wearing all the proper fall protection equipment and have an available anchor point (Deckers, as well, get a similar exemption if utilizing a Controlled Decking Zone). That’s a big difference from “nobody needs fall protection until 30 feet.” (P.S. – that all goes out the window on a boom lift where all of the exemptions go away, and fall protection is required at all times).

Understand Fall Clearance

If you don’t recognize the term Fall Clearance, stop and review our fall clearance article for a quick refresher. Once you’re done you’ll probably fall into one of two camps: 1) I knew that or 2) I never stopped to think about that! Either way, it’s important that anyone planning fall protection be very familiar with Fall Clearance as well as it’s common pitfalls. Grabbing a harness and lanyard out of the job box will do you no good if the configuration of your fall protection equipment will allow you to strike a lower level. This is even worse when you are unaware that it will enable you to strike a lower level because the false sense of security you have may, in your mind, justify you taking more risks than you would have otherwise. Remember, if you’re wearing a 6’ lanyard with a deceleration device, the minimum height that your anchor point should be from the lower level is approximately 18.5’.

Have a Rescue Plan in Place

Most people think that a Personal Fall Arrest System (PFAS) is made up of three parts: the harness, the lanyard, and the anchor point. What’s missing from this equation is the life-critical rescue plan. Fall prevention plans such as guardrails and travel restraint don’t require rescue because nobody should be able to reach an unprotected edge, but the very nature of Fall Arrest means that if it has to be deployed, somebody will be left hanging from a platform, roof, or structure. That person is going to need to be rescued, and they are going to need to be rescued quickly. Once somebody falls and is saved by their PFAS, every minute is critical. Suspension trauma can begin to set in in a matter of minutes. This means that even though your worker was saved from the fall, their lives could still be in danger. Without a plan, you also run the risk of workers scrambling to attempt to rescue their co-worker in ways that could be putting their own lives in danger. The worst thing, however, would just be to realize that you don’t have the means to rescue somebody that has fallen. What could have been a happy moment turns to dread and helplessness? Planning is crucial; this includes calling your local fire department to visit the site, if you plan on summoning them for rescue, to ensure that they have the training and capability to rescue somebody. Discovering that you don’t have the means to rescue *after *the fact could be a fatal mistake.

Comfort Helps

While we’re talking about PFAS, it’s important to note that one of the challenges is getting people to wear the equipment and wear it properly. Let’s face it, harnesses and lanyards can be cumbersome or, at the very least, annoying and some people need to have them on for very long stretches of their day. If they’re uncomfortable, chest straps get loosened, leg straps unbuckled, and lanyards get left lying around. While it certainly isn’t required for you take comfort into account when purchasing your equipment, it could be helpful in ensuring compliance. If you look at all the available options for safety harnesses, you could find everything from no-frills harnesses for $60 to $200+ harnesses complete with padding. You can find heavy steel-cased retractable lanyards or lightweight, portable plastic cased ones. From a performance perspective, as long as the equipment meets the ANSI standards, it should all do the same thing. The difference is going to be in additional features and comfort. Perhaps spending a few more dollars here could result in your workers wearing the equipment correctly.

Collective Fall Protection

Not all fall protection involves harnesses and lanyards. Collective fall protection – also called passive fall protection – is a very effective method and, often, is the simplest for your workers. Guardrail systems like KeeGuard are a means of collective fall protection. One installation protects all the workers in the area. We call these systems passive systems because no one has to take any particular action to utilize them. As opposed to a PFAS where the user would need to don their harness, adjust it to the proper size, clip their lanyard to their D-ring and to an anchor point that was hopefully selected ahead of time, passive systems require nothing more than you going to work in that particular work area. This eliminates some of the risks caused by human error. Not all, mind you because humans still set up the guardrail in the first place, but some. Even when guardrail is installed correctly, there are still some inherent risks. Lack of inspections, lack of maintenance, people removing rails for various reasons, people actively bypassing the rails, or simple complacency while around the rails, could all prove to be deadly, but they could also be easily managed. Assigning a small team to inspect and maintain a guardrail is much simpler than ensuring that 20 individuals are all tying-off properly and all have acceptable anchor points.

Warning Lines for Designated Areas

No single fall protection subject has caused more debate, in my opinion, than the allowance for a warning line system while working on roofs. The fact that is missed most often is that the allowance for such a system was designed only for roofers or those performing roofing work under the construction standard. Just about every trade has attempted to commandeer this solution since its release and telling them that it’s not allowed has made for many interesting days on the job site. In the years since this became a viable solution, the use of warning lines for other types of work has been clarified via OSHA Letters of Interpretation and even codified to some extent for General Industry in the form of Designated Areas. However, simply put, if you are not performing roofing work, you cannot have a warning line at 6’ from the roof’s edge; only roofers are allowed that distance (10’ if the mechanical equipment is being used perpendicular to the line). At 15’, other workers performing construction work could utilize the line, running the risk of a *de minimis *citation from OSHA (no monetary penalty). For workers not performing construction work, you can get a rundown of Designated Areas here. Who can and who cannot use warning lines is not the only part of this solution that gets confused. Another thing that often gets missed is that – for roofers – there is no situation in which they can use a Warning Line and not have a safety monitor (and that that monitor can have no other duties but to ensure nobody is getting too close to the lines). If you are considering using a warning line system, ensure that you fully research the requirements.

Fall Arrest vs Fall Prevention

Fall protection breaks down into a couple of different categories: fall arrest and fall prevention. They are what they sound like. Fall prevention prevents people from falling in the first place, while fall arrest slows and stops (arrests) somebody’s fall after they have fallen. Put that way; it’s easy to see which one is preferable. Let’s be clear: even a perfectly planned and perfectly executed fall arrest system could result in injury (not to mention the difficulty of rescue as discussed above). If you have the option to prevent falls, do so. Guardrails and travel restraint will keep people from getting hurt because when used properly, nobody will have the opportunity to fall – even a few inches.

Fall Protection Training

I could end every article this way. If your workers don’t know what they are supposed to be doing, the odds that they will do it are slim. Here’s an experiment: take a full body harness, find somebody that’s never worn it before and ask them to put it on. Give them no direction, just time them. When they think they’re done, see if it’s on and adjusted correctly. How long did it take for them to get it wrong? I still see it so many times – companies handing people fall protection equipment and telling them to get to work (if they give them fall protection equipment at all). Train your employees. Don’t leave their actions to chance. Let them know what they should be doing so that they can recognize when something isn’t right. And, when they come to you to tell you something isn’t right, hear them out. Don’t dismiss them as troublemakers or primadonnas. That concern that they’re voicing could save somebody’s life.

2018 is here and, as we all know, will be gone before we know it. Take stock now. Review your fall protection program, ensure everyone is trained, have a Competent Person inspect your equipment if you haven’t already. To not do these things is to play with the lives of your employees.

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

When it comes to fall protection, a common method OSHA employs is one in which a certain area is demarcated by some type of warning line, and when employees can work without more traditional means of fall protection. It can be called different things – a Controlled Access Zone or a Controlled Decking Zone, but the one that has most recently garnered attention with the release of the new Walking/Working Surfaces standard is a Designated Area.

A Designated Area is defined by OSHA as "A distinct portion of a walking-working surface delineated by a warning line in which employees may perform work without additional fall protection."

This sounds almost identical to what was used above to describe controlled zones, so what makes a Designated Area different?

The answer to that would be the same regardless of which zone we were discussing. What makes each of the zones unique is in which situations they can be used. So, just when does the new Walking/Working Surfaces standard call for a Designated Area? According to 29 CFR 1910.28(b)(13) a Designated Area can be used for work on low-slope roofs if your work is performed between 6' and 15' from the edge AND is both infrequent and temporary. A Designated Area may also be used at any time when employees are working greater than 15' from the edge of a low-slope roof (NOTE: if the work greater than 15' from the edge is both temporary and infrequent and a rule is in place prohibiting workers from going within 15' of the roof edge without fall protection, the employer has no duty to provide fall protection whatsoever, including a Designated Area).

This begs the question, just what is 'infrequent' and 'temporary'? It's easy to say that these concepts are what they sound like, but that's not a definition that would hold up in a court of law. Luckily OSHA has been approached with this question and has provided more detail for us.

How OSHA Defines Temporary

In the context of a Designated Area, temporary refers to tasks that usually takes less than 1-2 hours to complete. Examples given by OSHA were tasks like changing HVAC filters on rooftop units or re-caulking around a skylight.

How OSHA Defines Infrequent

Infrequent was also defined in the context of a Designated Area and is possibly even more vague. Suffice to say that infrequent tasks cannot be tasks that a worker performs as part of his or her daily job. Infrequent tasks are ones that get performed at intervals like once per month or once per year. Infrequent can also refer to tasks that are performed as needed, like when a piece of equipment breaks down. If you intend to use a Designated Area, be sure your tasks fall into these categories.

While this is a quick overview, one similarity between a Designated Area and the rest of the controlled zones is that, with all of them, you often need a boundary to demarcate your zone, and that boundary is what OSHA calls a control line. It may be tempting to run out and grab a string of plastic flags to set up your line, but OSHA does have specific requirements for things like sag, load, and visibility. Your best bet is to look into manufactured warning line systems that come with weighted stanchions (or permanent mounts if you so desire), carrying carts, or even stamped steel flags. Set up properly, these systems should help you achieve compliance.

Designated areas can be useful tools that help alleviate some of the burden of more stringent fall protection requirements in situations where the risk of falls is minimal. However, they are only effective when they are set up correctly and utilized properly. Your employees also need to fully understand the Designated Area and what it means. In order to ensure that they do, you need to make sure each and every employee that will need to work in or around a Designated Area is properly trained in a language they understand. After all, making sure these employees are safe is the entire purpose.

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

Anchor point selection is not nearly as simple as finding the nearest solid-looking object to which you can clip your lanyard.  Understanding the forces which anchor points are required to withstand, the type of anchor point your lanyard can safely connect to, and the work that you are going to need to perform are all critical components of proper anchor point selection.  Too many people take this for granted and feel that just being “tied-off” to something is safe enough. This couldn’t be further from the truth.  Accidents abound where people are tied off to insufficient anchor points or what should have been sufficient anchor points were used, but because of improper usage, they failed.  Your workforce needs to understand what a proper anchor point is and, should one not be readily available, they need such an anchor point provided to them. 

Existing Structures

Shy of a good ol’ structural I-Beam, it’s going to be hard to make a case for making a field decision to use any other structural member as an anchor point.  In order for something to qualify, it must be able to withstand 5000 lbs. of force per person attached or a safety factor of 2 (meaning 2x the forces that would be applied to it in a fall).  Now, here’s a little test.  Grab any person in the field and ask them what the criteria for an anchor point is.  Those who don’t know can’t possibly make a decision on which part of the structure to choose.  Still, if you have anybody remaining that did know the criteria, ask which parts of the structure meet these criteria.  Many are going to say “I don’t know.”  Eliminate them as well, because they can’t select an anchor point by their own admission.  If somebody gives you an answer other than “I don’t know,” ask them how they know what they selected meets the criteria.  If they can’t explain, then they can’t select an anchor point either.  If they can (or attempt to), ask them if they’d be willing to sign a piece of paper stating that the anchor point is sufficient or provide data that supports their selection.

The point I’m trying to make is that, other than an engineer who has stopped to review some specs and perform some calculations, most people aren’t going to know what can or can’t meet the requirements of an anchor point and, even if they could, they’re not going to be able to provide the proof you need to make the anchor point a valid option. I-Beams are pretty much your only randomly selected option. Like all other options, the connection still needs to be approved by an engineer and you’re going to need to make sure you have the proper equipment with which your workers will connect.  Whether a beam clamp, a beam wrap, or some other designed system, every last piece needs to be in place.  It only takes the failure of one component for the whole system to fail.

Engineered Systems

One of the best things to do is to purchase an engineered system.  There are a variety of different kinds: horizontal lifelines, mobile anchor points, and permanently installed engineered anchor points to name a few.  Each comes with their own pros and cons.

Horizontal Lifelines are fantastic once they’re in place.  The design phase could be a little time-consuming and the systems could be pricey, but they allow your workers freedom of movement, can be custom designed to just about any configuration, and can be installed to minimize or eliminate lanyards on the working surface (trip hazards).  However, they aren’t just quickly thrown in place and they shouldn’t be installed by somebody who is not extensively trained in doing so (luckily many suppliers will offer this service).  Horizontal Lifelines take time – from design, to installation, to being trained in their use, this is something that needs to be thought out ahead of time and is probably more realistic for long term projects or permanent installations. For instance, a roofer going to a rooftop to perform a quick one-day patch probably won’t be erecting a horizontal lifeline, but if there is going to be frequent maintenance on rooftop air-handling units, then maybe a lifeline is the way to go.

Portable anchor points are another option.  There are a number of different types, from counterweighted systems like Weightanka to rolling roofing carts, portable anchor points can give you an engineered solution to help you with those quick or intermittent jobs at heights.  These systems are designed in such a way that they do not require rooftop penetration and can often be broken down into components that can be moved around by one or two people.  Set up is quick, so, simply drop the parts, assemble, connect to it and you’re ready to go.  Other options exist for residential roofers and similar trades that can nail directly into the roof sheeting.  For almost any application, a portable anchor can be found.

Permanent engineered anchor points are a viable solution as well.  Unlike their portable counterparts, these systems are designed to penetrate the roof and attach to structural steel so that once they are installed they are left in place.  These are good for situations in which you know exactly where your work is going to take place, because workers are going to be restricted to a set radius around this anchor point.  For work that will take place in various locations outside this radius, multiple anchor points or a Horizontal Lifeline will need to be installed.  If you are pouring concrete, you may want to consider straps that get poured into the concrete that then get cut off when the work is finished. 

Training

As always, when it comes to fall protection, nothing works if your employees aren’t properly trained.  If you are using a mobile anchor point, workers will need to fully understand how it works, how it is assembled, how many people can use it at once, and how they should properly tie off to it.  Just handing workers equipment without teaching them how to use it is not only a violation of OSHA standards, but it’s outright dangerous.  Take the time to assure your workers are properly educated.

In the end, anchor point selection is not a simple decision that can be made “on the fly” in the field.  Like all fall protection solutions, anchor point selection should be thought about in the planning stages of the work.  If not, you can almost guarantee that workers will be working unprotected or insufficiently protected.  Don’t leave the lives of your employees to chance.  Plan for their safety.

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

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.

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

• 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:

•  FallProof
• Guardian F.I.R.S.T Choice Training

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.

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

If you’ve ever had the pleasure of climbing the side of a building, chances are you are well-aware of the round metal cage whose function it is to protect you from violently crashing to the ground.

Also, it’s likely that at some point during your ascent you thought, “How is this round metal cage supposed to protect me from violently crashing to the ground?”  Well, it looks like you weren’t the only one.  In fact, it was widely recognized that ladder cages did nothing in terms of worker safety and fall prevention. So, as of the release of the new Walking/Working Surface standard, ladder cages are being phased out. 

Now, don’t panic if you’ve got a facility full of them.  OSHA has various dates for compliance to allow for a gradual transition and to ease the financial burden on property owners/employers who find themselves needing to make a change.  For now, existing ladder cages are grandfathered in, but that will change eventually.

The first compliance date comes late next year and is the deadline for when employers must ensure that all fixed ladders have some type of safety system.  The deadline, November 19, 2018, still allows employers to select wells as their fall protection option as long as the ladder already existed. Technically, that means that a newly installed ladder between now and then could still have a cage installed because it will have been “existing” on November 19, 2018.  Of course, to make things easier going forward, employers could simply opt to install a ladder safety system or personal fall arrest system, as well, or as their main fall protection solution.

On that same date, all new fixed ladders (as well as any replacement ladders or ladder sections) will be required to be installed with either a ladder safety system or a personal fall arrest system.  No new installations will be allowed with cages or wells.
For the most part, that takes care of the near-future deadlines.  But, OSHA is phasing wells and cages out altogether, so while you may try squeezing new installations in before the deadline, keep in mind that in 20 years’ time (November 18, 2036 to be exact) all fixed ladders greater than 24’ in length will be required to have fall arrest systems or ladder safety systems. This means that your existing ladders with cages and wells will need to be retrofitted because there will no longer be any grandfathering allowed.  Granted, this is quite a way down the road, but there’s no sense in employers waiting 19.5 years and scrambling at the last minute to change everything in their facility.  

So, as mentioned above, this leaves you with a choice between two remaining acceptable solutions: ladder safety systems and personal fall arrest.  Most people are familiar with personal fall arrest systems (PFAS) – a harness, lanyard, and suitable anchor point.  The requirements here are no different than the requirements elsewhere: fall clearance, freefall distance, proper inspection and maintenance of equipment, anchor point capacities and training in the equipment’s use must all be taken into account just as if you were using this equipment to keep somebody from falling off the edge of a building.  Ladder safety systems, though, may be a little bit less familiar.  While they still require a harness, ladder safety systems are rails or cables that run the length of the ladder vertically.  An employee “ties-off” by hooking the front D-Ring of his or her harness to the trolley or rope grab and proceeds to climb.  Certain systems will require some manual action by the user while others will simply allow them to climb, locking into place only in the event of a fall.  Keep in mind that employees will need to be able to transition from the ladder to the level to which they are climbing without exposing themselves to a fall, so the ladder safety device may need to extend farther than the ladder.  Ensure that this is designed into the system when installed or it could cause problems later on.

Whichever method you choose – PFAS or Ladder Safety Device – your employees will be safer when climbing your fixed ladders than they were while relying on a cage or well.  Make sure you train them so they can properly use the equipment and are safe.  Improperly worn/used fall protection equipment may be offering nothing more than a false sense of security.  And false senses of security make people take unnecessary risks that could lead to disaster.  Make sure to review your facility and start taking the necessary precautions now.

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

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

Late last year, OSHA published a long-awaited final rule on Walking and Working Surfaces.  One of the main reasons for this update to the existing general industry standard was an attempt to bring the fall protection requirements for manufacturing, warehousing, maintenance, and other similar operations more in line with the construction requirements.  To those who, at times, are governed by the construction regulations, much of the new rule will be familiar, specifically the section on Personal Fall Arrest Systems (PFAS).  However, this is definitely not all that is new.  Below is a guide to what has changed.

Fall Protection

Prior to this rule, the general industry regulations required that a company consider guardrails as their primary method of fall protection.  While passive systems are always a great option, they are not always feasible.  The new rule gives companies the flexibility to decide which method works for them, including Personal Fall Arrest Systems (harnesses, lanyards, anchor points, or what is commonly known as “tying off”).  The new rule not only allows for this type of system to be used, but also lays out requirements for their performance, use, and inspection.

In addition, the rule allows for certain methods to be used in situations that can be considered “temporary and infrequent.”  For example, work being performed on a low slope roof that meets the criteria for temporary and infrequent may be allowed to utilize a designated work area.  This area, 15’ back from the edge may preclude the use of other fall protection equipment, as long as all of the requirements set forth in the regulation are met.

Scaffolding

Rather than update the outdated scaffolding section, OSHA now requires that employers who are using scaffolding under the general industry regulations follow the construction guidelines found in 29 CFR 1926. This is a quick, simple change that could eliminate a great deal of confusion.

Fixed Ladders

Say goodbye to cages and wells.  Kind of.  Over the next 20 years (based on whether or not a ladder already exists, is being repaired or replaced, or is a new installation), fixed ladders that are over 24’ in length will need to be equipped with ladder safety devices or personal fall arrest systems.  Cages and wells will no longer be acceptable as they have not proven to prevent falls.

Qualified Climbers

This one only affects you if you’re in outdoor advertising, but the allowance for “qualified climbers” in outdoor advertising to climb without fall protection is gone.  The phase-in timeline for fixed ladders mentioned above applies, but if their ladders have no cages or wells currently, they have 2 years in which they could choose to install those to become compliant with existing regulations.  After that, they will still need to meet the timeline set forth for ladder safety devices or PFAS.

Rope Descent Systems

This part is basically taking an OSHA memorandum and making it law.  Companies that use Rope Descent Systems (RDS) may not do so over 300’ above grade.  It also requires that building owners provide (and employers obtain) information to show that the anchorage points have been inspected, tested, certified and maintained to meet the requirements.

Inspection of Walking-Working Surfaces

While this may seem like it goes without being said, it apparently needs to be said: employers must regularly inspect walking-working surfaces and maintain/repair them as necessary.

Training

What rule would be complete without a section on training?  Most notable is the fact that employers – as in construction – must train employees on how to use, inspect, store, and maintain their PFAS.  Workers in specified high-hazard situations must be trained in those hazards and the hazards associated with their fall protection equipment.  As always, workers must be trained in a manner that they understand.  It is the employer’s responsibility to determine what that manner is and to verify that their employees have understood the material.

While the changes may not be earth-shattering to many, the addition of the use of PFAS is a long-anticipated change that gives employers much more flexibility in determining fall protection solutions.  Likewise, while ladder changes may be costly for facilities that have many fixed ladders, the timeline helps companies to spread that cost out and, in the end, replaces an ineffective system with something that will actually prevent injuries and fatalities.  Some of these requirements simply make it easier by having one place to go, i.e. for scaffolding, rather than having to worry which regulations you are supposed to be following and whether or not those regulations match up.  And isn’t giving employers flexibility, making things simpler and preventing injuries and fatalities exactly what we want?

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+

Whether you’re a plumber, painter, electrician, maintenance worker or any other number of trade professionals, the portable ladder is a go-to solution for difficult-to-reach work tasks.  Whether it’s an A-Frame or an extension ladder, we take for granted that they’re the safest way to do our jobs.  That may not be the case.  Ladders could be unstable, especially if they’re not being used properly.  In many cases, the Easi-Dec Portable Work Platform offers a much safer solution, but companies won’t invest the time or money needed to have them available.  Other times, companies are simply not aware there is another solution, so ladders continue to permeate our job sites.  Therefore, it is important workers know how to properly and safely use portable ladders.

Angles

Extension and straight ladders must be set at the proper angle in order to keep them from tipping back.  This angle is a 4:1 ratio.  In other words, for every 4 feet in height from the ground to the point the ladder makes contact with the structure, the base must be a foot away from the structure.  Now, most of the time, nobody is busting out a measuring tape.  There are two easy ways to tell if you’re at the proper angle.  1) Stand at the base of the ladder so that your toes are touching it.  Extend your arm at a 90 degree angle from your body.  If your hand touches a rung or a side-rail, you are approximately at a 4:1 angle.  2) Download the NIOSH ladder app.  Simply lean your phone along the rail of the ladder to see what angle you’ve set the ladder at.

Securing the Ladder

Most people are concerned about a ladder tipping backwards, but it’s much more likely it will actually shift laterally.  Therefore, it is important that you secure the ladder – near the top – to the structure to prevent it from shifting.  Do not use the ladder’s adjustment rope to secure it to the structure.  Ensure that somebody is holding the ladder in place during the initial setup.

Proper Height

Your ladder must extend 3’ above the level to which you are climbing, or there must be a grab rail that extends 3’ up.  While this is important when dismounting the ladder, it is even more important when mounting the ladder from the top.  The last thing you want is somebody walking to the edge of a building or platform and having to lean down to grab the ladder.  One moment of light-headedness could end in disaster.  To see if your ladder is properly extended, count the rungs.  There is approximately one foot between rungs.  

Setup

The ladder will never be a safe tool if it’s not set up in a safe location to begin with.  Make sure your ladder is on firm, level ground and that the safety feet are in place.  If you need to kick the feet up to dig into the surface material, that’s what they’re there for.  For an A-Frame ladder, ensure you’ve fully opened the ladder and locked it into place.  No A-Frame should ever be used while folded or partially closed.  This is not what the ladder is designed for and not how it’s tested.

Maximum Height

Your A-Frame ladder has a maximum working height.  You’ll notice a label that says “Do Not Work On or Above This Step.”  Pay special attention to the “On or Above” part.  Most people look at that and think that they can step on that step but not above it.  This is not the case.  And definitely, don’t ever straddle the ladder or sit on top of it.  In addition, the label on the side of the ladder contains a maximum working height in case you’re unsure.  If you can’t read the labels, that’s a whole different problem and you need new ladders.

Labels and Paint

Labels on the ladder must be legible.  If they are worn off or painted over, then you cannot use the ladder.  (NOTE: You do not need to destroy or throw away ladders because the label is illegible. Instead, call the manufacturer to get a new label shipped to you.) In addition, you must be able to inspect your ladder for cracks, defects, and damage.  Painting ladders with an opaque paint may prevent you from doing so, therefore do not paint your ladders.

Safe Use

You can set up a ladder as safely as you want.  If you don’t use it safely, you can still get hurt.  Always maintain three points of contact when climbing a ladder.  This means two feet and a hand, or two hands and a foot.  Doing this precludes you from carrying tools or materials in your hands – which is a good thing.  While working aloft, your tools should be at the very least in a tool belt or tool vest.  At best, they should be tethered to you.  Also, maintain your center of gravity between the side rails – no leaning off to one side or another.  Keep your eyes out for other hazards or unsafe conditions.  Many ladder accidents, for instance, occur when employees mount the ladder at the top by swinging around it.  Perhaps you can purchase ladder toppers to eliminate this hazard.  These toppers attach to the top of the ladder and extend the necessary 3’ above the surface you’re climbing to while allowing the worker to step THROUGH them instead of around.  Finally, only use ladders as intended.  Do not separate parts if they’re not intended to be separated.  Do not lash sections together.  Do not climb both sides of an A-Frame unless it is specifically designed for that.

Inspecting

Ladders are a tool, so you need to treat them like one.  Just with any other tool, you need to inspect your ladder prior to use and remove it from service if anything is wrong with it.  Do not take chances.  A new ladder is much more inexpensive than a broken bone or a lost life.

Training

Don’t believe that just because we use ladders at home that your employees know how to use them safely.  People use ladders wrong ALL THE TIME.  It is your responsibility as an employer to ensure that your employees are properly trained in the safe use of ladders and that you are designating a Competent Person(s) regarding ladders.  That Competent Person, according to OSHA, must be knowledgeable enough to recognize a hazard and must have the authority to correct it.

Ladders are a very familiar and very useful tool, but as such, people tend to become complacent when working with them.  Unfortunately, complacency can be safety’s mortal enemy.  Make sure that if you are going to choose ladders as the proper means for your workers to complete their work tasks that they are fully aware how to use them safely. Ladders are cheap.  People are not.

This post contributed by:

John Braun, CSP, CHST

Co-Owner, Signature Safety, LLC.

Email: john@signaturesafety.net

Website: http://www.signaturesafety.net

John Braun has been in the EHS field for more than 16 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+