Saturday, February 1, 2014

OSHA Fall Protection Requirements - General Industry

 
When I conduct OSHA 10 and 30-hour training classes, most students seem to know that Federal OSHA requires some form of fall protection for employees working at heights greater than four (4) feet in General Industry (1910), and at heights over six (6) feet in Construction (1926). However, many of them are unaware that there are numerous other OSHA standards requiring fall protection at other heights; some are lower, some are higher, and some only apply (or do not apply) in certain situations.
 
So in this month's blog I decided to provide an overview of the most prevalent Federal OSHA 1910 General Industry standards requiring some form of fall protection when employees are working at various heights (next month I'll list the 1926 Construction standards) so that, should you come across one of these scenarios, you'll be up to speed on the actual OSHA requirements.
 

16 comments:

  1. Thanks You for this information.
    I do the same work in my spanish blog.

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  2. Thanks for sharing this, Curtis. I'm often struggling to correctly understand a hazardous fall position as part of our #Hazardspotting campaign (where readers submit photos of potentially hazardous worksites):
    http://mysafetysign.com/blog/hazardspotting

    Fall protection is almost always more complicated than the 4 or 6 foot rule, so I'm going to bookmark this article as a resource! - Krissa

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  3. Nice post!

    Deontaye

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  4. This always dumfounded me. The problem with OSHA is that they have taken different standards and created piecemeal regulations because they didn’t the skill or funds to do it right. I run into this type of “patchwork thinking” in the community noise control arena as well, where noise from certain events is OK – or has less restriction – for no good reason.

    A fall is a fall, regardless of where it occurs or what activity precedes it. As safety professionals, we should tell OSHA what height requires fall protection – PERIOD!

    Down here in south Florida, virtually no fall protection is in use in residential venues. I must say that the workers are quite skilled at what they do, and that is the only protection they have.

    Robert N. Andres, CSP, CPE, DABFE, INCE

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  5. Thanks for posting. When I conduct my OSHA 30 and include fall protection I use a similar spreadsheet. But to get people thinking I use examples of fatal falls from floor height and reinforce the concept of housekeeping and dry/obstacle free floors to prevent falls.

    By John Walsh, CSP

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  6. Thanks for the information.
    I have clients that struggle with guidance using ladders and when fall protection is needed. Some have fall protection requirements for anything over four feet and some have only when using extension ladders. The standards do not seem to address this. What have you found?

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    Replies
    1. Greg.

      The only fall protection requirement for ladders in on fixed ladders, there are no standards requiring it on portable ladders. Here is an OSHA letter of interpretation on that topic: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=23870

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  7. Is there an exception for in Fed OSHA for the leading edge/open side of a loading/truck dock?

    Cal OSHA has an exception - always interesting to see an exterior loading dock with a 4+ foot drop and no fall protection needed there. Interior docks are easy to protect by lowering the door when not in use, but exterior docks are a challenge.

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    Replies
    1. Interesting question. I've not seen an exception in federal OSHA for unoccupied truck docks. However, in many cases I have measured truck docks and in most cases found them to be less than 48 inches tall. If they were over that height, I have seen retractable (accordion type) gates that are pulled horizontally across the door opening when there is no trailer backed up to the door.

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  8. If you stick to OSHA regs, you will miss the big picture: safety. OSHA regs are interesting to ensure you are in compliance, but not compelling--if you miss a few, no worries, little fines.

    The more important aspect is safety--how do we help workers be safe?

    So, we can take a risk-based approach and decide how we ought to protect workers from portable ladders, flat falls, loading docks, etc.

    Again, looking at the OSHA regs is a good starting point (notice, I did not say minimum), but let's broaden our scope and work towards safety (and that is largely disconnected from OSHA regs).

    Norman da Safety Man

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  9. Very informative, but what about loading docks which exceed the 48" threshold? Is fall protection required?

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    Replies
    1. I am not aware of any current OSHA general industry regulation that exempts employers from protecting workers on truck docks greater than 48 inches high. If anyone is, please let us know.

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  10. I strongly suggest NOT using the body belt language in your article as body belts are no longer fall protection. A Full Fall Protection Harness is now the current standard for PFAS to be properly protecting the workers.
    Body belts added with the Full Body Harness can be used for worker positioning only.

    Paul

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    Replies
    1. Paul. I mention body belts because OSHA does in this standard - for body positioning only. Read the blog post a little closer and see if you agree. Thanks, CC

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  11. What about fall protection on building roofs greater than 6' above the nearest surface below that do not have parapets or guardrails (42" high) around the perimeter where building maintenance personnel will be present from time to time? This is post construction, after the building is occupied and the roof is accessed for maintenance purposes only. Is any fall protection required in these cases, and if so, what would you recommend other than guardrails? Thanks.

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    Replies
    1. OSHA requires fall protection in a general industry setting if the worker is exposed to a fall of four feet or more, including on the roof. There are myriad means and methods to achieve this, such as temporary rails, lifeline systems, rat lines . . .

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