This OSHA Training blog is dedicated to enhancing knowledge of OSHA-related matters, especially in the areas of OSHA training and new/revised OSHA regulations.
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This OSHA Training blog is dedicated to enhancing knowledge of OSHA-related matters, especially in the areas of OSHA training and new/revised OSHA regulations.
Thanks You for this information.
ReplyDeleteI do the same work in my spanish blog.
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):
ReplyDeletehttp://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
Nice post!
ReplyDeleteDeontaye
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.
ReplyDeleteA 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
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.
ReplyDeleteBy John Walsh, CSP
Thanks for the information.
ReplyDeleteI 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?
Greg.
DeleteThe 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
Is there an exception for in Fed OSHA for the leading edge/open side of a loading/truck dock?
ReplyDeleteCal 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.
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.
DeleteIf 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.
ReplyDeleteThe 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
Very informative, but what about loading docks which exceed the 48" threshold? Is fall protection required?
ReplyDeleteI 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.
DeleteI 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.
ReplyDeleteBody belts added with the Full Body Harness can be used for worker positioning only.
Paul
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
DeleteWhat 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.
ReplyDeleteOSHA 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 . . .
DeleteIn view of Fall protection from Mobile ladder stands and platforms, what is the threshold height for considering a fall protection scenario and also let me know if the mobile work platforms have landing height of 4 feet (1.2 m) or above but less than 10 feet and have handrails with a height of 29.5 inches (75 cm) to 37 inches (94 cm), measured from the front edge of a work platform is adequate or not as per OSHA 1910.23.
ReplyDeleteWhen working from a scissor lift, is it acceptable to attached your lanyard to the rail of the scissor lift or do you require another tie-off point?
ReplyDeleteRead this blog post that addresses that topic, it should help answer your questions: https://oshatrainingservices.blogspot.com/2013/09/fall-protection-requirements-for-aerial.html Thanks, Curtis
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