Are you a residential contractor?
Are your workers exposed to fall hazards?
If you answered yes to any of these questions, do you also feel as though June 16th is an important date you need to prepare for? Well, you should answer yes to this too! Why?
As of June 16th, all residential construction employers must comply with OSHA 29 CFR 1926.501(b)(13) Fall Protection standard. What does this mean to you, the residential contractor?
Residential construction employers must ensure that employees working six feet or more above lower levels use guardrails, safety nets, or personal fall arrest systems. A personal fall arrest system may consist of a full body harness, a deceleration device, a lanyard, and an anchor point. Keep in mind, personal fall arrest systems are always your last choice – do you know how many people wear it incorrectly even when trained? Speaking of training, if you choose to allow workers to use a personal fall arrest system, make sure you have completed training for all workers who will be using the fall protection. Document all training – I can guarantee an OSHA Compliance Officer will ask for it!
OSHA allows the use of a fall restraint system in lieu of a personal fall arrest system. To be effective, a fall restraint system must be rigged to prevent a worker from reaching a fall hazard and falling over the edge. A fall restraint system may consist of a full body harness or body belt that is connected to an anchor point at the center of a roof by a lanyard of a length that will not allow a worker to physically reach the edge of the roof. Again, make sure any workers who will be wearing fall protection are trained in how to use the equipment and the equipment’s limitations.
OSHA does state that if the employer can demonstrate that use of conventional fall protection methods is infeasible or creates a greater hazard, it must ensure that a qualified person:
- Creates a written, site-specific fall protection plan in compliance with 29 CFR 1926.502(k); and
- Documents, in that plan, the reasons why conventional fall protection systems are infeasible or why their use would create a greater hazard.
In my experience with OSHA Compliance Officers, good luck trying to prove infeasibility! There are so many products on the market today that are either for temporary or permanent use and they are not only intended for new construction. The fall protection standard includes alterations and additions to buildings.
I suggest to all my clients whether it is feasible or infeasible to use fall protection, you should always have a written plan. Training has to be completed to ensure your workers understand how to safely build the building and know what types of fall protection measures you plan on using, so if you don’t have a written plan, what are you training them on?
For further information, there is a guidance document from OSHA available on their website: http://www.osha.gov/doc/guidance.html
Remember, fall protection equipment is not “one size fits all”. You might have to try out a few different products before you find your right fit! If you need help ensuring you’re ready for the June 16th date, call today to have your safety program reviewed. Pre-planning never hurt anyone!