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The “New” Fall Protection Standard

Don’t Get Caught Off Guard!

On June 16th, the “new” fall protection standard goes into effect for all residential contractors. Previously, certain residential construction activities were allowed to have alternative methods of fall protection such as slide guards on a roof or a safety monitor who told workers to be careful when they got close to a fall hazard. But obviously, these “alternative” methods did not keep people from falling off buildings – in 2009, there were 645 fatal falls reported to OSHA. Additionally, there were countless injuries from preventable incidents.

Over the next few weeks, we’ll examine parts of the fall protection standard which all contractors should be made aware of. This particular blog post will concentrate on the training requirements found in the fall protection standard.

OSHA 1926.503, the Fall Protection Training requirements, detail exactly what training is required of a contractor to provide to their employees. But keep in mind, OSHA regulations are minimum requirements. It’s always better to go above and beyond what OSHA requires.

First of all, the standard states, “The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards”. A training program consists of a thought out plan in which the employer documents how they intend to keep their employees safe from fall hazards. The standard states in an earlier section that a written fall protection plan is only required when fall protection is infeasible. I disagree with this – a plan stating what fall protection measures will be in place is a large part of this training program to meet the requirements under “procedures to be followed”.

The second part of the regulation states, “The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas: nature of fall hazards in the work area; the correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used; the use and operation of guardrail systems, warning line systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones, and other protection to be used; the role of each employee in the safety monitoring system when this system is used; the limitations on the use of mechanical equipment during the performance of roofing work on low-sloped roofs; the correct procedures for the handling and storage of equipment and materials and the erection of overhead protection; the role of employees in the fall protection plans; and the standards contained in this subpart”. That’s a lot of information you have to make sure your employees are trained in! And trained by a competent person? A competent person, as per OSHA, is someone who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. As the employer, you want to make sure if you or someone you deem as your competent person is actually knowledgeable in all training components which OSHA requires.

The next section of the OSHA training requirements is “Certification of Training”. This is one of the first documents and OSHA Compliance Officer will ask for when making a site visit – especially when you have workers working from heights of 6 feet or more to the lower level. So what does that tell you? It tell you the training of employees is a very important component of the fall protection standard.

The requirement for “Certification of Training” reads, “The employer shall, verify compliance with paragraph (a) of this section by preparing a written certification record. The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer…”. This is a living document – it must be updated when you hire new employees, when you change the type of fall protection equipment or most importantly, “when the employer has reason to believe thatn any affected employee who has already been trained does not have the understanding and the skill required…”.

Next blog posting, we’ll examine the need of having a written fall protection plan in place, whether fall protection is feasible or infeasible, before you start your construction project. Pre-planning is key!

Make sure you have all the parts and pieces in place before OSHA comes knocking. Call today for your written fall protection plans, advice on fall protection equipment, training for your employees and competent people or choose us to administer your fall protection program.

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