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Fall Protection Options

Feasible or Not?

Attention all residential contracting companies: September 15, 2011 is only 6 days away! If you’re not one of the many residential contracting companies that have already been fined for not providing fall protection to your employees, congratulations! But don’t pop the corks on those champagne bottles just yet.

OSHA’s “Three Month Enforcement Phase In” is about to come to an end. And if you think this phase in was to “help” contractors have time to comply, you’re partially wrong. Over the last few months, many OSHA Compliance Officers have been attending training classes on how they are expected to enforce these regulations.

In past blog entries, we went over what the actual regulations means to you, the residential contractor as well as components to the fall protection plan. Today, let’s look at how to implement some fall protection practices and equipment.

The OSHA Fall Protection standard can be found under Subpart M. There are many options for you to choose from, from guardrail systems to personal fall arrest systems, but keep in mind, just one type of fall protection may not work for all parts of your building; it’s not a one fits all scenario. And the fall protection will never work if they are not installed properly.

  • Guardrail System: Guardrails systems are great but contractors often feel as though purchasing more materials are too costly and eventually wasteful. The cost of the extra materials must be included in your bid price. And then you need to cross your fingers and hope your competitors are doing the same to ensure your bid isn’t outrageously high but still competitive. Remember, cost is not considered a reason for infeasibility.
  • Horizontal Lifeline: If you are looking into a horizontal lifeline system, good for you! Make sure you have a Qualified Person on site at all times – it’s a requirement! The reason for this requirement is easy – they have to be installed correctly in order to work and you have to supervise your employees when the lifeline is in use to ensure it’s safe, correct use. This is an area where OSHA ends up seeing a lot of violations because depending on the total strength of the line, that determines how many people can attach to it: 5,000lbs = 1 person; 10,000lbs = 2 people
  • Anchor points: There are so many anchor points available to contractors today compared to 6+ years ago. Some anchors are excellent so I’ve stuck with them (as in “if it aint broke” kind of thinking).

So there are your options. Simple enough? Well, not really…

One glaring issue with Subpart M is under 1926.502(d)(16)(iii) which states:         “Personal Fall Arrest Systems, when stopping a fall shall: (iii) be rigged such that an employee can either free fall more than 6 feet, nor contact any lower level.”

The problem with residential construction is there is hardly ever an anchor point overhead which means having to place the anchor at the users feet. If the user falls, there is about a 90% chance the employee will either free fall more than 6 feet or contact a lower level (see one interpretation letter here). So does this mean fall protection is infeasible?

It is the Qualified person’s job to determine which tasks are not feasible to complete while wearing fall protection. This is when a plan must be written which will address these infeasible fall hazards. For a review, check out a previous blog posting on fall protection plans: http://lawsafety.wordpress.com/2011/06/07/fall-protection-plan/

If OSHA does visit your construction site, the goal is for you to be doing everything in your power to maintain a safe jobsite so you will not be fined. If you follow the proper protocol when it comes to fall protection for your employees, there’s a good chance you won’t be fined. If you do nothing but write a general plan stating all fall protection is infeasible, get ready to pull out your checkbook.

If you are in need of a written fall protection plan, contact L.A.W. Construction Safety Consultants, LLC today for assistance.

(770) 880.1487

 

2 Comments
  1. I came across your articles re: fall protection/arrest; and, I have one pertinent comment. You make the statement, “The problem with residential construction is there is hardly ever an anchor point overhead which means having to place the anchor at the users feet”; however, this is not the case. For the past few years, there have been several pieces of equipment developed and ready for market use, that provide continuous temporary and permanent “above the head” vertical life-line attachment to an anchor engineered to REALLY handle the potential fall arrest forces that could be applied. Unfortunately, until the oversight agencies start exacting a “pound of flesh” from the employers and developers for not providing these anchorages – the small contractors and employees will continue to use inferior anchorages and fall control devices that, at best, only minimally address the issues. It is unfortunate, as there is the technology already available to provide 100% fall protection/prevention/arrest for all elevated platform work, starting at the 1st floor top plates; and, continuing on through complete construction and future maintenance access. That equipment is both functional, worker productive, and cost efficient.

  2. I totally agree with you – there are plenty of great manufactured equipment out there but the argument is always cost. The majority of residential contractors that I have come across in the past few months do not have any money because of the downturn in the housing market – they are just starting to make their come back. But until they are “forced” to implement specific equipment, they are going to continue to do what they are doing. Until, of course, when someone is badly injured on their site and their WC policy goes through the roof and puts them out of business…and all the while, the anchor point would have been the much cheaper alternative.

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