Fall Protection 2019

MAY 2019 INDUSTRY LETTER IN THIS ISSUE: Fall Protection GET YOUR FALL Does your fall prevention plan meet current industry standards or OSHA PROTECTION PLAN UP TO OSHA REQUIREMENTS requirements? Fall protection can be confusing: FALL PROTECTION CONSIDERATIONS • There are different standards between 1. 29 CFR 1910 and 29 CFR 1926 are not industry and construction interchangeable • The presence of “Proposed Rules” Part 1910 covers general industry and • Letters of Interpretation that modify the includes Operations and Maintenance activities. Part 1926 covers construction Rules are difficult to locate and includes modifications to your facility. • Consensus standards are frequently There are significant differences in these Rules including different heights at which changing fall protection is required, different height requirements on stair guards, and different The ever-changing rules and regulations requirements for fall protection on roofs. can make it difficult to determine if your fall prevention plan meets current industry standards or OSHA requirements. 1

INDUSTRY LETTER 2. Safe edge distance 4. Being connected to a fall arrest For the Construction Industry system does not necessarily make MAY 2019 A 1996 Letter of Interpretation to Part 1926 you safe (construction) allows a De Minimis violation Industry Letter, a publication of Shive-Hattery, for an unprotected edge if employees Fall distances and loads imposed on the features issues, trends and innovations in working 50 to 100 feet away from an anchor during a fall are often grossly industrial design. unprotected edge have been properly underestimated. Shock absorbing lanyards trained. De Minimis violations are not typically require a distance between the Cedar Rapids, IA included in citations. For work performed D-ring attachment and closest obstruction 800.798.0227 less than 50 feet away from an unprotected of 17-18 feet. Fall distances when using Iowa City, IA edge a warning line no less than 15 feet from self-retracting lanyards can vary by model. 800.798.3040 the edge is also a De Minimis violation if These distances are valid only if the fall Des Moines, IA constructed in accordance with 1926.502(f ) protection system is being used correctly 800.798.8104 (2) and the employer implements a work and the anchorage point is attached at Bloomington, IL rule prohibiting work beyond the warning or above D-ring height, or about five feet 800.798.8992 line. There are some specific exemptions above the elevated walking working surface. Chicago, IL noted in CFR 1926.502 for certain activities In addition, loads imposed on the anchorage 312.324.5500 which include leading edge type work. point during a fall are often underestimated. Quad Cities, IL & IA If attached to a horizontal lifeline without 800.798.7650 For General Industry energy absorbers, the force on anchorage Valparaiso, IN According to Part 1910 of OSHA, an points can easily reach over 15,000 pounds 219.476.1400 unprotected edge with a risk of falling 4 feet during a fall. or more must be protected with a guardrail, s h i ve - h a t t e r y. co m safety net, or fall protection system. FALL PROTECTION SERVICES OSHA allows work in a “designated area” Shive-Hattery’s team of engineers meet the conforming to rule 29 CFR 1910.28(b)(13). requirements of OSHA’s “qualified person” This rule requires that work is of a temporary by degree, experience and training in nature, the designated area is surrounded by fall protection. We can help you navigate a warning line conforming to the height and through the rules and regulations and strength requirements, the perimeter is no develop a fall prevention plan that meets less than 6 feet from an unprotected edge, current industry standards and OSHA and the roof has a slope of 4:12 or less. requirements. • Design or specification of complete 3. Fall restraint is an acceptable means of fall protection Fall Protection Systems, including flexible horizontal lifeline systems, rigid Fall restraint using a tether or other horizontal lifeline systems and single acceptable means is allowed. Note that anchorage connectors. “fall restraint” is not “fall positioning” or “fall • On-site condition evaluation of existing arrest.” Fall restraint is achieved through systems and recertification. the use of a restraint system, which does • Design of guardrail systems, hole not allow a worker to reach an unprotected protection (cover or guarding) edge or other fall hazard. Fall restraint in the • Design of stair and ladder systems construction industry is allowed by Letter of Interpretation. This Letter of Interpretation requires that the anchorage point for fall restraint systems be capable of supporting 3,000 lbs. or twice the maximum expected force. According to CFR 1910.140(c)(14), a fall restraint line must be capable of supporting 5,000 lbs. 2