The Challenge of Fall ProtectionPosted on March 05, 2013 by Joel Gregier
For the past twenty years, fatalities related to falls have consistently ranked in the top four causes of workplace deaths. The Occupational Safety and Health Act requires employers to protect their employees from recognized hazards that may result in death or serious physical harm and to comply with OSHA standards. So which standards might the employer need to consider in addressing workplace fall protection?
The Occupational Safety and Health Administration (OSHA) requires employers in General Industry to first address safeguards to the physical structures and devices within the workplace, and then use personal protective equipment for employees when they are unable to completely control the hazards through engineering or administrative methods.
Fall protection standards for physical structures are located under the “Walking and Working Surfaces” standards [29 CFR 1910, Subpart D]. These standards cover floor and wall openings/holes, elevated platforms, fixed stairs, and fixed ladders. For each work surface, OSHA has established minimum construction requirements for safeguards such as railings, handrails, and toe boards. The goals of these standards are to minimize:
- Employee falls, and
- Objects falling on employees from surfaces above their heads
General Fall Protection Rules
As a general rule, openings and platforms 4 feet or more above floor-level, or fixed stairs with 4 or more risers, must be constructed with railings and/or hand rails. The Walking and Working Surfaces standards provide specific instructions regarding the construction of these structures.
Toe boards must be installed on platforms and around openings whenever:
- Persons can pass beneath the platform, or
- The platform is above moving machinery, or
- There is equipment below the platform with which falling materials could create a hazard.
Also, open-sided floors and platforms require railings and toe boards, even if the elevation is under 4 feet, if they are above or adjacent to hazardous locations (e.g., dangerous equipment).
Unconventional Elevated Work Surfaces
Because there are many unconventional elevated working surfaces (i.e., conveyors, tops of machinery, and other structures not normally considered “walking and working” surfaces), OSHA clarifies what it means by “platforms” at STD 1-1.13. According to this directive, OSHA considers something a platform, and therefore subject to the platform guarding standards, if employees will work on it on a “predictable and regular basis.” “Predictable and regular” covers functions such as, but not limited to, inspections, service, repair, and maintenance that are performed at least once every two weeks or for a total of 4 man-hours during any sequential 4-week period. For instance, if 2 employees work for 2 hours each (4 man-hours total) within a 4-week period, that elevated surface would be considered a “platform.”
Personal Protection Equipment
As a general rule, personal protective equipment (PPE) must be provided, used, and maintained in reliable conditions whenever hazards in the workplace can cause injury or impairment from physical contact [29 CFR 1910.132(a)]. If, after securing the workplace by installing mandatory safeguards, employees are still at risk from falling hazards, then employers must select, provide, and train their employees in the proper use and care of their personal protective equipment.
The General Industry Standards do not have standards for specific fall protection PPE. However, there are specifications for certain fall prevention and fall arrest systems within the Construction Standards [29 CFR 1926). While these standards may not directly apply to non-construction related practices, they may serve as a basis for demonstrating the general requirements at 29 CFR 1910.132. In addition, there may be consensus standards that pertain to a workplace scenario that may provide assistance to the employer in assuring that fall protection PPE has been evaluated and implemented properly under the General Industry Standards.
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References: OSHA Instruction STD 1-1.13, April 16, 1984. 29 CFR 1910.23(c), 1910.132