1. BETTER
WRONG
Fall Protection Susan Harwood Grant Training Program 2013 Wood Frame Construction

2. Learning Objectives
Understand how OSHA defines residential construction
Understand the proper use of guardrails during framing operations
Identify best practices during roof truss installation
Understand the proper use of personal fall arrest systems (PFAS) during roofing activities

3. Your Rights Under OSHA You have the right to:
A safe and healthful workplace
Know about hazardous chemicals
Information about injuries and illnesses in your workplace
Complain or request hazard correction from employer
Training
Hazard exposure and medical records
File a complaint with OSHA
Participate in an OSHA inspection
Be free from retaliation for exercising safety and health rights 3

4. Employer Responsibilities
Provide a workplace free from recognized hazards and comply with OSHA standards
Provide training required by OSHA standards
Keep records of injuries and illnesses
Provide medical exams when required by OSHA standards and provide workers access to their exposure and medical records
Not discriminate against workers who exercise their rights under the Act (Section 11(c))
Post OSHA citations and abatement verification notices
Provide and pay for PPE 4

5. Complain or Request Corrections
Workers may bring up safety and health concerns in the workplace to their employers without fear of discharge or discrimination, as long as the complaint is made in good faith.
Workers may file a complaint with OSHA if they believe a violation of a safety or health standard, or an imminent danger situation, exists in the workplace.
OSHA regulations protect workers who complain to their employer about unsafe or unhealthful conditions in the workplace. 5

6. Fall Fatalities in Residential Construction
2005
2006
2007
2008
2009
2010
TOTAL FALLS
134
130
110 93 78 84
FALLS FROM ROOFS 48 49 35 28 31 24
Here's what the residential falls fatality picture looked like during that same period.
Residential falls accounted for roughly 29 percent of all construction fall fatalities and fall from roofs accounted for nearly 35 % of those.
Source: BLS CFOI Data

7. OSHA’s Fall Protection Rule and OSHA Instruction STD Compliance Guidance for Residential Construction
(b)(13) states … workers “engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system.”
… or, by alternative fall protection measures allowed under (b) for particular types of work.
Addressed further under OSHA’s STD Compliance Guidance for Residential Construction
Basically, the new directive simply states that all employers must protect their workers who are engaged in residential construction 6 feet or more, above lower levels by conventional fall protection systems (guardrail systems, safety net system, or personal fall arrest system).
… or, by other fall protection measures allowed under (b) for particular types of work.
Gone are the special alternative procedures allowed under the old directive for certain residential construction activities.
Slide guards or safety monitor systems were allowed in lieu of conventional fall protection without first demonstrating infeasibility or the creation of a greater hazard.
The new directive has not outlawed the use of slide guards or safety monitors.
Now, employers must first demonstrate that it is infeasible to comply with the provisions of the standard, or that it creates a greater hazard.
Then they can use those systems as part of a written, site-specific fall protection plan that meets the requirements of (k).
More simply put, all employers doing residential construction must now comply with 29 CFR (b)(13).
On low-slope roofs, warning lines and/or monitoring systems are allowed under (b)(10).

8. Greater Hazard
If the employer can demonstrate that it is infeasible or creates a greater hazard to use the required fall protection systems, the employer must instead develop and implement a written site specific fall protection plan in accordance with 29 CFR (k).
OSHA does not consider "economic infeasibility" to be a basis for failing to provide conventional fall protection. There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the fall protection systems.
OSHA expects that the fall protection methods listed in (b)(13) can be used without significant safety or feasibility problems for the vast majority of residential construction activities.
29 CFR (b)(13), Residential construction fall protection states “ There is a presumption that it is feasible and it will not create a greater hazard to implement fall protection systems, Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which meets the requirements of paragraph (k)”
The Agency has never been convinced that there are significant safety or feasibility problems with the use of conventional fall protection equipment for the vast majority of residential construction activities.
But, we also acknowledge that there may be isolated situations where it may be infeasible or create a greater hazard to use conventional fall protection in residential construction. We believe that 29 CFR (b)(13) provides sufficient flexibility to accommodate employers in those rare situations where they find it necessary to develop a site specific alternative fall protection plan .

9. Definition of Residential Construction
In order to be classified as residential construction, two elements must be met:
The end-use of the structure being built must be as a home, i.e., a dwelling; and
The structure being built must be constructed using traditional wood frame construction materials and methods.
The limited use of steel I-beams to help support wood framing does not disqualify a structure from being considered residential construction.
The end- use of the structure being built must be as a home, i.e., a dwelling … and,
The structure must be constructed using traditional wood frame construction materials and methods.
The limited use of steel I-beams to help support wood framing does not disqualify a structure from being considered residential construction.

10. Deck Protection All open edges and holes must be protected
Guardrails or other forms of fall protection must be provided
Protect the Hole
Protect the Edge
All edges and holes must be protected immediately after they’re created.

11. Guardrail Systems
Here we see a 2nd AND 3RD floor perimeters completely protected by a guard rail system.
Here we see a floor perimeter completely protected by a guardrail system. 11

12. Guardrails for Edges
These guardrails were set in a way that the walls could be set without removing them.

13. Fall Hazard
Stud walls with 24” OC studs for non-load bearing walls must have guardrails.
Any opening over 19” wide must be guarded
Stud walls on 16” centers are acceptable.
Falling from roofs is not the only area where fatalities have occurred. Open sides like this must be protected.

14. Other Work Methods
Here is the same system still in place through Mechanical, Electrical, Plumbing installation and dry wall.
Priming and painting can be done before installing the permanent handrail and removal of the guardrail.
Here is a guardrail system still in place that allows installation of dry wall and painting before installing the permanent handrail and removing the guardrail.

15. Fall Hazards Stairways must have railings before they can be used.
Floor holes must be protected immediately as decking is constructed around the hole.
Not Good!!

16. Guardrail Systems

17. Guardrail Systems
Brackets and boots are available for guardrail systems that can either be side mounted or deck mounted.
Employers should look to the manufacturer’s instructions for proper installation.
The ability to be either side mounted or deck mounted allows flexibility to employers when using the engineered guardrail systems we just observed.
Either way, consult the manufacturer’s instructions or a registered professional engineer to ensure proper installation. .

18. Window Guard Rails
Window openings less than 39” high must be guarded

19. Stay Off Top Plates
These workers are standing on the top plates of the walls to install trusses.
Workers should instead work from scaffolds or ladders.
There is no need to work from top plates. Ladders or scaffolds can be used.
There are several residential fall protection videos available from the State of Washington. Consider enhancing framing safety by showing an example for residential framing safety which is 13 minutes long and can be found at the following link.

20. Fall Hazards
All sites have unprotected sides or floor holes at some point during construction.
If these sides and holes are not protected, injuries from falls can happen.
There’s no reason to work like this …
Today, there’s no reason for this worker to work like this …

21. Installing Roof Trusses
Workers installing roof trusses from interior bracket scaffolds or ladders.

22. Wall or Bracket Scaffolds
Here are examples of a wall bracket or top plate, scaffold systems.
Here are examples of wall bracket, or top plate scaffold systems. (pause)

23. Other Work Methods
Some contractors are using these systems for rolling trusses and cutting rafter tails.
(b)(3)
Guardrail systems shall be capable of withstanding, without failure, a force of at least 200 pounds (890 N) applied within 2 inches (5.1 cm) of the top edge, in any outward or downward direction, at any point along the top edge.
(b)(4)
When the 200 pound (890 N) test load specified in paragraph (b)(3) of this section is applied in a downward direction, the top edge of the guardrail shall not deflect to a height less than 39 inches (1.0 m) above the walking/working level. Guardrail system components selected and constructed in accordance with the Appendix B to subpart M of this part will be deemed to meet this requirement.
(b)(5)
Midrails, screens, mesh, intermediate vertical members, solid panels, and equivalent structural members shall be capable of withstanding, without failure, a force of at least 150 pounds (666 N) applied in any downward or outward direction at any point along the midrail or other member.
These workers are working from bracket/top plate scaffold systems.
Guardrails must be able to support 200 pounds in all directions.

24. Climbing on Trusses
Workers installing trusses should not stand on truss cords, especially while the truss is still supported on a crane.
Employees should work from ladders or scaffolds or work platforms installed in the trusses.
Workers can easily slip off truss cords.

25. Working on Trusses Workers on trusses must be protected from falling.
Fall protection must be established to protect workers
The stability of the truss system must be addressed before any fall arrest system is attached.
Most truss systems may have the structural integrity to support personal fall protection systems provided they are installed and securely braced and used in accordance with manufacture’s instructions and safe use guidelines.
Individual truss chords cannot normally support 5,000 lb. loads. A force less than 5,000 lbs. can be used if calculated to be 2 X the impact load (twice the potential impact energy of an employee free falling a distance of six feet, or the free fall distance permitted by the system whichever is less

26. Trusses as Fall Arrest Anchors
Single Trusses CANNOT be used as fall arrest anchors unless the anchorage is approved by a qualified person.
NOTE: Most single trusses CANNOT support a fall arrest load
This slide depicts an example of an improperly braced truss that was used to anchor a personal fall arrest system. Usually, an anchorage system requires at least two or more trusses braced and/or partially sheathed before they can safely accommodate an anchorage.
Truss anchorage points must be installed under the supervision of a “qualified person”, be securely braced, and installed and used in accordance with the manufacturer’s instructions, testing and safe use guidelines.
29 CFR (m) Qualified means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject mater, the work, or project.
More information can be found on safe installation of trusses on OSHA’s web site at the link below

27. Truss Collapse
Collapses can occur from failure to adequately brace or from an overload.
Collapse of the truss system can result in serious injuries or death
Truss systems can collapse

28. Alternate Access
Use of lifts or scaffolds keeps workers off of areas where the use of fall arrest is difficult.
Proper set up is required.
Discuss planking requirements for scaffold in bottom left.
Address worker on roof in top right to assure fall protection.
All workers in aerial boom lifts must be tied-off when working in the lift basket. While working from a scissors lift, the guardrail system provides the fall protection and being tied off is not required. Workers in both aerial boom lifts and scissors lifts must work from the deck of the lift and may not work from the guardrail system. This is further addressed in the Section on Scaffolds, Ladders and Lifts.

29. Use of Guardrails
Engineered guardrail systems allow easy access for sheathing, roofing and utility installation.
Multiple trades can be protected by these kinds of systems.
The positioning of this guard rail system allows easy access for sheathing, roofing and utility installation.

30. Pre-Assembly of Truss Sections
Flying pre-assembled structures into place can minimize worker exposure to fall hazards.
Assemble as many parts of the building as possible on the ground.
But proper engineering and crane issues must be addressed.
As we stated previously, working at heights cannot be eliminated, but there are ways to minimize exposure.
By assembling as many parts of the structure as possible on the ground we can reduce worker frequency and duration of exposure to falls.
Properly assembled and braced systems, erected in accordance with the Building Component Safety Information booklet, can be hoisted …
Fall protection anchorages can also be installed during the pre-assembly process before flying the trusses into place
Properly assembled and braced IAW the manufacturer’s instruction and the BCSI guide

31. Fall Arrest System Anchors For Wood Frame
Here are examples of various anchorage devices. All anchorage points must be capable of supporting at least 5,000 pounds per employee attached or 2x the intended load with (twice the potential impact energy of an employee free falling a distance of six feet, or the free fall distance permitted by the system whichever is less).
All anchor points should be installed under the supervision of “qualified person” and always follow the manufacturer’s instructions for installation, testing and safe use guidelines.
Wood members must be evaluated to assure that can support the forces imposed by fall arrest anchors

32. Anchors An example of a spreader attached to roof trusses.
Manufacturer’s requirements must be met.
NOTE:
Truss systems and individual members must be evaluated to assure that they can support the forces imposed by fall arrest anchors
There are serious concerns about stability of the truss system if it is not adequately braced. The attachment points may overload the truss chord member’s ability to support it in a fall

33. Guardrails for Roofing
Guardrails in place during re-roofing activities.
In this slide we see re-roofing activities being performed behind guardrails.
The picture on the right lacks protection for the rake edge so another means of protecting this worker (safety nets or Personal Fall Arrest System) must be used.
Note: The picture on the right lacks protection for the rake edge so some means of protecting this worker (guardrail, safety nets or PFAS) must be used.

34. Personal Fall Arrest Systems on Roofs
Next, the Full Body Harness – Here we see Personal Fall Arrest System in use during roofing and re-roofing operations.
Some fall protection “kit in the buckets” can be purchased for less than $
PFAS in use during roofing and re-roofing activities.

35. Personal Fall Arrest System Anchor Point
Anchors must be capable of supporting at least 5,000 pounds per employee attached for fall arrest, or must be designed and used:
As part of a complete personal fall arrest system which maintains a safety factor of at least two.
Or under the supervision of a qualified person.
Employers should look to the manufacturer’s instructions or the recommendations of a properly qualified person for proper installation.
(d)(15): Proper installation of the Anchorage point is critical to the success of this system. It must be designed and installed to support the twice the impact load – twice the potential impact energy of an employee free falling a distance of six feet, or the free fall distance permitted by the system whichever is less - that would be applied to it if a worker fell. Consulting the manufacturer’s instructions or a registered professional engineer or properly qualified person with an engineering background and the ability to determine load forces and support criteria will ensure this critical component is properly installed and maintained.
This is a 900 lb. Anchor

36. Roof Anchors

37. Permanent Fall Anchorage on Roof
Workers can attach a safety rope to the anchors.
One worker per anchor.
Anchors must be inspected before use.
Inform students to never assume that permanent anchorages will support a PFAS. Always make sure anchorages are inspected by a qualified person prior to their use.
Anchors

38. Roof Fall Restraint Workers are restrained from reaching the edge.
If they can reach the edge, full fall arrest must be implemented
The photo in the lower left may not depict the safe use of a fall restraint in that there appears to be too much slack in the system near the rake edge. The system tethers a worker in a manner that will not allow a fall of any distance. When rope grabs are used they must be set in a manner that allows minimal slack in a line to keep a user away from an edge of a structure. The Anchorage design can be less than that of an anchorage for a PFAS, thus a failure could result in a fall with arrest forces applied.
In a November 2, 1995, interpretation letter to Mr. Dennis Gilmore, OSHA suggested that, at a minimum, a fall restraint system have the capacity to withstand at least 3,000 pounds or twice the maximum expected force that is needed to restrain the person from exposure to the fall hazard. In determining this force, consideration should be given to site-specific factors such as the force generated by a person (including his or her tools, equipment and materials) walking, slipping, tripping, leaning, or sliding along the work surface.

39. Use of Retractables
Anchorage must be able to support at least 3,000 lbs.
Retractables CANNOT be used in a restraint set.
… when there are systems available to protect them from falling and hitting the ground.

40. Shingle Demolition or Tear-off
Fall protection is required during all roof operations
Incomplete Fall Protection
Picture in bottom left photo is a 4:12 pitch would could qualify for a safety monitoring system.

41. Wood Frame Fall Anchors
These anchor straps are installed during framing and available for use during roofing and siding.
NOTE:
Wood members must be evaluated to assure that they can support the forces imposed by fall arrest anchors

42. Ladder Jack Scaffolds Platforms shall not exceed a height of 20 feet.
Workers on ladder jacks must use a PFAS.
Fall arrest must be tied-off above.
Ladders used to support ladder jacks shall be placed, fastened and equipped with devices to prevent slipping.
(g)(1)(i) Each employee on a boatswains' chair, catenary scaffold, float scaffold, needle beam scaffold, or ladder jack scaffold shall be protected by a personal fall arrest system;
(k) "Ladder jack scaffolds."
(k)(1) Platforms shall not exceed a height of 20 feet (6.1 m).
(k)(2) All ladders used to support ladder jack scaffolds shall meet the requirements of subpart X of this part -- Stairways and Ladders, except that job-made ladders shall not be used to support ladder jack scaffolds.
(k)(3) The ladder jack shall be so designed and constructed that it will bear on the side rails and ladder rungs or on the ladder rungs alone. If bearing on rungs only, the bearing area shall include a length of at least 10 inches (25.4 cm) on each rung.
(k)(4) Ladders used to support ladder jacks shall be placed, fastened, or equipped with devices to prevent slipping.
(k)(5) Scaffold platforms shall not be bridged one to another.

43. Pump-jack Scaffolds Pump jacks are safer than ladder jacks.
Pump jacks are a popular system used by many contractors to install building wrap and siding. Some contractors have used different variations of the pump jack that allow them to jack it up to just under the fascia and be used as catch platforms. There the system can be used as perimeter protection while sheathing and roofing operations are performed.
Remember the potential “electrocution hazards resulting from contact with power lines” while standing or moving poles and access ladders.
Pump jacks are safer than ladder jacks.
There are fall issues when anchoring pump jack poles.

45. Additional Information
Additional information can be obtained from the Reference Files located on the included CD.
Additional material can be found at websites such as:
OSHA –
NIOSH –
National Association of Home Builders –
AGC of America –
Include and links for OSHA information and NIOSH material, and other resources like NAHB’s site as well as AGC’s, etc.
Include hot links in the presentation that can play videos if possible
Example link below: