Fall Protection Paul Mangiafico OSHA Compliance Assistance Specialist Hartford Area Office

Introduction Why Fall Protection?

These headlines are all from the third and fourth quarter of 2003 Construction worker dies in fall from condo project Worker Hurt In Fall At University Project Bridge construction accident injures six Elementary school construction accident sends 2 to hospital Ironworker who fell had been on job only 3 weeks Worker injured in second floor fall These headlines are all from the third and fourth quarter of 2003

Did you know? .33sec./2 feet .67 sec./7 feet It takes most people about 1/3 of a second to become aware. It takes another 1/3 of a second for the body to react. A body can fall up to 7 feet in 2/3 of a second. 1 sec./16 feet 2 sec./64 feet

Susan Harwood Grant Training Program Fall Protection This is an actual fatality photograph Region 6 News Release:   OSHA-02-92 Thurs., June 13, 2002 Contact: Diana Petterson or Elizabeth Todd Phone: (214) 767-4776, ext. 222 or 221 Failure to Protect Tower Construction Workers Brings New Braunfels, Texas, Firm $44,100 in OSHA Fines Agency Cites Texcom Services Following Fatal Accident in May DALLAS -- The failure of a New Braunfels, Texas, communications tower erector firm to provide appropriate hoisting equipment and training for its employees has resulted in citations and proposed penalties of $44,100 from the Occupational Safety and Health Administration (OSHA).OSHA has cited The Waylon Group Ltd., doing business as Texcom Services with two alleged safety violations, following its investigation of a May accident in which two workers were killed and one was seriously injured. All three fell approximately 200 feet while being lowered from the tower by a single rope.The Labor Department agency cited the company for one alleged willful violation for failing to use appropriate equipment to hoist the workers, contrary to guidelines established by OSHA and the tower erection and servicing industry for personnel hoisting. A willful violation is defined as one committed with an intentional disregard of or plain indifference to the OSHA Act and regulations.An alleged serious violation was issued for failing to train employees to recognize jobsite hazards. A serious violation is one that could cause death or serious physical harm to employees when the employer knew or should have known of the hazard.Texcom Services employs about nine workers. The company was erecting a Verizon Wireless tower near the intersection of Highways 21 and 77 near Lincoln, Texas.Employers and employees with questions regarding workplace safety and health standards can call the nearest OSHA office. OSHA's toll-free hotline may be used to report workplace accidents, fatalities, or situations posing imminent danger to workers. The number is 1-800-321-6742.The company has 15 working days from receipt of the citations to comply, request an informal conference with the area director, or to contest the citations and penalties before the independent Occupational Safety and Health Review Commission. Susan Harwood Grant Training Program

Falls Falls are the leading cause of fatalities in the construction industry. An average of 300 fatal falls occurred each year in construction.

Susan Harwood Grant Training Program Fall Protection We may spend a great deal of time discussing fatal falls, and their affect on the industry, but… Susan Harwood Grant Training Program

Susan Harwood Grant Training Program Fall Protection Frequency of falls is an equally important issue. Many employees have been very seriously injured (but not killed) in falls from ladders, scaffolds, etc. Susan Harwood Grant Training Program

What is OSHA Focusing On? Citations What is OSHA Focusing On?

Most Frequently Cited Construction Standards Fall Protection Most Frequently Cited Construction Standards Fall protection – unprotected sides and edges Scaffolds - fall protection PPE - hard hats Fall Protection - residential construction Scaffolds - access Excavation - Protection of employees Aerial lifts - Fall protection Scaffolds - platform construction Information for the Bureau of Labor Statistics, compiled by OSHA Training & education Ladders -three foot above Susan Harwood Grant Training Program

Fall Protection Subpart L 1926.450-454 Scaffolds Scaffolds over 10 feet with no fall protection Access to scaffolds Aerial lifts - Fall protection Scaffold platform construction Employee training for scaffold use Information for the Bureau of Labor Statistics, compiled by OSHA Susan Harwood Grant Training Program

Subpart M 1926.500-503 Fall Protection Fall protection - Unprotected sides & edges Fall protection for residential construction Fall hazards training program Fall protection for low-slope roofs Fall protection for steep roofs Information for the Bureau of Labor Statistics, compiled by OSHA Susan Harwood Grant Training Program

Subpart R 1926.750-761 Steel Erection Fall Protection Subpart R 1926.750-761 Steel Erection Fall Protection 15 Feet Fall Hazard Training Commencement of Steel Erection Connectors PFAS over 15 Feet Concrete Strength Tested Information for the Bureau of Labor Statistics, compiled by OSHA Susan Harwood Grant Training Program

Fall Protection Subpart X 1926.1050-1060 Ladders Portable ladders not extending three feet above the landing surface Stair rails & handrails Stairways/ladders required Appropriate use of ladders Training program Information for the Bureau of Labor Statistics, compiled by OSHA Susan Harwood Grant Training Program

Most Frequently Cited Construction Standards 50% of the top 25 OSHA Construction standards violated were Fall Related.

Philosophies of Fall Protection Stop/Prevent The Fall Catch The Fall Restraint/Positioning Fall Arrest Guardrails Safety Nets Warning Lines Do these stop/prevent the fall? CAZ – No, it merely attempts to limit employee access. Human error, misjudgment, and inattentiveness can be a problem CDZ – Similar to CAZ, a CDZ is an area defined in Subpart R where positive fall protection is not required, and a “plan” can be used to protect employees. Human error, misjudgment, and inattentiveness can be a problem Safety Monitors – Do not necessarily prevent falls, their function is to warn employees of potential hazards as they occur. Human error, misjudgment, and inattentiveness can be a problem Catch Platforms Controlled Access Zones Controlled Decking Zones Do these stop/prevent the fall? Safety Monitors Susan Harwood Grant Training Program

Planning for Fall Protection Best practice dictates that fall prevention/protection becomes an integral part of the project planning process, from constructability, to systems installation, to use and maintenance A project cannot be truly safe unless fall prevention/protection is incorporated into every phase of the construction process Planning will keep workers safe and minimize liability for all parties involved While a plan is not required for all projects, and is not required to be written in any case, having a written, jobsite and hazard-specific plan is recommend. Remember that training (employee orientation to the specifics) is a critical component of a good plan Susan Harwood Grant Training Program

Controlling Fall Exposures Fall Protection Controlling Fall Exposures • Select fall protection systems appropriate for given situations. • Use proper construction and installation of safety systems. • Supervise employees properly. • Use safe work procedures. • Train workers in the proper selection, use, and maintenance of fall protection systems. Evaluate the effectiveness of all steps OSHA recognizes that accidents involving falls are generally complex events frequently involving a variety of factors. Only a systematic approach to fall exposures will help to minimize the potential for these accidents Susan Harwood Grant Training Program

Fall Protection Competent Person means one who is capable of identifying existing and predictable hazards in the the surroundings, or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has the authorization to take prompt corrective measures to eliminate them. Susan Harwood Grant Training Program

Falls onto dangerous equipment Fall Protection Falls onto dangerous equipment 0’ Allowable Fall Distance (You Must Be Protected) Definition of Dangerous Equipment Dangerous equipment means equipment (such as pickling or galvanizing tanks, degreasing units, machinery, electrical equipment, and other units) which, as a result of form or function, may be hazardous to employees who fall onto or into such equipment. Susan Harwood Grant Training Program

Break in elevation without a step 19”

First step onto a scaffold system 2’

Work on forms or steel reinforcing 6’

Work on surfaces such as decks, roofs, ramps, etc 6’

Scaffold platforms without guardrails 10’

Vertical fixed ladders without cages, etc. 24’

Climbing steel reinforcing Fall Protection Climbing steel reinforcing 24’ If structured like a ladder – see interpretations for more guidance Susan Harwood Grant Training Program

Steel erection work 15-30’

Falls from portable extension ladders Fall Protection Falls from portable extension ladders No Limit Must be installed and used properly (three point stance), never use a portable ladder as an anchorage point Susan Harwood Grant Training Program

Fall Protection It’s Not Just Subpart M! Which Standards Apply? It’s Not Just Subpart M! This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Fall protection, Subpart M – employees on the wall Fall Protection, Subpart L – employees on the scaffold Access – Subpart L, or, if they were using an extension ladder, Subpart X Subpart E – personal protective equipment – glasses, gloves It also appears that they are grouting the wall – chemical safety issues, pump safety issues, etc… Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub X, Ladders Sub E – no hard hat Sub M – if he was to tie off, how? Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub M – working on the structure Sub L – working on the scaffold Sub X – ladder construction and installation Sub Q – impalement hazards, adequate strength of formwork systems Sub E - PPE Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub M – Fall protection, harness use Sub L – scaffold guardrails, boomlift safety Sub T – demolition operations Sub H – Material handling Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub L – scaffold platform construction, access, fall protection Sub E - PPE – hardhats backwards, lack of safety glasses Sub D – potable water supply Sub M – trip and fall hazards, ramps into excavation Sub P – excavation safety, sloping Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub L – scaffold platform construction, capacity Sub X – ladder construction and installation Sub Q – impalement hazard Sub M – fall protection from floor into hole, or over side of floor Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub L – mobile scaffold use Sub M – fall protection (note cables in foreground, it is 80’ to the ground over the cables), anchorage point capacity Rolling mobile scaffolds can be inherently dangerous, and have very specific requirements for safe use, especially when employees remain on the scaffold. Be sure to consult the applicable requirements in Subpart L. Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub L – Ladder jack usage, fall protection from the system Maximum height of ladder jack scaffolds is 20’ Sub M – Fall protection from the roof Sub E – PPE (or lack thereof) Sub X – Ladder usage, installation Susan Harwood Grant Training Program

Which Standards Apply? Fall Protection This section is intended to prod the viewer to assess situations typically found in construction, and to understand that standards other than Subpart M must be addressed (and may overlap). For instance, a photo may show violations of Subpart M (Fall Protection), Subpart X (Ladders), and Subpart L (Scaffolds). It is not the intent of this section to specifically determine citable standards, it is to illustrate the interaction between standards. Because, in many instances, a photo may not provide all of the required information to make a citation determination, these slides are to be used for discussion purposes only. Some suggestions: Sub L – Aerial work platform usage, fall protection requirements Sub M – Fall protection at roof edge Sub E – PPE Sub C – Training, competency, effective safety program – this is the foreman on the jobsite, not leading by example Harnesses are required at all times when using boomlifts Susan Harwood Grant Training Program

Guardrails Primary Issues Complete System Proper construction Fall Protection Guardrails Primary Issues Complete System Full coverage Accessways/Ladderways Material Handling Areas Proper construction Strength Deflection Maintenance Custody & Control Who builds them? Who maintains them? If they are cables installed by the steel erector, have we provided for turnover to the Controlling Employer, as required by Subpart R? Controlling contractor means a prime contractor, general contractor, construction manager or any other legal entity which has the overall responsibility for the construction of the project -- its planning, quality and completion. 1926.760(e) Custody of fall protection. Fall protection provided by the steel erector shall remain in the area where steel erection activity has been completed, to be used by other trades, only if the controlling contractor or its authorized representative: 1926.760(e)(1) Has directed the steel erector to leave the fall protection in place; and 1926.760(e)(2) Has inspected and accepted control and responsibility of the fall protection prior to authorizing persons other than steel erectors to work in the area. Susan Harwood Grant Training Program

Coverage Bad Better Fall Protection Gaps at end of rails, extension beyond posts… Susan Harwood Grant Training Program

Accessways/Ladderways Fall Protection Accessways/Ladderways Bad Better What are some of the things we need to know about ladder installation? Prevented from slipping, extended above the platform 36’ unless another suitable grab is provided… The ladderway requires fall protection as well, with a maximum opening of 18” to the side of the ladder, or an offset entry to minimize the hazard of employees “stumbling” into the opening Susan Harwood Grant Training Program

Material Handling When areas have been opened, PFAS is required Fall Protection Material Handling If we are using loading platforms, the platform must be capable of supporting the weight of all employees, materials, and equipment – times 4. A system should in place to allow employees to tie off prior to removing guardrails from loading areas, if they can be exposed to the fall. A restraint system works best. When areas have been opened, PFAS is required Gates are preferred to removable rails Susan Harwood Grant Training Program

Wood Guardrail Construction Fall Protection Wood Guardrail Construction Proper Height Midrails Toeboards Adequate Strength 42” plus or minus 3”, must support 200# in an outward or downward direction. Must be surfaced to prevent injury. All posts cut flush. Susan Harwood Grant Training Program

Cable Guardrail Construction Fall Protection Cable Guardrail Construction Proper Height Cannot deflect below 39” Marked every 6’ Terminations and Attachments Maintenance! If they are cables installed by the steel erector, have we provided for turnover to the Controlling Employer, as required by Subpart R? Controlling contractor means a prime contractor, general contractor, construction manager or any other legal entity which has the overall responsibility for the construction of the project -- its planning, quality and completion. 1926.760(e) Custody of fall protection. Fall protection provided by the steel erector shall remain in the area where steel erection activity has been completed, to be used by other trades, only if the controlling contractor or its authorized representative: 1926.760(e)(1) Has directed the steel erector to leave the fall protection in place; and 1926.760(e)(2) Has inspected and accepted control and responsibility of the fall protection prior to authorizing persons other than steel erectors to work in the area. Susan Harwood Grant Training Program

Holes Covers Guardrails Fall Protection Covers must be properly marked, positively affixed, and capable of supporting twice the intended load Susan Harwood Grant Training Program

Skylights Must be protected Fall Protection Ideally, barricades prevent access to the skylights. If covers are provided, they must support twice the intended load. The photo on the right is from a fatality investigation, where an employee sat on the skylight to eat his lunch, and fell through. Must be protected Susan Harwood Grant Training Program

Leading Edges Catch Platforms PFAS Nets Fall Protection Definition from Sub M: Leading edge means the edge of a floor, roof, or formwork for a floor or other walking/working surface (such as the deck) which changes location as additional floor, roof, decking, or formwork sections are placed, formed, or constructed. A leading edge is considered to be an "unprotected side and edge" during periods when it is not actively and continuously under construction. The definition is the same in Sub R, except that the last sentence is not included. So, as we finish decking at the perimeter, but continue along the filler beams, must the edge that is done be protected? How soon? See interpretations and Compliance Directive for Sub R for more guidance. Susan Harwood Grant Training Program

Scaffolds Supported Fabricated Frame Tube & Coupler Wall Brackets Fall Protection Scaffolds Supported Fabricated Frame Tube & Coupler Wall Brackets Form Brackets Ladder Jacks Pump Jacks What is wrong with these pictures? Employee working outside pump jack posts, no fall protection off end… Bulldozer mounted “mobile scaffold”? Guardrails missing at ends of form bracket scaffolds… Susan Harwood Grant Training Program

Scaffolds Suspended Swings Multi-point Catenary Fall Protection Personal fall arrest and guardrails are required – Each employee on a scaffold more than 10 feet (3.1 m) above a lower level shall be protected from falling to that lower level. Paragraphs (g)(1)(i) through (vii) of this section establish the types of fall protection to be provided to the employees on each type of scaffold. Paragraph (g)(2) of this section addresses fall protection for scaffold erectors and dismantlers. Note to paragraph (g)(1): The fall protection requirements for employees installing suspension scaffold support systems on floors, roofs, and other elevated surfaces are set forth in subpart M of this part. 1926.451(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; 1926.451(g)(1)(ii) Each employee on a single-point or two-point adjustable suspension scaffold shall be protected by both a personal fall arrest system and guardrail system; Are the systems compatible, and being used properly? What are the PFAS anchored to? Have employees been properly trained? Susan Harwood Grant Training Program

Scaffolds Access Planking Guardrails Erection & Dismantling Training Fall Protection Scaffolds Access Planking Guardrails Erection & Dismantling Training Employees putting their training to work in a hands-on scaffold erection class at an industrial facility. Susan Harwood Grant Training Program

Scaffold Access Bad Better Fall Protection Adequate, safe access must be provided when elevation changes more than 24” on scaffolds. Climbing cross braces is specifically disallowed, and can be very dangerous. The photo on the left was taken from the street – unfortunately for contractors, many scaffold violations are readily visible, and an invitation to OSHA to do a comprehensive inspection. Susan Harwood Grant Training Program

Scaffold Platform Construction Fall Protection Scaffold Platform Construction Bad Better A good scaffold management plan, including adequate training of all employees, would ensure that planks damaged as badly as the one on the left would never make it to the jobsite, much less onto a scaffold. Susan Harwood Grant Training Program

Scaffold Guardrails Bad Better Be especially aware of scaffold ends! Fall Protection Scaffold Guardrails Bad Better The photo on the left was taken from the street (on a highway construction project) – unfortunately for contractors, many scaffold violations are readily visible, and an invitation to OSHA to do a comprehensive inspection. Missing end rails are perhaps one of the most common hazards on scaffolds. Be especially aware of scaffold ends! Susan Harwood Grant Training Program

Use of Braces for Guardrails Fall Protection Use of Braces for Guardrails Although allowed (and in some instances required by site conditions, such as to prevent a fall to the inside of a scaffold from an outrigger), the use of cross bracing as either guardrail is not a recommended practice. Brace can be used as a Top Rail. Susan Harwood Grant Training Program

Use of Braces for Guardrails Fall Protection Use of Braces for Guardrails Although allowed (and in some instances required by site conditions, such as to prevent a fall to the inside of a scaffold from an outrigger), the use of cross bracing as either guardrail is not a recommended practice. Brace can be used as a Mid Rail Susan Harwood Grant Training Program Install Top Rail < 48" 20 - 30" Platform

Fall Protection Braces as Guardrails The guardrails are in compliance using a 2x4 as one rail and the brace as the other rail. May not be the safest way Although allowed (and in some instances required by site conditions, such as to prevent a fall to the inside of a scaffold from an outrigger), the use of cross bracing as either guardrail is not a recommended practice. Susan Harwood Grant Training Program

Scaffold Erection & Dismantling Fall Protection Scaffold Erection & Dismantling “Competent Person” Determines Where Fall Protection is “Feasible” and Does Not Create a Greater Hazard Using Scaffolds as Anchorage Points? Letter of Interpretation allows use as anchorage if they meet strength requirements – be sure to read and understand the process you may have to follow to use a scaffold as an anchorage. Remember that most welded-frame scaffold manufacturers have specifically disallowed this practice, and liability for any improper use or installation may fall squarely on the employers’ (or competent persons’) shoulders Susan Harwood Grant Training Program

Aerial Work Platforms Boomlifts Scissorlifts Fall Protection Aerial Work Platforms Boomlifts Scissorlifts Boom Trucks (Cherry Pickers) Mast Climbers It is important to read and follow the latest ANSI standards for use of these specific types of systems, as the OSHA-referenced standards may be obsolete. See: ANSI/SIA A92.2-1990 Vehicle-Mounted Elevating and Rotating Aerial Devices ANSI/SIA A92.3-1990 Manually Propelled Elevating Aerial Platforms ANSI/SIA A92.5-1990 Boom Supported Elevating Work Platforms ANSI/SIA A92.6-1990 Self-Propelled Elevating Work Platforms ANSI/SIA A92.7-1990 Airline Ground Support Vehicle-Mounted Vertical Lift Devices ANSI/SIA A92.8-1993 Vehicle-Mounted Bridge Inspection and Maintenance Devices ANSI/SIA A92.9-1993 Mast-Climbing Work Platforms (or later versions as they come into play) Susan Harwood Grant Training Program

Stairs Fall Protection Susan Harwood Grant Training Program Proper care and maintenance of stair rail systems is critical. Rails must be constructed and support loads in accordance with Sub X requirements. Stair pans may require temporary fill prior to pour. Human nature being what it is, you have to assume workers will climb over or through rails unless you provide them with another safe means of access/egress. It may be a good idea to scaffold over landings/stairwell openings to provide fall protection during the installation or permanent rails, especially if walls and floors have been installed or finished… Susan Harwood Grant Training Program

Ladders Extension Step Vertical Fixed Job-built Fall Protection Note the hazard of climbing over/through guardrails at the top of a ladder. This is a violation that could be eliminated by adding a post and keeping rails back from the opening. A removable guardrail at the opening may also be used. Note the unpoured deck at the top of the ladder as well, this exacerbates the hazard of falling while accessing the floor. Susan Harwood Grant Training Program

Ladders Extension Fall Protection Susan Harwood Grant Training Program What is wrong with these pictures? Employee extending weight over side rails, safe access at top not provided, improper ladder jack installation, employees holding extension ladder vertical while another employee climbs (and exposure to traffic, possible overhead lines) Susan Harwood Grant Training Program

Ladders Step Fall Protection Susan Harwood Grant Training Program Employees should not straddle ladder tops, use top rungs, lean ladders against the wall or surface, or use stepladders as access to heights… Susan Harwood Grant Training Program

Roofs Fall Protection Susan Harwood Grant Training Program Lower left photo, no fall protection on a steep roof Susan Harwood Grant Training Program

Methods of Roof Fall Protection Fall Arrest Safety Monitors Guardrails and warning lines When performing roofing activities, not necessarily working on roofs… Roof means the exterior surface on the top of a building. This does not include floors or formwork which, because a building has not been completed, temporarily become the top surface of a building. Roofing work means the hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck. Susan Harwood Grant Training Program

Flat/Low Slope 4:1 Slope or Less Fall Protection Flat/Low Slope 4:1 Slope or Less Beyond the Use of Guardrails, OSHA Allows the Use of Warning Lines Safety Monitors Recommended: Guardrails or PFAS where feasible Limited use of lines and monitors on flat roofs only When performing roofing activities, not necessarily working on roofs Low-slope roof means a roof having a slope less than or equal to 4 in 12 (vertical to horizontal). Susan Harwood Grant Training Program

Roof Warning Lines Must be 6 feet back from edges (10’ with equipment) Fall Protection Roof Warning Lines Must be 6 feet back from edges (10’ with equipment) NO CAUTION TAPE! See interpretations for guidance Warning line system means a barrier erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area. Susan Harwood Grant Training Program

Safety Monitor Oversees work outside the warning lines. Fall Protection Safety Monitor Oversees work outside the warning lines. Establishes the procedure to protect. Workers must receive special training. Use should be extremely limited Some things should be painfully obvious Susan Harwood Grant Training Program

High Slope Over 4:1 Slope OSHA Mandates Guardrails Catch Platforms Fall Protection High Slope Over 4:1 Slope OSHA Mandates Guardrails Catch Platforms Nets Restraint Devices Personal Fall Arrest Systems (PFAS) See interpretations for guidance Steep roof means a roof having a slope greater than 4 in 12 (vertical to horizontal). Susan Harwood Grant Training Program

Fall Distances Total Fall Distance Free Fall Distance Fall Protection See interpretations for additional guidance. Susan Harwood Grant Training Program

Impacting Structures Below (Total Fall Distance) Fall Protection Impacting Structures Below (Total Fall Distance) Consider: anchorage point location in relation to D-ring height lanyard length, harness elongation, shock absorber opening length, body below D-ring body viscosity (soft tissue injuries!) See interpretations for additional guidance. Susan Harwood Grant Training Program

Impacting Structures Below (Total Fall Distance) Fall Protection Impacting Structures Below (Total Fall Distance) 6’ Lanyard Length 3.5’ Deceleration Device 5’ From D-Ring to Worker’s Feet 3’ Safety Factor (stretch, bounce, etc.) Total 18.5’ below anchorage point See interpretations for additional guidance. All distances are approximate, and shown for illustration only. Susan Harwood Grant Training Program

Fall Protection Free Fall Distance How far a worker falls before shock absorbing or deceleration equipment begins to take effect Affects both impact forces and total fall distance Anchorage point location in relation to D-ring height Below the D-ring allows excessive falls Above the D-ring minimizes free fall to less than 6’ See interpretations for additional guidance. Susan Harwood Grant Training Program

Free Fall Distance or “Vertical Displacement” Fall Protection Free Fall Distance or “Vertical Displacement” 6’ Lanyard Length 3.5’ Deceleration Device 5’ From D-Ring to Worker’s Feet Total 11’ travel distance of d-ring before fall arrest takes effect. This potential impact force exceeds many lanyard capacities (and OSHA standards). When added to “total fall distance”, anchoring at the feet can become problematic 3’ Safety Factor (stretch, bounce, etc.) See interpretations for additional guidance. All distances are approximate, and shown for illustration only. Susan Harwood Grant Training Program

Minimizing Free Fall Distance or “Vertical Displacement” Fall Protection Minimizing Free Fall Distance or “Vertical Displacement” 6’ Lanyard Length 3.5’ Deceleration Device Extended Lanyard Length Plus maximum 2’ extension (usually within inches) Tie to anchor above the D-ring Or use a retractable See interpretations for additional guidance. Using an anchorage above the D-ring and a standard lanyard may still allow an employee to fall a distance that may be difficult to rescue from. Using a retractable minimizes forces on the body, and may make rescue easier (and therefore more timely) All distances are approximate, and shown for illustration only. This is why it is critical to maintain the safety factor distance! Susan Harwood Grant Training Program

Practical Implications of Total & Free Fall Distance Added Together Fall Protection Practical Implications of Total & Free Fall Distance Added Together These workers are tied to the beams they are standing on with choker slings. How far will they fall? See interpretations for guidance Susan Harwood Grant Training Program

Fall Protection Watch Swing Falls This worker is tied off using a retractable lifeline. There is a major swing fall potential if he fell to either side. Swing Fall Be aware of potential swing fall hazards – many manufacturers also require that their SRL’s be installed above the worker to ensure proper action of the retractable mechanism. Susan Harwood Grant Training Program

Anchorages Must support 5000# per employee attached, Fall Protection Anchorages Must support 5000# per employee attached, Or as part of a complete personal fall arrest system which maintains a safety factor of at least two Or 3000# when using fall restraint or a Self-Retracting Lifeline (SRL, Retractable, or “yo-yo”) which limits free fall distance to 2 feet Should always be at or above D-ring height NOTE---HORIZONTAL LIFELINES---ONLY OPTION IS TWICE MAXIMUM ARRESTING FORCE – which will require some calculation, unless using a manufactured system in accordance with the manufacturers’ requirements Susan Harwood Grant Training Program

Roof & Deck Anchors Wood Roof Anchor Permanent Anchors Metal Roof

Girder Grip Anchorage Rings Fall Protection Girder Grip Anchorage Rings Another possible anchorage connector that can be inserted in bolt holes. These attachments can be mounted through bolt holes on steel members. They are rated at 5,000 lbs. in all directions Susan Harwood Grant Training Program

Beam Clamps Be sure pin is inserted full length and clamp is tight. Fall Protection Beam Clamps Beam clamps can make an effective anchorage when used properly, and with the correct lanyard TIGHT BEAM CLAMP PIN SET What happens when the employee reaches the next joist? He/she needs a second beamer to make the traverse over the joist end, otherwise will not be tied off 100% of the time. Also, some prefabricated building rafters/joists may not be suitable for the application of a beamer, as the flange is too thin to support the potential impact. Be sure pin is inserted full length and clamp is tight. Susan Harwood Grant Training Program

Beware of potential for pulling off of coped ends on filler beams! Fall Protection Many beams are coped back (top flange removed) to a point where the beamer is narrow enough to slip off of the end. This has happened, and employees below have been hit by the falling beamer! (Not to mention the fact that the employee above may lose his/her balance) Beware of potential for pulling off of coped ends on filler beams! Susan Harwood Grant Training Program

Horizontal Life Lines Provide maneuverability. Fall Protection Horizontal Life Lines Provide maneuverability. Must be designed, installed and used under the guidance of a qualified person This could be interpreted as requiring the use of manufactured systems, which is recommended Shall be designed, installed, and used, under the supervision of a qualified person, as part of a complete personal fall arrest system, which maintains a safety factor of at least two. Susan Harwood Grant Training Program

Fall Protection Body (Harnesses) Need to be inspected frequently (daily before use by the worker, at least monthly by a Competent Person) Should never be modified Should be taken out of service immediately if defective or exposed to an impact Note: Body belts are excluded as of 1/1/98 Note: If the personal fall arrest system meets the criteria and protocols contained in Appendix C to subpart M, and if the system is being used by an employee having a combined person and tool weight of less than 310 pounds (140 kg), the system will be considered to be in compliance with the provisions of paragraph (d)(16) of this section. If the system is used by an employee having a combined tool and body weight of 310 pounds (140 kg) or more, then the employer must appropriately modify the criteria and protocols of the Appendix to provide proper protection for such heavier weights, or the system will not be deemed to be in compliance with the requirements of paragraph (d)(16) of this section. 1926.502(d)(17) The attachment point of the body belt shall be located in the center of the wearer's back. The attachment point of the body harness shall be located in the center of the wearer's back near shoulder level, or above the wearer's head. 1926.502(d)(18) Body belts, harnesses, and components shall be used only for employee protection (as part of a personal fall arrest system or positioning device system) and not to hoist materials. 1926.502(d)(19) Personal fall arrest systems and components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse. 1926.502(d)(20) The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves. ..1926.502(d)(21) 1926.502(d)(21) Personal fall arrest systems shall be inspected prior to each use for wear, damage and other deterioration, and defective components shall be removed from service. Susan Harwood Grant Training Program

Harness Fitting Harness must be sized for the worker Chest strap tightened at mid chest “D” ring between shoulder blades Proper snugness shoulder to hips Leg straps snug but not binding Butt strap supports the load Harness must be sized for the worker

Proper Adjustment Is Key “Rules of Thumb” Be able to reach your D-ring with your thumb Maximum Four (flat) Fingers of Slack at the legs, straps as high as comfortably possible Ensure chest strap is across the chest/breastbone Have a buddy double check for twists, etc…

Harness Pressure Points Spread load across butt strap and belt strap if on the harness Excess pressure here can cut blood flow to the legs Some studies have indicated permanent damage to the lower extremities when the worker hangs for more than twenty (10) minutes

Retractable Lifelines Very effective for vertical applications. Will normally lock up in 1 –2 feet, minimizing total fall distance and impact forces on the worker’s body

Do Not Hook Lanyards to Retractables! This worker is hooked to a retractable lifeline with his lanyard. This can cause hook failures and affect the locking capability of the retractable. The retractable should be attached directly to the “D” ring.

Positioning Systems Positioning Devices Provide Hands-free Work Fall Protection Positioning Systems Positioning Devices Provide Hands-free Work Additional Fall Protection (tie-off) may be required to move or access For use on vertical surfaces only Susan Harwood Grant Training Program

Positioning

Restraint Devices Provide Access but Prevent the Fall Limit anchorage requirement to 3000# May be more suitable for loading areas, scaffold erection and dismantling Should be installed and used under the supervision of a Competent Person

Fall Restraint Restraint Line Edge Fall restraint assumes the employee cannot reach the edge. He is basically on a short leash. If the employee could reach to the edge and fall over the edge, he must be in fall arrest.

Use of Restraint Cables Example of restraint cables used during deck anchoring. RESTRAINT CABLE

Will This Work? Fall Protection Susan Harwood Grant Training Program What are some of the problems in this picture? D-ring too low on the wearer’s back… Retractable tied at the end of a long line, allowing the line itself to become fall protection, possibly allowing a swing fall, a fall in excess of 6’, or excessive impact forces… Vertical lifeline (supposed to be vertical) looped all over the deck – who knows how much slack? How far is it to grade below? (In this instance it was about 10-12’) Retractables are typically designed to be used overhead, and many manufacturers specifically exclude use horizontally, as locking mechanisms may not function properly… Susan Harwood Grant Training Program

Fall Protection Worst-case Scenario? Planning For Rescue Worst-case Scenario? 911 is not necessarily an adequate response Susan Harwood Grant Training Program

When All Works!

Rescue Plan Put Into Motion Fall Protection Rescue Plan Put Into Motion Follow requirements in 1926.550(g) for the use of personnel platforms Susan Harwood Grant Training Program

Safe

On The Ground And Still Alive!

Training Define “Adequate”

Training By a “qualified” or “competent” person The nature of hazards Appropriate systems and use Limitations Evaluated Re-training Documentation/Certification?

Classroom

Hands-on

Site Specific

Planning for Fall Protection Best practice dictates that fall protection becomes an integral part of the project planning process, from constructability, to systems installation, to use and maintenance A project cannot be truly safe unless fall protection is incorporated into every phase of the construction process Planning will keep workers safe and minimize liability for all parties involved Photos shown in this presentation may depict situations that are not in compliance with applicable OSHA requirements. It is not the intent of the content developers to provide compliance-based training in this presentation, the intent is more to address hazard awareness in the construction industry, and to recognize the overlapping hazards present in many construction workplaces. It should NOT be assumed that the suggestions, comments, or recommendations contained herein constitute a thorough review of the applicable standards, nor should discussion of “issues” or “concerns” be construed as a prioritization of hazards or possible controls. Where opinions (“best practices”) have been expressed, it is important to remember that safety issues in general and construction jobsites specifically will require a great deal of site- or hazard-specificity – a “one size fits all” approach is not recommended, nor will it likely be very effective. No representation is made as to the thoroughness of the presentation, nor to the exact methods of remediation to be taken. It is understood that site conditions vary constantly, and that the developers of this content cannot be held responsible for safety problems they did not address or could not anticipate, nor those which have been discussed herein or during physical presentation. It is the responsibility of the employer, its subcontractors, and its employees to comply with all pertinent rules and regulations in the jurisdiction in which they work. Copies of all OSHA regulations are available from your local OSHA office, and many pertinent regulations and supporting documents have been provided with this presentation in electronic or printed format. It is assumed that individuals using this presentation or content to augment their training programs will be “qualified” to do so, and that said presenters will be otherwise prepared to answer questions, solve problems, and discuss issues with their audiences. Areas of particular concern (or especially suited to discussion) have additionally been marked with a ? symbol throughout the program…as a presenter, you should be prepared to discuss all of the potential issues/concerns, or problems inherent in those photos particularly. Susan Harwood Grant Training Program

Questions?