ASSE to OSHA: Use consensus standards when developing rule for reducing slips & falls (8/27)
In a recent letter to OSHA on the proposed ‘Walking-Working Surfaces and Personal Protective Equipment’ rule (29 CFR, Part 1910), the American Society of Safety Engineers (ASSE) urged OSHA to utilize existing fall standards and the voluntary consensus standards process widely used in industry as it develops the new rule.
ASSE believes the process and the end users would be better served if standards such as the American National Standards Institute (ANSI) ANSI/ASSE Z359 Fall Arrest Code as well as the ANSI/ASSE A1264.1-2007 Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace Floor, Wall and Roof Openings; Stairs and Guardrails Systems standards were utilized in developing the OSHA rule.
A voluntary consensus standard is a documented agreement, established by a consensus of subject matter experts and approved by a recognized body that provides rules, guidelines or characteristics to ensure that materials, products, processes and services are fit for their purpose. Voluntary consensus standards developed by industry in accordance with ANSI’s procedures for due process, openness and consensus are often subsequently adopted by the government as part of the regulatory framework. Currently, ASSE is secretariat for 11 standards projects overseeing several committees made up of subject matter experts.
In his August 19 letter to Assistant Secretary of Labor for OSHA David Michaels, ASSE President Darryl C. Hill, Ph.D., CSP, said, “ASSE’s members are most concerned with several inconsistencies between the proposed rule and relevant consensus standards. We believe OSHA has been given a responsibility to utilize consensus standards like Z359 and A1264 by Congress in Public Law 104-113, ‘The National Technology Transfer and Advancement Act of 1995’ and through the Office of Management and Budget’s Circular A-119, ‘Federal Participation in the Development and Use of Voluntary Consensus Standards and in the Conformity Assessment Activities’.
“We understand the agency’s responsibilities in developing a standard are more complex than simply mirroring consensus standards and that its current ability to update references to consensus standards is inadequate, but we believe the ANSI/ASSE Z359 and the ANSI/ASSE A1264.1-2007 standards developed by subject matter experts should be used in developing this rule revision,” Hill said. “ASSE supports the performance-oriented approach that would set a general requirement coupled with a non-mandatory appendix of appropriate national consensus standards proposed in OSHA’s rulemaking, ‘Updating OSHA Standards Based on National Consensus Standards; Personal Protective Equipment’. We urge OSHA to move that proposal forward, especially when it comes to enhancing workplace safety and health.”
ASSE stated its overall appreciation for OSHA’s effort in this rulemaking to be consistent with the approaches to fall protection reflected in current national voluntary consensus standards and that some of the concerns ASSE raised earlier in the rulemaking process have been addressed.
However, there are concerns. Hill commented on several specific topics that ASSE’s members believed OSHA had not gone far enough in addressing in the rule including body belts for work positioning devices; the hierarchy of controls in Z359; fall protection on rolling stock and motor vehicles; fall protection for employees standing or climbing on stacked materials; qualified climbers; qualified person inspecting walking/working surfaces; trigger heights; training; competent person; body belts; snaphooks; personal fall protection systems; the deceleration distance requirement; the conversion factor; and, positioning systems.
“While ASSE’s members have various concerns about the current proposed rule, we do commend OSHA for its efforts to advance this rulemaking and offer whatever assistance our members or the Z359 and A1264 committees can provide to help ensure a positive outcome,” Hill concluded.
ASSE believes the process and the end users would be better served if standards such as the American National Standards Institute (ANSI) ANSI/ASSE Z359 Fall Arrest Code as well as the ANSI/ASSE A1264.1-2007 Safety Requirements for Workplace Walking/Working Surfaces and Their Access; Workplace Floor, Wall and Roof Openings; Stairs and Guardrails Systems standards were utilized in developing the OSHA rule.
A voluntary consensus standard is a documented agreement, established by a consensus of subject matter experts and approved by a recognized body that provides rules, guidelines or characteristics to ensure that materials, products, processes and services are fit for their purpose. Voluntary consensus standards developed by industry in accordance with ANSI’s procedures for due process, openness and consensus are often subsequently adopted by the government as part of the regulatory framework. Currently, ASSE is secretariat for 11 standards projects overseeing several committees made up of subject matter experts.
In his August 19 letter to Assistant Secretary of Labor for OSHA David Michaels, ASSE President Darryl C. Hill, Ph.D., CSP, said, “ASSE’s members are most concerned with several inconsistencies between the proposed rule and relevant consensus standards. We believe OSHA has been given a responsibility to utilize consensus standards like Z359 and A1264 by Congress in Public Law 104-113, ‘The National Technology Transfer and Advancement Act of 1995’ and through the Office of Management and Budget’s Circular A-119, ‘Federal Participation in the Development and Use of Voluntary Consensus Standards and in the Conformity Assessment Activities’.
“We understand the agency’s responsibilities in developing a standard are more complex than simply mirroring consensus standards and that its current ability to update references to consensus standards is inadequate, but we believe the ANSI/ASSE Z359 and the ANSI/ASSE A1264.1-2007 standards developed by subject matter experts should be used in developing this rule revision,” Hill said. “ASSE supports the performance-oriented approach that would set a general requirement coupled with a non-mandatory appendix of appropriate national consensus standards proposed in OSHA’s rulemaking, ‘Updating OSHA Standards Based on National Consensus Standards; Personal Protective Equipment’. We urge OSHA to move that proposal forward, especially when it comes to enhancing workplace safety and health.”
ASSE stated its overall appreciation for OSHA’s effort in this rulemaking to be consistent with the approaches to fall protection reflected in current national voluntary consensus standards and that some of the concerns ASSE raised earlier in the rulemaking process have been addressed.
However, there are concerns. Hill commented on several specific topics that ASSE’s members believed OSHA had not gone far enough in addressing in the rule including body belts for work positioning devices; the hierarchy of controls in Z359; fall protection on rolling stock and motor vehicles; fall protection for employees standing or climbing on stacked materials; qualified climbers; qualified person inspecting walking/working surfaces; trigger heights; training; competent person; body belts; snaphooks; personal fall protection systems; the deceleration distance requirement; the conversion factor; and, positioning systems.
“While ASSE’s members have various concerns about the current proposed rule, we do commend OSHA for its efforts to advance this rulemaking and offer whatever assistance our members or the Z359 and A1264 committees can provide to help ensure a positive outcome,” Hill concluded.
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