Achieving compliance with new OSHA fall protection regulations

Now that the OSHA rule on Walking-Working Surfaces and Personal Fall Protection Systems (29 CFR 1910 Subparts D&I) has been effective for more than a year, organizations are still working to understand and implement required changes to fall protection projects, policies and programs. As a bottom line up front, compliance with the ANSI Z359 Fall Protection Code is your surest way to create a safe, cost-effective and compliant fall protection program.  More information can be found here: http://www.asse.org/departments/standards/fall_protectionarrest_z359/

Getting back to OSHA, if your organization has not already reviewed the new regulations, planned for changes and started implementation, you are behind the curve. Other than a few items that have specified compliance dates, the majority of the changes were effective immediately upon publication of the rule in January 2017.

The list below outlines some significant changes and requirements that organizations should already be in compliance with today:

• Fall hazard risk assessments, with documentation, are now required (1910.132(d))
• Ladder design changes related to clearances, rung spacing, etc. (1910.23)
• Stair design changes related to handrail, etc. (1910.25)
• Guardrail design changes related to spacing, swing gates, etc. (1910.25)
• Building owner responsibility for certification of anchorages for rope descent systems (1910.27(b)(1)(i))
• Documented load rating of all walking-working surfaces (1910.22 (b) and (d)(1))
• Training for all workers exposed to fall hazards or using fall protection equipment (1910.30)

Another significant development with the new regulation is the inclusion of guidelines regarding safe distance to a roof edge for low slope roofs. The regulation states that work at less than six feet from the roof edge requires conventional means of protection (guardrail, personal fall arrest, etc.). From six-15 feet, the new rule allows for a designated area for infrequent or temporary work, which are further defined in the commentary section of the rule.

Similar to the construction regulations, a warning line is also required at six feet to serve as a warning that a worker is nearing an unprotected edge. For work more than 15 feet from a roof edge, the new rule states that the employer is not required to provide any permanent or temporary fall protection, provided the work is both infrequent and temporary. In this last case, the language allows for the application of an administrative control and training, preventing workers from getting closer than 15 feet from an unprotected edge.

In addition, as of November 2018, all new fixed ladders exceeding 24 feet must include a ladder safety system or active fall protection system, with all ladders of this nature—regardless of age—needing to have these safety measures by 2036.

With recent increases in fall fatalities and fall protection-related citations, it’s no surprise that fall protection is, and will continue to be, a hot topic for OSHA. Now’s the time to make a concerted effort toward reviewing and updating your policies and procedures.

If you’re looking for a place to start, my recommendation is to first tackle the assessment and training pieces so that you can accurately describe the current state to leadership within your organization. From there, you can effectively build a master plan that will allow you to improve safety and reduce risk for your workers-at-height in a systematic manner, with phased plans and related budgets.