At What Height is Fall Protection Required? Every safety professional wishes this was a simple answer. One height across all tasks and industries would certainly make enforcement easier, but this is not the case under OSHA. Whether the varying height requirements for fall protection are for good reason or not is up for debate, but the fact remains that they are law and they are what can be enforced. However, keep in mind that contracts and/or site policies sometimes go above and beyond the regulatory requirements, so you need to be aware of what the rules of your site are. The Basics There must be a starting point from which to work so that when nothing else seems to fit, you can know what the default answer is. •For General Industry, this is at 4’. • For Construction, the default answer is 6’. •In shipyard work and marine terminal work, your trigger height may be 4’ or 5’ depending on the situation This means that at any point your employees are exposed to heights equal to or greater than these, they must have some sort of protection, whether it be fall arrest systems, railings, or some other means. Look around your facility or jobsite. Are there locations above these heights where employees could be reasonably expected to go? If so, are they protected? If not, what is your plan? The No Minimum Height Rule There is an instance in which there is NO minimum height, and it is important to understand. If your employees are working over dangerous equipment, machinery, or any hazard into which they could fall, they must have fall protection at all times or machine guarding needs to be put into place. No exception. Exceptions to the Basics There are a number of exceptions to the basic rules – the aforementioned defaults, many in the construction industry. Remember, construction is dynamic. It is harder to recognize a fall hazard and have a railing system permanently installed like you might be able to do on a manufacturing floor. Due to this, a few exemptions have sprung up over the years. Scaffolding According to Subpart L of the Construction regulations, fall protection on scaffolding is not required until you are greater than 10’ off the lower level. This allows scaffold users to not have to worry about rails or other means of fall protection every time they set up a single bay or level of scaffolding. Most frame scaffolds are greater than 6’ high, but less than 10’. This exemption allows for unprotected work on top of a single bay of scaffolding. There is, however, an exception to the exception. Boom lifts fall under the scaffolding regulations. Anyone in the basket of a boom-lift must be tied-off at all times using a travel restraint lanyard. This is due to the potential to be brought above the 10’ mark (and let’s be honest, the vast majority of work done from a boom lift is well above 10’) as well as the potential for being catapulted from the basket. Steel Erection The Steel Erection regulations, Subpart R of the Construction standards, are notorious for being lenient and difficult to understand. Simply put, anybody involved in steel erection activities is not required to have fall protection until they are 15’ in the air (the exception to the exception would be somebody in a boom lift who is still required to be tied off at all times). Here’s where it gets tricky. Connectors – those employees on a steel erection crew actively receiving and connecting steel members – do not need to be tied off up to 30’ or two stories, whichever is less. HOWEVER, they MUST be wearing the proper fall protection equipment and have an approved anchor point after 15’. In this situation, a connector may choose to not tie off, but the ability to tie off must exist. Common problems safety professionals run into while attempting to enforce this subpart are all members of a steel erection crew believing they get the 30’ rule or every member of the crew trying to claim that they are connectors. It is important that the safety professional be aware of the definition of a connector and who is required to be tied off at what point. In addition, many crews either forget or are unaware of the ‘or two stories, whichever is less’ portion of the rule. Connectors may be required by law to be tied off at, say, 24’, if it was two stories of 12’ each while they would not be required to be tied off if it was one story of 24’. Deckers are also allowed a 30’ exception. This exception basically says that deckers may establish a CDZ (Controlled Decking Zone) into which access is restricted and in which fall protection is not necessary. This exception is good, just as the connector’s exception is, up to 30’ or two stories, whichever is less. Stairs and Ladders Most people don’t think about fall protection when it comes to ladders and stairways, mostly because stairwells are often enclosed or have some type of railing by the time you are using them, but in construction this is not always the case. OSHA requires in subpart X that all stairways having four or more risers or that rise more than 30 inches be equipped with a stair rail along each unprotected side or edge. This is important to remember since temporary stairs are often built on jobsites or new staircases are installed without railings and/or without the walls that will eventually enclose them. Ladders are a bit different and fall protection mostly comes into play with fixed ladders. With fixed ladders, the key number to remember is 24’. In any instance where the climb on a fixed ladder is greater than 24’ or where the climb is less than 24’ but the top of the ladder is greater than 24’ above a lower level, fall protection must be provided as one of the following: a ladder safety device, a self-retracting lifeline, or a cage or a well. Climbing Vertical Rebar Assemblies For this exemption, you need to dig a little deeper. In the past, concern was raised as to whether or not fall protection was needed for employees climbing on the face of a vertical rebar assembly such as one that would be constructed for a wall that was to be poured in place. In a letter of interpretation dated December 23, 1994, OSHA states that fall protection is not required while the employees are in motion up to 24’ because they consider the multiple handholds and footholds of a vertical rebar assembly to provide similar protection as that of a ladder. However, just as in the ladder standard, should that employee need to climb to a height greater than 24’, they would be required to utilize fall protection. In addition, note that this exception is given during climbing or moving only. Once the employee reaches their place of work, they would need to have fall protection which could be a harness and lanyard or a positioning belt. In the end, there is no single simple answer. As a safety professional or the person in your organization responsible for employees working at heights, it is imperative that you look at each situation and determine what is required. Be aware that certain companies may perform activities that fall under the general industry regulations and others that fall under the construction regulations. Find which standard is applicable, then find the section within that standard that addresses the work you are performing. Remember that a more specific section (vertical standard) always overrides a broader section (horizontal standard). For instance, Subpart R for steel erection (a vertical standard) overrides Subpart M for Fall Protection (a horizontal standard). If there is no applicable section to what you are doing, remember your industry defaults. And don’t forget to check if your facility or jobsite goes beyond the OSHA requirements. When it comes to falling, you can never be too safe.
Posted on: Tue, 22 Oct 2013 06:48:54 +0000
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