March 2, 2014 - This month I provide a non-exhaustive overview of the different thresholds for fall protection found throughout the Federal OSHA 1926 construction standards. This is in contrast to last month’s discussion of the 1910 general industry standards, which required some form of fall protection for employees working at heights ranging from ground level all the way up to 24 feet. As you will soon see, the construction regulations are even more varied.
Most people are quite aware that Subpart M of the Federal OSHA 1926 Construction standards mandates the utilization of some form of fall protection device or practice to protect workers from falls of greater than six (6) feet. In fact, you will find fifteen distinct ways that a worker can fall covered in section 1926.501, titled “Duty to have fall protection”. And the allowable methods specified for fall protection devices and practices listed in this Subpart go well beyond merely installing a standard guardrail; other allowable methods include installation of a safety net system, as well as using a personal fall arrest system, body positioning devices, covers, fences, barricades, warning lines, controlled access zones, and a safety monitor system, and even a written fall protection plan. However, be warned that many of these fall protection methods are only allowed in certain situations (a topic I will cover in some detail in a future blog post). So pay careful attention to 1926.501(b) as well as to 1926.502, titled “Fall protection systems criteria and practices”, to make sure you are only utilizing a fall protection device or method which is specifically allowed for a given situation.
As mentioned earlier, there are many other height thresholds other than the six foot rule found in other sections of the Construction standards that trigger a requirement for some form of fall protection. For example, in Subpart X, paragraph 1926.1052(c)(1) of the stairways standard requires a stair-rail be installed along all open sides of stairways having four or more risers or rising more than 30 inches (whichever is less). And paragraph (c)(12) requires unprotected sides and edges of stairway landings be provided with guardrail systems meeting the requirements of Subpart M mentioned above.
In another section of Subpart X that addresses fixed ladders, paragraph (a)(19) requires that when the total length of a climb equals or exceeds 24 feet, the fixed ladder must be equipped with ladder safety devices, a self-retracting lifeline and rest platforms at intervals not to exceed 150 feet, or a cage or well and multiple ladder sections not to exceed 50 feet in length per section. And in those cases where the length of climb is less than 24 feet but the top of the fixed ladder is at a distance greater than 24 feet above lower levels, paragraph (a)(18) of this section also requires fixed ladders be provided with cages, wells, ladder safety devices, or self-retracting lifelines. You might have picked up on the fact that Federal OSHA ladder standards in Subpart X do not have any specific fall protection requirements for portable ladders, and neither does Subpart M.
For scaffolding, paragraph 1926.451(g)(1) in Subpart L of the OSHA construction standards requires specific form(s) of fall protection be provided for workers higher than ten (10) feet above the ground or floor (as was the case in General Industry). Subparagraphs (g)(1)(I0 through (vii) spec out the specific forms of fall protection required, depending on the type scaffolding in use, and typically specify a guardrail system and/or a personal fall arrest system, although (g)(ii) actually allows a three-fourth inch (1.9 cm) diameter grab-line or equivalent handhold securely fastened beside each crawling board as fall protection. And finally, employers are required in paragraph (g)(2) to provide some form of fall protection for employees erecting or dismantling supported scaffolds where the installation and use of such protection is feasible and does not create a greater hazard; the competent person for the scaffold erector makes that determination of feasibility.
Also found in Subpart L is paragraph 1926.453(b)(2)(v), which requires workers using an aerial boom-lift to wear a body belt with lanyard attached to the boom or basket when working in the basket. There is no height specified for this requirement, which is related to the purpose of tying off; this is a body “positioning” device to keep the person from being thrown out of the basket, as opposed to a fall arrest system (see related blog post for additional information about this topic).
There is only one fall protection requirement appearing in Subpart P - Excavations. Paragraph 1926.651(l), which requires a walkway to be provided where employees or equipment cross over excavations, states that guardrails which comply with Subpart M be installed if a walkway is six (6) feet or more above a lower level. But be aware that the general requirement for fall protection involving employees working “around” excavations is actually addressed in section 1926.501 paragraph (b)(7)(i)of Subpart M, which requires that each employee at the edge of an excavation six (6) feet or deeper be protected from falling by guardrail systems, fences, or barricades, but only when the excavations are not readily seen because of plant growth or other visual barrier. However, paragraph (7)(ii) requires that all wells, pits, shafts, and similar excavations 6 feet or more in depth be protected by guardrail systems, fences, barricades, or covers.
Subpart V of 1926, which covers construction work in Power Transmission and Distribution, paragraph 1926.951(b)(1) requires that body belts with straps or lanyards shall be worn to protect employees working at “elevated locations” on poles, towers, or other structures, except where such use creates a greater hazard to the safety of the employees, in which case other safeguards shall be employed. And in paragraph 1926.950(g), crews engaged in work over or near water where a danger of drowning exists must be provided with “suitable” protection as stated in 1926.104 (safety belts, lifelines, and lanyards), 1926.105 (safety nets) , or 1926.106 (floatation devices).
The Demolition standards located in Subpart T specify in paragraph 1926.850(g) that where a hazard exists to employees falling through wall openings, the opening must be protected to a height of approximately 42 inches. And paragraph (h) in that section requires that where debris is dropped through holes in the floor without the use of chutes, the area onto which the material is dropped must be completely enclosed with barricades not less than 42 inches high and not less than 6 feet back from the projected edge of the opening above. And paragraph (i) requires that all other floor openings that are not used as material drops be covered over with material substantial enough to support the weight of any load which may be imposed, and properly secured to prevent its accidental movement. Furthermore, paragraph 1926.852(e) states that any chute opening into which workers dump debris be protected by a substantial guardrail approximately 42 inches above the floor or other surface on which the worker stands to dump the material, and any space between the chute and the edge of openings in the floors through which it passes be solidly covered. And last but not least, 1926.856(b) of the demo standards requires floor openings have curbs or stop-logs to prevent equipment from running over the edge.
A relatively new standard addressing fall protection can be found in the recently revised standards for cranes and derricks in construction (Subpart CC). Paragraph 1926.1423(e)(1) covers fall protection requirements for non-assembly and disassembly work, and specifies the use of fall protection equipment by workers who are on a walking/working surface with an unprotected side or edge more than Six (6) feet above a lower level when moving point-to-point, on a non-lattice boom (any position), on a lattice boom that is not horizontal, or on a horizontal lattice boom where the fall distance is 15 feet or more. The six foot threshold also applies to employees located at a work station on any part of the equipment (including the boom, of any type), except when the employee is at or near draw-works when the equipment is running, in the cab, or on the deck (see paragraph (e)(2)).
But the fall protection threshold is different for workers performing assembly and disassembly work on the crane. Paragraph (f) states that fall protection equipment must be utilized by employees who are on a walking/working surface with an unprotected side or edge more than 15 feet above a lower level, except when the employee is at or near draw-works (when the equipment is running), in the cab, or on the deck. Tower cranes have similar fall protection thresholds as the other type cranes addressed above; see paragraphs (h)(1) and (2).
In those relatively rare occasions where a personnel platform is hoisted by a crane, the platform must be equipped with a standard guardrail system which meets the requirements of Subpart M, and must also be enclosed from the toe-board to mid-rail (or higher) with a solid material or expanded metal with openings no greater than ½ inch, per 1926.1431(e)(6). And paragraph (k)(10)(i) of that section requires that employees occupying the personnel platform use a personal fall arrest system attached to a structural member within the platform, except when working over or near water, where the requirements of 1926.106 (life vests . . .) apply instead.
And the most liberal of all fall protection requirements in the Federal OSHA construction standards can be found in section 1926.760 of the Steel Erection (Subpart R). Employees engaged in steel erection activities on a walking/working surface with an unprotected side or edge more than 15 feet above a lower level must be protected by a guardrail system, safety net system, personal fall arrest system, positioning device system, or fall restraint system, per paragraph (a)(1). However, an employee performing work as a “connector” (the employee who, working with hoisting equipment, is placing and connecting structural members and/or components) is only required to be provided with a personal fall arrest system, positioning device system, or fall restraint system and wear the equipment necessary to be able to be tied off when exposed to fall hazards of more than 15 feet up to 30 feet above a lower level, per paragraph (b)(3). And the actual utilization of the fall protection system is only mandatory whenever the connector is working two stories or 30 feet above a lower level (whichever is less), per (b)(1).
So there is my non-exhaustive review of the various Federal OSHA 1926 construction industry regulations which specify some form of fall protection system be used by workers. As you can see, many are based on the six (6) foot “fall distance” threshold most people in the construction industry are familiar with. But several of these standards have requirements that don’t kick in until the worker is exposed to a fall of ten feet, fifteen feet, and amazingly enough, 30 feet, whereas a few apply regardless of the height. So the next time someone tells you fall protection is only (or always) required above six (6) feet during construction work, recall that is not always the case; sometimes it may be required at lower, or even higher, thresholds.
Were you aware of all the different OSHA construction fall protection requirements appearing in this post? Do you know of any other federal OSHA 1926 construction industry standard that specifies fall protection? If so, please share that information with us in the “Comments” section of this post by clicking here and then scrolling down the page to the “Comments” box. Last but not least, I encourage you to Share This Blog with Others in Your Network who might benefit from reading this post.
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