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December 2016

Heads up: Fall protection requirements for construction are about to change

There are two new safety requirements in store next year for employers who do construction work in Oregon and they are both about fall protection.

  • On Jan. 1, Oregon OSHA's 10-foot trigger height – the minimum height at which workers must be protected from falls – will fall to six feet (no pun intended).
  • On Oct. 1, slide guards will no longer be permitted as a method of protecting workers from falling off of sloped roofs.

These new requirements mean that – if you do construction work – you will need to use some form of fall protection to prevent your employees from falling six feet or more to a lower level, beginning Jan. 1, 2017. And, if you are using slide guards as fall protection, you will have to replace them with another type of fall protection, starting Oct. 1, 2017.

The six-foot trigger-height requirement is not entirely new for Oregon construction contractors; it's always been required for work on established floors, mezzanines, balconies, and walkways that have unprotected sides and edges. And many large commercial construction contractors are already using some using fall protection at six feet. More likely to be affected by the new requirements are contractors who do construction projects on singlefamily homes that have a ground-to-eave height between six and 10 feet and those who do projects where slide guards are used for fall protection.


Why did the rules change?

The story goes back to June 2013, when federal OSHA began reviewing fall protection requirements in the 26 states and territories that have some form of OSHA-approved state plan.

OSHA identified Oregon's 10-foot trigger height for construction work and the use of slide guards as areas of concern. At issue was whether the 10-foot trigger height and the use of slide guards as a means of fall protection were as effective as OSHA's requirements. (OSHA required a six-foot trigger height for fall protection and prohibited the use of slide guards in 24 states that are under its jurisdiction).

Lowering Oregon OSHA's 10-foot general trigger height to six feet and prohibiting the use of slide guards as fall protection were necessary to ensure that Oregon OSHA's requirements were at least as effective as federal OSHA's.

What rules have changed?

The key change – in Oregon OSHA's Subdivision 3/M fall protection requirements – states [Except where permitted by another standard,] "when employees are exposed to a hazard of falling 6 feet or more to a lower level, the employer must ensure that fall protection systems are provided, installed and implemented…"

The rules that permitted the use of slide guard systems, manufactured roof brackets, and jobmade slide guards were also repealed.

The fall protection trigger height requirements in Subdivisions 3/L (Scaffolding), 3/R (Steel Erection), 3/S (Underground Construction), and 3/CC (Cranes and Derricks in Construction) are not affected.

What do the changes require me to do?

If your employees are exposed to a hazard that could cause them to fall six feet or more to a lower level, you must use a fall protection method described in Subdivision 3/M to protect them.

Seven ways to prevent falls at your site

For many in the construction industry, equipment is the first thing that comes to mind as a means for preventing falls. But fall protection is more than just equipment. Here are seven ways to prevent falls at your site.

1 Make fall protection part of your safety program and ensure that everyone has a role to play in preventing falls.

Effective safety programs have committed managers and involved employees – they are committed to safety and involved in keeping your site hazard free.

2 Enforce safe practices with on the job supervision

Effective supervisors know how to motivate employees and, when discipline is necessary, they know how to apply it fairly. Essential tasks for supervisors:

  • Verify that employees have been trained and can safely perform their work.
  • Periodically review the safety performance of each employee.
  • Instruct, retrain, or discipline employees who work unsafely.
  • Closely supervise new employees after they have been trained.
  • Require employees to demonstrate they can work safely before permitting them to work independently.

3 Prepare a safety policy

Does your company have a written safety policy? It should. A written policy reflects commitment to a safe and healthful workplace, summarizes management and employee responsibilities, and emphasizes the importance of your safety program. Keep the policy brief, commit to it, and enforce it.

Falls to a lower level are the leading type of fall in the construction industry

graph showing total numbers of falls grouped by cause

4 Designate competent and qualified persons

The competent person

  • Is responsible for recognizing hazards that cause falls and warning workers about the hazards
  • Trains employees to recognize fall hazards and follow safety procedures
  • Serves as the monitor when a safety-monitoring system is used as a fall protection method
  • Determines, when safety nets are used, if the nets meet Subdivision 3/M requirements
  • Inspects a personal fall-arrest system after it arrests a fall and determines if the system is damaged
  • Evaluates any alteration in a personal fall-arrest system and determines if it is safe to use

The qualified person

  • Supervises the design, installation, and use of horizontal lifeline systems and fall restraint and fall arrest anchors

5 Plan to prevent falls

Consider factors such as the following to help you plan your job at the site:

  • Which areas of the project are most likely to have fall hazards? What can you do to prevent falls from happening?
  • What tasks could expose employees to fall hazards?
  • Are walking and working surfaces structurally sound and stable?
  • How will employees access and move about the structure to do their jobs? Will they move horizontally, vertically, or in both directions?
  • Will guardrails and covers for holes meet Subdivision 3/M requirements?
  • Are there existing anchors for arrest and restraint systems? Do they meet Subdivision 3/M requirements?
  • Have employees been trained to use ladders properly?
  • Will other contractors' employees be exposed to falls after your employees finish their work? Who is responsible for ensuring that fallprotection, such as guardrails and covers, are replaced if they have been removed to finish a job?

Most falls happen between six feet and 20 feet

graph showing fall distance resulting in overnight hospitalizations of at least one night between October 2014 and October 2016

6 Train workers about fall protection

Don't assume your employees know how to protect themselves from falls. They may not be familiar with fall hazards at a new job site or know how to protect themselves until you train them.

Employees must be trained before they begin tasks that could expose them to falls and before they use fall-protection equipment. They must know how to recognize fall hazards and follow safe practices.

Put it in writing: You must document in writing that employees have been trained and that they

know what fall-protection systems or methods to use, how to use them, and when to use them, regardless of their experience. Include their names, training dates, and the trainer's signature.

Employees must be retrained for any of the following reasons:

  • They don't recognize fall hazards.
  • They don't understand the procedures that control the hazards.
  • Changes in the workplace or the fallprotection systems or methods make previous training obsolete.

7 Use equipment that prevents falls from happening

When possible, use equipment such as guardrails, covers, and restraint systems that will eliminate employees' chances of falling.

If it's not possible to eliminate fall hazards, protect workers if they do fall. Use equipment that will minimize the risk of injury if a worker does fall. Options include personal fall arrest systems and safety nets. Also, develop a rescue plan that tells employees how to respond if something does go wrong.

Fall hazards: Know how to spot them

Most people don't enjoy falling when a soft landing isn't an option. Those unintended experiences are usually caused by fall hazards. You can avoid them if you know where to look and how to prevent them. Here's a summary:

Fall hazards

What to do

Wall openings

Use guardrails, safety nets, arrest, or restraint systems if the inside bottom edge is less than 39 inches high and the outside bottom edge is six feet or more above a lower level.

Holes in roofs and floors

Cover them or use an equivalent method to prevent trips and falls.

Attics

Use a fall protection system described in Subdivision 3/M to prevent falls of six feet or more to a lower level.

Skylights and smoke domes

Ensure that skylights and smoke domes meet Subdivision 3/M strength requirements – or use guardrails or barricades to protect employees.

Roofs

Use a fall protection system described in Subdivision 3/M to prevent falls of six feet or more to a lower level.

Stairways, ramps, and walkways

Stairways that have four or more risers or that rise more than 30 inches, whichever is less, must have at least one handrail and one stair rail system along each unprotected side or edge.

Ramps and walkways must be at least 18 inches wide and support at least four times the maximum intended load. The maximum slope cannot exceed one vertical foot for every three horizontal feet.

Excavations

Use guardrails, fences, or barricades to protect employees when the excavation is six feet or more deep and not readily seen.

Floors with unprotected edges

Use a fall protection system described in Subdivision 3/M to prevent falls of six feet or more to a lower level.

graphic of a house with cut-away views exposing potential fall hazards
You can avoid fall hazards if you know where to look and how to prevent them.

Solving fall protection problems

Most fall protection problems can be solved by planning, training employees how to protect themselves, enforcing safe practices, and using fall protection methods that are appropriate for the project. Consider the following possibilities:

Can you change your construction methods?

Can you modify your construction methods so that you can eliminate or minimize employee's exposure to fall hazards?

Setting floor joists, sheathing, and decking

  • Walk around the house and measure the fall distances on each side.
  • Set 4-6 joists – enough to establish the first row of sheathing – which can provide a place to anchor a fall-restraint or fall-arrest system. Then alternate setting joists and sheathing so there will always be anchor points nearby.
  • Backfill around the foundation when possible. When you do this before framing, it's easier to erect scaffolding, use ladders, and handle material.
  • Erect nonbearing and nonsupporting interior walls after the joists and decking and sheathing are set so there is room for scaffolding.
  • Build wall sections on the ground and use a crane or wall jacks to place them.
  • Attach guardrails to the outside walls before lifting them into place to provide perimeter fall protection on the next level for sheathing and decking and for framing the walls.

Setting trusses

  • Set the hip rafter in place to mark it, and then take it down to saw the plumb cut.
  • Erect and sheet a series of trusses on the ground and then lift the unit into place with a crane.
  • Sheet the gabled end then flip it up and then secure it to two outside supports on the building exterior; this can be done from scaffolding.

Can you use scaffolding?

Setting trusses

Consider having employees work from scaffolding to roll out and set trusses, attach the lateral bracing, nail freeze blocks, cut rafter tails, attach the fascia board, and nail the first row of roof deck sheeting. This keeps them off the top plate and is safer and faster than using a ladder.

Setting floor joists, sheathing and decking

  • Attach a carpenter's bracket or top plate bracket scaffold to the inside or outside of the exterior walls. Two two-inch by six-inch planks or a 12-inch-wide fabricated scaffold plank can be used for the platform. The scaffolding can be used for setting floor joists and attaching the first row of decking and sheathing. When the scaffold brackets are set so that the platform is 39-45 inches below the top plate, the top plate becomes a guardrail.
  • Place a two-by-four across door and window openings when the distance between the bottom of the header and the scaffold platform is greater than 20 inches.

Working on the roof

Scaffolding can be erected at the edge of the roof or as a catch platform. Catch platforms must have a standard guardrail and toeboard and extend at least two feet past the eave overhang; the guardrail must extend substantially above the slope plane of the roof and prevent a person from passing over or through the rails.

Working in attics

It is challenging trying to move through a cramped attic to do a job while avoiding falling through the joists. Consider using stationary or mobile scaffold platforms under the work area.

Can you use an aerial lift?

Setting floor joists, sheathing, and decking

With enough room and a solid level surface, you can use a scissor lift to set joists or help with decking and sheathing work – and it's not necessary to use a harness or a lanyard in a scissor lift.

Working on the roof

On stable, level terrain, you can use an aerial lift to access hard-to-reach areas near the eave of a roof.

You can also use a work platform attached to the forks of a rough-terrain forklift if the worker on the platform uses a fall-arrest or restraint system, guardrails are at the proper height, and the fall protection anchors will hold 5,000 pounds. The platform floor can't exceed the overall width of the truck measured across the load-bearing tires plus 10 inches on either side.

Don't forget guardrails

Working on the roof

Guardrails can be attached to the edge or surface of the roof, or held in place by a weighted counter-balance system.

Working on established floors

  • Guardrails are the most effective method for protecting employees on established floors that have unprotected sides and edges. Use temporary guardrails until permanent guardrails can be installed.
  • When workers need to remove guardrails temporarily, they must use another fall-protection system or method until the guardrails are replaced.

Access areas

Reusable, temporary guardrail systems make it easy to construct freestanding railings for stairways, ramps, walkways, and balconies.

Arrest and restraint systems

Working on the roof

Personal fall arrest and fall-restraint systems are the best options when permanent anchors are available or when secure temporary anchors can be installed. Remember that the anchor for a personal fall arrest system must be able to support at least 5,000 pounds and 3,000 pounds for a personal fall arrest system.

What about ladders?

Falls from ladders are a leading source of injuries in the construction industry, but ladders are an option when there aren't safer ways to work above a lower level.

If you have employees who use ladders, make sure that a competent person has trained them. Their training must cover ladder hazards, how to use ladders, ladder capacities, and Oregon OSHA's requirements for the ladders they use.

Other options

Other fall protection options include safety nets, positioning devices, and warning lines and safety monitoring systems for roofing work. You'll find the requirements in Oregon OSHA's Subdivision 3/M fall protection requirements (1926.502, Fall protection systems, criteria, and practices).


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