Implement Appropriate Fall Protection Systems

Construction is a hazardous profession.

Employees are routinely exposed to changing conditions, environments and hazards not found in the traditional workplace. Last year, the construction industry alone experienced more than 412,000 record injuries. 

This means that one in every five workers was injured on the job, and a large portion of these injuries were caused by falls. Fall hazards continue to top the charts in employer citations and fines as one of OSHA’s most violated standards. And each year, between 150 and 200 workers are killed and more than 100,000 are injured as a result of falls on construction sites.

To help protect your employees, business and bottom line, you must understand why falls occur. OSHA recognizes that accidents involving falls are generally complex events, frequently involving a variety of factors. Consequently, the standard for fall protection deals with both the human- and equipment-related issues. For example, employers and employees are required by OSHA standards to do the following:

• Select fall protection systems appropriate for given situations where protection is required.
• Use proper construction and installation of safety systems.
• Supervise employees properly.
• Use safe work procedures.
• Train workers in the proper selection, use and maintenance of fall protection systems.

In order to protect worker safety and health, OSHA requires employers to provide fall protection, sets the criteria and practices for fall protection systems and requires training.

Under 29 CFR Subpart M, “Fall Protection,” employers must assess the workplace to determine if the walking or working surfaces have the strength and structural integrity to safely support workers. Employees are not permitted to work on those surfaces until the surface is considered safe with the requisite strength and structural integrity to support the workers.

Once the surface is considered safe, the employer must select a fall protection option that is suitable for the work operation if a fall hazard is present. For example, if an employee is exposed to a 6-foot drop from an unprotected side or edge, the employer must select either a guardrail system, safety net system or personal fall arrest system to protect the worker.

OSHA specifically addresses some of the following types of fall protection: controlled access zones, safety nets, guardrail systems and personal fall arrest systems.

Controlled Access Zones

A controlled access zone is a work area designated and clearly marked for certain types of work.  For example, overhand bricklaying may take place without the use of conventional fall protection systems-guardrail, personal arrest or safety net-to protect the employees working in the zone. Instead, controlled access zones are used to keep out workers who are not authorized to enter work areas from which guardrails have been removed. Where there are no guardrails, the masons, in this example, would be the only workers allowed in controlled access zones.

Controlled access zones, when created to limit entrance to areas where leading edge-work and other operations are taking place, must be defined by a control line or by any other means that restrict access. Control lines can be constructed of ropes, wires, tapes or equivalent materials, and supporting stanchions, and each must be:

• Flagged or otherwise clearly marked at not more than 6-foot intervals with high-visibility material
• Rigged and supported in such a way that the lowest point (including sag) is not less than 39 inches from the walking/working surface and the highest point is no more than 45 inches-or more than 50 inches when overhand bricklaying operations are being performed-from the walking/working surface
• Strong enough to sustain stress of no less than 200 pounds; control lines should extend along the entire length of the unprotected or leading edge and run approximately parallel to the unprotected or leading edge
• Control lines also must be connected on each side to a guardrail system or wall

Safety Nets and Guardrail Systems

Many employers are aware that employees must be protected when working from a height but fail to realize that falls can occur in other places as well. Excavations are a perfect example of this. Often, employees work at the edge of excavations 6 feet or deeper and are not protected from falling with guardrail systems, fences, barricades or covers as required by the OSHA standards. Where walkways are provided to permit employees to cross over excavations, guardrails are also required on the walkway if the fall would be 6 feet or more to the lower level.

Holes in a walking or working surface also pose a hazard to workers. A “hole,” according to OSHA, is “a void or gap 2 inches or more in the least dimension in a floor, roof or other walking/working surface. ”  OSHA requires that all such holes be covered, and all covers must be able to support at least twice the weight of employees, equipment and materials that may be imposed on the cover at any one time. To prevent accidental displacement resulting from wind, equipment or workers’ activities, all covers must be secured and bear the markings “Hole” or “Cover.”  A piece of plywood, a few nails and a can of spray paint will do the trick.

If the employer chooses to use guardrail systems to protect workers from falls, the systems must meet regulations. A framer who only nails up a few 2×4’s can get you into some trouble if he or she is not trained on the requirements. Top-rails and mid-rails of guardrail systems must be at least ¼-inch nominal diameter or thickness to prevent cuts and lacerations. If wire rope is used for top-rails (usually on commercial steel erection), it must be flagged at less than 6 feet intervals with high-visibility material.

Steel and plastic banding, or formed steel banding such as steel studs, cannot be used as top-rails or mid-rails. The top edge height of top-rails or (equivalent) guardrails must be 42 inches from the walking or working surface plus or minus 3 inches. When workers are using stilts such as in residential drywall activities, the top edge height of the top rail or equivalent member must be increased by an amount equal to the height of the stilts.

Screens, mid-rails, mesh, intermediate vertical members or equivalent intermediate structural members must be installed between the top edge of the guardrail system and the walking or working surface when there are no walls or parapet walls at least 21 inches high. When mid-rails are used, they must be installed at a height midway between the top edge of the guardrail system and the walking or working level. When screens and mesh are used, they must extend from the top rail to the walking/working level and along the entire opening between top rail supports.

Once the guardrail system is properly installed, there is still another catch: It has to work to protect the employees. For this reason, OSHA also requires that the guardrail system must be capable of withstanding a force of at least 200 pounds applied within 2 inches of the top edge in any outward or downward direction. When the 200-pound test is applied in a downward direction, the top edge of the guardrail must not deflect to a height less than 39 inches above the walking or working level.

Mid-rails must be capable of withstanding a force of 150 pounds applied in any downward or outward direction. Because hands often grab guardrails during the course of a day, OSHA also requires that guardrail systems are surfaced to protect workers from punctures or lacerations and to prevent clothing from snagging. The ends of top-rails and mid-rails are not allowed to overhang terminal posts either, unless the overhang does not constitute a projection hazard.

Personal Fall Arrest Systems

One of the most commonly used forms of fall protection in the jobsite is the personal fall arrest system. This system consists of an anchorage, connectors and a body harness and may include a deceleration device, lifeline or suitable combinations. If a personal fall arrest system is used for fall protection, the employee must be trained on its use, proper care and maintenance. OSHA requires that anchorages be designed, installed and used under the supervision of a qualified person, as part of a complete personal fall arrest system. An easy way to meet this requirement is to purchase anchor points and follow the manufacturer’s guidelines for proper installation.

Employees using a personal fall arrest system must manipulate in a way to avoid free falling more than 6 feet and contacting any lower level. Calculating the distance of a fall before the fall arrest system stops your employees is not just an OSHA requirement, but also may be the difference between life or death. Make sure employees are trained on this!

There are many more fall protection standards that may apply to you. Refer to 29 CFR 1926 Subpart M to ensure your type of work or work environment is in compliance. If you need assistance, OSHA’s area offices offer a variety of informational services, such as publications, audiovisual aids, technical advice and speakers for special engagements.

Construction Business Owner, Decemebr 2008