FAQs on new OSHA fall protection regulations – Blog series, Volume 1

Now that the new OSHA rule on Walking-Working Surfaces and Personal Fall Protection Systems (29 CFR 1910 Subparts D&I) has been out for more than eight months, many organizations are still working to understand and implement required changes to their fall protection programs.

Our team at LJB has been working to educate our clients and friends in the industry since November 2016. We have provided webinars and presentations, as well as individual program or training reviews, to help organizations digest the new requirements and what they mean to their program. Based on all these interactions, I realized that many organizations have similar questions and uncertainties.

So, this blog series is intended to answer some common questions about the new regulations and to provide guidance on how to address these compliance issues. The series is organized into key areas of the regulation: (1) roof edge/designated area; (2) hazard assessments; (3) anchorages; and (4) design changes for items like ladders, stairs and guardrail. We will publish a new volume in the blog series each Wednesday morning, so subscribe now to get notifications about new posts. Please feel free to contact me directly or comment here with questions of your own.

FAQs: Roof Edge and Designated Areas

What should we use as the safe distance to an unprotected roof edge? 

In the new rule, OSHA provides some definition for work on low-slope roofs. These are important to understand since it is contrary to OSHA’s original position that there is no safe distance to an unprotected edge.

This graphic illustrates requirements for NOT infrequent or temporary work on low slope roofs.

 

    • At less than 6 feet from the roof edge, OSHA requires you to use conventional means of protection: guardrail, PFAS, etc.
    • From 6-15 feet, the new rule allows for a designated area for infrequent or temporary work. Similar to the construction regulations, a warning line is also required at 6 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 allows the application of an administrative control, preventing workers from getting closer to an unprotected edge.

On the other hand, this graphic illustrates requirements for infrequent or temporary work on low slope roofs. Take note of the different requirements between 6-15+ feet, compared to the other graphic.

 

Related to the 6-15 foot category, many organizations are questioning the meaning of “infrequent or temporary.” In the commentary section, OSHA gives the following clarifications:

    •  “Brief” “Simple” “Short-term”
    • Performed in less time than set up of fall protection
    • Completed at one time
    • Does not require significant equipment, personnel or resources
    • Only on occasion
    • Not routine part of job
    • Examples include:
      1. Annual maintenance
      2. Monthly replacement of batteries, filters, etc.

I believe this lack of definitive definition could open the rule up to interpretation by employers as to what is considered “infrequent or temporary.” Previously, OSHA STD 1-1.13 provided clear guidance on what that was, but it is my understanding that STD 1-1.13 is no longer relevant with the new rule.

Let me know how this new information affects your organization.

Check back next Wednesday for Volume 2 of this blog series, which covers additional FAQs related to roof work.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s

%d bloggers like this: