FAQs on new OSHA Fall Protection Regulations: Vol. 3 – Assessments I

This installment in our blog series on new OSHA fall protection regulations focuses on common questions related to fall hazard assessments.

One of the most significant requirements provided in the new rule is the stated need for the assessment of fall hazards, as outlined in 1910.132(d). It’s important to note that this is an existing rule, but effective January 2017, the requirements now apply to fall protection PPE.

A variety of questions has stemmed from this new requirement.

What exactly does the assessment need to accomplish?

As stated in the regulation text, employers must “determine if hazards are present.” OSHA considers there to be two categories of hazards in your workplace – areas where you have a duty to provide fall protection (e.g., unprotected edges, openings, runways, etc.) and whether the existing systems meet their criteria (guardrail, designated areas, ladder safety systems, etc.).

Beyond just identifying that there is a hazard, the regulation states that employers must select types of PPE to protect employee, communicate to employees, and ensure proper fit of PPE.

OSHA provides an example of a compliant assessment in 1910 Subpart I Non-Mandatory Appendix B. While the example is not specific to fall protection, it shows a sample assessment that includes information on the source of the hazard, assessment of the hazard, the selected protection for each hazard and relevant notes.

What do you have to present to OSHA to show that you’re in compliance?

The rules states that written certification is required, so OSHA will not be taking your word for it. Your documentation needs to answer the following:

  • What workplaces were evaluated
  • Who certifies that the evaluation was performed
  • Date of the assessment

Since OSHA provides and references the example in Non-Mandatory Appendix B, I would consider that to be a bare minimum level of detail to include in an assessment.

Please subscribe or check back next Wednesday morning for the next installment in this blog series, which answers additional questions related to assessments. And, if you have your own specific questions, please comment below.

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