FAQs on new OSHA Fall Protection Regulations: Vol. 4 – Assessments II

Following up on Volume 3 in our series, this installment answers additional questions related to the new requirement for conducting fall hazard assessments.

When does the assessment need to be complete?

Technically, the new regulation became rule in January 2017, so it is theoretically required now. If you don’t have documentation of a compliant assessment now, get a plan in the works. While it is unclear if or when OSHA will cite employers for not having the required assessment, it is clear from the regulation and related commentary that OSHA’s intent is for organizations to proactively identify hazards, rather than waiting until an issue or new project arises.

The cost, time and other resources required to complete an assessment depends on the scope and size of your facilities and operations, so we expect some leniency if your organization takes a phased approach – as long as there is an active plan in place. We’ve identified well over 200,000 hazards in various assessments we’ve performed, so if you need to better understand strategies to accomplish this, please contact me.

Who has to perform the assessment? What are the required qualifications of the assessor?

First, it’s important to note that OSHA does NOT require a third-party assessment, so the work does not necessarily have to be outsourced. However, the assessor must have adequate knowledge of fall hazards, so you need to think about whether your personnel truly have the qualifications—or more importantly, will OSHA believe that your internal staff has the qualifications and time to assess properly?

If you don’t have anyone that fits OSHA’s definition of a Competent or Qualified Person—or if you just don’t think your team has the capacity or objectivity to do it right—you may want to consider outsourcing the task.

Please subscribe or check back next Wednesday morning for the next installment in this blog series, which focuses on new requirements for rope descent system anchorages. And, if you have your own specific questions, please comment below.