Clearing Up the Confusion Surrounding Fall Protection

Fall protection is defined as any means used to protect workers from falls from heights.

Falls from heights are a concern at many worksites and there are threshold heights established where various types of fall protection are required. For employees in general industry, the height is 4 feet above a lower level. In construction work, the threshold height is 6 feet above a lower level. Fall protection on scaffolding is required at 10 feet. In addition to falls from heights, workers also can slip or trip on ground surfaces that are uneven or cluttered with debris.

GENERAL INDUSTRY

Employees in general industry perform work on scaffolds, climb up and down ladders, walk on stairs, work in areas where there may be holes in the floor or work on elevated floors which have unprotected sides and edges. These workers often need fall protection, and training in how to use it.

The key to protecting employees in these situations is to use the right type of fall protection systems or equipment.

Ladders — First, fall protection is not required for portable ladder use in either general industry or construction work. You don't want employees tying off to ladders or other objects nearby. Fixed ladders are a different story, as they may or may not have cages or ladder safety devices.

OSHA's general industry fall protection regulations are at 29 CFR 1910.23, Guarding Floor and Wall Openings and Holes. Fall protection systems (e.g., guardrails for platforms and railings for stairs) are addressed, but personal fall arrest equipment, such as lanyards and harnesses, are not.

Housekeeping — High traffic areas should be kept free from tools, materials, debris or spilled or leaked liquids. These types of items can contribute to slips and trips on the same level. OSHA requires employers, in 1910.22(a), to keep their facilities clean, orderly and as dry as possible.

For work on a level surface that could pose a slip hazard, you can install slip-resistant floors. Options to increase slip-resistance include materials such as textured, serrated or punched surfaces and steel or metal grating. These types of floor surfaces often can be installed in work areas that are slippery because of wet, oily or dirty operations. Another option is to provide slip-resistant footwear, which also may be useful in reducing slipping hazards.

Guardrails and handrails — Falls from an elevation involve falling from one level to another. Examples include falling from a scaffold to the ground below. There are several types of fall prevention systems you can use to stop a fall from an elevated surface:

A guardrail is a vertical barrier, normally consisting of an assembly of toprails, midrails and posts, erected to prevent employees from falling to lower levels. A toeboard is a barrier placed to prevent the fall of materials to a lower level, or to keep employees' feet from slipping over an edge. Falling objects also can be hazards, especially tools dropped or kicked from scaffolds or work platforms such as scissor or aerial lifts.

A standard railing consists of a top rail, intermediate rail and posts, and has a vertical height of 42 inches from the upper surface of the top rail to floor, platform, runway or ramp level. The top rail must be smooth-surfaced throughout the length of the railing. There must be an intermediate railing approximately halfway between the top rail and the floor.

A standard toeboard needs to be 4 inches in vertical height from its top edge to the level of the floor, platform, runway or ramp. It has to be securely fastened in place and with not more than ¼-inch clearance above floor level. The toeboard can be made of any substantial material that either is solid or has openings 1 inch or less in size.

A handrail is used to assist employees going up or down stairways, ramps or other walking/working surfaces by providing a handhold for support. A stair rail protects employees from falling over the edge of an open-sided stairway.

A handrail is mounted directly on a wall or partition by brackets attached to the lower side of the handrail. The height of handrails must be between 30-34 inches from the upper surface of handrail to the surface of stair tread.

GENERAL INDUSTRY AND CONSTRUCTION

Personal fall arrest equipment — Sometimes fall prevention systems can't be used. In these cases, employers need to provide personal fall arrest equipment. These systems often consist of lanyards, harnesses and anchorage devices that may not prevent the fall, but reduce the chance of injury or death if the employee does fall.

However, personal fall protection equipment is not adequately discussed in OSHA's general industry standard. In this case, general industry employers should consult the construction standard at 1926 Subpart M for information. Remember, the kind of personal fall arrest system selected should match the particular work situation.

Scissor lifts — Scissor lifts are considered by OSHA to be a form of scaffolding. As such, the fall protection requirements for scaffolding apply: 10 feet above a lower level. However, most scissor lifts come from the manufacturer fitted with guardrails.

If the lift is considered mobile scaffolding (i.e., a scissor lift) under 1926.452(w), then a body belt and lanyard does not need to be used as long as the employee remains in the lift. The following is from an OSHA Letter of Interpretation dated July 21, 1998:

“In regards to your specific question, when working from an elevated scissors lift (ANSI A92.6 series), a worker need only be protected from falling by a properly designed and maintained guardrail system. However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required. The general scaffolding fall protection provision found in 1926.451(g)(1)(vii) reads in part, “‘[f]or all scaffolds not otherwise specified in this section, each employee shall be protected by the use of personal fall arrest systems or guardrails systems.’”

Aerial lift fall protection — If the device is considered an aerial lift under either 29 CFR 1910.67 or 1926.453, then OSHA states, “A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.” Regarding extensible and articulating boom platforms, look at the requirements at 1910.67(c)(2)(iv), which state, “Employees shall always stand firmly on the floor of the basket, and shall not sit or climb on the edge of the basket or use planks, ladders or other devices for a work position.”

CONSTRUCTION WORK

Falls are the leading cause of worker fatalities in construction. According to the Bureau of Labor Statistics, each year, several hundred workers die as a result of falls at construction sites. OSHA's construction fall protection rule (29 CFR 1926, Subpart M) deals with both employee and equipment issues in protecting workers from falls. Here are some frequently asked questions:

  • Who does the rule apply to? Subpart M covers most construction workers except those inspecting, investigating or assessing workplace conditions prior to the actual start of work or after all work is done.

  • What is the threshold height? The threshold for fall protection in construction work is 6 feet. You must protect your employees from fall hazards whenever an employee is working 6 feet or more above a lower level. If an employee is working on a scaffold, the height requirement for fall protection is 10 feet, and this protection usually is provided by a built-in guardrail.

  • What are the employers' responsibilities? Employers need to select systems and equipment appropriate for the situation; properly construct and install safety systems and; train workers in the proper selection, use and maintenance of fall protection systems.

  • What are the employees' responsibilities? Employees need to use safe work practices; use fall protection equipment properly; and always wear provided fall protection equipment.

The rule identifies areas or activities where fall protection is needed. These include: ramps, runways and other walkways; excavations; hoist areas; holes; formwork and reinforcing steel; leading edge work; unprotected sides and edges; overhand bricklaying and related work; roofing work; precast concrete erection; wall openings; residential construction; and other walking/working surfaces.

Not all fall protection regulations are located in Subpart M. Other sections have fall protection requirements for scaffolds (including aerial lifts), cranes and derricks, steel erection, tunneling operations, electric transmission and distribution lines and equipment work and stairways and ladders.

A CONCERN FOR ALL EMPLOYERS

Protecting employees from falls should be a concern for all employers. Always select fall protection measures and equipment compatible with the type of work being performed. Fall protection generally can be provided through the use of proper housekeeping, guardrails and handrails, safety nets, personal fall arrest equipment, positioning devices and warning line systems.

Whatever system you choose, make sure your employees know how to use it and you enforce its use.


Mark H. Stromme is a workplace safety editor with J. J. Keller & Associates Inc., Neenah, Wisc., where he works with the OSHA construction and general industry regulations and is an authorized OSHA construction trainer. Stromme can be reached at 920-722-2848 or via e-mail at [email protected].

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