ISEA Comments on OSHA Construction Fall Protection Standards

Feb. 2, 2000
Among its comments, ISEA said that vendors delivering materials to construction sites should be covered by the same fall protection requirements as construction workers.

The Safety Equipment Association (ISEA) recently submitted comments to OSHA responding to an Advance Notice of Proposed Rulemaking (ANPR) on its Safety Standards for Fall Protection in the Construction Industry.

Since publication of the construction fall protection standard in 1994, OSHA has received numerous comments claiming that compliance with the rule is infeasible while performing some activities.

In 1995, it issued interim procedures for fall protection in residential construction that permits employers to use work practice controls instead of claims of infeasibility.

OSHA also announced its intention to rescind the interim procedures for residential construction unless persuasive evidence was submitted demonstrating that for most residential construction employers, complying with the rule is infeasible or presents significant safety hazards.

ISEA expressed concern that the exemptions permitted by this instruction weaken the rule by expanding the use of behavioral controls over environmental controls.

"We maintain that environmental controls, including the use of work platforms, guard rails, nets and other protective measures, are superior to behavior based controls," suggested in the instruction.

ISEA called the exemptions "problematic and harmful if applied to other work categories beyond those originally intended, which further dilutes the effect of the current rule."

OSHA's ANPR included 10 issues on which it sought information and comment.

ISEA said its detailed comments addressed many of the issues, providing information on residential construction, precast concrete erection, climbing reinforcing steel and others.

In its comments, ISEA said that vendors delivering materials to construction sites should be covered by the same fall protection requirements as construction workers

Likewise ISEA said OSHA needs to ensure that equipment designed for restraint systems is not used where fall protection equipment is necessary.

Responding to some users' contention that OSHA should prohibit harnesses that incorporate body belts, ISEA pointed out that these belts are useful for work positioning or carrying tools, and can be used safely if they are properly attached.

The concern that they may injure workers in a fall relates to misuse and improper training, ISEA said, since the fall arrest attachment point must always be to the harness, not the belt.

OSHA will evaluate ISEA's comments and others it receives on the ANPR, and will then decide what further steps are appropriate.

For a copy of ISEA's comments, e-mail the association at [email protected].

About the Author

EHS Today Staff

EHS Today's editorial staff includes:

Dave Blanchard, Editor-in-Chief: During his career Dave has led the editorial management of many of Endeavor Business Media's best-known brands, including IndustryWeekEHS Today, Material Handling & LogisticsLogistics Today, Supply Chain Technology News, and Business Finance. In addition, he serves as senior content director of the annual Safety Leadership Conference. With over 30 years of B2B media experience, Dave literally wrote the book on supply chain management, Supply Chain Management Best Practices (John Wiley & Sons, 2021), which has been translated into several languages and is currently in its third edition. He is a frequent speaker and moderator at major trade shows and conferences, and has won numerous awards for writing and editing. He is a voting member of the jury of the Logistics Hall of Fame, and is a graduate of Northern Illinois University.

Adrienne Selko, Senior Editor: In addition to her roles with EHS Today and the Safety Leadership Conference, Adrienne is also a senior editor at IndustryWeek and has written about many topics, with her current focus on workforce development strategies. She is also a senior editor at Material Handling & Logistics. Previously she was in corporate communications at a medical manufacturing company as well as a large regional bank. She is the author of Do I Have to Wear Garlic Around My Neck?, which made the Cleveland Plain Dealer's best sellers list.

Nicole Stempak, Managing Editor:  Nicole Stempak is managing editor of EHS Today and conference content manager of the Safety Leadership Conference.

Sponsored Recommendations

10 Facts About the State of Workplace Safety in the U.S.

July 12, 2024
Workplace safety in the U.S. has improved over the past 50 years, but progress has recently stalled. This report from the AFL-CIO highlights key challenges.

Free Webinar: ISO 45001 – A Commitment to Occupational Health, Safety & Personal Wellness

May 30, 2024
Secure a safer and more productive workplace using proven Management Systems ISO 45001 and ISO 45003.

ISO 45003 – Psychological Health and Safety at Work

May 30, 2024
ISO 45003 offers a comprehensive framework to expand your existing occupational health and safety program, helping you mitigate psychosocial risks and promote overall employee...

Case Study: Improve TRIR from 4+ to 1 with EHS Solution and Safety Training

May 29, 2024
Safety training and EHS solutions improve TRIR for Complete Mechanical Services, leading to increased business. Moving incidents, training, and other EHS procedures into the digital...

Voice your opinion!

To join the conversation, and become an exclusive member of EHS Today, create an account today!