In 2016, OSHA passed a final rule expanding the scope of the existing walking and working surface standard for general industry and adding a fall protection standard for general industry; acknowledging that many general industry workers face similar types of fall hazards as those in construction. More than 25 years in the making, the new rule requires general industry employers to identify fall hazards in their workplace and establish plans and procedures to ensure that slip and fall hazards on floors, roofs, stairs, ramps, dockboards, scaffolds, elevated platforms and other walking-working surfaces are guarded. The rule also establishes specific requirements for workplaces that use personal fall protection systems as a means of protecting employees from fall hazards to ensure that the components, devices and equipment that will be used are adequately rated and that employees are properly trained to use them.
Under the old rule, which was established in 1971, guardrails were the primary method of fall protection that employers were required to use when guarding against fall hazards. The new rule is performance-based, acknowledging that guardrails aren't always the best way to protect workers from falls; and it provides employers with the flexibility to determine the most effective methods of guarding their workers from specific fall hazards.
OSHA's long-established rule for fall protection in the construction industry provides a framework for employers to identify fall hazards and establish the necessary plans and procedures to keep workers who perform various construction jobs at heights safe. Until recently, workers in general industry have not had a similar set of protective standards.
Wherever possible, the general industry rule mirrors the construction standard to help avoid confusion, especially in workplaces where both general industry and construction activities may occur. An example of this is the requirement to train employees which, according to the Federal Register, principally was drawn from the existing construction fall protection standard.
Training Is Necessary
Establishing plans and procedures to prevent workplace fall hazards are two important steps in preventing incidents. But without adequate training, employees aren't likely to know these elements exist or how they protect them from harm. As part of the final rule, OSHA established training requirements that outline what employees who may be subject to fall hazards need to know before they are exposed to a fall hazard [29 CFR 1910.30(a) (1)].
"OSHA believes that the new training requirements are necessary, and effective worker training is one of the most critical steps employers can take to prevent employee injuries and fatalities," according to the Federal Register notice. The AFL-CIO, American Society of Safety Engineers (ASSE) and other industry groups support this requirement and acknowledge that training is an essential element of this rule.
Like other requirements in the final rule, the training requirements are performance-based, allowing employers the flexibility to choose the methods that they feel are most effective. Employers may use classroom, audio-visual, demonstrations, field training, web-based, computer-based or other forms of training to meet the requirements of the standard. No matter which method(s) are chosen, training must be performed by a qualified person [29 CFR 1910.30(a) (2)] and if web, video or computer-based methods are used, a qualified person must be available to answer questions.
Although the qualified person does not need to have a formal degree, he or she must have extensive knowledge of "the types of fall hazards, how to recognize them and the procedures to minimize them; the correct procedures for installing, inspecting, operating, maintaining and disassembling personal fall protection systems and other equipment." Internal personnel, outside personnel (such as vendors) or a combination of the two may be used to meet the training requirements.
To be effective, training must be understandable [29 CFR 1910.30(d)]. For some employers, this may mean conducting training in multiple languages or employing different training methods. Even if the only training they need to receive is to stay out of posted affected areas where fall hazards are present, this training only is valuable if they understand that a hazard is present and how their restriction from being in an affected area protects them.
Specific Training Requirements
Effectively trained employees will be able to identify and recognize fall hazards in the workplace and the areas where fall events are likely to occur. For each fall hazard that is identified, employees also must understand how following the procedures that have been established will protect them from injury or death [29 CFR 1910.30(a)].
Instruction must include how to properly use any tools and equipment such as ladders and safety net systems, portable guardrails, mobile ladder stands and mobile platforms. Employees also need to understand any limitations that these devices present and how misuse can cause injury or death. If personal fall protection systems will be used, training must include proper hook-up, anchoring, tie-off techniques, inspection and equipment storage [29 CFR 1910.30(a)(3)].
Using the equipment manufacturer's specifications and instruction manuals can help simplify training on the proper care, inspection, storage and use of each item. OSHA also permits employers to use "designated areas" when they determine that other fall protection methods and equipment are not feasible. When designated areas are used, employers must properly mark the areas and provide training on the procedures to be used there.
Because falls continue to be a leading cause of workplace injury and death, employers need to ensure that training remains effective over time. According to the Federal Register notice, training requirements "impose an ongoing responsibility on employers to maintain worker proficiency. As such, when workers are no longer proficient, the employer must retrain them."
There is no annual retraining or other specific required interval for retraining. Some of the events that can trigger the need for retaining include: performing a job or operating equipment in an unsafe manner, a fall incident or a near miss. Changes in the workplace or in fall protection/prevention equipment also trigger retraining requirements [29 CFR 1910.30(c)].
Fall protection standards for the construction industry, coupled with advances in fall protection technology and a heightened awareness of fall hazards, have helped to reduce the number of fall-related construction injuries and deaths. Mirroring these efforts in general industry will help to simplify training requirements for many employers and provide additional levels of safety for general industry employees.
Karen Hamel, CSP, WACH, is a regulatory compliance specialist and technical writer at New Pig Corp.