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]