Existing subpart D of the OSHA standard does not specifically address or exclude fall protection on rolling stock or motor vehicles. OSHA requested comment on whether it should include requirements specifying that, when employees are exposed to falls from rolling stock and motor vehicles at heights greater than 4 feet, protective work practices, methods or systems must be instituted.
FPS offered insight on two questions posed by OSHA:
OSHA Asked: How many or what percentage of employees working on top of rolling stock are exposed to fall hazards?
FPS Answers: Following personal site evaluations and discussions with clients, FPS concluded that anyone who is climbing on top of rolling stock is exposed to fall hazards. Over the last 10 years, FPS documented over 50 falls from railcars: 14 resulted in a fatality and 30 resulted in severe injuries. In seven cases, injury was prevented due to some form of fall protection system.
According to OSHA-provided data, 25.9 lost workdays per 10,000 employees are reported each year for falls to a lower level in the rail transportation industry. According to the data OSHA provided, the average railroad worker is paid approximately $23/hour with benefits. If projected across rail transportation employment, this amounts to over $476,000 in lost pay annually.
OSHA Asked: How many or what percentage of employees working on top of motor vehicles are exposed to fall hazards?
FPS Answers: After speaking with customers and conducting site evaluations, FPS concluded that anyone climbing on top of motor vehicles (truck, trailer, bus, etc.) is exposed to fall hazards.
In the last decade, FPS documented over 27 falls from motor vehicles: 10 resulted in fatality and 16 resulted in severe injuries. In one case, injury was prevented due to some form of fall protection system.
According to an insurance company that surveyed over 80 truck drivers, 86 percent of drivers stated they had fallen or had nearly fallen from the truck, trailer or load. Ninety percent stated their employers were not considering the addition of fall protection, which could save them from serious injury or worse. OSHA data reveals that 29.1 lost workdays were reported annually per 10,000 employees as result of falls to a lower level within the truck transportation industry. Assuming the average truck driver is paid approximately $25/hour with benefits, this results in $3,600,000 in lost pay annually if projected across the total truck transport industry. Fall protection therefore could be a worthy investment.
While it is uncertain how OSHA will use the information requested, FPS advises employers with workers on top of rail or moving vehicles to consider fall protection solutions to protect their employees.
Fall Protection Systems Corp. has been working with employers in the rail, trucking, barge and aircraft industry for more than 15 years. For more information, visit http://www.fallprotectionsystems.com/EHS or call 1-888-596-5367.