OSHA has several thresholds for fall protection dependant upon the work activity involved. These thresholds are discussed in 29 CFR OSHA 1910 (General Industry), 29 CFR OSHA 1915 (Shipyard), and 29 CFR OSHA 1926 (Construction). A review of these thresholds is in order: General Industry: 4 Feet OSHA 29 CFR 1910.23 (c)(1) requires open-sided floors or platforms 4 feet or more above adjacent floor or ground level to be guarded by a standard railing (guardrail) or equivalent. The standard railing shown right is equipped with a top rail, mid rail, and toe board. However, the standard railing needs to be extended to adequately protect employees. Construction: 6 Feet OSHA 29 CFR 1926.501 (b)(1) requires each employee on a walking/working surface with an unprotected side or edge 6 feet or more above a lower level to be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems. 29 CFR 1926.502 (d) prohibits the use of body belts for fall protection. A body belt may only be used as a positioning device where free fall potential is no more than 2 feet. General Industry Scaffolds: 10 Feet The OSHA General Industry standards contain a scaffold standard 29 CFR 1910.28. General industry does not address fall protection, so OSHA references the construction standard 1926.451 (g)(1) Each employee on a scaffold more than 10 feet (3.1 m) above a lower level shall be protected from falling to that lower level. Paragraphs (g)(1)(i) through (vii) of this section establish the types of fall protection to be provided to the employees on each type of scaffold. MEMIC 2009 Page 1
Construction Scaffolds: 6 Feet MEMIC Insurance mandates that fall protection on construction scaffolding begins at 6 feet and not 10 feet as allowed by OSHA. OSHA 29 CFR 1926.451 (g)(1)each employee on a scaffold more than 10 feet (3.1 m) above a lower level shall be protected from falling to that lower level. Paragraphs (g)(1)(i) through (vii) of this section establish the types of fall protection to be provided to the employees on each type of scaffold. Shipbuilding Scaffolds: 5 feet OSHA will consider any boatbuilding operations to fall under shipyard 1915 standards when the property is adjacent to navigable waters. 1915.71(j)(1) Scaffolding, staging, runways, or working platforms which are supported or suspended more than 5 feet above a solid surface, or at any distance above the water, shall be provided with a railing which has a top rail whose upper surface is from 42 to 45 inches above the upper surface of the staging, platform, or runway and a midrail located halfway between the upper rail and the staging, platform, or runway. Portable Ladders: Fall Distance Limited to Working Height of Ladder Employees may work on an extension or step ladder up to the maximum working height of the ladder as specified by the ladder manufacturer. It is not permissible, however, for an employee to work on a portable ladder on an elevated surface, such as a roof, and be exposed to the fall height of the ladder plus the height of the roof as shown in the photograph at right. MEMIC 2009 Page 2
Fixed Ladders: 20 Feet OSHA 29 CFR 1910.27 (d)(1)(ii) requires safety cages or ladder safety devices on all fixed ladders more than 20 feet in height and to a maximum unbroken length of 30 feet. An example of a safety cage is shown at right. Steel Erection: 15 Feet Steel erection is considered construction work and is therefore regulated by OSHA 29 CFR Part 1926 Subpart R Steel Erection. 29 CFR 1926.760 (a)(1) requires all employees (except connectors) engaged in steel erection with an unprotected side or edge more than 15 feet to utilize adequate fall protection. 29 CFR 1926.760 (b) requires connectors (workers who connect the steel to the frame) to utilize fall protection when working above a lower level of two stories or 30 feet, whichever is less. MEMIC 2009 Page 3
Roof Work Fall Protection Low-Slope Roofs - 1926.501(b)(10) Each employee engaged in roofing activities on low-slope roofs with unprotected sides and edges 6 feet (1.8 meters) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems or a combination of a warning line system and guardrail system, warning line system and safety net system, warning line system and personal fall arrest system, or warning line system and safety monitoring system. On roofs 50 feet (15.25 meters) or less in width, the use of a safety monitoring system without a warning line system is permitted. Steep Roofs - 1926.501(b)(11) Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 meters) or more above lower levels shall be protected by either guardrail systems with toeboards, a safety net system, or a personal fall arrest system. Warning lines Warning line systems consist of ropes, wires, or chains, and supporting stanchions and are set up as follows: Flagged at not more than 6-foot (1.8 meters) intervals with high-visibility material. Rigged and supported so that the lowest point including sag is no less than 34 inches (0.9 meters) from the walking/ working surface and its highest point is no more than 39 inches (1 meter) from the walking/working surface. Stanchions, after being rigged with warning lines, shall be capable of resisting, without tipping over, a force of at least 16 pounds applied horizontally against the stanchion, 30 inches (0.8 meters) above the walking/working surface, perpendicular to the warning line and in the direction of the floor, roof, or platform edge. The rope, wire, or chain shall have a minimum tensile strength of 500 pounds, and after being attached to the stanchions, must support without breaking the load applied to the stanchions as prescribed above. Shall be attached to each stanchion in such a way that pulling on one section of the line between stanchions will not result in slack being taken up in the adjacent section before the stanchion tips over. Warning lines shall be erected around all sides of roof work areas. When mechanical equipment is being used, the warning line shall be erected not less than 6 feet (1.8 meters) from the roof edge parallel to the direction of mechanical equipment operation, and not less than 10 feet (3 meters) from the roof edge perpendicular to the direction of mechanical equipment operation. When mechanical equipment is not being used, the warning line must be erected not less than 6 feet (1.8 meters) from the roof edge. Guard rails offer protection on monolithic roofs and stairwells. They include 4 inch high toe-boards, 2x4 upright posts spaced 8 feet apart or closer, a 2x4 top rail 42 to 45 inches high, and a 1x6 mid-rail. Use select lumber or equivalent material for rails. The top rail should withstand a force of 13 pounds per linear foot applied vertically or horizontally. MEMIC 2009 Page 4
Roof Work Fall Protection Slide Guard System: A slide-guard system prevents workers from sliding down a sloped roof. The system consists of a slide guard (typically 2-by-6-inch lumber) and at least two roof brackets and must be installed under the supervision of a competent person. Roof brackets are available from roofing-equipment suppliers. A slide-guard system can also be made at the work site without manufactured roof brackets. Slide-guard systems cannot be the only means of fall protection on roofs with a ground-to-eave height greater than 25 feet. Catch platforms include guardrails. Locate them just below eaves near the work area. They should extend 2 feet horizontally beyond the eave. Covers for holes shall withstand a weight of 400 pounds or twice the potential weight of the employees, equipment, or material imposed upon the cover. Painted a distinctive color or marked with the wording Opening Do Not Remove. Fasten securely. Eave barriers offer protection on monolithic roofs and multiple unit roofs with slope greater than 5:12. Anchor them substantially at eave level or by ropes to the roof. Personal Fall Restraint System - Unlike the personal fallarrest system, which is designed to stop a fall, a personal fallrestraint system prevents a worker from reaching an unprotected edge and thus prevents a fall from occurring. The system consists of an anchorage, connectors, and a body harness or a body belt. The attachment point to the body belt or full body harness can be at the back, front, or side D-rings. The anchorage for a fall-restraint system must support at least 3,000 pounds or be designed and installed with a safety factor of at least two. If you're not sure how much an anchorage will support, have a qualified person evaluate it. Parapets are protective walls along the edge 24 inches or higher. They offer protection on monolithic roofs with slope greater than 4:12 and multiple unit roofs of any slope. MEMIC 2009 Page 5
Roof Work Fall Protection Safety Monitor System When no other alternative fall protection has been implemented, the employer shall implement a safety monitoring system. Employers must appoint a competent person to monitor the safety of workers and the employer shall ensure that the safety monitor: Is competent in the recognition of fall hazards, Is capable of warning workers of fall hazard dangers and in detecting unsafe work practices, Is operating on the same walking/working surfaces of the workers and can see them, and Is close enough to work operations to communicate orally with workers and has no other duties to distract from the monitoring function. Personal fall arrest systems with safety lines need approval from a qualified3 person. They offer protection on monolithic roofs with slopes greater than 4:12 and multiple unit roofs with slopes greater than 5:12. Anchor them to the roof; secure lanyards no lower than the employee s waist; and limit the falling distance to 6 feet. Anchors and lifeline shall support a 5,000 pound dead weight. Personal fall arrest systems consist of an anchorage, connectors, a body harness and system should include a deceleration device, lifeline, or suitable combinations. If a personal fall arrest system is used for fall protection, it must do the following: Limit maximum arresting force on an employee to 1,800 pounds when used with a body harness; Be rigged so that an employee can neither free fall more than 6 feet nor contact any lower level; Bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet and Have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet or the free fall distance permitted by the system, whichever is less. Scaffold platforms offer protection on monolithic roofs or multiple unit roofs with slope of greater than 5:12. As a fully planked part of a scaffold, locate them near eave level. Roof jack systems offer protection on multiple unit roofs4. MEMIC 2009 Page 6
Fall Protection Specialty Systems for General Industry RAILROAD CARS TRUCK LOADING SECURING LOADS CLIMBING DURING SERVICE WORK MEMIC 2009 Page 7