WSC-Appling Construction Fall Protection Concepts to ... · ... OSHA aligned fall protection requirements for ... • Fixed Ladders • Mobile Ladder Stands AND Mobile Ladder Stand

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Appling Construction Fall Protection

Concepts to General Industry

Presented by:

Michael Tesmer, CSP Conney Safety Products

2 WESCO Confidential—Do not copy or distribute without express permission from WESCO Distribution, Inc.

Overview of Standard

• Original 1910 Subpart D was published in 1971 (update proposed in 1983)

• This rule became effective January 17th, 2017

• The training deadline was May 17th, 2017 (most facilities will need this)

• The final rule creatively brings together almost all of the fall-related standards into one location

• This standard affects 112 million workers at 7 million workplaces

• As much as possible, OSHA aligned fall protection requirements for general industry with those of construction – easing compliance for

those doing both


Most Significant Update

• Allowing employers to select the fall protection system that works best for them (4’ trigger)

Fall Protection: Any equipment, device, or system that prevents a worker from falling from an elevation OR mitigates the effect of such

a fall.

1. Guardrail System

2. Safety Net System

3. Personal Fall Arrest System

4. Positioning System

5. Travel Restraint System

6. Ladder Safety System

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Final Subpart D (compared to the old)

Final Subpart D (New) Previous Subpart D (old)

1910.21 Scope and definitions 1910.21 Definitions

1910.22 General requirements 1910.22 General requirements

1910.23 Ladders1910.23 Guarding floor and wall

openings and holes

1910.24 Step bolts and manhole steps 1910.24 Fixed industrial stairs

1910.25 Stairways 1910.25 Portable wood ladders

1910.26 Dockboards 1910.26 Portable metal ladders

1910.27 Scaffolds and rope descent

systems1910.27 Fixed ladders

1910.28 Duty to have fall protection and

falling object protection

1910.28 Safety requirements for

scaffolding

1910.29 Fall protection systems and

falling object protection - criteria and

practices

1910.29 Manually propelled mobile

ladder stands and scaffolds (towers)

1910.30 Training requirements 1910.30 Other working surfaces

1910.140 Personal fall protection systems

Subpart I


Important considerations or differences

• Lots of terms related to fall protection

• Qualified describes a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive

knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems relating to

the subject matter, the work or the project.

NOTE: OSHA states that training needs to be done by a Qualified Person (in General Industry)

1910.21 Scope and definitions







openings and holes









scaffolding



practices





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1910.22 General RequirementsKey Point – think slips, trips and falls…

HOUSEKEEPING

INSPECTIONS/ ASSESSMENTS







openings and holes









scaffolding



practices






1910.23 LaddersKey Components

• Portable Ladders• Fixed Ladders• Mobile Ladder Stands AND Mobile Ladder Stand

PlatformsNOTE: an important part of this standard (general requirements) (b)(9) requires employers ensure “ladders are inspected before

initial use in each work shift, as well as more frequently as necessary”This implies you must TRAIN workers on ladder safety (for inspections and use)

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1910.23 LaddersKey Components

• An important component to the general requirements is (b)(12): Each employee uses at least one hand to grasp the ladder when

climbing up and down it; and• (b)(13): No employee carries any object or load that could cause

the employee to lose balance and fall while climbing up or down the ladder.


1910.23(c) Portable LaddersKey Components

(c)(2) – metal spreader or locking device in open position when

ladder is in use


1910.23(c) Portable LaddersKey Components

(c)(11) – when used to gain access to upper landing surface, side rails

must extend 3’ above the upper surface

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1910.23(d) Fixed LaddersKey Components

(d)(4): The side rails of through or side-step ladders extends 42” above the top of the access level or landing platform….


1910.23(d) Fixed LaddersKey Components


1910.23(e) Mobile ladder stands and mobile ladder platformsKey Components

• Top step of 4’ or higher must have handrails (29” – 36”)• Support 4X intended load

• Treads need to be slip-resistant , etc.

• With mobile ladder platforms, handrails on platform (from 4’-10’) only have to be 36” high w/ midrail

• Above 10’, require standard height guardrails and even toeboards• Chains can be used for special-use scenarios (step-through)

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openings and holes









scaffolding



practices






1910.24 step bolts and manhole steps







openings and holes









scaffolding



practices





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1910.25 StairwaysKey Components







openings and holes









scaffolding



practices






1910.26 DockboardsKey Components

• Run-off protection

• Secure trailer

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openings and holes









scaffolding



practices






1910.27 Scaffolds and Rope Descent Systems (RDS) Key Components

1) Scaffolds identical to Construction standard

2) New anchorage requirements for RDS

3) 300’ RDS height limit

4) Prohibit use of RDS in bad weather and protecting ropes from hazardous exposure

5) Each employee must have a separate, independent fall arrest system







openings and holes









scaffolding



practices





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Ways in which OSHA made final rule consistent with the Construction standard

• Control flexibility (range of acceptable options)• Those allowed fall protection systems have been determined

to provide appropriate and equal level of safety to guardrails (can choose cost effective option)

• Flexibility allows employers ability to select products that enables best job efficiency (reducing exposure)

• Employers can take advantage of advances in newer technology

• Greater control flexibility makes this rule consistent with construction standards – should increase compliance (same

equipment used in both industries)• Because of the additional flexibility and consistency in the

standard, OSHA believes injuries and deaths will be reduced


1910.28(b) Protection from Fall hazards

1) Unprotected sides and edges

2) Hoist areas

3) Holes (including skylights)

4) Dockboards

5) Runways and similar walkways

6) Dangerous equipment

7) Openings

8) Repair pits, service pits, and assembly pits less than 10’ deep

9) Fixed ladder (that extend more than 24’ above a lower level)

10) Outdoor advertising

(billboards)

11) Stairways

12) Scaffolds and rope descent systems

13) Work on low-slope roofs

14)Slaughtering facility platforms

15) Walking-working surfaces not

otherwise addressed

Guardrail Systems Safety Net Systems Personal Fall Protection Systems

Positioning Systems Travel Restraint Systems Personal Fall Arrest Systems

Handrails Designated Areas Ladder Safety Systems




2) Hoist areas


4) Dockboards



7) Openings



10) Outdoor advertising

(billboards)

11) Stairways

12) Scaffolds and rope descent systems



15) Walking-working surfaces not

otherwise addressed




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Unprotected sides and edges




2) Hoist areas


4) Dockboards



7) Openings



10) Outdoor advertising (billboards)

11) Stairways

12) Scaffolds and rope descent

systems



15) Walking-working surfaces not otherwise addressed





Hoist areas

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2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








Holes




2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems







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Dockboards




2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








Runways and similar walkways

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2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








Dangerous Equipment




2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems







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2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








Repair pits less than 10’


Other repair pit options?

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2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








Fixed Ladder (extends more than 24’)




2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems







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Outdoor advertising (billboards)




2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








Stairways

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2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








Scaffolds and rope descent systems




2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems







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Low sloped roofs





2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems







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Slaughtering facility platforms




2) Hoist areas


4) Dockboards



7) Openings




11) Stairways


systems








1910.28(c) Protection from falling objects

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openings and holes









scaffolding



practices






1910.29 Fall protection systems and falling object protection-criteria and practices

This section simply stating that each fall protection system (and falling object protection) , other than “personal” fall protection systems, meet

the requirements in this section (“personal” fall protection systems in Subpart I)

• (b) Guardrails• 42” height – midrail 21” height (unless parapet at least this

high)• When used as a point of access, have self-closing gate that

slides or swings away from hole (or is offset to prevent from falling in hole)



• (c ) Safety net systems

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• (d) Designated Areas



• (e) Covers



• (f) Handrails and stair rail systems

• Handrail >30” but <38”• Requirements for stair rails installed before

and after 1/17/17• Opening in stair rail system no more than 19”

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• (g) Cages, wells and platforms used with fixed ladders

• Designed, constructed, and maintained to permit easy access to and from ladder

• Platforms have surface of at least 24” x 36”• Opening in stair rail system no more than 19”

• Must follow 1910.29 when cages wells used as means of fall protection



• (h) Outdoor advertising

• Must ensure employees physically capable• Completed special training or apprenticeship

program• Demonstrated skill, climbing part of routine work,

etc.



• (i) Ladder safety systems

• System must allow for hands free use of device• Connection does not exceed 9”

• Discussion of rigid and flexible carriers (track vs. cable)

• Can handle drop test of 19” at 500 lbs.

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• (j) Personal fall protection systems

• Includes body belts, harnesses, and other components used in personal fall arrest systems,

positioning systems and travel restraint systems• Only states they must meet the requirements of

1910.140 (Personal fall protection systems)



• (k) Protection from falling objects

• Ensure toeboards used where needed along walking-working surface (3.5”)

• Handle 50 lbs. force



• (l) Grab handles

• At least 12” long• At least 3” clearance to grab from mounting area

• Handles 2X max intended load

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openings and holes









scaffolding



practices






1910.30 Training Requirements

• Required before any employee is exposed to a fall hazard, use a personal fall protection system, or to be trained

elsewhere in this subpart• Training on or before May 17, 2017

• Trained by a Qualified Person

FALL HAZARDSEQUIPMENT HAZARDS







openings and holes









scaffolding



practices





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• This section establishes performance, care, and use criteria

• Another review of definitions (only related to PPE)

• NOTE: Competent Person defined here

Key Comments

• Lots of components w/ 5,000 min tensile strength (lanyards, vertical lifelines, snap hooks, D-rings,

carabiners

• Gate strength of snaphooks and carabiners proof tested to 3,600 lbs.



• Limit max arresting force on employee to 1,800 lbs.

• There is discussion about 310 lb. combined weight of employee and tools – make sure system tested for that

limit (or if you go over)

Key Comments

• Employer must provide for prompt rescue in event of a fall


Appendix C to Supart I – Personal Fall Protection Systems (non-mandatory guidelines)

• Planning considerations (suitable anchor points, etc.)

• Selection and use considerations: (Free fall distances, type of PPE based on conditions, providing for prompt rescue)

• Component compatibility

• Training, instruction considerations (limits of equipment), inspection considerations, tie-off considerations

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Appendix D to Supart I – Test Methods and Procedures for Personal Fall Protection Systems (non-mandatory guidelines)

• Details to manufacturers for testing protocols


Questions?

Documents

WSC-Appling Construction Fall Protection Concepts to ... · ... OSHA aligned fall protection requirements for ... • Fixed Ladders • Mobile Ladder Stands AND Mobile Ladder Stand