Does this apply to me?
According to 29 CFR 1926.500 Subpart M — Fall Protection
- If you have any work that is 6 feet or more above a lower surface you must have fall protection in place for your workers.
- This does not apply to scaffolds, ladders and steel erection which have their own OSHA requirements.
- Some jobsites may have requirements that ANY work that is 6 feet or more in height must have a jobsite fall protection plan in place.
What does this cover?
OSHA rules require that all workers are protected from falling after they are exposed to a fall of more than 6 feet which includes all working areas. Some examples would be:
Floors on multi-story buildings
Make sure that workers are protected by guardrails. Guardrails should be inspected to make sure they are not loose or damaged. If guardrails are removed workers should use a personal fall protection system like a full body harness and lanyard to protect them.
Interior floor openings like stairways, elevator shafts and pits
Guardrails must be installed around all these when there is a drop of 6 feet or more.
Roofing work and skylights
There are different options available for roofing work such as warning lines and safety monitors but these can only be used to protect workers who are actually installing roofing materials. If skylights are on the roof, then guardrails or covers will have to be used, even during roofing work.
Working on concrete forms
Workers can use work positioning lanyards when they are installing bolts or tying rebar, but have to use other personal fall protection equipment when over six feet. Double lanyards or self-retracting lifelines, tied off overhead, can provide 100 percent fall protection.
Installing precast planks (leading edge work)
Since the edge where falls could happen is always moving, this is called a leading edge. Since installing guardrails would be difficult, there are other options that can be used, such as fall restraint. Fall restraint keeps workers from falling by not allowing them to get too close to the leading edge. However, guardrails still need to be installed on the sides and only workers installing precast planks are allowed in the area.
Building a brick or concrete block wall from the interior of the building
If guardrails can’t be installed, workers can use a controlled access zone in some cases. This is an area that is taped off to keep other workers out. However, consider using fall restraint for workers building the wall.
Falling objects like tools or materials
Anything falling on a worker can cause serious injury. Remind your workers to keep out of areas that are taped off due to overhead work. If your workers are dropping materials due to their work, like stripping forms, have the area below taped off and tell other contractors to keep out. Once the work is done, make sure you remove the Danger Zone tape and signs.
What else do I need to know?
OSHA inspectors will be looking for fall hazards and want to know what your company is doing to protect workers.
You need to have a competent person who knows what your fall hazards are and also knows how to use, install and inspect the fall protection systems (guardrails, covers, personal fall protection) that will be used to protect your workers.
What about training?
All your workers have to be trained to understand how to use the fall protection system(s) you have in place for their protection. It may be a fairly simple program if you are just using guardrails, but it gets more complicated when you have them wear personal fall protection or work in controlled access zones.
- Make sure they are trained before they start work, so they know how to protect themselves.
- Training needs to be provided by a competent person; someone who understands fall protection hazards and equipment.
- Document the training and keep records on file.
The competent person
You should designate someone from your company to be your fall protection competent person. OSHA may ask who the person is, so be prepared. Make sure you have given this appointed person the proper support, which may require several days of training. This person must know all the OSHA requirements and even the manufacturer requirements for full body harnesses, lanyards and self-retracting lifelines. This person can also help in planning what fall protection would work best and develop a job site fall protection plan, which you may have to provide to a client or general contractor.
Where can I get more help?
The Hanover Risk Solutions website has additional information that you can review or use for worker training. Additional resources can also be found on the OSHA website.
This material is provided for informational purposes only and does not provide any coverage or guarantee loss prevention. The examples in this material are provided as hypothetical and for illustration purposes only. The Hanover Insurance Company and its affiliates and subsidiaries (“The Hanover”) specifically disclaim any warranty or representation that acceptance of any recommendations contained herein will make any premises, or operation safe or in compliance with any law or regulation. By providing this information to you. The Hanover does not assume (and specifically disclaims) any duty, undertaking or responsibility to you. The decision to accept or implement any recommendation(s) or advice contained in this material must be made by you.
LC JAN 2019 12-376