IRE21 - Frank J. Marino, CSP - Fall Protection - LAS VEGAS (1)

8/7/2021

1

Information Classification: General

Fall Protection Competent Person29 CFR 1926.500-503 (Subpart M)

OSHA Standards for Fall Protection in Construction


Scope & Application

• Requirements apply to walking/working surfaces

• Walking/working surface means any surface, whether horizontal or vertical on which an employee walks or works, including, but not limited to, floors, roofs, ramps, bridges, runways, formwork and concrete reinforcing steel but not including ladders, vehicles, or trailers, on which employees must be located in order to perform their job duties.


2019 Worker FatalitiesTOTAL: 4,779CONSTRUCTION: 1,008• 591 (59%) due to Fatal Four

1. Falls: 338 (34%)2. Struck by Object: 112 (11%)3. Electrocutions: 86 (9%)4. Caught-in/between: 55 (5%)

1

2

3

8/7/2021

2




4

5

6

8/7/2021

3




OSHA Top 10 – FY 2019Most Frequently Cited Standards 1. Fall Protection2. Hazard Communication3. Scaffolding4. Lockout / Tagout5. Respiratory Protection6. Ladders7. Powered Industrial Trucks8. Fall Protection Training9. Machine Guarding10. Eye & Face Protection

7

8

9

8/7/2021

4


1. Duty to Have Fall Protection $11,704,742 50%2. Ladders $2,639,794 55%3. Fall Protection Training $1,076,359 50%4. Eye & Face Protection $1,426,257 40%5. Programs / Inspections $871,007 35%6. Head Protection $547,059 34%7. Fall Protection Systems $511,147 40%8. Scaffolding $497,742 10%9. Abatement Verification $44,607 52%10. General Safety Training & Education $200,696 14%

OSHA Top 10 – FY 2020Most Frequently Cited StandardsNAICS: 238160 (Roofing Contractors)

Proportion of all Construction Industry (NAICS: 23) Penalties


Scope & Application

• This subpart sets forth requirements and criteria for fall protection in construction

• Exception: When employees are making an inspection, investigation, or assessment of workplace conditions prior to the actual start of construction work or after all construction work has been completed.


• Excluded from Subpart M:• Subpart X – Stairways & Ladders• Subpart L – Scaffolds• Subpart CC – Cranes & Derricks• Subpart R – Steel Erection• Subpart S – Underground• Subpart V – Power Line Construction

Scope & Application

10

11

12

8/7/2021

5


Low-Slope Vs. Steep-Slope


LOW-SLOPE (< 4:12)• Can use conventional or

alternative methods• Guardrail Systems• Personal Fall Arrest Systems (PFAS)• Safety Net Systems• Warning Line / Guardrail• Warning Line / Safety Net• Warning Line / PFAS• Warning Line / Safety Monitor• Safety Monitoring System (< 50’

wide)

STEEP-SLOPE (> 4:12)• Can only use conventional

methods• Guardrail Systems

(with toe-boards)• Personal Fall Arrest Systems• Safety Net Systems

Fall Protection Options (Roofing Work)


Competent Person• A person who:

• Is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees

• Has authorization to take prompt corrective measures to eliminate them

13

14

15

8/7/2021

6



Competent Person Responsibilities• Frequent and Regular inspections of the job sites, materials,

and equipment (Subpart C General Safety & Health Provisions)• Certification of Safety Net Systems• Inspection of Personal Fall Arrest System components subject

to impact loading• Monitor the safety of other employees and provide warning

when it appears that an employee is unaware of a fall hazard or is acting in an unsafe manner (when using Safety Monitoring System)

• Supervise the implementation of a fall protection plan (e.g. residential construction)

• Train each employee who might be exposed to fall hazards


Qualified Person• A person who:

• by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project

16

17

18

8/7/2021

7


Qualified Person Responsibilities

• Supervise design, installation, and use of horizontal lifeline systems

• Supervise design, installation, and use of anchorages that are used as part of personal fall arrest systems (PFAS) that rely on a safety factor of two

• Prepare and approve changes to the written Fall Protection Plan (e.g. residential construction)



Duty To Have Fall Protection

6 feet or more above lower levels

19

20

21

8/7/2021

8



• Employers are required to provide fall protection systems

• Employers shall also ensure that walking/working surfaces on which its employees are to work have the strength and structural integrity to support employees safely



22

23

24

8/7/2021

9


What is Roofing Work?29 CFR 1926.500(b): Roofing Work means the hoisting, storage, application, and removal of roofing materials and equipment, including related insulation, sheet metal, and vapor barrier work, but not including the construction of the roof deck.


Conventional Fall Protection• Guardrail Systems

• Covers

• Safety Net Systems

• Personal Fall Arrest Systems (PFAS)


Alternative Fall Protection• Warning Line / Safety

Monitoring System

• Safety Monitoring System

• Fall Protection Plan (e.g. residential)

25

26

27

8/7/2021

10



Conventional• Hoist Areas• Disposal Areas• Holes / Skylights• Steep-Slope Roofs• Mechanical Equipment*• Wall Openings

* Permitted within a warning line system

Alternative• Roofing Work on

Low-Slope Roofs



Hoist Areas

28

29

30

8/7/2021

11




31

32

33

8/7/2021

12


Disposal Areas



Holes / Skylights

34

35

36

8/7/2021

13




37

38

39

8/7/2021

14




40

41

42

8/7/2021

15


Steep-Slope Roofs (> 4:12)



43

44

45

8/7/2021

16


Wall Openings



Mechanical Equipment

46

47

48

8/7/2021

17


29 CFR 1926.500(b): Mechanical equipment means all motor or human propelled wheeled equipment used for roofing work, except wheelbarrows and mopcarts.

• Motor or human propelled• Wheeled• Used for roofing work

Exceptions: • Wheelbarrows• Mopcarts

What is Mechanical Equipment?

Not Mechanical Equipment per OSHA definition


29 CFR 1926.502(f)(4): Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by:

• warning line system• guardrail system; or • personal fall arrest system


49

50

51

8/7/2021

18




29 CFR 1926.502(h)(2): Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low-slope roofs.

52

53

54

8/7/2021

19




Protection from Falling Objects

• Employees shall be required to wear hard hats as well as:• Erect toe-boards, screens, or guardrail systems;

• Erect a canopy structure and keep objects away from the edge; or

• Barricade the area where objects could fall, prevent employee access to the area, and keep objects away from the edge.

55

56

57

8/7/2021

20



1926.502(j)(7)(i): Materials and equipment shall not be stored within 6 feet of a roof edge unless guardrails are erected at the edge

1926.502(j)(7)(ii): Materials which are piled, grouped, or stacked near a roof edge shall be stable and self-supporting.


58

59

60

8/7/2021

21


29 CFR 1926.502Fall Protection Systems Criteria & Practices

• Warning Line Systems• Safety Monitoring Systems• Guardrail Systems• Safety Net Systems• Personal Fall Arrest Systems• Covers


Warning Line Systems• Warning line system: a barrier

erected on a roof to warn employees that they are approaching an unprotected roof side or edge, and which designates an area in which roofing work may take place without the use of guardrail, body belt, or safety net systems to protect employees in the area.

• Roofing Work on Low-Slope Roofs (< 4:12)


Warning Line Systems• Shall be erected around all sides of the

roof work area• Erected not less than 6 feet

from roof edge

• Mechanical equipment:

• 6 feet from roof edge when usedparallel to the edge

• 10 feet from roof edge when usedperpendicular to the edge

61

62

63

8/7/2021

22


Warning Line Systems• Warning lines shall be:

• Flagged at least every 6 feet with high-visibility material

• Between 34 to 39 inches above the walking/working surface

• Stanchions shall resist a tipping over force of 16 pounds

• Warning line shall have a minimum tensile strength of 500 pounds (No caution tape)


Warning Line Systems• Points of access, materials handling areas, storage areas,

and hoisting areas shall be connected to the work area by an access path formed by two warning lines

• No employee shall be allowed in the area between a roof edge and a warning line unless the employee is performing roofing work in that area

• Mechanical equipment on roofs shall be used or stored only in areas where employees are protected by a warning line system, guardrail system, or personal fall arrest system


64

65

66

8/7/2021

23


• Should be connected to the work area by an access path formed by two warning lines



67

68

69

8/7/2021

24



• Not less than 6 feet from the roof edge


• When warning lines need to be moved, move them in away from edge, not less than 6 feet

70

71

72

8/7/2021

25


• Plan to use guardrails where warning lines cannot be maintained properly


• Form 90 degree angles at warning line –guardrail transitions


• Around all sides of the roof work area

73

74

75

8/7/2021

26


• Around all sides of the roof work area


• 34” – 39” above walking-working surface


76

77

78

8/7/2021

27


• Flagged with high-visibility material at not more than 6-foot intervals


• Minimum tensile strength: 500 lbs.


• Attach to stanchion in such a way that pulling on one section does not affect the other before tipping over

79

80

81

8/7/2021

28



Safety Monitoring Systems• Safety Monitoring System: a safety

system in which a competent person is responsible for recognizing and warning employees of fall hazards.

• Must be used in conjunction with a warning line system on roofs that are more than 50 feet wide

• May be used by itself if roof section is 50 feet or less in width; however other activities may prohibit this (e.g. mechanical equipment)


Safety Monitoring Systems

• A competent person designated to monitor the safety of other employees

• Competent to recognize fall hazards;• Warn the employee when it appears that the employee is

unaware of a fall hazard or is acting in an unsafe manner;• On the same walking/working surface and within visual sighting

distance of the employee being monitored;• Close enough to communicate orally with the employee; and• No responsibilities which could take the monitor's attention from

the monitoring function

82

83

84

8/7/2021

29




85

86

87

8/7/2021

30





• A competent person designated to monitor the safety of other employees

• Competent to recognize fall hazards;• Warn the employee when it appears that the employee is

unaware of a fall hazard or is acting in an unsafe manner;• On the same walking/working surface and within visual sighting

distance of the employee being monitored;• Close enough to communicate orally with the employee; and• No responsibilities which could take the monitor's attention from

the monitoring function

88

89

90

8/7/2021

31




• Mechanical equipment shall not be used or stored in areas where safety monitoring systems are being used to monitor employees engaged in roofing operations on low-slope roofs.



• No employee, other than an employee engaged in roofing work, shall be allowed in an area where an employee is being protected by a safety monitoring system.

91

92

93

Documents

IRE21 - Frank J. Marino, CSP - Fall Protection - LAS VEGAS (1)