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  • Fall Protection in Residential Construction, PPE Harnessing for Safety

    Have you ever really given any thought to the definition and purpose of “Harnessing? As a teenager my Dad (May he rest in peace) used to harness a team of horses to plow a field. In some areas of this technology driven country of ours it is still being used by our Amish friends, and hobby farmers anxious to reconnect with Mother Earth. “The Free Dictionary” defines it this way:

    1. The gear or tackle, other than a yoke, with which a draft animal pulls a vehicle or implement.

    2. Something resembling such gear or tackle, as the arrangement of straps used to hold a parachute to the body.

    3. A device that raises and lowers the warp threads on a loom.

    4. Archaic Armor for a man or horse.

    So feeling a little like a Horse? Well that part of the definition really isn’t that far off. Here’s some more of its relevant definition: 2. To bring under control and direct the force of: If you can harness your energy, you will accomplish a great deal.

    So essentially what we are talking about here is PPE (Personal Protective Equipment) a harness worn by you to control the energy of a fall. Fall Protection, by use of a safety Harness, is what we’re concerned about here. In the last year or so OSHA has made a concerted effort to protect those workers by redefining “Fall Protection in Residential Construction”.

    Today we’ll discuss the Key Changes to OSHA’s residential Construction fall program. To do this I’ve invited a guest author from “Falltech”. Falltech is our provider for fall arrest equipment and systems, her name is Kelly May. Her article follows:

    Up until late last year, people working in residential construction did not have to follow the same fall protection regulations as other industries where work at height is performed. The Interim Fall Protection Compliance Guidelines for Residential Construction (STD 03-00-001), allowed residential construction companies to use alternative fall protection methods, such as safety monitoring systems or slide guards instead of the more traditional methods of protecting workers from falls. All of that changed when OSHA rescinded STD-03-00-001 at the end of 2013.

    Falls continue to be the leading cause of death among residential construction workers - accounting for 76 percent of fatalities. Even worse, workers in the roofing industry are three times more likely to experience fatal work-related injuries than other construction workers*. It was statistics such as these that led OSHA to decide that something must be done.

    Now, all workers engaged in residential construction six feet or more above lower levels must be protected by guardrail systems, safety nets, or personal fall arrest systems.

    There are exceptions. In the roofing industry, alternative fall protection measures can be used, depending on the pitch of the roof. On low sloping roofs, with pitch of 4:12 or less, warning lines and safety monitoring systems are allowed. However, if the roof pitch is over 4:12 guardrails or personal fall protection systems are now required. OSHA does allow the use of fall restraint systems instead of personal fall arrest systems as long as it will prevent a worker from reaching a fall hazard and falling over the edge.

    Also, if employers can show that such fall protection systems are not feasible or create a greater hazard, a qualified person may develop a plan outlining alternative fall protection measures. This plan must be in writing and site-specific; however, a plan that is developed for repeated use for a particular model of home will be considered site specific.

    Employers must also ensure that each employee who might be exposed to fall hazards is trained by a competent person to recognize the hazards of falling and the procedures to be followed in order to minimize those hazards. In addition, the employer must verify the training of each employee by preparing a written certification record that contains the name/identity of the employee trained, the date(s) of training, and the signature of the employer or the person who conducted the training.

    The differences between the Interim Guidelines and Subpart M? **

    General Requirements

    Interim Fall Protection Guidelines (Dec. 8, 1995 – June 15, 2011)

    Fall Protection Requirements of Subpart M (June 16, 2011 and beyond)

    Use of Conventional Methods (guardrails, safety nets, or personal fall arrest systems) for fall exposures over 6 feetRequired, unless infeasible or creates greater hazardRequired, unless infeasible or creates greater hazard
    Use of Alternative Methods (slide guards, safety monitoring systems, warning line, etc.)Allowed, for prequalified tasks identified by OSHA as meeting a greater hazard and other tasks where infeasibility or greater hazard could be demonstratedAllowed, but employer has the burden to demonstrate conventional methods are infeasible or creates greater hazard before using
    Site Specific Fall Protection Plan (only if using Alternative Methods)Required, but does not have to be writtenRequired, must be written
    TrainingEmployees must be trained to understand and follow the Fall Protection PlanEmployees must be trained to understand and follow the Fall Protection Plan
    Roofing-Specific Requirements
    Low Slope Roofs (4:12 pitch or less)Use of warning lines and safety monitoring systems allowedUse of warning lines and safety monitoring systems allowed
    Slope Roofs (over 4:12 up to and including 8:12)Use of slide guard allowedGuardrails or personal fall arrest system required
    Steep Slope Roofs (over 8:12)Guardrails or personal fall arrest system requiredGuardrails or personal fall arrest system required

    * Fatal Falls from Roofs Among U.S. Construction Workers; Xiuwen Sue Dong,Sang D. Choi,James G. Borchardt,Xuanwen Wang,Julie A. Largay; Journal of Safety Research; February 2013

    **Resource Guide; NAHB/NAHB Research Center Fall Protection Training; Sept. 2011; Page 7 of 8

    You can reach Kelly at Falltech 800-719-4619

    General descriptions, definitions and rules for components of an acceptable fall protection system are found in OSHA Standard 29 CFR 1910.66 Appendix C. The information found in this standard applies to safety harnesses and fall protection systems used in any industry.

    So there you have it, “from the horse’s mouth” so to speak, harnessing your energy for more important things in life. Harnessing for Safety, Fall protection in residential construction.

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