Fall-through hazards (i.e. holes) are among the myriad of safety concerns commonly found on construction sites. Contained within OSHA’s Fall Protection regulations, a ‘hole’ is defined as a gap or open space in a floor, roof, horizontal walking-working surface, or similar surface that is at least 2 inches (5 cm) in its least dimension.
In this article, Civil Engineer & Construction Safety Expert, David Gardner shares the steps that should be taken on a construction site to prevent falls and other injuries related to holes.
Holes as Fall Hazards on Construction Sites - Expert Overview
Holes that present a potential safety hazard(s) can be found inside of buildings, in shops or warehouses, on work platforms, on roofs, on roadway/bridge construction, and in other outdoor working environments. Some common examples of holes found on construction projects are: skylights, roof ducts/drains, unfinished stairs or missing steps, unsupported walkways and/or ceilings, chutes, and manholes. Unprotected holes in the floor, deck, or roof have been responsible for a number of very serious injuries. Yet, through planning and personal attention, falls through holes can be easy to prevent.
Construction Standards for Managing Holes
Regulations such as OSHA 29 CFR 1926 Construction Industry Regulations, Subpart M - Fall Protection, as well as other nationally recognized standards such as ANSI A10.18 Safety Requirements for Temporary Roof and Floor Holes, Wall Openings, Stairways, and Other Unprotected Edges in Construction and Demolition Operations are helpful in defining the standard-of-care for managing holes on construction sites. Presented below is a summary of the industry safety regulations and/or standards for holes.
- If you make a hole, guard it. Before cutting the hole, barricade the work area to keep people out.
- If the hole must be open, and the fall distance is more than 6 feet, then employees must be protected by either the use of a fall arrest system, guardrails or covers.
- If a fall arrest system is to be used, it must meet the OSHA criteria established in 1926, Subpart M.
- If guardrail is used they need to be a minimum of 42 inches high, have a mid-rail, and be capable of withstanding a 200 pound load, similar to railings around the edge of a building or stairwell. Toe boards are recommended at all times and are required if anyone is going to work under the hole.
- If the hole is not guarded, then it must be covered. The cover must be capable of supporting at least a 200 pound load, be larger than the opening, secured against displacement, and properly labeled/identified – such as “Floor Opening Do Not Remove.”
NOTE: If you have a choice, make both the hole and cover round. An oversized round cover cannot fall through a smaller round hole.
- Never cover a hole with any type of non-substantial or non-weight bearing material(s) such as paper, cardboard or plastic.
- Regardless of the fall distance, industry standards require that employees be protected from tripping and/or stepping into holes by placing covers over them.
In layman’s terms: if a hole is big enough to fall through, then it must be either be covered, guarded, or fall protection measures utilized. If it is a small hole that presents only a tripping hazard (ex: a 4 inch diameter hole for a pipe), then you must cover it regardless of the fall distance below the hole.
Contractor Responsibilities for Site Safety
Particularly on residential and small commercial projects, skylights and utility vents are very common; and accordingly, are a prime factor in fall through accidents. If openings such as skylights and vents are slated for the project, the contractor must protect the openings in the manner as presented above; until the installation is complete, and the potential hazard is removed.
Regardless of the type (i.e. residential, commercial, or heavy/highway) or complexity of the project, it is the General Contractor’s (GC) responsibility to assure that all parties are properly communicating with one another, and that potential safety hazards are brought forth and discussed. “If you see something – say something.” Hence - as an example - on a project where there are various contractors that potentially could be working in the same area/vicinity (i.e. Framing, Roofing, HVAC, etc.), the GC must ensure that when the framing subcontractor creates an opening for a future skylight:
- The framing sub properly guards, marks, etc. the opening. If not, then that responsibility falls to the GC.
- The location of said opening(s) and/or hole(s) is properly and fully communicated to the subcontractors whose work will likely follow (i.e. Roofing and HVAC).
Fall from Elevated Height Case Examples
As a Civil Engineer Expert in construction matters, I have encountered fall from elevated height cases that occurred in both residential and commercial construction projects in the following manner(s):
- A direct employee to the GC fell through an opening that was created by another co-worker; but the opening was not guarded, nor was its existence ever communicated internally.
- An HVAC subcontractor employee fell through a walking surface that was not properly supported. The GC instructed a different subcontractor to use a piece of drywall to cover over an opening that previously acted as an access to the ceiling/working area; however, the GC never ensured that this work was properly communicated to their various subcontractors, nor did they guard and/or mark the area.
- The employee of a painting subcontractor was required to work immediately next to an open elevator shaft that was unguarded, and no fall protection measures were provided and/or utilized.
- An employee for a masonry subcontractor fell through an opening in a residential roof that was covered over by the roofing subcontractor with only felt paper. The GC was fully aware of the existence of the opening and the fact that the roofing sub had conducted work on this section of the roof immediately prior to the masonry sub’s work. The subject opening was not guarded and/or marked.
Construction Safety Investigations
The Construction Safety experts at Robson Forensic have worked at every level within the industry, from bricklayer on residential projects to project manager on multi-prime worksites. Our experts have done the work central to your case and can testify regarding the hazards, risks, and responsibilities in the construction industry.
Submit an inquiry or contact the author of this article to discuss your case with an expert.
Civil Engineer & Construction Safety Expert
David Gardner is a civil engineer with more than 25 years of professional experience. He provides investigations, reports, and testimony in matters involving construction claims and injuries. Dave’s project experience crosses various disciplines within civil engineering, including heavy highway and bridge construction, municipal engineering, compressor stations/site work for the natural gas industry, and residential/commercial building development.