ArticleThe Construction Safety Experts at Robson Forensic have compiled the OSHA Fall Protection Reference Guide. This guide covers the construction fall protection standards that are most commonly cited in construction injury disputes.
OSHA Fall Protection Reference Guide
The OSHA rules concerning fall protection are addressed in several Subparts of the regulations. This article addresses the various fall protection subpart rules.
It is interesting to note that the height at which workers are required to be protected from falling varies depending upon the industry in which they are employed, and, within the construction industry, the height varies depending upon the nature of the work being performed. Workers employed in general industry, such as warehouse and industrial workers, must be protected at heights at or above 4 feet. In construction, workers must generally be protected at heights at or above 6 feet but, depending upon the work task, can be exposed to falls up to 30 feet in height.
How is this variation in “acceptable” fall exposure justified? The key is training. All construction workers who might be exposed to fall hazards must be trained in the recognition of fall hazards and the procedures to be followed in order to minimize those hazards. Those workers performing specific tasks with increased exposures must be provided with additional specific fall hazard training.
General Industry Fall Protection Standards
Part 1910, Subpart D 1910.28 - Walking/Working Surfaces
- 1910.28 - Duty to have fall protection and fall object protection
- (b) Protection from fall hazards
- (b)(1) Unprotected sides and edges
- (c)(1)Every open-sided floor or platform 4 feet or more above an adjacent floor or ground level shall be guarded by a standard railing . . .
- Since its inception in the early 1970’s, 29 CFR 1910 OSHA General Industry Regulations (general industry as opposed to construction specifically, i.e. warehouse, industrial, etc. workers) have required workers to be protected from falling at heights at or above 4 feet.
- There are no specific Subpart D fall protection training requirements in the General Industry regulations
Construction Industry Fall Protection Standards
Part 1926, Subpart M 1926.501 - Fall Protection
- 1926.501 - Duty to have fall protection
- (b)(1) Unprotected sides and edges. Each employee on a walking/working surface with an unprotected side or edge which is 6 feet or more above a lower level shall be protected from falling by use of guardrail systems, safety net systems, or personal fall arrest systems.
- Since its inception in the early 1970’s, 29 CFR 1926 OSHA Construction Industry Regulations have generally required workers to be protected from falling at heights at or above 6 feet.
- Subpart M, section 1926.503 Training Requirements require fall protection training for all employees on construction sites who may be exposed to fall hazards:
- 1926.503(a)(1) The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.
Part 1926, Subpart L 1926.451 - Scaffolds
- 1926.451 -General requirements (g) Fall Protection
- (g)(1) Each employee on a scaffold more than 10 feet above a lower level shall be protected from falling to that lower level.
- OSHA originally established the maximum unprotected fall distance for scaffolds at 6 feet. By 1973, this height was increased to 10 feet in recognition of the fact that ANSI A10.8-1969 Scaffolding, the relevant consensus standard for scaffolding, had already established the threshold height for scaffolding fall protection at 10 feet.
- Subpart L, section 1926.454 Training Requirements require additional fall protection training for all employees on construction sites who may be exposed to fall hazards on scaffolds:
- 1926.454 (a) The employer shall have each employee who performs work while on a scaffold trained [in] . . .
- 1926.454(a)(2) The correct procedures for dealing with . . .the fall protection systems being used . . .
Part 1926, Subpart R 1926.760 - Steel Erection
- 1926.760 -Steel Erection 1926.760 Fall protection
- (a) General requirements
- (b) Connectors
- (c) Controlled Decking Zone
- (a)(1) Except as provided in paragraph (a)(3) of this section, each employee engaged in a steel erection activity who is on a walking/working surface with an unprotected side or edge more than 15 feet above a lower level shall be protected from fall hazards . . .
- (a)(3) Connectors and persons working in controlled decking zones (CDZ) shall be protected from fall hazards as provided in paragraphs (b) and (c) of this section, respectively.
- (b)(1) Each connector shall be protected in accordance with paragraph (a)(1) of this section from fall hazards of more than two stories or 30 feet above a lower level, whichever is less.
- (c)(1) Each employee working at the leading edge in a CDZ shall be protected from fall hazards of more than two stories or 30 feet, whichever is less.
- Following nearly 10 years of development by the Steel Erection Negotiated Rulemaking Advisory Committee (SENRAC), in 2001 OSHA published the revised Subpart R addressing steel erection work, including fall protection. (SENRAC was the first time that OSHA incorporated a negotiated rulemaking process involving a committee of individuals from government and private industry representing a cross-section of the industry. Following SENRAC, the Crane & Derrick Negotiated Rulemaking Advisory Committee, C-DAC, worked to overhaul the Cranes and Derricks in Construction subpart of Part 1926.) OSHA and the steel erection industry recognized the unique nature and challenges of the fall protection elements of steel erection especially as it relates to connecting and decking work.
- Subpart R, section 1926.761 Training requires additional fall protection training for all employees on construction sites who may be exposed to fall hazards during steel erection work, including specific training for connectors and deckers:
- 1926.761(b) Fall hazard training. The employer shall provide a fall protection program for all employees exposed to fall hazards . . .
- 1926.761(a) Training personnel. Training required by this section shall be provided by qualified person(s).
- 1926.761(c) Special training programs. In addition to the training required in paragraphs (a) and (b) of this section, the employer shall provide special training to employees engaged in the following activities:
- 1926.761(c)(2) Connector procedures . . .
- 1926.761(c)(3) Controlled Decking Zone Procedures . . .
Construction Injury 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.
The Construction Safety Experts at Robson Forensic bring to bear many years of hands-on construction experience and a working knowledge of applicable safety standards. They regularly address construction safety issues, including:
Planning for fall protection begins at the bidding stage. The cost of furnishing appropriate equipment must be included in contractors’ budgets. Prior to construction, contractors should determine what fall protection measures should be taken so that those elements can be procured. How will workers gain vertical access throughout the project? Temporary stairways, ladders, scaffolds, and aerial lifts need to be provided. How will workers be protected when working at leading edges? Steel members can have holes pre-punched to receive perimeter cables or horizontal lifelines. Davits can be embedded in concrete elements to serve as anchor locations for fall arrest systems.
Proper equipment needs to be furnished, properly used, and maintained. Fall protection equipment includes the aforementioned stairways, ladders, scaffolds, aerial lifts and fall arrest systems. Also, covers for floor, roof and wall openings need to be considered. Safety nets may be a possible fall protection solution. Guard rails will need to be provided at locations along the building perimeter and at interior openings. Aerial lifts and man-baskets need to be equipped with railings and tie-off points. Personal fall arrest systems must include lanyards which match their particular use. Ladders need to be of sufficient height that they are easily grasped at the top when ascending or descending. This equipment must be regularly inspected and repaired or replaced when parts are worn, broken, bent, frayed, or otherwise damaged.
Falls can be prevented when employees learn to recognize fall hazards and what corrective procedures to utilize to erect, inspect, and maintain fall protection systems. OSHA 1926.503 requires employers to provide training programs for each employee who might be exposed to fall hazards. Retraining may be required for employees who haven’t demonstrated the proper fall protection skills. Specific scaffold training is required for those working on scaffolds.
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Civil Engineer & Construction Safety Expert
Brent heads the Civil Engineering group at Robson Forensic and can help put you in touch with the expert whose qualifications best meet the demands of your case. The variety and depth of Brent’s experience over the past 35 years is significant. He worked in the construction trades prior to pursuing his engineering degree. He has personal experience working on ladders and scaffolds, pounding nails and laying brick. He has also been responsible for construction site safety on multi-million dollar projects.