February 1, 2014 - When I conduct OSHA 10 and 30-hour training classes, most students seem to know that Federal OSHA requires some form of fall protection for employees working at heights greater than four (4) feet in General Industry (1910), and at heights over six (6) feet in Construction (1926). However, many of them are unaware that there are numerous other OSHA standards requiring fall protection at other heights; some are lower, some are higher, and some only apply (or do not apply) in certain situations.
So in this month's blog I decided to provide an overview of the most prevalent Federal OSHA 1910 General Industry standards requiring some form of fall protection when employees are working at various heights (next month I'll list the 1926 Construction standards) so that, should you come across one of these scenarios, you'll be up to speed on the actual OSHA requirements.
As already mentioned, there are Federal OSHA standards which mandate guardrails or some other form of fall protection system be utilized to protect workers from falls of greater than four (4) feet. Included among these are 1910.23(c), which requires a standard guardrail (or equivalent) be installed along unprotected edges of open-sided floors, platforms, and runways greater than four (4) feet above the floor or lower level. And in that same subpart you will find 1910.23(b), which requires fall protection (typically rails or covers) at wall and floor openings of various types, such as stairwells, chute openings, and ladder openings.
However, paragraph 1910.23(c)(3) requires a standard guardrail be installed along open sides of any open-sided floor, walkway, platform, or runway located above or along the side of dangerous equipment, pickling or galvanizing tanks, degreasing units, and similar hazards, regardless of its height. And paragraph 1910.23(d)(1) requires a stair rail to be installed on each open side of any flight of stairs having four or more risers; on many smaller industrial stairs with just a few risers, this could easily be less than four (4) feet high. So there you have a couple of examples where fall protection is required at less than the four (4) foot threshold.
There are also numerous OSHA general industry standards for various types of scaffolding which require guardrails be installed along open sides and ends of work platforms, but only if they are located greater than ten (10) feet above the ground or floor. See 1910.28(b)(15), (c)(14), (d)(7), (f)(15), (g)(5), (h)(8), (k)(5), (m)(7), (o)(2), and (p)(7) for the specific requirements for rails to be placed on these types of scaffolds. However, there are a few types of suspended scaffolds, such as float or ship scaffolds [1910.28(u)], two-point suspension scaffolds [1910.28(g)(9)] and a boatswains chair [1910.28(j)] which require the worker(s) be protected from falls by wearing a “safety lifebelt” attached to a lifeline, regardless of the height. But the requirements for needle beam scaffolds [1910.28(n)] requires only those workers located 20 feet or more above the ground or floor and working with both hands be protected by a “safety life-belt” attached to a lifeline.
OSHA standard 1910.27(d)(1)(ii) requires fixed ladders be equipped with cages or wells on ladders of more than 20 feet (to a maximum unbroken length of 30 feet). However, fixed ladders on towers, water tanks, and chimney ladders that are over 20 feet in unbroken length may be equipped with suitable safety devices such as lifebelts, friction brakes, and sliding attachments in lieu of cages.
OSHA standard 1910.66(f)(5)(i)(G) requires that each working platform of powered platforms used for building maintenance be provided with a guardrail system on all sides. And standard 1910.66(f)(5)(ii)(M) requires a vertical lifeline be provided as part of a fall arrest system meeting the requirements of appendix C of that standard for each employee on a working platform suspended by two or more wire ropes if the failure of one wire rope or suspension attachment would cause the platform to be upset. However, if a secondary wire rope suspension is used, then vertical lifelines are not required for the fall arrest system provided that each employee is attached to a horizontal lifeline anchored to the platform.
OSHA standard 1910.67(c)(2)(v) for aerial boom-lifts requires the user(s) to wear a body belt with lanyard attached to the boom or basket when working in the basket. There is no height specified for this requirement, which is related to the purpose of tying off; this is a body positioning device to keep the person from being thrown out of the basket, as opposed to a fall arrest system (see related blog post for additional information about fall protection in aerial lifts).
There are also fall protection requirements appearing in several of the OSHA standards for specialty industries, such as those regulating paper, pulp, and paperboard mills. 1910.261(e)(4) requires that protective equipment be provided for persons working over water. Furthermore, OSHA standard 1910.261(e)(12)(i) requires that when platforms or floors allow access to the sides of continuous barking drums, a standard railing shall be constructed around the drums. And employees working around the broke hole for pulp and paper machinery must be protected from falling into the hole by a guardrail [see 1910.261(k)(13)(i)], or, in cases where the pulpers are located directly below the broke hole on a paper machine and the broke hole opening is large enough to permit a worker to fall through, any employee pushing broke down the hole must wear a safety belt attached to a safety belt line which is rigged so that it is impossible for the person to fall into the pulper [1910.261(k)(13)(ii)].
OSHA standard 1910.268(g)(1) for the telecommunications industry require safety belts and straps be provided and used when work is performed at positions more than four (4) feet above ground, on poles, and on towers, except when work platforms with suitable guardrails are provided on elevated work platforms. Similarly, OSHA standard for electric power generation, transmission, and distribution [1910.269(g)(2)(v)] requires that fall arrest equipment, work positioning equipment, or travel restricting equipment be used by employees working at elevated locations more than four (4) feet above the ground on poles, towers, or similar structures if other fall protection has not been provided. However, fall protection equipment is not required to be used by a "qualified" employee climbing or changing location on poles, towers, or similar structures, unless conditions, such as, but not limited to, ice, high winds, the design of the structure (for example, no provision for holding on with hands), or the presence of contaminants on the structure, could cause the employee to lose his or her grip or footing.
So there is an overview of the various Federal OSHA 1910 general industry regulations which specify some form of fall protection system be provided for workers. As you can see, many are based on the four (4) foot threshold. But several of these standards have requirements that don’t kick in until the worker is exposed to a fall of ten (10) feet, or even a much greater height, while other standards require protection be provided for workers at lower thresholds, all the way down to ground level. So the next time someone tells you fall protection is only (or always) required above four (4) feet in general industry workplaces, recall that is not always the case; sometimes it may be required at lower, or even higher, thresholds.
Were you surprised by any of the fall protection requirements (or lack of a requirement) appearing in this post? Or, are you aware of another federal OSHA 1910 general industry standard that specifically requires fall protection? If so, please share that information with us in the “Comments” section of this post by clicking here and then scrolling down the page to the “Comments” box. And don’t forget to read next month’s blog, when we list the fall protection thresholds for the construction industry.
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