Look Out Below

OSHA’s "6-foot rule" for fall protection is pretty straightforward. It states that if any employee is in a situation where they may lose balance and fall to a lower level or simply fall 6 feet or more, fall protection must be provided and used. So why is fall protection consistently included in OSHA’s top 10 most frequently cited violations? For one, unfortunately, contractors often believe it is easier, faster and cheaper not to comply. A second reason may be a misinterpretation of the standards related to fall protection.

Scenario 1

A portable ladder is placed on the roof of a structure within a larger building. The roof of the inner structure is at least 10 feet above the lower level, about 10 feet by 10 feet, and strong enough to support the load of workers, materials and tools.

This situation relates to two standards, Subpart M and Subpart X. First is the need for fall protection from the 10-foot roof. Second is fall protection while the worker is on the ladder. The roof falls under Subpart M, Fall Protection as a walking/working surface. Section 1926.501(b)(1) of Subpart M states that a work surface with an unprotected side or edge that is 6 feet or more above a lower level must be protected by some form of fall protection. This can be a guardrail, safety net or personal fall arrest system. Since the work surface is unprotected and 10 feet above the lower level, fall protection is required for any employee working on this surface.

Although working on a ladder is not specifically covered in Subpart M, ladders and any fall protection are covered in Subpart X, Stairways and Ladders. Subpart X does not require fall protection for working on a portable ladder in the same manner as Subpart M. Protection is provided in the proper use of the ladder, such as setting the ladder at the appropriate angle, maintaining three points of contact with the ladder and keeping the body centered on the ladder.

Scenario 2

Work is being done on a low-slope roof by both roofers and heating, ventilating and air conditioning (HVAC) installers. The roofers can comply with fall protection on a low-slope roof by using a warning line placed at least 6 feet from the roof edge (1926.501(b)(10) of Subpart M). In order for the HVAC installers to go without personal fall protection, the warning line must be at least 15 feet from the edge. Since both are working on the roof at the same time, would the 6-foot warning line be sufficient for both trades?

The purpose of the warning line is to keep employees away from the unprotected edge, thus preventing a fall. There are a few specific situations where the standard allows the use of a warning line instead of fall protection, including low-slope roof work, some leading edge work, precast concrete erection and residential construction, i.e., situations in which the feasibility of fall protection is limited. HVAC equipment does not fit into any of the exempted categories, so a warning line at 6 feet is not an option.

There are at least two solutions for this situation. One is to run two separate warning lines, one at 6 feet for the roofers and another at 15 feet for the HVAC installers. Depending on the particular work site, this may be confusing or simply unworkable. The other possibility is to equip the HVAC installers with conventional fall protection (e.g., personal fall arrest systems), while running a warning line at 6 feet for the roofers’ fall protection. This way, both trades comply with the fall protection standards that apply and are kept safe on the job site.

Scenario 3

Employees are performing work-related tasks while on a guardrail-equipped scissor lift platform. The lift’s platform extends beyond the wheelbase of the lift. The scissor lift and its guardrails meet all applicable requirements in Subpart L, Scaffolds. Work is conducted from the scissor lift only when the lift is stationary. Would the workers be required to have fall protection in addition to the guardrail?

According to Subpart L, employees working on a scaffold more than 10 feet above a lower level must be protected from falling to the lower level. There are, however, different ways to protect the employees. Since a scissor lift is not named specifically in the standard, it would be covered under 1926.451(g)(1)(vii), which states that employees can be protected by either a personal fall arrest system or a guardrail system that meets the appropriate requirements. Since the guardrail system meets the requirements, no further fall protection is required.

The need for fall protection on the job cannot be denied. Unfortunately, determining if it is needed and what should be used can be a time-consuming and tedious task. Although it may be a challenge, the safety afforded to the employees and the benefits to them and their families makes it worth the effort.

KELLY is a safety and health specialist with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. She can be reached at 800.745.4818 or dkelly@intecweb.com. Joe O’Connor edited this article.

About the Author

Diane Kelly

Safety Columnist
Diane Kelly is a safety and health specialist with Intec, a safety consulting, training and publishing firm that offers on-site assistance and produces manuals, training videos and software for contractors. She can be reached at 800.745.4818 or dkell...

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