Each year, we continue to see that fall protection is one of OSHA’s top 10 cited violations. Why is that? Is it because there is limited guidance on what is required? Is there limited availability of the equipment necessary to comply? The answer to these key questions is a flat-out no. We have the necessary information and equipment availability to comply with the OSHA standards on fall protection.
Whether climbing a pole or tower structure or working on a low-sloped roof, off of a scaffold or even out of a bucket, OSHA requires proper fall protection techniques for workers. Be it under 1910.269 Appendix F, Work-Positioning Equipment Inspection Guidelines, or 1926 Subpart M, there are standards we must follow.
Under 1910.269, the standard covers inspection requirements for body belts, positioning straps and climbers, as well as when and how to use these devices. The more specific requirements on fall protection fall under 1926.502(d) and (e) Subpart M, which 1910.269 refers us to. Other information on OSHA standards covering fall protection can be found in 1910 Subpart D, Walking/Working Surfaces; 1910 Subpart I, Personal Protective Equipment; and 1910.140, Personal Fall Protection Systems.
Simply put, you are required to have a personal fall-arrest system in place anytime you are 4 feet or more above ground, and must limit the potential free fall to no more than 2 feet. In the past, when climbing a pole, a “qualified” climber could “free climb” a structure and then belt off once they got to the work position. You can no longer do this.
When climbing poles or similar structures today, folks use equipment such as a pole shark or buck squeeze to climb, which limits potential for a free fall. The standards point out the type, strength and inspection requirements for all equipment being used. Great, but how do you achieve compliance?
Compliance with any standard comes down to an understanding of what is required, how to train to meet that objective and continual reinforcement of the practice in the field. How many times have you been out in the field and witnessed an employee, for example, not wearing their harness properly or not having the proper guard rails in place when working from a low-sloped roof, because doing so would take longer, at times, than the actual job?
How we react in those situations tends to influence our employees’ actions. We need to reinforce the proper techniques and work rules that keep people safe when aloft and retrain those workers who don’t practice proper fall-arrest procedures. Safety needs to take precedence over production, and how you, as a leader in the organization, emphasize that is the key to your success.
It only takes one fall to bring to light the dangers of improper technique. So when conducting your training, emphasize the proper techniques, daily inspection of equipment and the proper testing required for each item in a fall protection system. Take the time to stop an unsafe practice and point out the proper protections needed to take place when out in the field. It may slow down the job for a bit, but it also may prevent a catastrophic injury to one of your valued employees.
Compliance with OSHA standards can be confusing. Those of us who have read OSHA rules and participated in rule-making over the years know that there is a broad range of interpretation. We argue with OSHA to publish rules in “performance-based” language so we can adapt them to our various work environments.
Once OSHA does that, we then argue that there isn’t enough specificity in the rule for us to understand compliance. We want to be able to comply with the rules, but we need to adapt them to our specific business. After all, as we say, there is no “one size fits all” in safety.
Historically, in any OSHA rule-making, there is a wide variety of participating entities, including specific companies, industry trade associations, labor unions and manufacturers. These are sources of compliance assistance when you embark on training and compliance for a specific rule. Don’t be afraid to use the available expertise from outside of your own organization. The benefits will make your job a lot easier.