Does a 6 ft. edge clearance provide adequate fall protection safety for OSHA guidelines? Are construction rules interchangeable? Do portable ladders require fall protection? OSHA’s fall protection safety guidelines CFRs 1910 and 1926 have been met with mixed levels of adoption, clarity, and confusion, caused by self interpretation and a lack of awareness of the OSHA 351 Standard Interpretations since their introduction in 1973. Many of the current myths and misconceptions surrounding OSHA fall protection standards began as self-interpretation, where a company decided what the standards meant, and their interpretation became so popular that many people are unable to differentiate those practices from actual OSHA standards.
Spider will address some of the common myths and misconceptions surrounding fall protection safety.
Misconception: 29 CFR 1910 (General Industry) & 29 CFR 1926 (Construction) Standards Are Interchangeable
Many professionals treat CFR 1910 General Industry and CFR 1926 Construction standards as though they are interchangeable. This is a common misconception and can result in dangerous situations in at-height workplaces. It is crucial to determine the type of work before setting the safety standards. However, the gaps between CFR 1910 and CFR 1926 are closing, but most at-height work applies to CFR 1926, which means that those standards should be applied if you are uncertain of the type of work being done.
Myth: 6-Foot Rule
The 6-foot rule, or the idea that no fall protection is needed if all work is performed at least 6 feet from an edge, is a myth. It is also completely wrong according to both OSHA standards. OSHA has created multiple interpretation letters to attempt to clear up the issue, including a 1996 letter and a May 2000 letter. While OSHA determines that there is no distance that provides absolute safety from a fall, a distance of 50-100 feet would be considered a de minimis violation of standards (it is a violation of standards to not have the fall protection, but it does not directly affect health and safety and is therefore not included on a citation), and the use of non-conforming guardrails 15 feet from the edge is another de minimis violation.
For General Work, a designated area is close to the 6-foot rule. However, a designated area must have a clearly marked perimeter, be on a roof with a slope of 10 degrees or less, and only applies for temporary work. Also, access to the area must be clearly marked.
According to CFR 1926 Standard Subpart M, there is no safe working distance for construction work, and a guardrail or other standardized fall protection measures should be included.
OSHA 1926.5010(b)(10) requires that employees working on low-sloped roofs with unprotected sides and edges and drops of six feet or more be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a warning line system combined with either a guardrail system, safety net, safety monitoring system, or personal fall arrest system.
Myth: Portable Ladders Require Fall Protection
It is a common myth to assume that no fall protection is required on portable ladders. While it is understood that fixed ladders of certain heights require a cage or well for ladders of 20 to 30 feet, many people assume that these rules also apply to portable ladders. While General Work CFR 1910 does not include any references to portable ladders, Construction CFR 1926 refers to portable ladders, but fails to outline specific rules. However, in interpretation letters, OSHA states that fall arrest and fall protection are not required for portable ladders but does recommend fall arrest systems for any heights over 15 feet. It’s also important to meet the envelope requirements for ladder stability (4:1 angle, tie-off, footing, hands free, center of gravity. etc.), and follow the manufacturer’s recommendations.
Misconception: A Body Harness and a Lanyard Immediately Make a Worker Safe
The idea that a worker is safe as soon as he or she puts on a body harness connected to a lanyard is a dangerous misconception. In order to ensure actual safety, it is crucial to calculate the distance of the lanyard, appropriately position the anchor, calculate pendulum fall, and ensure that the lanyard will not bounce when the worker falls on it. Without the appropriate calculations, a worker could be in just as much danger with a body harness and a lanyard as without them.
Myth: Rescue Planning Just Means Calling Emergency Services
Leaving a worker in a suspended situation after a fall might result in their death while waiting for emergency services to arrive. In many cases, suspension trauma must be dealt with within 14 minutes in order to prevent permanent damage or death. Construction standards state that the employer must attempt the prompt rescue of an employee after a fall, but does not specify the definition of ‘prompt’.
Myth: You Don’t Need Fall Protection for Very Temporary Work
For construction, it is mandatory to provide fall protection in any area where workers are on a surface that is more than six feet above a lower level. Because workers can fall at any time, the duration of the work has no bearing on whether or not the standard should be implemented, except during initial inspections prior to the start of the job. In fact, OSHA 1926.501(b)(1) requires fall protection for jobs even lasting only a few minutes.
Other: Fall Restraint
Fall restraint and fall positioning are frequently confused. Fall restraint is the process of using a physical apparatus to prevent a fall, and fall positioning is the process of using a physical apparatus to restrict any fall to a maximum of 2 feet. The big question here is whether or not fall restraint is permissible under General Work or Construction instead of Fall Arrest. While not explicitly mentioned in the original CFR 1910 or CFR 1926, both General Work and Construction guidelines include standard interpretations that allow for fall restraint.
The proposed changes to CFR 1910 sections D and I incorporate fall restraint as restraint line systems and mandate that lines should be capable of sustaining a tensile load of at least 3,000 lbs. In situations where you cannot fall, body belts are acceptable rather than a full body harness, and you can use a longer lanyard with a tether that prevents a fall in any direction and a 3,000 lb. anchor. If a personal fall arrest system is needed, refer to the guidelines and standards for personal fall arrest instead.
The best way to combat potentially dangerous fall safety misconceptions is to ensure that everyone on the job site is fully educated and aware of OSHA standards and their interpretations. You can review fall protection training requirements in 1926.503(a)(1).
Spider is the largest manufacturer and distributor of suspended access and fall protection solutions in North America. Contact us at 877-774-3370 for a range of fall safety protection equipment including lanyards, full body harnesses, and guardrails, or to request more information regarding our OSHA-approved fall protection safety training.
The content in this blog post was derived from the Lawrence Livermore National Laboratory and published by OSHA. To read the original post in its entirety click here.