OSHA’s Top 5 Fall Protection Violations – Part 5

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For 6 year in a row now, OSHA’s Fall Protection standard is the most cited annually. In this blog series, we already pointed out 4 of the 5 most cited sections and provided advice about how to prevent being cited for each section. In this last part, we will outline the most cited section within the Fall Protection standard:

Subpart 1926.501(b)(13) Residential construction

“Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.”

What does this standard mean?

The standard applies to workers at construction sites for single family houses or townhouses that are constructed using traditional wood frame construction materials and methods. Furthermore, the standard applies to workers who work at heights of 6 feet (1.8 m) or higher above a lower level. For example: workers who work on top of walls, wooden roof structures, walk on narrow beams unfinished floors or on roofs.

These are situations where lots of workers would often find themselves in and thus, proper safety measures need to be taken.

The risks at a residential construction site

Taking a look at the big difference in number of violations between the number 1 and 2 most cited violations (3,911 versus 1,278), we can conclude that the risk of falls at a residential construction site is big.

Not only workers who erect or install roofs are exposed to falling hazard by slipping or tripping. Also workers at floor levels with unprotected sides and workers on scaffolds or cherry pickers risk a fall from height if no safety measures are taken.

Construction sites are often crowded with workers, carrying a wide arrange of tools and materials with them. Furthermore, unstable and small surfaces are present at construction sites. As a result, tools, debris or materials laying around impose a big risk of tripping and subsequently falling from height.

Falls at a residential site might be perceived by workers as ‘not that dangerous’ because of the relatively low drops and not causing any serious injuries, but that is a big underestimation. Imagine an impact force of around 5500 lbs (2500 kg) when you hit the ground after a fall of just 6.6 ft (2 m). A fall like this means serious injuries could be caused, or even death. The risk of serious injuries increases, when the danger of impalement by scaffolding or stakes is present.

This underlines the importance of taking the right safety measures at a (residential) construction site.

Safety measures at a residential construction site

Due to the large variety of working environments at residential job sites (walls, roofs, scaffolds, unfinished structural parts etc.), determining the right safety solution for each situation is key.
Basically, conventional safety measures like guardrails, safety nets and personal arrest systems (all described earlier in this series) are suitable to be used at a residential construction site and comply to the “Residential Construction” standard. But when an employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer can develop and implement a fall protection plan that meets specific OSHA requirements, other than the “Residential Construction” standard.

In practice, this means that workers can work from scaffolds, ladders or aerial lifts as well or use other fall protection systems. Also, a combination of multiple solutions is possible: an aerial lift can be used to install a guardrail system on a higher level for example.

Eliminating risks as much as possible

Apart from these safety measures, OSHA advises to eliminate fall hazard whenever possible. Working at heights can never be totally eliminated, but there are ways to minimize exposure. Assembling as many parts of the structure as possible on the ground and hoisting them into position minimizes the frequency and duration of workers’ exposure to falls. Also, pre-fabricating and pre-positioning guardrail systems or another safety measure on the ground and placing them on the structure with a crane or aerial lift will minimize hazards.

Doing a Last Minute Risk Assessment prior to starting the work will help in identifying possible risks and actively think about measures to eliminate or minimize these risks.

The right safety measures for each situation

We believe that for each situation where work at height is performed, whether this is at a residential site, on a steep or low-slope roof, a platform with unprotected sides or on a flat roof, there is always a suitable safety measure available.

That’s why we continue to emphasize the importance of assessing and being aware of the risks and dangers during work at height.

We provide a simple overview of the top 5 fall protection violations and how to prevent dangerous situations. Use it to create awareness of the dangers and possible solutions that eliminate risks of falling from height.

Always keep safety in mind when working at height

This article concludes the series about the top 5 most cited violations within the OSHA Fall Protection standard. We continuously strive to increase safety for workers at height around the world and these blogs contribute to that goal. Our advice to you is to always keep safety in mind when working at height. By doing this, OSHA (or any other governmental occupational safety organization) doesn’t have to cite violations and you minimize the chance of accidents happening.

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