Brad Mang, Safety Consultant, FRSA Self Insurer’s Fund
As we approach OSHA’s annual National Safety Stand- Down to Prevent Falls in Construction (May 1 - 5), this is
the perfect time to remind roofing contractors of their responsibilities to provide the proper training on fall
protection to their employees.
Each year, falls to a lower level are the leading cause of death among construction workers and account for one-third of all construction fatalities. According to the latest report from the Bureau of Labor Statistics, the fatality rate for workers killed because of falls remains at 38 percent (378 of 986 total deaths for 2021).
Along with this troubling data, OSHA’s release of their Top 10 Violations for 2022 included, at number one, Fall Protection – General requirements (5260 citations issued) and, again on the list at number eight, Fall Protection – Training requirements (1566 citations issued).
In addition to the loss of life, a fatality from a fall can easily bankrupt a company. More than $40 billion in workers’ compensation benefits are paid out each year from employers and their insurance companies. OSHA has come down hard on employers who violate the fall protection standards through monetary fines. In 2023, the agency’s fines were adjusted for inflation, resulting
in an increase that lifted the maximum penalty for a serious violation to $14,502 and repeat or willful violations to a maximum of $145,027.
In a recent study conducted by OSHA, of almost 100 fall related fatalities, it was shown that these deaths could have been prevented if fall protection such as guardrails or personal fall arrest systems had been used on the jobsite. An easy way to help prevent these deaths is to ensure that each worker exposed to a fall hazard has the proper training required by OSHA
standards.
OSHA standards state that an employer shall provide a training program for each employee who might be exposed to fall hazards. OSHA notes, “The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed to minimize these hazards. Training should provide in-depth sessions on regulations, potential hazards, equipment selection and instruction on how to use the equipment correctly.” The training must be implemented by a “competent person” qualified in the following areas:
1. Procedures for erecting, maintaining, disassembling and inspection of fall protection systems to be used
2. Use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, controlled access zones and other possible protection to be used
3. The role of each employee in a safety monitoring system
4. The limitations on the use of mechanical equipment for low-slope roofs
5. Correct procedure for handling and storage of equipment and materials
6. Role of employees in the fall protection plan.
Along with the standard, please note the brief description that OSHA defines as a competent person – “one who is capable of identifying existing and predictable conditions in work areas which are unsanitary, hazardous or dangerous and who has the authorization to take prompt corrective action.” This is a very important detail to point out because roofing contractors need to consider who is training their employees to ensure they are compliant with OSHA standards. The amount of time required for competent person training varies based on the scope of work performed but on average it is 8 to 40 hours. The training will need to combine discussions, demonstrations by instructor, testing and hands-on demonstration by employees for each fall protection system used by the employer. A certification of training will also need to be completed. The employer must create a written certification identifying each employee trained, the dates of training and the signature of the person who conducted the training or the signature of the employer. All materials used in the training should be maintained with the company records for documentation in the event of an OSHA inspection. After employees have completed the proper fall protection training, it is imperative that
company management conducts frequent and regular inspections of jobsites to verify each employee’s understanding of what they have been trained on. If an employer has reason to believe that an employee is still lacking the required understanding, retraining will be necessary or termination may be necessary if the employee refuses to follow the company’s safety policies.
The impact of an effective fall protection training program is a competent employee who can control fall hazards resulting in a higher level of safety and compliance. By investing in safety training, companies can avoid serious injuries and save lives, decrease
insurance modification rates and improve working conditions. A solid fall protection training program is a sound investment, not just another added expense to the company’s bottom line. For more information on OSHA’s National Stand-Down program, please visit www.osha.gov/stop-falls-stand-down.
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