Lisa Pate, FRSA Executive Director
Fall Protection – General Requirements (1926.501) maintained its position as OSHA’s most frequently cited worker safety and health standard in fiscal year 2022, marking its 12th straight year atop the agency’s “Top 10” list. Three out of the top five top violations affect the roofing industry and should be of concern to all employers. Protecting your most valuable asset begins with information and training.
OSHA Standard 1926.501 received 5,980 violations last year. The standard outlines where fall protection is required, which systems are appropriate for given situations, the proper construction and installation of safety systems and the proper supervision of employees to prevent falls. It’s designed to protect employees on walking-working surfaces (horizontal or vertical) with an unprotected side or edge above 6 feet.
Fall Protection hazards include falls, fractures and deaths – all preventable with proper training, which include face-to-face instructions, directions on the jobsite and constant reminders. You may know how to avoid these hazards and the tips below may seem like common sense but they are certainly worth repeating. Share them with your team and ensure they understand what’s expected of them.
■ Ensure that the jobsite is assessed to determine if the walking and working surfaces have the strength and structural integrity to safely support workers.
■ Ensure that the workers exposed to falling 6 feet or more from an unprotected side or edge are protected by a guardrail system, safety net system or personal fall arrest system.
■ A personal fall arrest system consists of an anchorage connector, body harness and may include a lanyard deceleration device lifeline or a suitable combination.
■ Ensure that workers in a hoist area exposed to falling 6 feet or more are protected by either a guardrail system or a personal fall arrest system.
■ Ensure that employees exposed to a floor hole (including skylights) more than 6 feet above lower levels are protected by personal fall arrest systems, covers or guardrail system.
■ Ensure that employees using ramps, runways and other walkways are protected from falling 6 feet or more by a guardrail system.
■ Ensure that employees engaged in roofing activities on low-slope roofs with unprotected sides and edges 6 feet or more above the lower level are protected from falling by a guardrail system, personal fall arrest system, safety net system or a combination warning line system and guardrail system, warning line system and personal fall arrest system, warning line system and safety
monitoring system or warning line system and safety net system.
■ Ensure that employees engaged in roofing activities on steep roofs with unprotected sides and edges 6 feet or more above the lower level are protected from falling by a guardrail system with toe boards, safety net system or personal fall arrest system.
■ Ensure that employees constructing a leading edge 6 feet or more above a lower level are protected from falling.
■ Ensure that employees on walking or working surfaces 6 feet or more above a lower level where leading edges are under construction (but who are not engaged in the leading-edge work) are protected from falling.
■ Ensure that employees working above dangerous equipment are protected from falling into or onto the dangerous equipment by guardrail systems or by equipment guards.
■ Ensure that employees working on roofs 50 feet or less in width are, at a minimum, protected by the use of a safety monitoring system.
■ Ensure that employees engaged in residential construction activities 6 feet or more above lower levels are protected from falling by guardrail systems, safety net systems or personal fall arrest systems.
■ Employees working on, at, above or near wall openings (including those with chutes attached) where the outside bottom edge of the wall opening is 6 feet or more above lower levels and the inside bottom edge of the wall opening is less than 39 inches above the walking or working surface shall be protected from falling by guardrail systems, safety net systems or personal fall arrest
systems.
■ Personal fall arrest systems and positioning device systems shall be inspected before each use.
OSHA Standard 1926.1053 received 2,471 violations and ranked third on the Top 10 list. This standard covers general requirements for all ladders. Employers or superintendents should inspect all ladders and focus on these items:
Hazards: Broken or missing parts, used around energized electrical equipment; too short for work height; weight limit rating too low; not the correct equipment for the job.
Loads: Self-supporting (foldout) and non-self-supporting (leaning) portable ladders able to support at least four times the maximum intended load; extra-heavy-duty metal or plastic ladders able to sustain 3.3 times the maximum intended load.
Angle: Non-self-supporting ladders positioned with a horizontal distance from the top support to the foot of the ladder is about 1/4 the working length of the ladder; job-made wooden ladders positioned such that the horizontal distance is equal to about 1/8 the working length.
Rung: Rungs, cleats or steps must be spaced between 10 and 14 inches apart; on extension trestle ladders, the spacing must be 8-10 inches for the base, and 6-12 inches on the extension section, shaped so that an employee’s foot cannot slide off; skid resistant.
Storage: Store where ladders cannot be damaged, prevent warping or sagging, secure during transport.
Inspection: Check to ensure shoes and ladder are free of oil, grease, wet paint and other slipping hazards; warning labels are legible; spreader device can be locked in place and ensure areas around the top and bottom of the ladder are cleared of material.
Safe Practices: Face ladder and hold on with both hands when climbing; carry tools on belt or use hand line; hold on with one hand when performing work; never reach too far to either side or rear; do not climb higher than the second step from top on a stepladder or third from the top on a straight ladder; never attempt to move, shift or extend ladder while in use. Best practices include:
■ Do not place ladders in front of doors opening toward the ladder unless the door is blocked open, locked or guarded.
■ Do not place ladders on boxes, barrels or other unstable bases to obtain additional height.
■ Extend portable rung ladders, when used to gain access to elevated platforms, roofs, etc., at least 3 feet above the elevated surface.
■ Secure the ladder at the base of a portable rung or cleat-type ladder to prevent slipping or otherwise lash or hold it in place.
■ Legibly mark portable metal ladders with signs reading “CAUTION-Do Not Use Around Electrical Equipment” or equivalent wording.
■ Prohibit the use of ladders for other than their intended purposes.
■ Adjust extension ladders while employee stands at the base and not while standing on the ladder or from a position above the ladder.
OSHA Standard 1926.451 received 2,285 violations and ranks fifth on the list. This standard covers general safety requirements for scaffolding, which should be designed by a qualified person and constructed and loaded in accordance with that design. Employers are bound to protect construction workers from falls and falling objects while working on or near scaffolding at heights of 10 feet or higher. Best practices include:
■ Construct scaffolds according to the manufacturer’s instructions.
■ Ensure that scaffold components from different manufacturers are not intermixed unless the components fit together without force and the scaffold’s structural integrity is maintained and each manufacturer approves the interchange.
■ Ensure that scaffold platforms cannot be more than 14 inches from the work, unless guardrail systems are erected along the front edge and personal fall arrest systems are used.
■ Make sure that platforms are extended over the centerline of its support at least 6 inches unless cleated or otherwise restrained.
■ Platforms of 10 feet or less cannot extend more than 12 inches beyond the support.
■ Platforms greater than 10 feet cannot extend more than 18 inches beyond the support.
■ Make sure that scaffold plank ends abutted to create longer platforms are resting on separate supports.
■ Make sure that scaffolds that change direction (such as turning a corner), have platforms that rest on bearers and not on the right angle platforms.
■ Ensure that wood platforms are free from opaque finishes.
■ Scaffolds with a height to base width ratio of more than four to one (4:1), have to be restrained from tipping by guying, tying, bracing or equivalent means.
■ Scaffold poles, legs, posts, frames and uprights have to bear on base plates and mud spills or other adequate foundations.
■ Ensure that footings are leveled, sound, rigid and capable of supporting the loaded scaffold without settling or displacing.
■ Use only stable objects to support scaffold and platform units.
■ Use only stable objects as working platforms.
■ Plumb and brace supported scaffold poles, legs, posts, frames and uprights to prevent swaying and displacement.
■ Provide safe access means (e.g., portable ladders, hook-on ladders, ramps, walkways, etc.) to scaffolding platforms, when the platforms are more than 2 feet above or below a point of access.
■ Do not use cross bracings as a means of access.
■ Properly position portable, hook-on and attachable ladders so as not to tip the scaffold.
■ Ensure that stairway-type ladders can have a minimum step width of 11-1/2 inches and have slip-resistant threads on all steps and landings.
■ Provide stair rails with an adequate top rail and an adequate mid rail on each side of the scaffold stairway.
■ Provide handrails and top rails serving as handrails with an adequate handhold for employees grasping them to avoid falling.
■ Ensure stair rail systems are surfaced along with handrails to prevent injury to employees from punctures or lacerations and to prevent snagging of clothing.
■ Provide landing platforms at least 18 inches wide by at least 18 inches long at each level.
■ Provide threads and landings with slip-resistant surfaces.
■ Install stairways between 40 degrees and 60 degrees from horizontal.
■ Scaffolds need to be erected a minimum of 10 feet away from uninsulated overhead power lines.
■ Provide guardrails or proper construction on the open sides and ends of each landing.
■ Integral prefabricated scaffold access frames specifically designed and constructed can be used as ladder rungs.
■ Inspect scaffolds and scaffold components for visible defects ONLY by a competent person before each work shift and after any occurrence that could affect a scaffold’s structural integrity.
■ Scaffolds that have been damaged or weakened need to be immediately repaired, replaced or removed from service until repaired.
■ Prohibit employees from working on scaffolds covered with ice or other slippery material except as necessary for removal of such materials.
■ Use tag lines or equivalent measures to control the swinging loads.
■ Prohibit working on or from scaffolds during storms or high winds unless a competent person has determined that it is safe for employees to be on the scaffold and those employees are protected by a personal fall arrest system or wind screens. Also, do not use wind screens unless the scaffold is secured against the anticipated wind forces imposed.
■ Do not use ladders and other makeshift devices on top of scaffold platforms to increase the working level height of employees.
■ Train employees who perform work while on a scaffold only by a person qualified in the subject matter to recognize the hazards associated with the type of scaffold being used and to understand the procedures to control or minimize those hazards.
■ Train employees involved in erecting, disassembling, moving, operating, repairing, maintaining or inspecting a scaffold only by a competent person able to recognize any hazards associated with the work in question.
■ Train employees to never extend ladder jack scaffolds to heights greater than 20 feet.
The most effective training is accomplished through monthly safety meetings. Set aside one hour each month, review training procedures, company policies and utilize Toolbox Talks on various topics. Know that some employees may have a language barrier and provide information that they will understand. Make it a priority to train each employee and bring them home safely.
FRSA Members can access dozens of Toolbox Talks in English and Spanish through the Member Login section of the website, www.floridaroof.com.
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