BY JEFF STACHOWIAK, DIRECTOR OF SAFETY TRAININGSUNBELT RENTALS, A MEMBER OF MULTIPLE AGC CHAPTERS
The importance of safety when working from heights cannot be emphasized enough. It is critical to take the proper precautions to protect employees, which includes conducting detailed jobsite checks to mitigate any hazards that are present and could lead to injury. It also involves thorough employee training that provides a clear understanding of Occupational Safety and Health Administration (OSHA) regulations and American National Standards Institute (ANSI) standards.
Knowing some key factors about working from heights can help along the way.
1. Personal Fall Protection Equipment (PFPE) isn’t actually fall protection.
There is much more to fall protection than simply wearing a harness and securing the lanyard to an anchorage point. In fact, PFPE should never be solely relied upon when working from heights. Properly secured PFPE certainly prevents the wearer from reaching the ground in the event of a fall; however, it does not protect against a fall in the first place. Rather, it is a last line of defense.
Only guardrails protect against falls. Employees need to be trained to adhere to the OSHA and ANSI regulations related to them. Specifically, guardrails should never be climbed on even if the worker is tying off — it is forbidden.
2. Boom lifts and scissor lifts have different PFPE requirements.
Boom lifts (3b) and scissor lifts (3a) are both critical pieces of equipment on jobsites, but ones with differing requirements when it comes to PFPE.
OSHA says in 1926.453(b)(2)(v) that “A body belt shall be worn and a lanyard attached to the boom or basket when working from an aerial lift.”
Note to paragraph (b)(2)(v): As of January 1, 1998, subpart M of this part (1926.502(d)) provides that body belts are not acceptable as part of a personal fall arrest system. The use of a body belt in a tethering system or in a restraint system is acceptable and is regulated under 1926.502(e).
1926.453 only applies to boom-supported platforms to remove the hazard possibility of being catapulted.
Neither OSHA nor ANSI A92 has requirements to use PFPE on scissor lifts. However, some OEMs may recommend or require it for use in their scissor lifts. Always consult the scissor lift operating manual and request fall protection statements from each OEM.
If the manufacturer recommends or requires harness and lanyard use in their scissor lifts, then OSHA can enforce the use of them.
3. The 300-lb. drop test offers built-in protection.
The new ANSI/SAIA A92.20-2018 standard (current effective date of June 1, 2020) now requires passing the 300-lb. drop test for all scissor lifts that have designated fall arrest anchor points.
Based on Canadian Standards Association (CSA) and International Standards Organization (ISO), many OEMs have been building mobile elevating work platforms (MEWPs) to the standards of the 300-lb. drop test for some time.
So, what is the 300-lb. drop test?
First, it is officially called the ANSI/SAIA A92.20-2018 220.127.116.11 Dynamic Fall Arrest Anchorage Test and it is taken from the existing CSA and ISO standards.
Simply stated, it says “If the MEWP is going to have a designated fall arrest anchorages, with the MEWP loaded and in its least stable position, on firm ground, drop a 300-lb. mass weight connected to a 6-foot non-energy absorbing lanyard, typically wire rope, from outside the platform over the guardrail, and the lift must not tip. Deformation of the rails is okay; however, the mass cannot be released.”
4. Employees still need fall protection on roofs, even if they are away from the edge.
It is a common misconception that if a worker stays six feet from the edge of a roof, then fall protection isn’t required. That is not the case, and the distance may be confused with the requirement for fall protection when working at a 6-foot height.
When working on roofs, it’s critical to employ OSHA options for fall protection. There are seven in total. These include guardrails, which may include a parapet wall high enough to satisfy OSHA guardrail height and strength requirements. Safety nets, personal fall arrest systems and positioning device systems are also options, as are warning line systems, controlled access zones and safety monitoring systems. The latter three require a physical barrier between the worker and the fall hazard. If an employee is on a roof, one of these is necessary to protect against a fall — no matter how far they are from the roof’s edge.
5. There is more to keeping workers safe at heights than just training.
Training is, without a doubt, an important part of preventing accidents when working from heights — but there is more to the process of keeping employees safe. In fact, a successful safety program should have several other elements that occur simultaneously with training to help reduce hazards.
Having leadership supervise employees to correct unsafe behavior and encourage safe behavior is also important, as is sharing the results of effective accident and near-miss investigations. Enlisting the help of employees in the development of safety processes and gaining their input for correcting unsafe conditions can help empower them. Engagement like this builds a sense of investment in upholding safety training and building a culture around it.
As with any safety aspect on the jobsite, focusing on compliance and vigilance when working at heights is key to protecting employees. Revisit training regularly as a refresher and always follow regulations and standards set forth by OSHA and ANSI, including updates as they occur.
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