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As the result of new Occupational Safety and Health Administration fall protection requirements that will go into effect on June 16, employers must provide conventional fall protection systems — such as guardrails or personal fall arrest systems — to protect all employees engaged in residential construction activities 6 feet or more above a lower level..
In a May 6 NAHB webinar, Matt Murphy, president of SEE Inc., reviewed what employers will need to do in order to be in compliance with OSHA’s Subpart M fall protection regulation.
The webinar has been archived and is available to members who were not able to participate in the live presentation.
Under OSHA’s Interim Fall Protection Compliance Guidelines for Residential Construction, which expire next month, employers have been allowed to perform specified residential construction activities by implementing alternative fall protection and work procedures without first showing that the requirements would be infeasible or present a greater hazards and without a written fall protection plan.
That is about to change, said Murphy:
- When employers engaged in residential construction can demonstrate that it is infeasible, or more likely creates a greater hazard to use conventional systems, they have to develop and implement a site-specific written fall protection plan.
- Employers will be required to demonstrate the infeasibility or greater hazard of using conventional fall protection before they are allowed to use an alternative fall protection plan.
- Site-specific written fall protection plans that outline alternative fall protection systems taken to reduce or eliminate fall hazards must be developed by a qualified person who has extensive experience or a recognized degree and has the capabilities to write a fall protection plan that identifies and provides solutions for fall hazards on specific residential job sites.
In addition, the plans must be implemented by a competent person who has the training and expertise to identify fall hazards on the job site, and who also has the authority to take corrective actions to fix those hazards.
- Slide guards will no longer be permitted to be used in lieu of conventional fall protection methods during roofing work. Slide guards may still be used as part of a written fall protection plan that meets the requirements of 29 CFR 1926.502(k).
Employers that choose to use “alternative fall protection measures” must ensure the measures meet or exceed OSHA's fall protection standard and that they are reflected in the fall protection plan. They must also be prepared to explain to OSHA compliance officers how the decision was made to implement the alternative measures.
Murphy emphasized that fall protection plans must be written and site-specific.
Any alternative fall protection measures documented in the written plan must include:
- Reasons “conventional” fall protections are infeasible or create greater hazard
- Alternative measures to reduce or eliminate fall hazards
- Location and who can work in the Controlled Access Zone
For further information on changes to the requirements, click here for a related story in the Jan. 10 edition of Nation’s Building News.
To replay the archived May 6 webinar, NAHB members can click here. Members must be logged in first before they can play the program.
Non-members can click here to purchase the webinar.
The webinar is a 90-minute version of the four-hour, free, in-person Fall Protection Training Seminars, which are funded by OSHA’s Susan Harwood Training Grant Program. The seminars have trained nearly 1,000 housing professionals to date at more than 40 sites across the country.
Training materials used in these training sessions can be downloaded and delivered to employees and members directly. The materials include a PowerPoint presentation, an instructor’s guide and a post-instruction test, which can be downloaded in English or Spanish.
In an effort to increase job site safety and reduce the chance of job related accidents, NAHB has produced the “Fall Protection Video, English-Spanish” and “NAHB-OSHA Fall Protection Handbook, English-Spanish.”
Both are available through BuilderBooks.com.
The 30-minute “Fall Protection Video, English-Spanish” can be used by builders to train workers to use safe work practices that eliminate fall hazards and comply with OSHA fall-protection standards.
The “NAHB-OSHA Fall Protection Handbook, English-Spanish” provides guidelines for creating a written fall-protection plan and identifying safe work practices that can prevent costly accidents and injuries. Written with clear text, photographs and illustrations, the book serves as a user-friendly resource for promoting safety on any job site.
To purchase the handbook and video online, click here, or call 800-223-2665.