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1 Fall Protection: OSHA Construction ti and Industry working Ever Closer Together J. Nigel Ellis Ph.D., CSP, P.E., CPE; EFSS Michael Buchet, Esq.; OSHA Office of Construction Educational Site June 14, 2011

2 What we will offer you today: First Nigel What s new and what problems are there What you need to know about Fall Prot n today Then Mike The process of OSHA in Fall Protection The Hispanic effect: BLS statistics Residential Construction Fall Protection Then both The Future Together; then YOU The ASSE CD on this FP session is a vital The ASSE CD on this FP session is a vital historical reference document for you!

3 ASSE YEARS 1911 Church Steeples, Chimneys, ship sail rigging, window cleaning, tree trimming 1925 Rose Rope Grab 1936 First proposal: belt/lanyard testing due to injuries 1952 NSC/ASSE Report: Cadaver and anesthetized dog testing on belts/ropes 1964 Harness test report from Boeing 1971 OSHA Construction regs: belts/manila or nylon ropes, ANSI A10.14 Construction; rev OSHA Exterior Building Maintenance regs ( App. C) 1991 OSHA Subpart X Stairs and Ladders ( ) 1992 ANSI Z359.1 and R1999 Gen. Industry 1994 OSHA Subpart M Construction Fall Protection ( )( ) 1998 Harnesses in OSHA Construction 2001 Steel Erection fall protection through SENRAC 2004 ANSI A Z359.0, 1,.2,.3, Z359.6,.12, OSHA 1910 Sub D & I Proposal #2 (#1 1990) Q: Why so many falls even with $Billions Fall Equipment?

4 2011 Z359 component stds Z359.7 Certification of Fall Arrest Systems Z359.8 Rope Access Z Descender Devices Z Full Body Harnesses Z SRD Self Retracting Devices Z Vertical Lifelines Z Fall Arresters: rope/cable/rail p/ / Z HLL Packaged PFAS Z Anchorage Connectors Coming.. Soon..

5 What s New in Fall Protection Three Point Control engr g white paper horizontal hold* Fast Fall Arrester SRL sensed and arrested fall in 24 Z Platform Nets (Europe and S. Africa) walkable access Fabric covers as fall protection for metal building insulation Field temporary anchorages for unloading steel, concrete Ladder climbing powered assist 3600 lbs gates for all snaphooks (connectors) Inspection Tags with Velcro and e tags * FP education site

6 What to hold at heights: Rungs - yes Side rails not reliable Young, Justin G. et al, Biomechanics of Hand/Handhold Coupling and Factors Affecting the Capacity to Hang On. Doctoral Dissertation, Department of Industrial and Operations Engineering, University of Michigan, Ann Arbor, December Hold Ladder Side Rails at your peril

7 Three Point Control Engineered Horizontal grab bars, rungs Ladder is the product w/greatest fall injuries; Stairs high Gain 3 ft! Two stair rails held Fixed Ladder Horizontal Grab Bar (Rung) Ext n Roof Hatch Walk in/out

8 Portable Ladder safety extension fits to each side rail Falls from accessing upper levels l with ladders: 3 ft extension solved; no step-around ladder hazard UP DOWN

9 Platform Nets Walking working surface Expect soon in America eg S. African World Cup stadiums built this way in 2009

10 Fabric covers as fall protection Metal Building Construction Drop Test with 400 lbs sandbag as for nets presently Fabric with high strength th and low tear supports insulation

11 Fall Incidents of Concern: Ladder Climbing Fall Back with harness = free fall Ladder and pole climbing Push Down = acceleration Rope Grab Drive Down = free fall Y lanyard Star falls = neck injury as body spins Snaphook gates 220 lbs still >50% equipment sales* Rise in fatalities of Hispanic workers (#1 in 9 states ) Transportation: stationary vehicle fatalities loading Labels field obliteration now helped with e tags & velcro *Replacement of Equipment is Likely needed

12 Y lanyard Brisbane, Aus., 2004 Eliminate Guard Safety Factor* Redundancy *Y-linkage now 5000 lbs per Z

13 Snaphook Gates Check Equip t Post 2007 Gates 3600 lbs min. Pre 2007 Gates 220 lbs Gates get bent inward or outward due to incompatibility Employers should make all anchors compatible w/snaps Nose of hook problem still to be solved Weak nose Weak gate Weak nose? Strong gate Z Weak gate Weak nose Nose opens Z (R1999)

14 Other products of interest Tanktruck, truck top and crane boom access systems Mobile roof anchor cart w/claw /l (CalOSHA issues) Mobile anchor for truck work

15 Fall Hazard Concerns Not enough thinking about the elevated access Collapse of structure may be 50% of fall deaths Equipment should not be regarded as fool proof Use 3600 lbs or 5000 lbs snaphook gates Inspect frequently for any defect Follow the updated Hierarchy of Fall Protection: Eliminate first Guard (Railings and PFAS) Safety Factor strength and cross section section increased Redundancy two or more solutions

16 Industry, Construction & OSHA Mike Buchet on the progress of OSHA in Fall Protection and what you may not know Towards a safer America

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18 OSHA and Industry Working Ever Closer to Improve Construction Fall Protection Residential Fall Protection ti A Case Study Michael M.X. Buchet, Esq. Senior Occupational Safety and Health Specialist ASSE Safety Safety 2011, June 14, 2011 Session 678

19 Residential Fall Protection Early History Construction Safety Act (CSA) [P.L ; August 9, 1969] S / H Regs for Construction in 29 CFR Part 1518 ACCSH created to advise Secretary The Occupational Safety and Health Act (OSH Act) (84 Stat. 1590; 29 U.S.C. 651 et seq.), Adopted various construction standards, May 1971, including CSA related standards 6(a) rulemaking Re designated as Part 1926 in December 1971

20 Residential Fall Protection Early History 29 CFR 1518 relied on American National Standards Institute language. Became 29 CFR 1926 Subpart M (1971) For example 29 CFR Guardrails, handrails, and covers ANSI A12.1 (1967) Participation ANSI Consensus Fd Federal Register Public Notice

21 Residential Fall Protection 29 CFR 1926 Subpart M amended 1972: skylight openings and runways 1980: low pitched roofs built up roofing work Subpart M complete review: 1977 ACCSH multiple reviews and submitted meeting transcripts to Secretary Now in Docket Docket # OSHA S g 263 items

22 Residential Fall Protection History Agency extended comment period To August 1987 Agency held public hearings March 1988 Post hearing briefs / record certified May 1988 / August 1988: Judge Williams Items included single family and residential non single family Feasibility / relied on existing technology

23 Residential Fall Protection History 1992: Agency reopened record 6(b) rulemaking/notice & comment 1993 March: Agency reopened record ALSO included residential construction Feasibility Roof trusses Exterior walls Conventional fall protection Guardrail, Personal Fall Arrest, Safety Net systems

24 Residential Fall Protection History Received 28 Comments Comments closed May 28, 1993 Final rule: August 9, 1994 Included (b)(13) Residential construction STD 3.1 December 8, Groups: 1 frame/sheath, 2 CMU/form/foundation, 3 HVAC, Plumbing, other specific activities in attics/on roofs, 4 roofing work Definition for purposes of STD application only

25 Residential Fall Protection Recent History STD 3.1a (STD ) June 18, 1999 Plain language revision of STD 3.1 Feasibility/Fall protection plan written No determination required / No written plan required Continues interim enforcement policy

26 Residential Fall Protection December 2010 STD December 16, 2010 Scheduled enforcement June 16, 2011 Rescinds STD How? ACCSH recommendation OSHAPA recommendation Industry recommendation

27 Residential i Fall Protection STD cont d December 2010 Interprets (b)(13) Residential construction End use residence/dwelling requirement Traditional wood frame construction materials/methods requirement Limited use of steel beam Exterior brick/block walls over wood framing Metal studs also

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29 Questions about Fall Protection Understanding the Federal process and how we input Snaphook gate strength 3600 lbs Z359 v. 220 lbs A10.32 Skylights after 40 years: less than 1% have metal screens to prevent falls through uv exposed domes why? Should OSHA focus more on elimination i i of hazards

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NSC Congress 31 October

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