Applying Construction Fall Protection Concepts to General Industry
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1 Applying Construction Fall Protection Concepts to General Industry Applying Construction Fall Protection Concepts to General Industry Michael Tesmer, CSP and David Jewell, CSP Conney Safety Products This session is eligible for 1 Contact Hour. For these hours to appear on your certificate, you must: Have your badge scanned at the door Attend 90% of this presentation Fill out the online evaluation for this session: 2 1
2 Objectives Clarifying what is new to this standard (how it compared to the old) what was brought over from construction? Discuss subpart I Personal Fall Protection Systems (Use of PPE in your facility identifying best options) 3 Overview of Standard Original 1910 Subpart D was published in 1971 (update proposed in 1983) This rule became effective January 17 th, 2017 (here to stay!) The training deadline was May 17 th, 2017 (most facilities will need this) This standard affects 112 million workers at 7 million workplaces The final rule creatively brings together almost all of the fall-related standards into one location As much as possible, OSHA aligned fall protection requirements for general industry with those of construction easing compliance for those doing both 4 2
3 Ways in which OSHA Made Final Rule Consistent with the Construction Standard Flexibility Range of acceptable options Allows employers ability to select products that enables best job efficiency (reducing exposure) This new flexibility mirrors the construction standard should allow increased compliance (as equipment is same) Those allowed fall protection systems have been determined to provide appropriate and equal level of safety to guardrails (can choose cost effective option) Because of the added flexibility and consistency in the standard, OSHA believes injuries and deaths will be reduced 5 Most Significant Update Allowing employers to select the fall protection system that works best for them (4 trigger) Fall Protection: Any equipment, device, or system that prevents a worker from falling from an elevation OR mitigates the effect of such a fall. 1. Guardrail System 2. Safety Net System 3. Personal Fall Arrest System 4. Positioning System 5. Travel Restraint System 6. Ladder Safety System 6 3
4 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems 7 Subpart I Scope and Definitions Important Considerations or Differences Lots of terms related to fall protection Qualified describes a person who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience has successfully demonstrated the ability to solve or resolve problems relating to the subject matter, the work or the project. NOTE: OSHA states that training needs to be done by a Qualified Person (in General Industry) 8 4
5 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems General Requirements Key Point think slips, trips and falls HOUSEKEEPING INSPECTIONS/ ASSESSMENTS 10 5
6 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems Ladders Key Components Portable Ladders Fixed Ladders Mobile Ladder Stands AND Mobile Ladder Stand Platforms NOTE: an important part of this standard (general requirements) (b)(9) requires employers ensure ladders are inspected before initial use in each work shift, as well as more frequently as necessary This implies you must TRAIN workers on ladder safety (for inspections and use) 12 6
7 Ladders Key Components An important component to the general requirements is (b)(12): Each employee uses at least one hand to grasp the ladder when climbing up and down it; and (b)(13): No employee carries any object or load that could cause the employee to lose balance and fall while climbing up or down the ladder (c) Portable Ladders Key Components (c)(2) metal spreader or locking device in open position when ladder is in use 14 7
8 (c) Portable Ladders Key Components (c)(11) when used to gain access to upper landing surface, side rails must extend 3 above the upper surface (d) Fixed Ladders Key Components (d)(4): The side rails of through or side-step ladders extends 42 above the top of the access level or landing platform. 16 8
9 (d) Fixed Ladders Key Components (e) Mobile ladder stands and mobile ladder platforms Key Components Top step of 4 or higher must have handrails (29 36 ) Support 4X intended load Treads need to be slip-resistant, etc. With mobile ladder platforms, handrails on platform (from 4-10 ) only have to be 36 high w/ midrail Above 10, require standard height guardrails and even toeboards Chains can be used for special-use scenarios (step-through) 18 9
10 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems Step Bolts and Manhole Steps 20 10
11 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems Stairways Key Components 22 11
12 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems Dockboards Key Components Run-off protection Secure trailer 24 12
13 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems Scaffolds and Rope Descent Systems (RDS) Key Components 1) Scaffolds identical to Construction standard 2) New anchorage requirements for RDS 3) 300 RDS height limit 4) Prohibit use of RDS in bad weather and protecting ropes from hazardous exposure 5) Each employee must have a separate, independent fall arrest system 26 13
14 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems (b) Protection from Fall hazards 1) Unprotected sides and edges 2) Hoist areas 3) Holes (including skylights) 4) Dockboards 5) Runways and similar walkways 6) Dangerous equipment 7) Openings 8) Repair pits, service pits, and assembly pits less than 10 deep 9) Fixed ladder (that extend more than 24 above a lower level) 10) Outdoor advertising (billboards) 11) Stairways 12) Scaffolds and rope descent systems 13) Work on low-slope roofs 14) Slaughtering facility platforms 15) Walking-working surfaces not otherwise addressed Guardrail Systems Safety Net Systems Personal Fall Protection Systems Positioning Systems Travel Restraint Systems Personal Fall Arrest Systems Handrails Designated Areas Ladder Safety Systems 28 14
15 (c) Protection from Falling Objects 29 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems 30 15
16 Fall Protection Systems and Falling Object Protection-Criteria and Practices This section simply stating that each fall protection system (and falling object protection), other than personal fall protection systems, meet the requirements in this section ( personal fall protection systems in Subpart I) (b) Guardrails 42 height midrail 21 height (unless parapet at least this high) When used as a point of access, have self closing gate that slides or swings away from hole (or is offset to prevent from falling in hole) Fall Protection Systems and Falling Object Protection-Criteria and Practices (c ) Safety net systems 32 16
17 Fall Protection Systems and Falling Object Protection-Criteria and Practices (d) Designated Areas Fall Protection Systems and Falling Object Protection-Criteria and Practices (e) Covers 34 17
18 Fall Protection Systems and Falling Object Protection-Criteria and Practices (f) Handrails and stair rail systems Handrail >30 but <38 Requirements for stair rails installed before and after 1/17/17 Opening in stair rail system no more than Fall Protection Systems and Falling Object Protection-Criteria and Practices (g) Cages, wells and platforms used with fixed ladders Designed, constructed, and maintained to permit easy access to and from ladder Platforms have surface of at least 24 x 36 Opening in stair rail system no more than 19 Must follow when cages wells used as means of fall protection 36 18
19 Fall Protection Systems and Falling Object Protection-Criteria and Practices (h) Outdoor advertising Must ensure employees physically capable Completed special training or apprenticeship program Demonstrated skill, climbing part of routine work, etc Fall Protection Systems and Falling Object Protection-Criteria and Practices (i) Ladder safety systems System must allow for hands free use of device Connection does not exceed 9 Discussion of rigid and flexible carriers (track vs. cable) Can handle drop test of 19 at 500 lbs
20 Fall Protection Systems and Falling Object Protection-Criteria and Practices (j) Personal fall protection systems Includes body belts, harnesses, and other components used in personal fall arrest systems, positioning systems and travel restraint systems Only states they must meet the requirements of (Personal fall protection systems) Fall Protection Systems and Falling Object Protection-Criteria and Practices (k) Protection from falling objects Ensure toeboards used where needed along walking-working surface (3.5 ) Handle 50 lbs. force 40 20
21 Fall Protection Systems and Falling Object Protection-Criteria and Practices (l) Grab handles At least 12 long At least 3 clearance to grab from mounting area Handles 2X max intended load 41 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems 42 21
22 Training Requirements Required before any employee is exposed to a fall hazard, use a personal fall protection system, or to be trained elsewhere in this subpart Training on or before May 17, 2017 Trained by a Qualified Person FALL HAZARDS EQUIPMENT HAZARDS 43 Final Subpart D (compared to the old) Final Subpart D (New) Previous Subpart D (old) Scope and definitions Definitions General requirements General requirements Ladders Guarding floor and wall openings and holes Step bolts and manhole steps Fixed industrial stairs Stairways Portable wood ladders Dockboards Portable metal ladders Scaffolds and rope descent systems Fixed ladders Duty to have fall protection and Safety requirements for falling object protection scaffolding Fall protection systems and falling object protection criteria and practices Manually propelled mobile ladder stands and scaffolds (towers) Training requirements Other working surfaces Personal fall protection systems 44 22
23 Personal Fall Protection Systems This section establishes performance, care, and use criteria Another review of definitions (only related to PPE) NOTE: Competent Person defined here Key Comments Lots of components w/ 5,000 lb. min tensile strength (lanyards, vertical lifelines, snap hooks, D-rings, carabiners) Gate strength of snaphooks and carabiners proof tested to 3,600 lbs
24 A = Anchorage Are your employees confident in selecting 5,000 lb. rated anchors? If unsure or anchor needs to be verified, must be done by a Qualified Person 47 Anchor Examples 48 24
25 B = Body Wear Have you documented training to ensure they put harness on correctly and understand it s limitations? Do employees know how to inspect their harness?
26 C = Connective Device Employers need to realize there are numerous options, select what is safest and best for job (productivity does not have always have to be compromised) Personal Fall Protection Systems Key Comments Limit max arresting force on employee to 1,800 lbs. There is discussion about 310 lb. combined weight of employee and tools make sure system tested for that limit (or if you go over) Employer must provide for prompt rescue in event of a fall 52 26
27 Fall Arrest Considerations Clearance Freefall Energy Absorption Obstructions/Swing Fall Rescue clearance measured from shoulders (in this example)
28 Clearance distances Type A: 2 ft arresting distance (max) Type B: 4.5 ft arresting distance (max) 55 Fall Arrest Considerations Clearance Freefall Energy Absorption Obstructions/Swing Fall Rescue 56 28
29 Swing Fall Concerns 57 Fall Arrest Considerations Clearance Freefall Energy Absorption Obstructions/Swing Fall Rescue 58 29
30 Orthostatic Intolerance Suspension Trauma Relief Steps (these products only delay or help prevent suspension trauma does not rescue them!) 59 Integrated Self-Rescue Harness System Allows for controlled descent after a fall 60 30
31 Other Rescue Ideas
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34 Questions? For more Information: Visit us in Booth #943 Michael Tesmer, CSP Ph # David Jewell, CSP Ph #
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