Imhoff Custom Services Inc.

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1 Imhoff Custom Services Inc. Fall Protection Program Falls are the leading cause of deaths in construction situations and account for about one third of all fatalities. These falls and deaths involve a complex and variety of contributing factors. As a result, OSHA regulations take into account the human factor as well as the equipment related issues. ICS Inc. as an employer is responsible for checking the workplace and determining each glass replacement job by location. Assessment of the working surface for strength and safety and determination if fall protection is required. ICS Inc. Supervisors will inspect each jobsite before starting work and determine what kind of fall protection is best suited to the job, if required, and enforce all regulations for all employees. The supervisor will, in addition, personally inspect each piece of safety equipment to be used by ICS Inc. employees prior to use. Each employee will be instructed upon hiring date and before the first active employment date with this fall protection program. A log will be kept with the primary training date and any additional refresher courses as needed. This log will list the name of the person trained, the training personnel involved and the date of refresher course. This guide will be furnished to each employee as a reference for guidelines in fall arrest necessary job conditions. The supervisor is responsible for making sure that each of the conditions applicable to the job is met by each and every employee. Types of Fall Protection Required by ICS Inc. *Guard rails, safety net systems, and personal fall arrest systems are required in situations of hazardous circumstances. *The appropriate type of fall protection at each job site will be determined by the ICS Inc. supervisor. All fall protection equipment used by ICS Inc. will be OSHA approved ANSI and/or ASTM certified equipment with a valid certification date. Fall Protection is required when: 29 CFR (b)(2) Workers are at heights of 6 or greater. 29 CFR (b) (2) (i). It applies at heights of less than 6 when working above or near machinery with drive belts, pulleys, gears or open vats or containers with liquid agents or water. Workers are on a ramp, runway, or walkway at the edge of a roof or on a building roof or floor of a multistoried. Workers are on the roofs or upper floors of any building with open holes, unprotected edges which are 6 or more above a lower level. Working on Skylites or Skylite glass on the top of a structure. Working on low slope roofs 4/12 pitch or less with one or more unprotected side or edge 6 or more above a lower level. 29 CFR (b) (10)

2 Working on steep roofs with a roof pitch of 4/12 or more that has one or more unprotected sides or edges. 29 CFR (b) (11). Conventional Fall Protection Systems:29 CFR (b) Guard rails are barriers erected to prevent workers from falling to lower levels. Guidelines required by OSHA are: Top rails or equivalent guard rail system must be 42 plus or minus 3 above the walking or working level. If using stilts rails heights must be increased by the height of the stilts.29 CFR (b) (1) 2 Screens, mid-rails, mesh, intermediate vertical members or equivalent intermediate structural members must be installed between the top edge of the guard rail and the walking or working surface when there are no walls or parapet walls at least 21 high. 29 CFR (b) (2). If mid-rails are used they must be installed at a height midway between the top edge of the top rail and the working or walking surface.29 CFR (b) (2) (i). When screens or mesh is used, they must extend from the top rail to the walking or working level and along the entire opening.29 CFR (b) (2) (ii). When using intermediate posts or balusters they must be installed no more than 19 apart 29 CFR (b) (2) (iii) Other structural members such as midrails, architectural panels or similar must be installed leaving no openings more than 19 wide. 29 CFR (b) (2) (iv). Guard rail systems must withstand a force of 200lbs applied within 2 of the top edge, and in any outward or downward direction at any point along the top edge.29 CFR (b) (3). Midrails, screen, mesh, intermediate vertical members, solid panels, and equivalent structural members must be capable of withstanding a force of at least 150lbs. applied in any downward or outward direction at any point along the mid-rail or other member.29 CFR (b) (5). Guardrail systems must have a smooth surface to protect workers from punctures, lacerations and to prevent snagging of clothing. Ends of top-rails and mid-rails must not overhang end posts except where an overhang poses no projection hazard to employees. 29 CFR (b)(7) Steel and plastic banding may not be used as top or mid rails.29 CFR (b) (8). Top rails and mid rails must have a nominal thickness of at least ¼. 29 CFR (b) (9) If using wire rope, flagging must be attached at intervals of no more than 6 with high visibility material. 29CFR (b) (9)

3 3 When guard rail systems are used at a material hoisting site, a chain gate or removable guard rail must be used to secure the opening when not in use. 29 /CFR (b) (10). Guardrail systems at holes must be set up on all protected sides or edges. If a hole is used for material transfer, no more than 2 sides or guardrails may be removable.29 CFR (b)(11) and (12). If guardrail systems are used around holes being used as access points for workers, Gates must be used. In addition entry point must be placed offset from the ladder or point of access. 29 CFR (b) (13). If guardrails are used on ramps and runways, they must be installed on each unprotected side or edge. Manila, plastic, or synthetic rope used for top rails or mid rails must be inspected daily to ensure it is intact and protecting workers. 29 CFR (b)(15). Personal Fall Arrest Systems 29 CFR (d) This system is used to safely stop or arrest a falling worker from a working level. The parts of the system are: An anchorage Connectors Lanyard Deceleration device Body harness Safety Belts are prohibited from use with this system When using this system it must: Limit the maximum arresting force on a worker to 1800lbs. when used with a body harness 29CFR (d)(16)(ii). Be rigged so that a worker may not fall more than 6 and or contact a low level. 29 CFR 1926,502 (d) (16) (iii). Bring the worker to a complete stop and limit the deceleration distance to CFR (d) (16) (iv) Have sufficient strength to withstand twice the potential impact energy of a worker free falling a distance of 6 or the freefall distance permitted by the system whichever is less.29 CFR (d) (16) (v). Be inspected prior to each use for wear, damage or deterioration. Any defects found and the device must be removed from service and replaced with a functioning device. 29 CFR (d)(21). Personal Fall Arrest System Components Snaphooks : Must be the locking type and designed and used to prevent disengagement from any component part of the personal fall arrest system 29 CFR (d)(5). Locking type snaphooks may also be used to connect directly to wire rope, webbing, dee rings a horizontal lifeline, or to any object shaped differently

4 4 such that unintentional disengagement could occur by the connected object being able to depress the snaphook keeper and release itself. 29 CFR (d)(6). Horizontal Lifelines: On suspended scaffolds or similar work platforms with horizontal lifelines that could possibly become vertical lifelines, the devices used to connect to a horizontal lifeline must be capable of locking in both directions.29 CFR (d)(7). Horizontal lifelines must be designed, installed and used under the supervision of a qualified person as part of a complete personal fall arrest system that maintains a safety factor of at least two.29 CFR (d)(8). Vertical Lifelines and Lanyards: These items must have a breaking strength of 5000 lbs. These items must be used and maintained in a way that they are not abraided or cut. 29 CFR (d)(11). Self Retracting Lifelines and Lanyards Lifelines and lanyards that auto limit freefall distance to two feet or less must be capable of withstanding 3000 lbs. of load applied with the lifeline or lanyard fully extended. 29 CFR (d) (12). Self Retracting lifelines and lanyards that do not limit freefall distance to two feet or less, ripstitch lanyards, and tearing and deforming lanyards. 29 CFR (d)(13). must be capable of withstanding 5000lbs. of tensile load applied to the device with the lifeline or lanyard in the fully extended position. Ropes and Straps Webbing used in lanyards, lifelines, and strength components of body harnesses must be made of synthetic material.29 CFR (d)(14) Anchorages Anchorages used to attach personal fall arrest systems must be designed, installed and used under the supervision of a qualified person as part of a complete fall arrest system which maintains a safety factor of two. This anchorage must be used exclusively for personal fall protection of a worker and not be combine sustaining any other user. This anchorage must be capable of supporting 5000lbs. per worker attached or be capable of supporting at least twice the expected impact load.29 CFR (d) (15). Positioning Device Systems 29 CFR (e)(1) A body belt or body harness rigged to allow a worker to be supported on an elevated vertical surface, such as wall and work with both hands free. Body or belt harness systems are to be set up so that a worker can freefall no more than 2 feet. 29 CFR (e) (1).

5 Body belts or harnesses must be connected to an anchorage capable of supporting twice the potential impact load of a worker or 3000lbs, whichever is greater. 29 CFR (e) (2). Positioning Device System Components 29 CFR (d) and e (3)-(10) Snaphooks Dee-rings Other connectors Warning Line Systems29 CFR (f) Warning line system is a barrier erected on a roof to warn workers that they are approaching an unprotected roof side or edge and to designate an area where 5 work may take place without other safety systems. The warning lines may be ropes, chains or wire cables along with supporting stanchions If we use a warning line system The line must be erected around all sides of roof work areas. 29 CFR (f) (1) When mechanical equipment is not being used the line must be set up at least 6 from the roof edge. 29 CFR (f)(1)(i). When mechanical equipment is used, the warning line must be 6 from the roof edge parallel to the direction of the mechanical equipment operation. At least 10 from each roof edge perpendicular to the direction of mechanical equipment. 29 CFR (f)(1)(iii). The ropes, chains or wire cable must be flagged at no more than 6 intervals with high visibility material.29 CFR (f) (2) (i) The warning line must be rigged and supported so that the lowest sagging point is at least 34 above the walking or working surface, and the highest point is no more than 39 above the walking or working surface; and Stanchions after being rigged with warning lines must be capable of resisting without tipping over at least 16lbs. applied horizontally against the stanchion, 30 above the walking or working surface, perpendicular to the warning line and in the direction of the floor, roof, or platform edge. 29 CFR (f)(2)(iii). The warning line must have a tensile strength of at least 500lbs. After being attached to the stanchions, it must support without breaking the loads applied to the stanchions as prescribed previously. 29 CFR (f) (2) (iii) and (iv). Controlled Access Zones29 CFR (g) This is a zone or work area in which glazing may take place without using conventional fall protection systems. This could be where workers are setting or sealing glass over the edge of the building without the benefit of guardrails or a retainer wall. In this case only glazers and workers actually engaged in the glazing-sealing process would be allowed in the controlled access zone.

6 6 Controlling access areas where leading edge and other operations are taking place, the controlled access zone must be defined by a control line or another means that restricts access. 29CFR (g) (1) When control lines are used to define a controlled access area, they must be erected at least 6 and no more than 25 from the unprotected or leading edge. The exception to this rule is when precast concrete is being set simultaneously. In this case the control line must be at least 6 and no more than 60 or half the length of the member being erected, whichever is less.29 CFR (g)(1)(iii) and (iv). The control line must extend along the entire length of and approximately parallel to the unprotected side or leading edge and be connected on each side to a guardrail system. 29 CFR (g) (1) (iii) and (iv). When controlled access line are used to limit access to areas where glazing is occurring, a control line must be erected to define the work zone. This line must be 10 and no more than 15 from the working edge. The control lines must be approximately parallel to the working edge and must extend far enough to enclose all workers performing glazing or related work at the working edge. Additional lines must be erected at each end or the controlled access zone to enclose the work area.29 CFR (g) (1) (iii) and (iv). Only workers engaged in glazing or related operations may enter the controlled access zone Control lines must consist of ropes, wires, tapes or equivalent material along with supporting stanchions o o These lines must be flagged or otherwise clearly marked at no more than 6 intervals with high visibility material.29 CFR (g) (3) (10) The lines must be rigged and supported so that the lowest sagging point is not less than 39 from the walking or working surface, and the highest point is no more than 45 from the walking or working surface o The lines must have a breaking strength of at least 200lbs. 29 CRF (g)(3) (iii). On floors and roofs where guardrail systems are not in place, before glazing operations can commence controlled access zones must be enlarged as necessary to enclose all points of access, material and glass storage. o On floors and roofs where guardrail systems are in place but needs to be removed to allow glazing operations, only that portion of the guardrail necessary to accomplish that day s work may be removed. 29 CFR (g)(4). Safety Monitoring Systems 29 CFR (h) This is an alternative system for low slope work. When using this system, the supervisor is designated as the monitor person whose duties exclude all but the safety monitoring of the employees glazing on the roof and warning employees when their work takes them close to the roof edge.

7 Be competent in the recognition of fall hazards.29 CFR (h) (1) (i) Warn workers when they appear to be unaware of fall hazards or when the workers are acting in an unsafe manner. 29 CFR (h) (1) (ii). Be on the same walking or working surface as the workers and have a clear view of all employees. 29 CFR (h) (1) (iii) Be close enough to the workers to speak directly with workers.29 CFR (h) (1) (iv) and The monitor can have no other work duties during the monitoring period. Employers must ensure that Supervisors are the company representatives. 29 CFR (h) (1) (v). 7 Mechanical equipment is not being used or stored in areas where safety monitoring systems are being used to monitor workers on low sloped roofs.29 CFR (h) (2) If this occurs during operations the supervisor must immediately shut down glazing operations and change the safety system to another type such as the personal arrest system. No worker other than one glazing covered by a fall protection plan, enters an area where a worker is being protected by a safety monitoring system. 29 CFR (h)(3) All workers in a controlled access zone are instructed to promptly comply with fall hazard warnings issued by the safety monitor.29 CFR (h)(4). Safety monitoring systems must also be used as part of a fall protection plan where no other alternative measures have be implemented. The supervisor must first determine that it is infeasible, or creates a greater hazard to use conventional fall protection equipment. 29 CFR (k) Hoist Areas 29 CFR (b) (3) Workers in hoist areas must be protected from falling 6 or more by a guard rail systems or personal fall protection equipment. If there are occasions when guard rail systems, (gates or chains) must be removed in whole or part to facilitate hoisting materials. Occasionally a worker must lean out over the hole to guide materials or bundles through the opening. In this situation that worker must have personal fall arrest protection in place to protect him from a falling hazard. Holes: 29 CFR (b)(3) Each worker in a hoist area must be protected from falling six feet or more by guardrail systems or personal fall arrest systems. At times the guardrail system, chain, gate, or guardrail must be removed in whole or part to facilitate hoisting. At such times a personal fall arrest system must be used. Skylights or skylight openings Each worker on walking or working surfaces must be protected from falling through Skylight or glass openings that are more than 6 above lower

8 levels. Protection must be by personal fall arrest systems, covers, or guardrail systems around each hole or opening. Each worker on a walking or working surface must be protected from tripping in or stepping into or through these glass openings. Ramps, Runways and other Walkways 29 CFR (b) (6) Each worker on a ramp, runway, or other walkway must be protected by guardrails systems against falling 6 or more. Dangerous Equipment 29 CFR (b) (8) 8 *When working 6 or more above dangerous equipment, each worker must be protected against by guardrails systems, safety nets, or personal fall arrest systems. When working less than 6 above dangerous equipment, each worker must be protected from falling into or onto the dangerous equipment by a guardrail system or equipment guards. Wall Openings 29 CFR (b) (14) Each worker working on, at, or above, or near wall openings (including those with chutes attached), where the outside bottom edge of the opening is 6 or more above the lower level and the inside bottom edge of the wall opening is less than 39 above the walking or working surface, must be protected with a guardrail system, a safety net, or a personal fall arrest system.29 CFR (b) (8) Protection From Falling Objects Falling objects pose a hazard to workers and must be addressed with the following provisions. Guardrails 29 CFR (j) (5) When guardrail systems are used to prevent materials falling from one level to another, the openings must be small enough to prevent passage of our material and debris. During glazing operations no material may be stored within 6 of the working edge. All debris and trash must be kept clear of the working area in a continuous effort. Glazing on Rooftop: Workers glazing on the rooftop must store glass, glass crates sealant and cleaner at least 6 from the roof edge unless guard rails are in use. Any glass crates must be leaned at a 22% angle and be braced with 2 x 6 and kickers. Toeboards 29 CFR (j)(1) through (4) When toeboards are used as fall protection they must be installed along the edges of the overhead walking or working surface for the distance necessary to protect workers at the lower level. Toeboards must be capable of withstanding a force of at least 50lbs. applied in a downward direction or outward direction.

9 The toeboard must be at least 3.5 from the top edge to the working or walking surface. There can be no more than a ¼ space between the bottom of the toeboard and the working or walking surface. The horizontal direction the toeboard must be solid along the roof edge with no more than 1 opening at corners or board joints. 29 CFR (j) (4) Canopies 29 CFR (j)(8) Canopies may be used for fall protection from falling objects or material as long as they are strong enough to prevent collapse or penetration from the falling items or objects. 9 Fall Protection Plans In general OSHA requires using conventional safety fall protection on every job where required, however there are some circumstances when a company may use a site specific fall protection plan in place of a conventional plan if the conventional plan proves to create a hazard. Site Specific Fall Protection Plan 29 CFR (k) The plan must be prepared by a qualified person and developed specifically for the job site where the work is being performed.29 CFR (k) (1) The plan must be maintained and kept up to date. 29 CFR (k) (1) Any changes to the plan must be approved by a qualified person. 29 CFR (k) (2) A copy of the plan with all approved changes must be maintained at the job site 29 CFR (k) (3). A competent person must supervise the implementation of the plan 29 CFR (k) (4). The plan must document the reasons why the conventional fall protection plan would not work or would create a greater hazard. 29 CFR (k) (5) The plan must include a written discussion of other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided protection using conventional fall protection systems.29 CFR (k) (6). The plan must identify each location where conventional fall protection cannot be used. These locations must then be classified as controlled access zones and our company, workers and supervisor must comply with all the criteria.29 CFR (g) and 29 CFR (k) (7). When no other alternative measure has been put in place, we must put in place a safety monitoring system that complies with 29 CFR (h) and OSHA 29 CFR (8) The plan must include a statement which provides the name or other method of identification for each worker who will enter and is authorized to work in the controlled access zone. 29 CFR (k) (9).

10 10 In the event a worker falls or there is a serious incident ICS Inc. will investigate the incident/accident to determine if the site specific fall protection plan needs to be changed. ICS Inc. must implement whatever changes are needed to prevent other incidents/accidents from happening. 29 CFR (a) (1). Fall Rescue Procedure If a worker falls and the fall is arrested by fall protection equipment, immediate rescue is critical. All measures to rescue must be immediately implemented Before attempting a rescue, make sure that rescuers have all the fall protection equipment themselves and the victim. If lifting platform has the capacity for the victim as well as two rescue personnel, two people will maneuver the platform beneath the victim. The rescue personnel will bring the platform underneath the victim until the platform supports the victim. At this point the victims harness can be disconnected from previous lines and reconnect to the platform for the trip down Upon reaching the ground the first aid responder will attend to the victim following with an ambulance trip to the nearest medical facility. The ICS Inc. supervisor will accompany the victim to whatever medical facility is used. If the victim is unconscious or a back or neck injury is suspected medical personnel must be involved before any rescue attempt is made. Fall Protection Training Requirements 29 CFR ICS Inc. will provide a fall training program to workers who may be exposed to fall hazards. This training will include how to recognize fall hazards and how to minimize them. ICS Inc. will furnish a competent instructor to provide this training to all workers who may work in an area where falls are possible. This training is provided on the date of hire or prior to the first active day of employment. 29 CFR (a) (1). Training will cover: The nature of fall hazards in the work area. 29 CFR (a) (2) (i) The correct procedure for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used. 29CFR (a) (2) (ii). The use and operation of controlled access zones; guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems and any other protection to be used. 29 CFR (a) (2) (iii). The role of each worker in the safety monitoring system when used.

11 11 The limitations on the use of mechanical equipment during the performance of glazing on low slope roofs. 9 CFR (a) (2) (iv). The correct procedures for equipment and materials handling and storage of glass and other materials common to glazing operations. 29 CFR (a) (2) (v). The role of workers in the fall protection plans. 29 CFR (a) (2) (iv) OSHA s fall protection requirements. 29 CFR (a) (2) (vi). Verification of Training This record will contain the name of the worker trained, the date of training and the signature of the person who conducted training. 29 CFR (b) (1). When an employer has reason to believe that an affected worker does not recognize existing fall hazards at some point after the intial training, the employer is required to provide retraining for that worker. For example, workers must be retained when: Changes in the workplace render previous training obsolete. 29 CFR (c) (1). Fall protection equipment or systems have changed.29 CFR (c) (2). Inadequacies in workers knowledge or use of fall protection systems or equipment indicate that they have not adequately understood or retained previous training. 29 CFR (3). Fall Protection Requirements in Other OSHA Fall Protection Requirements in Other OSHA Construction Standards Requirements-29 CFR : Employers must provide a fall protection training program to workers who might be exposed to fall hazards. Training must include how to recognize fall hazards and how to minimize them 29 CFR (a) (1) The employer must assure that each worker has been trained as necessary, by a competent person who is qualified in the following areas: The nature of fall hazards in the work area. 29 CFR (a)(2)(i). The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used. 29 CFR (a) (2) (ii)/ The use and operation of controlled access zones; guardrail, personal fall arrest, safety net, warning line, and safety monitoring systems; and other protection to be used. 29 CFR (a) (2) (iii). The role of each worker in the safety monitoring system when the system is used. 29 CFR (a) (2) (iv). The limitations on the use of mechanical equipment during the performance of roofing work on low-slope roofs. 29 CFR (a) (2) (vi).

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