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 www.fallsafety.com: Educational Site June 14, 2011
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both The Future Together; then YOU The ASSE CD on this FP session is a vital The ASSE CD on this FP session is a vital historical reference document for you!
ASSE 1911 2011 100 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, 1926.104.107.107 1975 ANSI A10.14 Construction; rev. 1991 1989 OSHA Exterior Building Maintenance regs (1910.66 App. C) 1991 OSHA Subpart X Stairs and Ladders (1926.1050.1053) 1992 ANSI Z359.1 and R1999 Gen. Industry 1994 OSHA Subpart M Construction Fall Protection (1926.500.503)(2001 1926.750) 1998 Harnesses in OSHA Construction 2001 Steel Erection fall protection through SENRAC 2004 ANSI A10.32 2007 Z359.0, 1,.2,.3,.4 2009 Z359.6,.12,.13 2010 OSHA 1910 Sub D & I Proposal #2 (#1 1990) Q: Why so many falls even with $Billions Fall Equipment?
2011 Z359 component stds Z359.7 Certification of Fall Arrest Systems Z359.8 Rope Access Z359.9 9 Descender Devices Z359.11 Full Body Harnesses Z359.14 SRD Self Retracting Devices Z359.15 Vertical Lifelines Z359.16 Fall Arresters: rope/cable/rail p/ / Z359.17 HLL Packaged PFAS Z359.18 Anchorage Connectors Coming.. Soon..
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 Z359.14 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 *www.fallsafety.com FP education site
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 2010. Hold Ladder Side Rails at your peril
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
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
Platform Nets Walking working surface Expect soon in America eg S. African World Cup stadiums built this way in 2009
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
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 2003 6) Transportation: stationary vehicle fatalities loading Labels field obliteration now helped with e tags & velcro *Replacement of Equipment is Likely needed
Y lanyard Brisbane, Aus., 2004 Eliminate Guard Safety Factor* Redundancy *Y-linkage now 5000 lbs per Z359.1-2007
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 Z359.1-2007 Weak gate Weak nose Nose opens Z359.1-1992(R1999)
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
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
Industry, Construction & OSHA Mike Buchet on the progress of OSHA in Fall Protection and what you may not know Towards a safer America
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
Residential Fall Protection Early History Construction Safety Act (CSA) [P.L. 91 54; 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
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 1926.500 Guardrails, handrails, and covers ANSI A12.1 (1967) Participation ANSI Consensus Fd Federal Register Public Notice
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 S206 2006 0699 www.regulations.gov g 263 items
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
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
Residential Fall Protection History Received 28 Comments Comments closed May 28, 1993 Final rule: August 9, 1994 Included 1926.501(b)(13) Residential construction STD 3.1 December 8, 1995 4 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
Residential Fall Protection Recent History STD 3.1a (STD 03 00 001) 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
Residential Fall Protection December 2010 STD 03 11 002 December 16, 2010 Scheduled enforcement June 16, 2011 Rescinds STD 03 00 001 How? ACCSH recommendation OSHAPA recommendation Industry recommendation
Residential i Fall Protection STD 03 11 002 cont d December 2010 Interprets 1926.501(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
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