I recently purchased the 3rd edition of your book Introduction to Fall Protection.
Using your book as a reference in addition to the OSHA confined space and scaffold construction requirements, I am prepared to issue a policy statement to my organization.
I would like your opinion on the following:
I work for an organization that operates several small industrial plants. Our typical plant is staffed with 4 people or less. With this in mind, we have made the decision to outsource our rescue services.
The issue in question is in regard to fall rescue team requirements during cooling tower cowling entry. Also in question is our potential liability in directing the fall protection efforts of contractors.
Under normal conditions, the cooling tower fan cowlings are a permit required confined space and entry into the fan cowling will require an “on site” rescue team.
However, we will reclassify the space and no “on site rescue team” will be required if:
- sections of the cowlings are removed to provide unhindered access/ egress,
- exposure to fall hazards over six feet are eliminated and
- all other conditions required by OSHA on PRCS reclassification are met.
To address the fall hazards associated with working over the cooling tower cell, we hired a reputable scaffold erection company with an on site competent
person to deck the entire opening of the cooling tower cell.
Questions for you:
Can we allow the scaffold company’s Competent Person to determine the method of fall protection used by their employees during the erection of the decking?
I believe we can, however, we have an obligation to assure that the fall hazards have been addressed and adequate rescue planning has been performed.
If while decking the work area, the scaffold company chooses a fall protection method that would allow a worker to fall into the cooling tower cell then the space cannot be reclassified and an “on site” rescue team would be required.
We have an obligation to assure that qualified and properly equipped rescue services are available, in the event of a fall whether we contract these services or the contractor provides them is immaterial.
If the scaffold company chooses a method of fall prevention that will prevent a worker from falling in to the cooling tower cell then no “on site” rescue team is required.
Do you agree with my advice to the operation groups?
Your advice is heading in the right direction. The problem is the way the scaffolds are built may not achieve your goal. For example, you should mandate the fall protection and safe access to scaffold platforms. What this means is that there is no climbing over railings or through them to access the ladder or platform; a swing or sliding gate allows access directly to the platform. Secondly, all ladder access over ten feet has fall protection such as SRL’s with tag lines. Thirdly, the levels are fully planked with metal decking – no gaps over two inches – please use your copy of Introduction to Fall Protection for more information on these ideas. NOTE: I strongly suggest assembly of the scaffold is required with 100% fall protection allowing free falls no greater than two feet.
Apart from that Achilles heel, your ideas sound great. The duties of the rescue team, however, are another matter, so come back to me on that at the right time!
Could you please send me information regarding the specific laws of fall protection as it applies to both structural ironworkers, and re-enforcing steel ironwokers? I have found there to be some confusion as to the height a worker can be until he must be tied off.
Did you read the 1926.760 on steel erection fall protection? 15ft is the trigger height, 30 ft for connectors. But the connectors must be able to use fall protection above 15 ft; over 30 ft it is mandatory. Wall forms trigger is 24 ft. Decking is 30 ft. These are minimum standards by OSHA.
Some plants realize that these different heights confuse other trades that are required to protect over 6 ft (scaffolds 10 ft). Therefore be prepared to see 6 ft universally more and more for ease of safety management. One reason for the 6 feet is due to the deaths from falls: 1% 6ft or less; 9% 10 ft; 20% 15 ft; 55% 25 ft and less. If steel erectors can stand the high EMR rating eg 1.0 – 1.5, for three years, and buy the right equipment and enough of it, they can get down to 0.2 like LPR Steel Erection in Denver with a 6 ft trigger. They are very competitive now they have the physics of fall death working for them and it is unlikely that another ironworker will be killed or maimed.
I’m having a hard time finding clarification on when fall protection is required
for scaffolding systems that use bolt-on ladders for access. I’ve read everything 10ft. up to 30ft. before a fall arrest system needs to be in place.
My interpretation is 10 ft trigger under 451(g)(1) or third level up for climbing to 2nd level on a supported guarded scaffold. I might argue for just over zero ft trigger in general industry. 1st level is at 7 ft height for frame scaffold. Suspended type is a different consideration.
Industry practice may be 20 ft trigger in parts of the Gulf area so that’s the fourth level for climbing to the 3rd level. Most scaffolds are 2-3 levels so that means more devices to buy. But they last 3-5 years and can be depreciated on a 3 year schedule if necessary to minimally affect the bottom line..
However the reason I use is that workers climb with things in their hands or under their arms necessitating mandatory back-up fall protection as a lifeline instead of a climbing device. Yes you tell them but hey why do you think some trades push holding the side rails instead of the rungs. Answer: because they are a ……. of the OSHA and A14.3 standard by holding something other than the ladder.
Some parts of the USA have already gone to swing gates for rest platforms, other parts still follow the inadequate standards notably A10.8 and the pathetic OSHA interpretations (“we have no industry concensus”).
Regarding ladders on scaffolds there should be fall protection all the way up because of inadequate ladder design and lack of ladder brackets that develop the correct strength for the stability of the top section
particularly. That means that the FP should be independent (6-12″ in
front of the ladder) of the ladder itself so that if the top section
comes down, protection is still available. Watch out for channel designs and rotating bolt heads that do not fully rotate near the extension pins. It is a matter of time before it pulls away on one side – then guess what happens.
What kind of FP? I would use SRL’s – meeting 1926.1053 and 1926.500 AppC. A tag line is used to get the hook to the level needed for hook-up. The scaffold must be secured for stability eg tied-in.
Summary: Hold the rungs (with gloves if necessary) always horizontal grab bars (never vertical members), order swing gates, use two brackets for the top ladder section (until you study the possible hazard of one
falling off), SRL’s at 21+ft, or stagger your ladder sections then no SRL’s are needed.
The question for clarity is as follows: Can you be severely injured falling above 10 ft? BLS reports 9% fall deaths are less than 10 ft. Do you know what the BLS percentage kill is for 20 ft. falls? It is 25%.
For severe fall injuries multiply deaths by 300 (Injury Facts).
Protection with SRL’s, when provided, is from the ground up (not like lanyards). BLS each year: Scaffolds, ladders and roofs add up to …. %
of fall deaths in construction. Is that enough?
Was wondering if you know the guidelines for handrails on scaffolds over 4 feet.
The general minimum requirements for guard rails for the various scaffold types is depicted in the governing regulation 1910 Subpart D Walking Working Surfaces General Requirements for Scaffolding 1910.28:
Guardrails not less than 2 x 4 inches or the equivalent and not less than 36 inches or more than 42 inches high, with a mid-rail, when required, of 1 x 4-inch lumber or equivalent, and toeboards, shall be installed at all open sides on all scaffolds more than 10 feet above the ground or floor. Toeboards shall be a minimum of 4 inches in height. Wire mesh shall be installed in accordance with paragraph (a)(17) of this section.
Now with that being said we know that general fall protection requirements related to general industry require protection over a 4 trigger height and guard rails of 42 +/- 3. We also know the strength/serviceability of these systems at the 200 lb. load and corresponding maximum deflection. Scaffold strength requirements are different at a multiplier against peak load.
One is more restrictive than the other&certainly we want to work safely vs. just meeting the minimum standard therefore my recommendation would be to have protection at a 4 trigger height and using the more restrictive requirement for the design of the guard rail systems.