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Revised OSHA Reg's For Fall Prevention

 
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Old 03-10-2011, 04:37 PM   #1
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Revised OSHA Reg's For Fall Prevention


http://blog.msdsonline.com/2010/12/o...ction-workers/
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Old 03-10-2011, 05:08 PM   #2
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Re: Revised OSHA Reg's For Fall Prevention


Thank you.

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OSHA Dramatically Alters Fall Protection Requirements for Residential Construction Workers

2010/12/23

OSHA announced a significant change in the level of fall protection required for residential construction workers, emphasizing the need to protect residential roofers. By withdrawing a 1995 special directive that allowed residential builders to bypass fall protection requirements, these same builders must now comply with OSHA Standard 29 CFR 1956.501(b)(13).
Assistant Secretary of Labor for OSHA, Dr. David Michaels, addressed the concerns, “Fatalities from falls are the number one cause of workplace deaths in construction. We cannot tolerate workers getting killed in residential construction when effective means are readily available to prevent those deaths. Almost every week, we see a worker killed from falling off a residential roof. We can stop these fatalities, and we must.”
According the announcement, construction and roofing companies have six months to comply with the new directive. The effective date is June 16, 2011. To assist companies in meeting the new requirements, OSHA has published a Residential Fall Protection page on its website.
Going forward residential construction employers will be expected to employ the following safeguards:
  • Employees working six (6) feet or more above lower levels must be protected by conventional fall protection methods listed in 1926.501(b)(13) ( i.e., guardrail systems, safety net systems, or personal fall arrest systems ) or alternative fall protection measures allowed by other provisions of 29 CFR 1926.501(b) for particular types of work.
  • An example of an alternative fall protection measure allowed under 1926.501(b) is the use of warning lines and safety monitoring systems during the performance of roofing work on low-sloped roofs. (4 in 12 pitch or less). (See 1926.501(b)(10)).
  • OSHA allows the use of an effective fall restraint system in lieu of a personal fall arrest system. To be effective, a fall restraint system must be rigged to prevent a worker from reaching a fall hazard and falling over the edge. A fall restraint system may consist of a full body harness or body belt that is connected to an anchor point at the center of a roof by a lanyard of a length that will not allow a worker to physically reach the edge of the roof.
  • When the employer can demonstrate that it is infeasible or creates a greater hazard to use required fall protection systems, a qualified person must develop a written site-specific fall protection plan in accordance with 1926.502(k) that, among other things, specifies the alternative fall protection methods that will be used to protect
Standard 29 CFR 1956.501(b)(13)
“Residential construction.” Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.
Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.
Standard 29 CFR 1926.502(k)
“Fall protection plan.” This option is available only to employees engaged in leading edge work, precast concrete erection work, or residential construction work (See 1926.501(b)(2), (b)(12), and (b)(13)) who can demonstrate that it is infeasible or it creates a greater hazard to use conventional fall protection equipment. The fall protection plan must conform to the following provisions.
1926.502(k)(1) – The fall protection plan shall be prepared by a qualified person and developed specifically for the site where the leading edge work, precast concrete work, or residential construction work is being performed and the plan must be maintained up to date.
1926.502(k)(2) – Any changes to the fall protection plan shall be approved by a qualified person.
1926.502(k)(3) – A copy of the fall protection plan with all approved changes shall be maintained at the job site.
1926.502(k)(4) – The implementation of the fall protection plan shall be under the supervision of a competent person.
1926.502(k)(5) – The fall protection plan shall document the reasons why the use of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard.
1926.502(k)(6) – The fall protection plan shall include a written discussion of other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided with protection from the conventional fall protection systems. For example, the employer shall discuss the extent to which scaffolds, ladders, or vehicle mounted work platforms can be used to provide a safer working surface and thereby reduce the hazard of falling.
1926.502(k)(7) – The fall protection plan shall identify each location where conventional fall protection methods cannot be used. These locations shall then be classified as controlled access zones and the employer must comply with the criteria in paragraph (g) of this section.
1926.502(k)(8) – Where no other alternative measure has been implemented, the employer shall implement a safety monitoring system in conformance with 1926.502(h).
1926.502(k)(9) – The fall protection plan must include a statement which provides the name or other method of identification for each employee who is designated to work in controlled access zones. No other employees may enter controlled access zones.
1926.502(k)(10) – In the event an employee falls, or some other related, serious incident occurs, (e.g., a near miss) the employer shall investigate the circumstances of the fall or other incident to determine if the fall protection plan needs to be changed (e.g. new practices, procedures, or training) and shall implement those changes to prevent similar types of falls or incidents.
Citing Bureau of Labor Statistics numbers, OSHA says an average of 40 workers are killed each year, one-third of them Latino workers who comprise more than one-third of all construction employees.
If you are interested in reading the directive in its entirety, visit OSHA’s Compliance Guide for Residential Construction
- The MSDSonline Team -

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Old 03-10-2011, 05:39 PM   #3
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Re: Revised OSHA Reg's For Fall Prevention


Great more government controll. I love it when the government gets to tell me exactly how I have to run my business.

All for worker safety don't get me wrong but isn't OSHA already strict enough on roofing or roof top safety?

Didn't read through all the changes but to those who have is 2x6's and roof jacks (3 courses up) still ok on roofs under 26ft off the ground?

Had to do a big commercial 40ft tear off last Summer so had to get versed very quickly on what OSHA did and didn't want.
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Old 03-10-2011, 06:27 PM   #4
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Re: Revised OSHA Reg's For Fall Prevention


6' above the ground Dougger. Stay below that and you'll be OK.
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Old 03-10-2011, 06:35 PM   #5
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Re: Revised OSHA Reg's For Fall Prevention


1926.501(b)(13)

"Residential construction." Each employee engaged in residential construction activities 6 feet (1.8 m) or more above lower levels shall be protected by guardrail systems, safety net system, or personal fall arrest system unless another provision in paragraph (b) of this section provides for an alternative fall protection measure. Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.

1926.501(b)(10)

"Roofing work on Low-slope roofs." Except as otherwise provided in paragraph (b) of this section, each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system. Or, on roofs 50-feet (15.25 m) or less in width (see Appendix A to subpart M of this part), the use of a safety monitoring system alone [i.e. without the warning line system] is permitted.

1926.501(b)(11)

"Steep roofs." Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest systems.




Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.
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Old 03-10-2011, 08:49 PM   #6
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Re: Revised OSHA Reg's For Fall Prevention


So you can't work on an 8' step ladder? most roofers i see on residential, none of them every have a harness or lanyard hooked up. no guardrails on the picks. etc.
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Old 03-10-2011, 08:57 PM   #7
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Re: Revised OSHA Reg's For Fall Prevention


That's what it looks like. They'll regulate how much water we can drink in a day by next month.
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Old 03-10-2011, 09:12 PM   #8
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Re: Revised OSHA Reg's For Fall Prevention


osha is NO where to be found, and there isn't enough enforcement to ever check all the residential sites. maybe the ones that are really in the spotlight of a large town or city. rural america though, osha is dead there.
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Old 03-10-2011, 10:24 PM   #9
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Re: Revised OSHA Reg's For Fall Prevention


They are driving around giving people tickets lately. Last year I would have agreed with you Apgar. This year they have really tightened up around here. Hard to drive down a street and not see a roof being done. If it aint hard for me, it aint hard for OSHA either. Any job done on a busy street will unfortunately receive a premium added onto the sale price where as before I used to discount for exposure and signage.

I wish someone would put it in plain english for me because when I read that lawer talk I think I understand but know in the back of my mind I am just guessing at what it means. For me, my interpretation, wear harnesses on all steep slope jobs, always, period, end of story. Would all agree with that interpretation?
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Old 03-10-2011, 10:40 PM   #10
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Re: Revised OSHA Reg's For Fall Prevention


OSHA had required a 'slide guard/stop board' minimum for resi slopes of 4/12 or less. They have deemed that unsatisfactory now. Sound like you need safety fences, and/or harnesses now.
Enforcement starts June 16.

You can bypass all that if you want. It says so in several places in the regulations:
Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

Note: There is a presumption that it is feasible and will not create a greater hazard to implement at least one of the above-listed fall protection systems. Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems.

Exception: When the employer can demonstrate that it is infeasible or creates a greater hazard to use these systems, the employer shall develop and implement a fall protection plan which meets the requirements of paragraph (k) of 1926.502.


Accordingly, the employer has the burden of establishing that it is appropriate to implement a fall protection plan which complies with 1926.502(k) for a particular workplace situation, in lieu of implementing any of those systems. et al

As long as you can prove they are wrong and in error, you can do it your own way. It says so. It also says something in there about having a comprehensive written plan in lieu of the system.
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Old 03-10-2011, 10:47 PM   #11
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Re: Revised OSHA Reg's For Fall Prevention


It says so right here. Do this and all that stuff is unnecessary.
Standard 29 CFR 1926.502(k)
“Fall protection plan.” This option is available only to employees engaged in leading edge work, precast concrete erection work, or residential construction work (See 1926.501(b)(2), (b)(12), and (b)(13)) who can demonstrate that it is infeasible or it creates a greater hazard to use conventional fall protection equipment. The fall protection plan must conform to the following provisions.
1926.502(k)(1) – The fall protection plan shall be prepared by a qualified person and developed specifically for the site where the leading edge work, precast concrete work, or residential construction work is being performed and the plan must be maintained up to date.
1926.502(k)(2) – Any changes to the fall protection plan shall be approved by a qualified person.
1926.502(k)(3) – A copy of the fall protection plan with all approved changes shall be maintained at the job site.
1926.502(k)(4) – The implementation of the fall protection plan shall be under the supervision of a competent person.
1926.502(k)(5) – The fall protection plan shall document the reasons why the use of conventional fall protection systems (guardrail systems, personal fall arrest systems, or safety nets systems) are infeasible or why their use would create a greater hazard.
1926.502(k)(6) – The fall protection plan shall include a written discussion of other measures that will be taken to reduce or eliminate the fall hazard for workers who cannot be provided with protection from the conventional fall protection systems. For example, the employer shall discuss the extent to which scaffolds, ladders, or vehicle mounted work platforms can be used to provide a safer working surface and thereby reduce the hazard of falling.
1926.502(k)(7) – The fall protection plan shall identify each location where conventional fall protection methods cannot be used. These locations shall then be classified as controlled access zones and the employer must comply with the criteria in paragraph (g) of this section.
1926.502(k)(8) – Where no other alternative measure has been implemented, the employer shall implement a safety monitoring system in conformance with 1926.502(h).
1926.502(k)(9) – The fall protection plan must include a statement which provides the name or other method of identification for each employee who is designated to work in controlled access zones. No other employees may enter controlled access zones.
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Old 03-10-2011, 10:52 PM   #12
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Re: Revised OSHA Reg's For Fall Prevention


This thread might have to merge with the other one in Health and Safety going on right now.
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Old 03-10-2011, 11:07 PM   #13
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Re: Revised OSHA Reg's For Fall Prevention


I use fall prevention on a roof mainly because I can't afford to fall and get hurt and end up doing the job for free. Seems like the way to not have to worry about OSHA is to work for and by yourself.
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Old 03-11-2011, 08:26 AM   #14
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Re: Revised OSHA Reg's For Fall Prevention


I don't read the other sections of the forum. Too much jibberish from handy men, general contractors, plumbers etc...
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Old 03-11-2011, 12:36 PM   #15
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Re: Revised OSHA Reg's For Fall Prevention


Attend the FREE 10 hour OSHA safety course sponsored by the NRCA the next time they hold one that you can get to.

You Do NOT have to be an NRCA member to sign up, but it is advantageous to subscribe to the NRCA e-mail through their site to get updated as to when that will occur.

A Safety Spotter from a competent man will suffice in many situations, but that is ALL he can be designated to do.

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Old 03-12-2011, 10:45 AM   #16
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Re: Revised OSHA Reg's For Fall Prevention


The only time I've heard of osha showing up on job sites is for large commercial mulit unit housing, or in large single family new developments.

My brother had them stop by once. He yelled at them so much they decided to leave. One man operation that day...

My aunt had them stop out on my uncles site once and she got on the phone with them and they decided to leave them alone. She's one of the types that rarely pays for food when going out and has gotten so much free stuff over the years she sort of figures that's how it is. After the one encounter to avoid that dreaded phone call again the job sup. would call my aunt and let her know when the osha guy was out on site. They would stay at home that day.

Weekends are best for me running my business for a few reasons.
1. No DOT's to pull me over just because I'm pulling a dump trailer.
2. No osha's to bother me at a job site.
3. Very little traffic on the roads.

Home owners doing roofs on the weekend like it for one reason too.
No inspectors out driving around!!!

I pull permits of course so don't worry about that.
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Old 03-13-2011, 10:10 AM   #17
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Re: Revised OSHA Reg's For Fall Prevention


something like this?



_________
This Fall Protection Plan is Specific for All Projects

The following Fall Protection Plan is prepared for the prevention of injuries associated with falls.

I. Statement of Company Policy
****** is dedicated to the protection of its employees from on-the-job injuries.
All employees of ****** have the responsibility to work safely on the job. The
purpose of the plan is to supplement our existing safety and health program and to ensure that every employee and subcontractor who works for ****** recognizes workplace fall hazards and takes the appropriate measures to address those hazards.
This Fall Protection Plan addresses the use of conventional fall protection at a number of areas on the project, as well as identifies specific activities that require non-conventional means of fall protection. During the construction of residential buildings under 48 feet in height, it is sometimes infeasible or it creates a greater hazard to use conventional fall protection systems at specific areas or for specific tasks. The areas or tasks may include, but are not limited to:

a. Setting and bracing of roof trusses and rafters;
b. Installation of floor sheathing and joists;
c. Roof sheathing operations; and shingeling
d. Erecting exterior walls

In these cases, conventional fall protection systems may not be the safest choice for builders.This plan is designed to enable the company and it’s employees to recognize the fall hazards associated with this job and to establish the safety procedures that are to be followed in order to prevent falls to lower levels or through holes and openings in walking/working surfaces.
Each employee will be trained in these procedures and will strictly adhere to them except when doing so would expose the employee to a greater hazard. If, in the employee’s opinion, this is the case, the employee is to notify the competent person of their concern and have the concern addressed before proceeding. It is the responsibility of ***** as the competent person, to implement this Fall Protection Plan. Continual observational safety checks of work operations and the enforcement of the safety policy and procedures shall be regularly enforced. The crew supervisor or foreman, ****** is responsible for correcting any unsafe practices or conditions immediately.
It is the responsibility of the employer to ensure that all employees understand and adhere to the procedures of this plan and to follow the instructions of the crew supervisor. It is also the responsibility of the employee to bring to management’s attention any unsafe or hazardous conditions or practices that may cause injury to either themselves or any other employees. Any changes to the Fall Protection Plan must be approved by ***** as a qualified person.

II. Fall Protection Systems To Be Used On This Job
Installation of roof trusses/rafters, exterior wall erection, roof sheathing, floor sheathing and joist/truss activities will be conducted by employees who are specifically trained to do this type of work and are trained to recognize the fall hazards. The nature of such work normally exposes the employee to the fall hazard for a short period of time. This Plan details how
**** will minimize these hazards.

Controlled Access Zones
When using the Plan to implement the fall protection options available, workers must be protected through limited access to high hazard locations. Before any non-conventional fall protection systems are used as part of the work plan, a controlled access zone (CAZ) shall be clearly defined by the competent person as an area where a recognized hazard exists. The demarcation of the CAZ shall be communicated by the competent person in a recognized manner, either through signs, wires, tapes, ropes or chains.
***** shall take the following steps to ensure that the CAZ is clearly marked or controlled by the competent person.

* All access to the CAZ must be restricted to authorized entrants.
* All workers who are permitted in the CAZ shall be listed in the appropriate sections of the Plan prior to implementation.
* The competent person shall ensure that all protective elements of the CAZ be implemented prior to the beginning of work.

Installation Procedures for Roof Truss and Rafter Erection
During the erection and bracing of roof trusses/rafters, conventional fall protection may present a greater hazard to workers. On this job, safety nets, guardrails and personal fall arrest systems will not provide adequate fall protection because the nets will cause the walls to collapse, while there are no suitable attachment or anchorage points for guardrails or personal fall arrest systems.
On this job, requiring workers to use a ladder for the entire installation process will cause a greater hazard because the worker must stand on the ladder with his back or side to the front of the ladder. While erecting the truss or rafter the worker will need both hands to maneuver the truss and therefore cannot hold onto the ladder. In addition, ladders cannot be adequately protected from movement while trusses are being maneuvered into place. Many workers may experience additional fatigue because of the increase in overhead work with heavy materials, which can also lead to a greater hazard.
Exterior scaffolds cannot be utilized on most jobs because the ground, after recent backfilling, cannot support the scaffolding. In most cases, the erection and dismantling of the scaffold would expose workers to a greater fall hazard than erection of the trusses/rafters.
On all walls eight feet zero inches or less, workers will install interior scaffolds along the interior wall below the location where the trusses/rafters will be erected. A sawhorse scaffold planks will often allow workers to be elevated high enough to allow for the erection of trusses and rafters without working on the top plate of the wall.
In structures that have walls higher than eight feet and where the use of scaffolds and ladders would create a greater hazard, safe working procedures will be utilized when working on the top plate. During all stages of truss/rafter erection the stability of the trusses/rafters will be ensured at all times.
**** shall take the following steps to protect workers who are exposed to
fall hazards while working from the top plate installing tresses/rafters.

* Only the following trained workers(subcontractors) will be allowed to work on the top plate during roof truss
or rafter installation:
joe
tim
bob
* Workers shall have no other duties to perform during truss/rafter erection procedures;
* All trusses/rafters will be adequately braced before any worker can use the truss/rafter as a support;
* Workers will remain on the top plate using the previously stabilized truss/rafter as a support while other trusses/rafters are being erected;
* Workers will leave the area of the secured trusses only when it is necessary to secure another truss/rafter;
* The first two trusses/rafters will be set form ladders leaning on side walls at points where the walls can support the weight of the ladder; and
* A worker will climb onto the interior top plate via a ladder to secure the peaks of the first two trusses/rafters being set.
The workers responsible for detaching trusses from cranes and/or securing trusses at the peaks traditionally are positioned at the peak of the trusses/rafters. There are also situations where workers securing rafters to ridge beams will be positioned on top of the ridge beam.
**** shall take the following steps to protect workers who are
exposed to fall hazards while securing trusses/rafters at the peak of the trusses/ridge beam:
* Only the following trained workers(sub contractors) will be allowed to work at the peak during roof truss or rafter installation:
joe
tim
bob
* Once truss or rafter installation begins, workers not involved in that activity shall not stand or walk below or adjacent to the roof opening or exterior walls in any area where they could be struck by falling objects;
* Workers shall have no other duties than securing/bracing the trusses/ridge beam;
* Workers positioned at the peaks or in the webs of trusses or on top of the ridge beam shall work from a stable position; either by sitting on a Aridge seat or other equivalent surface that provides additional stability or by positioning themselves in previously stabilized trusses/rafters and leaning into and reaching through the trusses/rafters;
* Workers shall not remain on or in the peak/ridge any longer than necessary to safely complete the task of securing of all truses/rafters
.
Roof Sheathing Operations
Workers typically install roof sheathing after all trusses/rafters and any temperary truss bracing is in place. Roof structures are unstable until some sheathing is installed, so workers installing roof sheathing cannot be protected from fall hazards by conventional fall protection systems until it is determined that the roofing system can be used as an anchorage point. At that point, employees shall be protected by a personal fall arrest system.
Trusses/rafters are subject to collapse if a worker falls while attached to a single truss with a harness. Nets could also cause collapse, and there is no place to attach guardrails.
All workers will ensure that they have secure footing before they attempt to walk on the
sheathing, including cleaning shoes/boots of mud or other slip hazards.
To minimize the time workers must be exposed to a fall hazard; materials will be staged to allow for the quickest installation of sheathing.
**** shall take the following steps to protect workers who are exposed
to fall hazards while installing roof sheathing;
* Once roof sheathing installation begins, workers not involved in that activity shall not stand or walk below or adjacent to the roof opening or exterior walls in any area where they could be struck by falling objects;
* The competent person shall determine the limits of this area, which shall be clearly
communicated to workers prior to placement of the first piece of roof sheathing.
* The competent person may order work on the roof to be suspended for brief periods as
necessary to allow other workers to pass through such areas when this would not create a
greater hazard;
* Only qualified workers shall install roof sheathing;
*The bottom row of roof sheathing may be installed by workers standing in truss webs;
* After the bottom row of roof sheathing is installed, a slide guard extending the width of the roof shall be securely attached to the roof. Slide guards are to be constructed of no less than nominal 4-inch height capable of limiting the uncontrolled slide of workers. Workers should install the slide guard while standing in truss webs and leaning over the sheathing.
* Additional rows of roof sheathing may be installed by workers positioned on previously
installed rows of sheathing. A slide guard can be used to assist workers in retaining their
footing during successive sheathing operations; and
* When strong winds (above 40 miles per hour) are present, roof sheathing operations are to be suspended unless windbreakers are erected.
* Wall openings (more than ten feet above the lower level), floor holes and roof holes:
As soon as sheathing has been installed around a floor hole, roof hole, or wall opening that is not going to be sheathed (such as a hole for a doorway, stairwell or skylight), it must be covered or protected by a guardrail.


Installation of Floor Joists and Sheathing
During the installation of floor sheathing/joists (leading edge construction), the following steps shall be taken to protect workers;
* Only the following trained workers will be allowed to install floor joists or sheathing;
joe
tim
bob
• Materials for the operations shall be conveniently staged to allow for each access to workers;
* The first floor joists or trusses will be rolled into position and secured either from the ground, ladders or sawhorse scaffolds;
* Each successive floor joist or truss will be rolled into place and secured from a platform
created from a sheet of plywood laid over the previously secured floor joists of trusses;
* Except for the first row of sheathing which will be installed from ladders or the ground,
workers shall work from the established deck; and
* Any workers not assisting in the leading edge construction while leading edges still exist
(e.g., cutting the decking for the installers) shall not be permitted within six feet of the
leading edge under construction.

Erection of Exterior Walls
During the construction and erection of exterior walls, Kubisiak Inc shall take the following steps to protect workers:
* Only the following trained workers will be allowed to erect exterior walls;
jo
tim
bob
* A painted line six feet from the perimeter will be clearly marked prior to any wall erection activities to warn of the approaching unprotected edge;
* Materials for operations shall be conveniently staged to minimize fall hazards; and
* Workers constructing exterior walls shall complete as much cutting of materials and other preparation as possible away from the edge of the deck.

ROOFING WORK (REMOVAL, REPAIR, OR INSTALLATION OF WEATHERPROOFING ROOFING MATERIALS SUCH AS SHINGLES, TILE AND TARPAPER)..
These procedures may only be used for this work where:
* the roof slope is 8 in 12 or less,
and the fall distance, measured from the eave to the ground level, is 25 feet or less.
* Only the following trained workers will be allowed to perorm roofing work;
joe
tim
bob
* Only workers who are proficient in the alternative methods of fall protection
Slip Hazards
* The roof surfaces shall be inspected for slipping hazards.
*The employer or the Independent Contractor shall either eliminate any such hazards or
* take effective measures to have workers avoid them.
*The employer shall have workers wear appropriate footwear to reduce the potential for slipping.
*Contractor shall have any damaged portions of the roof deck repaired as soon as practicable.
* Any holes (including skylight openings) or other areas where employees (of the builder and/or the Independent Contractor) would not have safe footing
* shall be covered or surrounded by guardrails
Access To Roof.
*Employers shall not allow workers to ascend or descend the roof’s slope within 6 feet of the rake edge except where that limitation would prevent the performance of work.
* Location of Materials. Supplies and materials shall not be stored within 6 feet of the rake edge, or three feet where tile roof systems are being installed.
For Roofs with an Eave Height Of Up To and Including 25 Feet
Roof Slope (Any Roof Type): Up to 4 in 12.
* safety monitoring system or roofing slide guards.

If roofing slide guards are used, they must be built and installed in accordance with the requirements set out below.

Roof Slope: Over 4 in 12 (and up to and including 8 in 12): Roofing Slide Guards are required.
Roof slopes over 8 in 12, and over 25 feet
Roof Slope (Any Roof Type): Over 8 in 12 - RESTRICTIONS APPLY. *Conventional fall protection must be used, either personal fall arrest systems, safety net systems or guardrail systems. Alternative procedures are not available.
Eave Height Over 25 feet (Any Slope, Any Roof Type): - RESTRICTIONS APPLY. Conventional fall protection must be used, either personal fall arrest systems, safety net systems, or guardrail systems. Alternative procedures are not available.

Roofing Slide Guards: Requirements for Material Configuration and Installation.

* Employers (Independent Contractors) who use roofing slide guards as fall protection during roofing operations work shall comply with the following requirements:

(1) Materials:

* Roof jacks or equivalent supports
* Nails – long enough and strong enough to withstand an employee (of the Independent Contractor) sliding down the roof onto the guard.
o All slide guards must be constructed of 2X6 (nominal) lumber stock (planks).

(2) Installation instructions

(a) On steep roofs with slopes greater than 4 in 12,up to and including 6 in 12.

Roofing slide guards shall be installed continuously along the eave.

To accomplish this:
* No more than three (6) rows of roofing material shall be installed across the lower eave before installing slide guards.
* The roof jacks (or equivalent supports) shall be installed using nails long enough to withstand an employee (of the Independent contractor) sliding into the slide guard.
* The face of the 2X6 plank must be perpendicular (about 90°) to the surface of the roof.

* On steep roofs with slopes greater than 6 in 12 up to and including 8 in 12.
Continuous slide guards must be installed across all lower eaves.
Additional slide guards shall be installed below each work area at intervals not to exceed thirteen feet.

To install the additional slide guards:

* The employee, while standing on the plank below, shall secure the roof jacks above with nails and then install the 2X6 planks.
* The employee then can climb up to the new slide guard and continue to install the roofing work.
* This procedure is repeated as work proceeds up the roof.
* Although the eave slide guards must run the entire length of the eave, higher slide guards only need to be long enough to provide protection below the area of the roof where work is being performed. The face of the slide guard does not have to be at 90° to the roof surface.

Removal Instructions:

* Once the roof is installed to the ridge, the employee will go down to the next lower plank and remove the planks and roof jacks from the upper level.
The employee repeats this process down the roof until all 2X6 planks and roof jacks are removed.When the roofing job is completed the 2X6 planks and roof jacks along the eave can be removed.
Exceptions: (OSHA – Interpretations and Clarifications Subpart M, February 1995)

Once on the roof, the vendor’s employees will receive the roofing products (from a conveyor belt, lift truck or similar equipment) and then distribute the products onto the roof at various locations. During this distribution process, the vendor’s employees are not required to install an anchorage point for fall protection equipment regardless of the slope of the roof or the fall distance.

III. Enforcement
Constant awareness of and respect for fall hazards, and compliance with all safety rules are considered conditions of employment. The crew supervisor or foreman, as well as individuals in the Safety and Personnel Department, reserve the right to issue disciplinary warnings to employees and subcontractors, up to and including termination, for failure to follow the guidelines of this program.

IV. Accident Investigations
All accidents that result in injury to workers, regardless of their nature, shall be investigated and reported. It is an integral part of any safety program that documentation take place as soon as possible so that the cause and means of prevention can be identified to prevent a reoccurrence.
In the event that an employee falls or there is some other related, serious incident occurring, this plan shall be reviewed to determine if additional practices, procedures, or training need to be implemented to prevent similar types of falls or incidents from occurring.
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Old 03-14-2011, 03:02 PM   #18
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Re: Revised OSHA Reg's For Fall Prevention


Liability.

The number one reason for rule changes.

I would really like to believe worker safety is the real driver, but I have seen and know too much otherwise.

Here (Canuckistan) we had those changes occur in the verbatim during 2006. Come 2009 on a few large institutional/commercial type projects safety officers started showing up and actually enforcing those changes from three years ago.

I played the game, even going so far as to call in on other contractors (which apparently if I don't and someone suffers an injury I am now liable for). Half of the complaints were never even responded to. Apparently there is a serious lack of safety officers in this province, with approximately half of them up in Ft Mac in the tarsands, when the majority of workers are located in the major centres. I would hate to be accused of suggesting the dollar value of oil being more important than the safety of our workers, because it isn't.

The reason it is all about liability is because not one shingler on the planet signing up for his (not usually hers) first day is going to understand more than a paragraph of any of the above, unless they hire a lawyer, and even then chances are slim. As it is most employers dont understand it...

So the new recruit signs the dotted line, no more lawsuits, everyone is happy .

Except for the guy hanging off the edge of the building because most (read:ropes) conventional fall restraint system(s) is(are) inapplicable for most sloped roofing purposes. Fall arrest sure, but the reality is that by the time the rescue plan kicks into action, you have more than likely suffered more than enough serious suspension trauma to be able to do that type of work again.

The rope is only there to strangle you my friends (this statement applies to all those guys actually doing the work on the roofs)

The safety documentation is only there to prevent you from being strangled (this statement applies to all the hands off people in the trade).

Maybe if the going rate was adjusted accordingly to reflect production loss as well as increased wear and tear on the body (discs and ligaments are not replaceable people) I might not be so grievous on the topic.

Eventually it will all be scaffolding anyway, but until then...baby steps . It is fortunate to see we are so forward with the thinking on this stuff.

Have a nice day .
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Old 03-14-2011, 05:49 PM   #19
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Re: Revised OSHA Reg's For Fall Prevention


You got it Kubie. I'd add about 8 more pages. You have to 'prove' your exceptions. If you have enough pages, you should be able to continue roofing and finish the job during an inspection while the inspector is wading through your paperwork.
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Old 03-16-2011, 03:26 PM   #20
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Re: Revised OSHA Reg's For Fall Prevention


Quote:
Originally Posted by Grumpy View Post
I wish someone would put it in plain english for me because when I read that lawer talk I think I understand but know in the back of my mind I am just guessing at what it means. For me, my interpretation, wear harnesses on all steep slope jobs, always, period, end of story. Would all agree with that interpretation?
Yes!

Lawyer talk? Me thinks more typical bureaucrat (gov workers who failed law school) civil service protected power hungry worker bee's who could never accomplish anything on their own but want to "protect" society from itself - makes em' feel good and self righteous. Soon they'll mandate soft rubber tipped hammers (with no claws, of course) and saw blades that won't cut your fingers off (or cut materials) and on and on and on...

OSHA's just trying to keep up with the bureacrats over at the EPA to see who can write the most business killing rules and regulations.

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