TITLE OF YOUR PRESENTATION - March 2, 2017 · OVERVIEW OF NEW OSHA RULE Updates general industry standards ＞Recognizes technology advances ... Jan 2017 Replaced or modified Nov

A Real-World View: Implementing New

OSHA Fall Protection Regulations

Indiana Safety Conference - March 2018

© LJB Inc. 1

A REAL-WORLD VIEW:

IMPLEMENTING NEW OSHA FALL

PROTECTION REGULATIONSIndiana Safety Conference – March 2018

TRACEY RIEPENHOFF, P.E., C.S.P. – LJB INC.

(419) 236-7050; [email protected]

AGENDA

Background/context

Commonly asked questions

＞ Roof edge/designated area

＞ Assessments

＞ Anchorages

＞ Design changes (ladders, stairs, guardrail, etc.)

＞ Program/policy changes

Case studies

Next steps: action plan




© LJB Inc. 2

BACKGROUND / CONTEXT

HISTORY

Originated1971

• 1990

• 1995

• 2014

Updates Published2017




© LJB Inc. 3

OVERVIEW OF NEW OSHA RULE

Updates general industry standards

＞ Recognizes technology advances

＞ Adopts industry best practices

＞ Establishes new requirements for PFAS

＞ Provides greater flexibility to choose solutions

＞ Increases consistency between construction and general

industry

5

UNDERSTAND REQUIREMENTS

Two “types” of hazards

Duty to have fall protection

1910.28

Systems criteria

1910.29(b)




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TIMELINE

Published 11/18/16

Effective 1/17/17

Employee Training

5/17/17

RDS anchorage

certif. 11/20/17

Ladder safety

systems 11/2018

TODAY

AUDIENCE QUESTIONHave you reviewed the new regulations?




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COMMONLY ASKED QUESTIONSRoof Edge/Designated Area

ROOF EDGE

Safe distance to an edge (low-slope roofs)

＞ Work less than 6 feet from roof edge

• Requires conventional protection

＞ Work 6-15 feet from roof edge

• Designated area allowed for infrequent/temporary work

• Warning line around work area or at 6 feet from edge

＞ Work 15 feet or more from roof edge

• Administrative control for infrequent/temporary work




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ROOF EDGE (INFREQUENT & TEMP.)

ROOF EDGE

Temporary

＞ “Brief” “Simple” “Short-term”

＞ Performed in less time than set up of fall protection

＞ Completed at one time

＞ Does not require significant equipment, personnel or resources




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ROOF EDGE

Infrequent

＞ Only on occasion

＞ Not routine part of job

＞ Examples:

• Annual maintenance

• Monthly replacement of batteries, filters, etc.

ROOF EDGE (FREQUENT)




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COMMONLY ASKED QUESTIONSHazard Assessments

NEW! ASSESSMENT REQUIREMENT

1910.132(d) requires workplace assessment

＞ Didn’t previously apply to fall protection….NOW IT DOES!

OSHA intent is for proactive hazard identification

No implementation or grandfather clause

＞ Technically required on January 17, 2017




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ASSESSMENT REQUIREMENTS

Written documentation required

＞ Who certifies evaluation was performed

＞ What workplace evaluated

＞ Date of assessment

UNDERSTAND REQUIREMENTS

Survey Select PPE Communicate Ensure

proper fit




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WHO CAN DO IT?

OSHA does not require a third party

But…

＞ Assessor must have adequate knowledge of fall hazards

＞ OSHA-defined Qualified Person?

＞ Is your internal staff too busy or too familiar to objectively and

thoroughly review?

AUDIENCE QUESTIONWill you have to change how you evaluate fall hazards?




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COMMONLY ASKED QUESTIONSWWS assessments

ARE YOU COMPLIANT?

Stairs Ladders

Platforms Roofs




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SAMPLE RESULTS PER 1910.29

Large chemical plant - compliant v. noncompliant items

CATEGORY COMPLIANT NON-COMPLIANT TOTAL

Stair 108 133 241

Ladder 88 226 314

Platform 200 332 532

Roof 10 22 32

Total 406 713 1,119

SAMPLE RESULTS

55% non-compliant

Stairs

72% non-compliant

Ladders

62% non-compliant

Platforms

100% non-compliant

Roofs




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SAMPLE RESULTS – WWS STRUCTURE

CATEGORY NONE MINOR QP EVAL TOTAL

Stair 73 160 8 241Ladder 104 182 28 314

Platform 124 338 68 532Roof 6 14 12 32

Total 307 694 116 1,119

SOLUTIONS

Develop standard fabrication details to avoid future

noncompliance

Focus on major deficiencies (not one inch of missing

clearance)

Focus on high-traffic areas




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COMMONLY ASKED QUESTIONSAnchorages

ROPE DESCENT SYSTEMS

OSHA’s 1910.27(b)(1)(i)

＞ …before any rope descent system is used…building owner has

identified, tested, certified, and maintained each anchorage

＞ Certification of anchorages – November 20, 2017




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IS ANCHORAGE TESTING REQUIRED?

Does not explicitly require 100% field testing of the

anchorages post installation

＞ Testing to 5,000 pounds could damage anchor or structure

＞ Depends on documentation for design and installation

WHAT IS ANCHORAGE CERTIFICATION?

Building owner must notify contractors and workers

“in writing” that requirements are met

＞ If you can’t do that, it needs to be a priority

Best guidance for anchorage certification

＞ ANSI Z359.6-2016




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Mixed use development tenants want clean windows

Building owner working toward compliance

＞ Certifying anchorages for fall arrest

and work positioning

ANCHORAGE CASE STUDY

ANCHORAGE CASE STUDY

Existing systems lack documentation

＞ When records are available

• Straightforward: certification = documentation

＞ When records are “lost”

• More challenging with documentation lacking

– Load testing

– Other investigative effort required




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COMMONLY ASKED QUESTIONSDesign Changes

REQUIRED STAIR DESIGN CHANGES?

Stairs details

Item Old Rule New Rule

Overhead clearance 84 inches 80 inches

Handrail height 30-34 inches 30-38 inches

Stair rail N/A 42 inches




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REQUIRED STAIR DESIGN CHANGES?

351910.29(f)

Installed after 1/17/17

＞ 42” stair rail required

• Plus handrail on open sides

＞ Handrail must be 30-38”

No retrofit requirement as

long as it meets the minimum

LADDER SAFETY SYSTEMS RULES?

Ladder safety systems required on

fixed ladders greater than 24 feet

Jan 2017 Replaced or modified

Nov 2018 New ladders

Nov 2036 Retrofit

http://www.georgiosironworks.com/iron-railings.html

http://www.georgiosironworks.com/iron-railings.html




© LJB Inc. 19

REQUIRED LADDER DESIGN CHANGES?

Fixed ladder details

Item Old Rule New Rule

Maximum rung spacing 12 inches 10-14 inches

Step across distance (step-thru

ladder)

2.5-12 inches 7-12 inches

Clearance between side rails

(step-thru distance)

18-24 inches 24-30 inches

IMPACT TO GUARDRAILS?

Chains not included for

ladder openings

Parapet option excluded

Previous grandfather

clause – 36 inches –

excluded




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RULES FOR SELF-CLOSING GATES?

• Self-closing gates equipped with a toprail and midrail

• January 17, 2017 compliance date: no grandfather

39

GRANDFATHERED CHANGES?

Unless otherwise

specified, changes

are not

grandfathered




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COMMONLY ASKED QUESTIONSUpdate Policies and Program

POLICY/PROGRAM UPDATES

Company policy OSHA 1910 Subparts D&I

ANSI Z359.1 standard




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WHAT NEEDS TO CHANGE?

Threshold Safe distance to roof edge


Awareness training vs. authorized person training




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Ladder safety systems rules: required

on fixed ladders greater than 24 feet

Jan 2017 Replaced or modified

Nov 2018 New ladders

Nov 2036 Retrofit

Anchorage certification

ANSI Z359.6-2016





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GAP ANALYSIS

Current State Desired/Required

State

OTHER CASE STUDIESFor practical tips




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UPDATING TRAINING CONTENT

Team discussed new reg. and need for revised training

Included gap analysis in conjunction with reg. edits

What changed?

＞ Changes related to new OSHA regs.

＞ Changes based on ANSI Z359 standards

＞ Content recommendations

＞ Length and delivery of training

PREVENTION THROUGH DESIGN

Organization recognized significant cost to

address safety in new facilities

Procured Prevention through Design training for internal staff

and consultants

Result:

＞ Documented lessons learned

＞ Documented changes with cost/benefits

＞ Develop process to incorporate into project life cycle




© LJB Inc. 26

RE-ROOFING

PMs confused between “certified” anchorage connectors

vs. “certified” anchorage

Changed process to coordinate directly with maintenance

team to ensure roof anchorages would meet their needs

Result:

＞ Minimized use of PPE – use of more aerial lifts, modified process

＞ Minimized use of anchors = fewer roof penetrations to maintain

TEMPORARY PPE

Discovered that PPE was installed incorrectly

＞ “Temporary” equipment permanently installed

Surveyed facility to locate all issues

Results:

＞ Plan to address all instances

• Timeline

• Cost

＞ Documented lessons learned to share with other locations




© LJB Inc. 27

AUDIENCE QUESTIONOn a scale of 1-5, how much does this impact your organization?

ACTIONS TO TAKE




© LJB Inc. 28

DEVELOP YOUR ACTION PLAN

3 factors to consider when planning implementation

＞ Who is your team?

＞ What are your priorities?

＞ What happens now vs. later?

IS WRITTEN PROGRAM REQUIRED?

New documentation

requirements

＞ Training

＞ Assessment

＞ RDS anchorage

certification




© LJB Inc. 29

RECOMMENDED FIRST STEPS

1. Read Regulatory Text (pages 82981 to 83006)

2. Determine what needs to be addressed and when

3. Plan communication and training for staff

PREAMBLE SECTIONS

Exhibit V-2: Key substantive differences

Tables V 6-9: where are the falls occurring?

Table V-11 – why only 29 deaths prevented?

Table V-17 delayed or grandfather clauses

Appendix A: Derivation of Prevention Factor Adjustments

Appendix B: Preventable Fatal Accidents




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OTHER RESOURCES

Blog series – thespot.ljbinc.com

＞ Answering FAQs on new OSHA fall protection regulations

Recording of webinar on new regulations

＞ http://bit.ly/OSHAweb

AUDIENCE QUESTIONWhat ideas do you have to address the new regulations?




© LJB Inc. 31

A REAL-WORLD VIEW:

IMPLEMENTING NEW OSHA FALL

PROTECTION REGULATIONSIndiana Safety Conference – March 2018

TRACEY RIEPENHOFF, P.E., C.S.P. – LJB INC.

(419) 236-7050; [email protected]

Documents

TITLE OF YOUR PRESENTATION - March 2, 2017 · OVERVIEW OF NEW OSHA RULE Updates general industry standards ＞Recognizes technology advances ... Jan 2017 Replaced or modified Nov