Comparison of the two proposals developed by the Ministry of Labour (MOL) and the SAE Working Group (SAE WG)

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1 to Ontario Regulation 213/91 (Construction Projects) under the Occupational Health and Safety Act (OHSA) related to Suspended Access Equipment (SAE) Comparison of the two proposals developed by the Ministry of Labour (MOL) and the SAE Working Group (SAE WG) FINAL SAE WG PROPOSAL and SAE Section 1 Definitions NO definition of allowable suspended load Recommendation 1: Definitions The ministry proposes to define, allowable suspended load to mean the combined weight of the suspended work platform or boatswain s chair, the hoisting device or devices, the rated platform capacity and the suspended portion of the suspension line; The Ministry intends to develop a guideline to assist stakeholders in complying with the new requirements for suspended work platform systems (if approved by the government). According to the SAE WG, the industry commonly follows the Canadian Standards Association (CSA) Standard, CSA Z271-10, Safety Code for Suspended Platforms. For this reason, both the SAE WG proposal and the MOL proposal reference specific provisions of the CSA standard, CSA Z271-10, Safety Code for Suspended Platforms to provide greater clarity and implementation consistency. The MOL s proposal includes more references to the CSA standard than the SAE WG proposal. New definitions The MOL proposes to add 8 new definitions. Allowable suspended load The MOL s proposed definition is modelled on the definition in the CSA standard, CSA Z271-10, Safety Code for Suspended Platforms to maintain industry s familiarity with a known term and ensure consistency in its application. Underlined words have proposed definitions Page 1 of 65

2 and SAE NO definition of anchorage connector anchorage connector to mean a component or a system of components of a fixed support that secures a suspended work platform or boatswain s chair, and associated suspension lines and lifelines to a fixed support. anchorage connector The MOL s proposed definition is modelled on the definition in the CSA standard, CSA Z271-10, Safety Code for Suspended Platforms to maintain industry s familiarity with a known term and ensure consistency in its application, particularly as the MOL proposes new design requirements for anchorage connectors. Critical weld, in relation to a suspended work platform, means a weld that the failure of which would result in a catastrophic failure or complete collapse of the suspended work platform. [applicable only to SAE sections] No definition of generic installation drawing critical weld to mean, in relation to a suspended work platform, a weld whose failure could result in the catastrophic failure or complete or partial collapse of the suspended work platform system that could endanger a worker. generic installation drawing to mean a drawing and related documentation, if any, provided by the manufacturer, supplier or owner of a suspended work platform system or powered boatswain s chair, or by an employer using the suspended work platform system or powered boatswain s chair, or prepared by a professional engineer that, - Identifies components, configurations and load limitations of the suspended work platform system or powered boatswain s chair; and - May be used at any project or at different locations on the same project where all of the requirements in the drawing are met; critical weld The two proposed definitions are very similar and would be applicable only to the SAE requirements. The proposed definition is an industry known term and is consistent with the general interpretation of the term used by professional engineers and would ensure consistency in its use. generic installation drawing A generic installation drawing refers to drawing(s) and related documentation that provide installation instructions for typical configurations of suspended access equipment commonly used by the industry. The MOL s proposed definition is a commonly used term in the industry and is meant to clearly distinguish this type of installation drawing from a site-specific installation drawing whose use has more extensive requirements in the proposal. This term is used throughout the MOL proposal particularly in Recommendation 13. In contrast, the SAE WG proposal uses the term manufacturer s instructions which is a general term used throughout the entire Regulation and which the MOL believes is not sufficiently specific or descriptive regarding installation drawings. The term manufacturer s instructions normally applies to any kind of equipment and includes much more than just SAE installation drawings. Underlined words have proposed definitions Page 2 of 65

3 and SAE Rated platform capacity means the combined weight of occupants, tools, equipment, and other material that may be carried by a suspended work platform or a work platform module as stated on the rated platform capacity marking.[applicable only to SAE sections] rated platform capacity to mean the combined weight of occupants, tools, equipment and other material that can be safely carried by a suspended work platform, a work platform module or boatswain s chair as specified by the manufacturer s marking. rated platform capacity The two proposed definitions are very similar and are modelled on the definition in the CSA standard, CSA Z271-10,Safety Code for Suspended Platforms. However, the MOL s proposed definition includes boatswain s chair as does the definition in the CSA standard. Both definitions would be applicable only to the SAE requirements. Site-specific installation drawing means a drawing and other documentation, if any, prepared by a professional engineer that identifies components, configurations and load limitations of a suspended work platform system for one particular project [applicable only to SAE sections] site-specific installation drawing" to mean a drawing and related documentation, if any, prepared by a professional engineer that identifies components, configurations and load limitations of a suspended work platform system or powered boatswain's chair for one particular project. site-specific installation drawing" A site-specific installation drawing provides installation instructions for nontypical configurations of suspended access equipment that take into consideration the unique features of the building or structure from which the equipment will be suspended. The two proposed definitions are very similar except for the addition of powered boatswain s chair in the MOL s proposed definition. A powered boatswain s chair refers to a boatswain s chair that is equipped with a mechanical or electrical hoist and does not include a boatswain s chair that uses a descent control device. Suspended work platform system is an access system comprised of an overhead fixed support, suspension line or lines, a hoisting device or devices, if any, and one or more suspended work platforms that may be moved horizontally and/or vertically but does not include a boatswain s chair or multi-point suspended scaffold. suspended work platform system to mean an access system comprised of one or more overhead fixed supports, one or more suspension lines, hoisting devices, if any, and one or more work platforms that can be moved vertically, but it does not include a boatswain s chair or a multi-point suspended work platform suspended work platform system The two proposed definitions are very similar and are modelled on the definition of suspended platform in the CSA standard, CSA Z271-10,Safety Code for Suspended Platforms. Both definitions would be applicable only to the SAE requirements. In addition, the MOL s proposed definition incorporates the MOL s proposed revisions to the current definition of multi-point suspended scaffold whereas the SAE WG s proposed definition continues to refer to the term multi-point suspended scaffold as currently defined. Underlined words have proposed definitions Page 3 of 65

4 and SAE Suspended work platform means a work platform including the necessary trusses, stirrups and connection frames that are suspended from an overhead fixed support but does not include a hoisting device No corresponding definition of suspended work platform in the MOL proposal. suspended work platform The MOL does not include this definition in its proposal. Instead, the MOL uses the term suspended as it is commonly interpreted to modify a work platform where appropriate in its proposal. Work platform means a work surface where a worker works or intends to work constructed of wood planks, fabricated planks or decks or other materials, but does not include a boatswain s chair. [applicable to entire Regulation] work platform to mean a work surface for a worker that is constructed of wooden planks, fabricated decks or other manufactured materials and that may include stirrups, trusses and other structural members but does not include a boatswain s chair. work platform The MOL s proposed definition is meant to be generic and applicable to any work platform used by a worker and not just for suspended work platform systems. The MOL intends to review the Regulation for all references to platform and work platform and proposes changing the references where appropriate to ensure consistent interpretation and application of the term work platform throughout the Regulation. multi-point suspended scaffold means a suspended scaffold or suspended work platform or a system of suspended scaffolds or suspended work platforms, each scaffold or platform being more than 750 millimetres in width, that is supported from an overhead support system by at least three primary loadcarrying means of suspension to maintain the system s stability; multi-point suspended work platform to mean a suspended work platform more than 750 millimetres in width or a system of suspended work platforms, where any platform is more than 750 millimetres in width, that is supported from an overhead fixed support system by at least three primary load-carrying means of suspension to maintain the stability of the work platform or work platforms. multi-point suspended work platform The MOL proposes to revise the existing definition of multi-point suspended scaffold to align it with the new proposed defined terms of suspended work platform system and work platform. The SAE WG proposal continues to use the current definition unchanged. Underlined words have proposed definitions Page 4 of 65

5 and SAE Section 7.2 Notification Requirements 7.2(1) Before a suspended work platform system or boatswain s chair is put into service for the first time at a project, (a) the constructor shall give notice in writing at least 48 hours in advance, in person, by fax, by electronic means or by other similar means, to the Ministry office located nearest to the project; or (b) if the suspended work platform system or boatswain s chair is to be used on an existing building or structure, the constructor and the owner of the building or structure, or the owner s agent, shall give notice at least 48 hours in advance, in person, by fax, by electronic means or by other similar means, to the Ministry office located nearest to the project. Recommendation 2: New Notice Requirements Before Using Suspended Access Equipment (i) Before a suspended work platform system is put into service for the first time at a project, the MOL proposes to add a new requirement for: the constructor to provide written notice to the ministry at least 48 hours in advance, and the notice to be on an approved form obtained from the ministry and to be submitted in person, by fax, by electronic means or by other similar means to the ministry office located nearest to the project. (b) No corresponding MOL requirement is included as the MOL proposal does not apply to owners of existing buildings or structures The MOL and SAE WG proposals are very similar except that the MOL proposal would not apply to boatswain s chairs or to owners of existing buildings or structures (differences highlighted in yellow). The proposed notification requirement is intended to strengthen enforcement by alerting MOL inspectors about projects where a suspended work platform system will be used. This would give inspectors an opportunity to visit the project to ensure compliance with the regulatory requirements re: suspended work platform systems analogous to the current requirements to submit a Notice of Project or Notice of trenching to the ministry. ss.(1)(b) of the SAE WG proposal: The MOL believes that since the constructor has overall responsibility under the OHSA for health and safety at a project, it would be appropriate to apply this notification requirement to constructors rather than also to building or structure owners who may not necessarily be aware of when a suspended work platform system would be put into service at their buildings or structures. (2) Despite subsection (1),a suspended work platform system or boatswain s chair may be used before the written notice in subsection (1) has been given to the Ministry if the following conditions are met: (ii) If it is necessary to use the suspended work platform system immediately to prevent personal injury or damage to property, ss.(2) and (3) of the SAE WG proposal: Although the formatting is different than the MOL s corresponding requirement, the content and intent are the same in both the MOL and SAE WG proposals. Underlined words have proposed definitions Page 5 of 65

6 and SAE (a) It is necessary to use the suspended work platform system or boatswain s chair immediately to prevent injury to people or damage to property, and (b) the constructor and the owner of the building or structure, or the owner s agent, notifies the Ministry by telephone or in person. (a) the constructor may give oral notification to the ministry by telephone or in person despite the 48 hour notice requirement above, and (3) The oral notification in subsection (2)(b) shall be followed by a written notice within 24 hrs. (b) the oral notification must be followed by written notice within 24 hours. (4) The written notice shall be posted at a conspicuous place on the project. (iii) The ministry proposes that the written notice must be posted in a conspicuous place at the project. (5) The written notice shall be on an approved form. Corresponding MOL requirement for an approved form is located in item (i) above Sections to 141, (a) apply to suspended work platforms systems and boatswain s chairs, and (b) do not apply to multi-point suspended scaffolds. Recommendation 3: Application The ministry proposes to replace current section with the following requirements: Every suspended work platform system and boatswain's chair must comply with Sections 137 to 141 inclusive of the Regulation; and Sections 137 to 142 inclusive of the Regulation do not apply to multi-point suspended work platforms. The MOL and SAE WG proposals are similar except for two additional points in the MOL s proposal highlighted in yellow: The proposed changes would ensure consistency with the proposed new requirements for suspended access equipment and proposed changes to the current definition of multi-point suspended scaffold. The term multi-point suspended scaffolds would be replaced with multi-point suspended work platforms to align the requirement with the new proposed defined terms Underlined words have proposed definitions Page 6 of 65

7 and SAE of suspended work platform system and work platform. The SAE WG proposal continues to use the existing term multi-point suspended scaffolds. The MOL would clarify that section 142 of the current Regulation that addresses outrigger scaffolds does not apply to multi-point suspended work platforms. Section Work Plans (1) Every employer who proposes to carry out work on a project using a suspended work platform system or boatswain s chair shall ensure that a written site specific work plan, setting out information, measures and procedures adequate to ensure the health and safety of workers using the suspended work platform system or boatswain s chair has been developed and implemented by a competent person for that project. (2) The work plan shall include, but not be limited to: Recommendation 4: New Work Plan Requirements for Suspended work platform systems & Boatswain s Chairs i. The MOL proposes that before a suspended work platform system or boatswain s chair is put into service for the first time at a project, an employer must ensure that a competent person: (a) conducts a risk assessment of the work that would be undertaken; (b) prepares and signs a written site specific work plan based on the results of the risk assessment, setting out information, measures and procedures adequate to ensure the health and safety of workers using the suspended work platform system or boatswain s chair; and, (c) implements the written site specific work plan. ii. The work plan must include, but would not be limited to: The proposed work plan requirements in both proposals are modelled on similar requirements in the current Window Cleaning Regulation (Regulation 859) under the OHSA. The proposed risk assessment in the MOL proposal and written work plans in both proposals are intended to ensure employers identify, evaluate and implement precautions to mitigate potential health and safety risks to workers using the suspended work platform system or boatswain s chair. The MOL and SAE WG proposals are very similar with minor differences highlighted in yellow and indicated below. Item i (a) of the MOL proposal: The MOL would require an employer to conduct a risk assessment of all work to be undertaken with the suspended access equipment and to develop a written work plan based on the results of the risk assessment. The SAE WG proposal has a more limited risk assessment requirement in its subsection (2) item (k) on page 9 that is meant to only identify hazards related to material hoisting, cutting, grinding and sandblasting associated with the work processes. Underlined words have proposed definitions Page 7 of 65

8 and SAE (a) procedures to install, move, or dismantle the suspended work platform system in accordance with manufacturer s instructions and if applicable, a sitespecific installation drawing if any of the conditions listed in ss. 139(7) apply; (b) the arrangement of the work platforms for the duration of the project; (c) the manner in which any suspension lines and lifelines that are used are to be attached to the fixed supports shown on any drawing(s) and/or diagrams referred to s.136.5; (d) the rated platform capacity of the suspended work platform or boatswain s chair, which shall be posted conspicuously on the platform or equipment; (e) the weight distribution plan to ensure equal loading across the work platform surface; (f) the maximum number of workers allowed on the suspended work platform; (g) the maximum amount or weight of construction debris, abrasive blasting grit or other materials that would be allowed to accumulate on the work platform as a result of the work, their placement on the work platform; a) procedures to install, move and dismantle the suspended work platform system or boatswain's chair; b) direction to use either a generic installation drawing or a site-specific installation drawing; c) the arrangement of the work platforms for the duration of the project; d) the manner in which all suspension lines and lifelines are to be attached to the fixed supports shown in a roof plan referred to in Recommendation 7 of this proposal; e) the rated platform capacity of the suspended work platform, work platform module or boatswain's chair; f) a weight distribution plan to ensure equal loading across the work platform surface; g) the maximum number of workers allowed on the suspended work platform; h) the maximum amount or weight of construction debris, abrasive blasting grit and other materials allowed to accumulate on the work platform, and their permissible location on the work platform; Item ii (b) of the MOL proposal: The MOL proposes to use the term generic installation drawing as it is defined on page 2. This term is used throughout the MOL proposal particularly in Recommendation 13. In contrast, the SAE WG proposal uses the term manufacturer s instructions which is a general term used throughout the entire Regulation and which the MOL believes is not sufficiently specific or descriptive regarding installation drawings as it normally applies to any kind of equipment and includes much more than just SAE installation drawings. Subsection (2) item (d) of the SAE WG proposal: The MOL located the same requirement to conspicuously post the rated platform capacity at the end of its Recommendation 4 on page 10 as a standalone provision in item v. Underlined words have proposed definitions Page 8 of 65

9 and SAE (g1) the arrangement and use of a material hoist or a similar device to transfer material to or from the work platform; (h) the weights of materials, tools and equipment that may be on the work platform or boatswain s chair; (i) written procedures to be followed in the event of an emergency that requires the rescue of a worker or workers from the suspended work platform system or boatswain s chair; (j) fall protection setup to address all work processes expected to be undertaken; (k) following a risk assessment of the work processes expected to be undertaken, the hazards related to material hoisting, cutting, grinding and sandblasting associated with the work processes; (l) protection of the public and workers below the suspended work platform or boatswain s chair; (m) overhead protection of workers from any work conducted above the suspended work platform or boatswain s chair; i) directions on whether and how to use a material hoist or other similar device to transfer material to and from the work platform; j) the weights of all materials, tools and equipment permitted to be on the suspended work platform or boatswain's chair; k) procedures to be followed in the event of an emergency that requires rescue of a worker or workers from the suspended work platform system or boatswain's chair; l) methods of fall protection that cover all work to be undertaken and their installation; m) an identification of the hazards related to material hoisting, cutting, grinding and sandblasting associated with the work; n) protection for the public and workers who may be below the suspended work platform or boatswain's chair; o) overhead protection for workers on a suspended work platform or boatswain's chair from any work conducted above the suspended work platform or boatswain's chair; ss.(2)(k) of the SAE WG proposal: The MOL believes this risk assessment requirement should be located more prominently at the start of this provision. The MOL has the same requirement for a risk assessment to be conducted at the start of its Recommendation 4, identified as an employer s responsibility. The MOL also clarifies that the written work plan must be based on the results of the risk assessment. Underlined words have proposed definitions Page 9 of 65

10 and SAE (n) any electrical hazards including proximity to electrical conductors; and (o) measures to be taken to protect the workers from weather conditions and other conditions that may endanger them. (3) Before a worker begins work using a suspended work platform system or boatswain s chair, the employer shall provide a copy of the written work plan to the worker and shall review it with the worker. (4) The employer shall keep a copy of the work plan available on the project. Corresponding requirement to post the rated platform capacities is located in subsection (2)(d) above. p) an identification of all electrical hazards, including close proximity to electrical conductors; and q) measures to be taken to protect workers from weather and other conditions that may endanger them. iii. The ministry also proposes that the employer must provide a copy of the work plan to a worker and review it with the worker before the worker begins installing or using a suspended work platform system or boatswain s chair. iv. In addition, the employer would be required to keep a copy of the work plan readily available at the project. v. The ministry proposes that the employer must post the rated platform capacity of a suspended work platform, work platform module or boatswain s chair conspicuously on the platform, module or boatswain s chair. Section Worker Training Operator/User (1) Prior to a worker being on a suspended work platform or a boatswain s chair, the employer shall ensure that, (a) the worker receives oral and written instruction on the following, including but not limited to, Recommendation 5: New Requirements for Worker Training i. Under the proposed requirement, before a worker gets on a suspended work platform or a boatswain s chair for the first time at a project, the employer must ensure that the worker is trained on its use by completing a training program that, (a) Provides instruction on, The MOL and SAE WG proposals are very similar except for the differences highlighted in yellow and noted below. Both proposals are modelled on Section 45 of the Window Cleaning Regulation which also addresses the use of suspended access equipment. They outline basic training requirements that would apply to any worker who may get on a suspended work platform, including workers not directly involved in the operation of the SAE (e.g. inspectors, Underlined words have proposed definitions Page 10 of 65

11 and SAE 1. applicable regulations under the Occupational Health and Safety Act; applicable regulations under the OHSA; fall hazards related to the use of the suspended work platform or boatswain's chair; engineers, consultants, etc.). This is to ensure that in the event of an emergency, equipment failure or incapacitation of the SAE operator, all workers on a suspended work platform would be able to safely descend and/or get off the platform. Item i (a) bullet 2 of the MOL proposal: The MOL added a new training subject, fall hazards related to the use of the suspended work platform or boatswain's chair. 2. the use and inspection of the personal protective equipment the worker is to use and its components; how to select, put on, use, inspect and maintain personal protective equipment the worker would use and its components; Item i (a) bullet 3 of the MOL proposal: The wording is consistent with that in item i (b) bullet 1 on page the use of any fixed supports used for the suspended work platform or boatswain s chair and for a worker s fall arrest system; any fixed supports used for the suspended work platform or boatswain's chair and for the worker's fall arrest system; 4. components, functionality and limitations of the suspension work platform system or boatswain s chair, tiebacks and operational controls; the components, functions and limitations of the suspended work platform system or boatswain's chair, tiebacks and operational controls; 5. reading and understanding the work plan and any drawing and/or diagram referred to in s.136.5; reading and understanding the work plan described in Recommendation 4 of this proposal and the roof plan described in Recommendation 7 of this proposal; 6. instructions on the load limitations of the suspended work platform system or boatswain s chair; and, the load limitations of the suspended work platform system or boatswain's chair; and 7. emergency rescue procedures; and emergency rescue procedures; and Underlined words have proposed definitions Page 11 of 65

12 and SAE (b) the worker successfully completes an oral and written evaluation based on the instruction in clause (a); and, (c) the worker is able to demonstrate adequate knowledge and proficiency in: 1. the use of the personal protective equipment the worker is to use including selecting, inspecting, putting on, using and maintaining; No corresponding requirement included in the MOL proposal. (b) Enables the worker to demonstrate proficiency in, selecting, putting on, using, inspecting and maintaining personal fall protection equipment the worker will use; ss.(1)(b) of the SAE WG proposal: The MOL proposal does not include a corresponding requirement for oral and written evaluation as in item 7 of subsection (1)(a) of the SAE WG proposal. Such a requirement would be inconsistent with Ontario s obligations under the intergovernmental Agreement on Internal Trade to reduce barriers to labour mobility. The MOL believes the next requirement below for a worker to demonstrate proficiency in the specified learning outcomes is more relevant for ensuring a worker has been adequately trained. 2. rigging procedures and tying acceptable knots; rigging procedures and tying adequate knots; 3. identifying and selecting appropriate fixed supports from a drawing and/or diagram referred to in s.136.5; and, 4. the safe operation of the suspended work platform system or boatswain s chair and its operating controls in accordance with s. (2) Workers shall have proof of training available on the project. (3) Workers shall have refresher training on the safe operation of the suspended work platform system or boatswain s chair as outlined in subsection (1) as required or at least every 3 years. identifying and selecting appropriate fixed supports from a roof plan described in Recommendation 7 of this proposal; and the safe operation of the suspended work platform system or boatswain's chair and its operating controls in accordance with the manufacturer's instructions. Corresponding MOL requirement is located in item (iv) below. ii. The ministry proposes that the worker must have refresher training on the safe operation of a suspended work platform system or boatswain s chair as described in item i above as often as required and, in any case, at least every three years. ss.(2) of the SAE WG proposal: The MOL located the same requirement for workers to have proof of training at the end of this Recommendation as item (iv). Refresher training: Both proposals require refresher training for workers at least every 3 years to ensure the requisite worker proficiency is retained. Workers need to keep their training up to date, particularly in case of equipment changes, long absences from work, or changes to applicable regulatory requirements or employers work procedures. Underlined words have proposed definitions Page 12 of 65

13 and SAE (4) The employer shall keep a record of the training provided to any worker on the suspended work platform system or boatswain s chair and have it available for an inspector upon request. iii. The ministry proposes that the employer must ensure that the person who provides the training program referred to in item "i" and the refresher training referred to in item "ii" above prepares a written training record for each worker who has successfully completed the training and signs the record. In addition, the employer must keep the written record readily available at the project and must make the record available to a MOL inspector upon request. iv. The ministry proposes that the worker must have written proof of completing the training, including refresher training, readily available at the project. The 3 year schedule is for the convenience of workers and employers as this would ensure consistency with the Working at Heights Training Program Standard that was released by the MOL s Chief Prevention Officer in December This training standard specifies that worker certification is valid for 3 years from the date of successful completion of the program. Workers who are required to use fall protection equipment will need to complete a training program that meets the Working at Heights Training Program Standard as of April 1, 2015 in accordance with O. Reg. 297/13, Occupational Health and Safety Awareness and Training. Item iii of the MOL proposal: The proposed requirement regarding training records is modelled on section 26.2 of the existing Construction Projects Regulation. Item iv of the MOL proposal: This is similar to subsection (2) of the SAE WG proposal. Consultation Questions 1. Do you agree with the list of training subjects and learning outcomes in item i of Recommendation 5? Are there any training subjects or learning outcomes that should be added to or deleted from the proposed list in Recommendation 5? Underlined words have proposed definitions Page 13 of 65

14 and SAE 2. What would be the estimated cost to employers of complying with the proposed training requirements in Recommendation 5? 3. How much time would the industry reasonably need to implement the ministry s proposed training requirements in Recommendation 5? 4. How much time would the industry reasonably need (employers, workers, training providers) to comply with the proposed training requirements in Recommendation 5? Section Worker Training Erector/Rigger Recommendation 6: New Training Requirements for a Competent Worker Who May Inspect a Suspended Work platform or Boatswain s Chair The MOL and SAE WG proposals are very similar except for the differences highlighted in yellow and noted below (1) In addition to the training required in s , the employer shall ensure that a worker who is designated as the competent worker to inspect a suspended work platform system or boatswain s chair and sign-off that it has been installed in accordance with the site-specific installation drawings or manufacturers instructions as the case may be, receives oral and written instruction on the following, including but not limited to: i. The ministry proposes that the employer would be required to ensure that the competent worker referred to in items (ii) and (iv) of Recommendation 13A successfully completes the training described in Recommendation 5 of this proposal, and receives additional training to enable the worker to conduct the inspections and attest to the installation of a suspended work platform system or powered boatswain s chair. The ministry proposes that the following subjects must be included in the training: The MOL s Recommendation 6 outlines the training requirements for the competent worker who inspects the installation of SAE under Recommendation 13A. Under Recommendation 13A of this proposal, the MOL proposes that a competent worker, as defined under the Regulation, may inspect a suspended work platform system or boatswain s chair under certain circumstances after it has been installed and verify in writing that the equipment has been installed correctly. The proposed training requirements would ensure that the designated competent worker is proficient in Underlined words have proposed definitions Page 14 of 65

15 and SAE a) Rigging o Torque procedures for hardware used in rigging o Acceptable rigging hardware angles and means to obtain acceptable angles b) Methods to Secure Beams and Equipment o Blocking methods o Fulcrum points o Strength of structure in relation to blocking and material placement c) Fixed supports o Structural elements used for anchorage including parapets, roof o Use of various methods to secure anchorage connectors Rigging Methods to secure beams and equipment Fixed supports inspecting the installation of suspended work platform systems or boatswain s chairs. The proposed refresher training provision would ensure the requisite worker proficiency is retained. Item i of the MOL proposal: The MOL s proposal applies to powered boatswain s chairs rather than to all boatswain s chairs as in the SAE WG proposal. A powered boatswain s chair refers to a boatswain s chair that is equipped with a mechanical or electrical hoist and does not include a boatswain s chair that uses a descent control device. o Use of temporary anchors on buildings under construction (i.e. reading drawings to select the appropriate fixed supports identified on approved drawings in s ) d) Principles of Suspension Lines, Hoisting Devices and Load Limits o Installation of lines protective devices to reduce possibility of chaffing/wear and tear o Identify when a professional engineer is required (regulatory requirements, specialty systems etc.) Principles of suspension lines, hoisting devices and load limits Underlined words have proposed definitions Page 15 of 65

16 and SAE e) Manufacturer s Instructions for assembly and installation more in-depth knowledge of load limits, inspection points, out of service criteria, annual inspections, record/log criteria, assembly drawings, use of different (not common but still in mfg. requirements) products such as truss beams and other beams. Manufacturers instructions for assembling, installing and disassembling suspended work platform systems or powered boatswain s chairs f) Work Plans and Roof Plans o More in-depth use of roof plans (how to read, critical items, etc.) o Know-how on development of a Work Plan o Verifying Roof Plans vs. actual on-site roof conditions g) Securing the suspended work platform or boatswain s chair to building face further instruction on means to secure the suspended work platform to building face in accordance with manufacturer s instructions. h) Electrical Systems: o Voltage drop issues o Proper set-up of electrical connections o Proximity to power lines o Assembly of power cords (waterproofing) o Use of GFCI s o Instruction on required certification of components and identification of appropriate certification marks accepted by the Electrical Safety Authority e.g. cul or CSA Work plans and roof plans Securing suspended work platforms or powered boatswain s chairs to the face of a building or structure Electrical systems Underlined words have proposed definitions Page 16 of 65

17 and SAE o Limitations on what the competent worker can and cannot do with respect to electrical components (i.e. no connecting of system to a panel etc.) (2)The employer shall ensure the worker designated in ss.(1) successfully completes an oral and written evaluation based on the instruction in ss. (1). (3) The worker designated in ss.(1) shall demonstrate adequate knowledge and proficiency in the use of the following: a) Installing and torqueing rigging hardware in accordance with manufacturer s instructions; b) Inspection of cable and terminations in accordance to manufacturer s instructions; c) Tying of adequate knots (minimum 2 different knots); and d) Proper set-up of a suspended work platform system or boatswain s chair in accordance with roof plans and manufacturer s instructions including: o o o Selection and use of fixed supports Equipment set-up Use of hoist from weaving cable to using descent controls, emergency controls No corresponding requirement included in the MOL proposal. ii. In addition, the training must enable the competent worker to demonstrate proficiency in, installing and torqueing rigging hardware in accordance with the manufacturer's instructions; inspecting suspension lines and terminations in accordance with the manufacturer's instructions; adequately tying different knots (a minimum of two different knots); properly setting up a suspended work platform system or boatswain's chair in accordance with roof plans described in Recommendation 7 of this proposal and the manufacturer's instructions, including, but not limited to: selection and use of fixed supports; set-up of equipment; use of hoists from reeving cables; use of descent control devices and emergency ss.(2) of the SAE WG proposal: The MOL proposal does not include a corresponding requirement for oral and written evaluation as in subsection (2) of the SAE WG proposal. Such a requirement would be inconsistent with Ontario s obligations under the intergovernmental Agreement on Internal Trade to reduce barriers to labour mobility. The MOL believes the next requirement below for a worker to demonstrate proficiency in the specified learning outcomes is more relevant for ensuring a worker has been adequately trained. Underlined words have proposed definitions Page 17 of 65

18 and SAE o o Impact of different work plans on set-up Public way protection. (4) A worker designated in ss.(1) shall have proof of training available on the project. (5) A worker designated in ss.(1) shall have refresher training on at least the items outlined in subsection (1) as required or at least every 3 years. (6) The employer shall keep a record of the training provided to a worker designated in ss.(1) and have it available for an inspector upon request. controls; impact of different work plans on set-up of equipment; and protection of public ways. Corresponding MOL requirement located to item (v) below. iii. The ministry proposes that the designated competent worker must have refresher training in the subjects listed in items i and ii above as often as required and, in any case, at least every three years. iv. The ministry proposes that the employer must ensure that the person who provides the training referred to in items "i", "ii" and "iii" above prepares a written training record for each worker who has successfully completed the training and signs the record. In addition, the employer must keep a record of the competent worker's training and make the record available to a MOL inspector upon request. ss.(4) of the SAE WG proposal: The MOL located the same requirement for workers to have proof of training at the end of this Recommendation as item (v). Item iii of the MOL proposal: Both proposals require refresher training be done every 3 years. This is for the convenience of workers and employers and would ensure consistency with the Working at Heights Training Program Standard that was released by the MOL s Chief Prevention Officer in December This training standard specifies that worker certification is valid for 3 years from the date of successful completion of the program. Workers who are required to use fall protection equipment will need to complete a training program that meets the Working at Heights Training Program Standard as of April 1, 2015 in accordance with O. Reg. 297/13, Occupational Health and Safety Awareness and Training. Item iv of the MOL proposal: The proposed requirement is modelled on section 26.2 of the existing Construction Projects Regulation and would provide more clarity than the SAE WG proposal. Underlined words have proposed definitions Page 18 of 65

19 and SAE v. The ministry proposes that the worker must have written proof of completing the training, including refresher training, readily available at the project. Item v of the MOL proposal: The MOL s proposed item (v) is similar to subsection (4) of the SAE WG proposal. Consultation Questions 5. Do you agree with the list of training subjects in item i and learning outcomes in item ii of Recommendation 6? Are there any training subjects or learning outcomes that should be added to or deleted from the proposed lists in Recommendation 6? 6. How much detail should be included, if any, under each of the training subjects listed in item i of Recommendation 6 to ensure a worker is competent to inspect the installation of a suspended work platform system or boatswain s chair? As a guide, the ministry has included below the detailed content for each of the training subjects listed in item i that was recommended by the industry Working Group mentioned in the Background part of the proposal. a) Rigging Torque procedures for hardware used in rigging Acceptable rigging hardware angles and means to obtain acceptable angles b) Methods to secure beams and equipment Blocking methods Fulcrum points Strength of structure in relation to blocking and material placement Underlined words have proposed definitions Page 19 of 65

20 and SAE c) Fixed supports Structural elements used for anchorage including parapets, roof Use of various methods to secure anchorage connectors Use of temporary anchors on buildings under construction (i.e. reading drawings to select the appropriate fixed supports identified on approved roof drawings described in Recommendation 7) d) Principles of suspension lines, hoisting devices and load limits Installation of protective devices on lifelines to prevent damage and abrasion to the lifelines Identify when a professional engineer is required (regulatory requirements, specialty systems etc.) e) Manufacturer s instruction for assembly, installation and disassembly more in-depth knowledge of load limits, inspection points, out of service criteria, annual inspections, record/log criteria, assembly drawings, use of different (not common but still in the manufacturer s instructions) products such as truss beams and other beams f) Work Plans and Roof Plans More in-depth use of roof plans (how to read, critical items, etc.) Underlined words have proposed definitions Page 20 of 65

21 and SAE Know-how on development of a work plan Verifying roof plans versus actual on-site roof conditions g) Securing the suspended work platform or boatswain s chair to building face further instruction on means to secure the suspended work platform to building face in accordance with manufacturer s instructions h) Electrical Systems: Voltage drop issues Proper set-up of electrical connections Proximity to power lines Assembly of power cords (waterproofing) Use of ground fault circuit interrupters (GFCIs) Instruction on required certification of components and identification of appropriate certification marks accepted by the Electrical Safety Authority e.g. Underwriters Laboratories of Canada (ULC) or CSA Limitations on what the competent worker can and cannot do with respect to electrical components (i.e. no connecting of system to a panel etc.) 7. What would be the estimated cost to employers of complying with the proposed training requirements in Recommendation 6? 8. How much time would the industry reasonably need to implement the ministry s proposed training requirements in Recommendation 6? Underlined words have proposed definitions Page 21 of 65

22 and SAE Section Roof Plans 136.5(1) Every Owner of a building or structure where a suspended work platform system or boatswain s chair is to be used shall have a roof plan approved by a professional engineer that, (a) is comprised of drawings and layout diagrams showing positions of fixed supports on the building or structure that are adequate for the attachment of the suspended work platform system, boatswain s chair and any lifelines, and Recommendation 7: New Requirements for Roof Plans i. The owner of a building or structure, where a suspended work platform system or boatswain s chair is to be used, must prepare a roof plan that: a) Is approved by a professional engineer; b) Includes drawings and layout diagrams showing the positions of all fixed supports on the building or structure that are adequate for attaching the suspended work platform or boatswain's chair, and lifelines, if any; and The MOL and SAE WG proposals are very similar except for the differences highlighted in yellow and noted below. Recommendation 7 of the MOL proposal is modelled on Section 39 of the Window Cleaning Regulation (Reg. 859), under the Occupational Health and Safety Act (OHSA) for building owners to provide roof drawings of anchor points and related structures. Currently, the Construction Projects Regulation does not require roof plans. The proposed requirement for roof plans would provide relevant information for employers and constructors for determining which fixed supports are to be used to attach the suspended work platforms and boatswain s chairs on individual projects. Employers using suspended work platforms must be assured that the fixed supports they are to use to suspend their work platforms are adequate i.e. capable of supporting the weight of their work platform when loaded with workers and equipment and while in operation. (b) meets the requirements of CSA Z271-10, Safety Code for Suspended Platforms, Clause (Roof Plan). c) Meets the requirements of Clause 8.2 of CAN/CSA Standard Z91-02 (R2008), Health and Safety Code for Suspended Equipment Operations. ss.(1)(b) of the SAE WG proposal: Clause of the CSA standard Z requires a roof plan to meet the requirements of Clause 8.2 of CAN/CSA Standard Z91-02 (R2008), Health and Safety Code for Suspended Equipment Operations. In contrast to the SAE WG, the MOL decided to make a direct reference to the CAN/CSA Standard Z91-02 (R2008) in its proposal to alert owners that another CSA standard is involved. The intent of both proposals is identical. Underlined words have proposed definitions Page 22 of 65

23 and SAE ii. Where the building or structure owner does not have a roof plan, the ministry proposes that a plan must be prepared by the building or structure owner, employer or constructor as described in item "i" above. Item ii of the MOL proposal: The addition of this requirement would provide clarity for building and structure owners as well as employers and constructors and would not change the intent of section of the SAE WG proposal. (2) The building or structure Owner shall provide a copy of the roof plan referred to in ss.(1)(a) and (b) to the constructor before the work is begun. (3) The building or structure Owner shall post a legible copy of the roof plan referred to in subsection (1)(a) and (b) at the building or structure near every entrance to the roof level or top level of the building or structure. iii. The building or structure owner or the preparer of the roof plan, as the case may be, would be required to provide a copy of the roof plan to the constructor and employer before any work using a suspended work platform system or boatswain's chair begins. iv. The ministry proposes that the building or structure owner or the preparer of the roof plan, as the case may be, would be required to post a legible copy of the roof plan near every entrance to the roof level or top level of the building or structure where the suspended work platform system or boatswain's chair is to be used. Item iii of the MOL proposal: The MOL added the phrase or the preparer of the roof plan, as the case may be to correspond to its item ii above which provides for an employer or constructor, in addition to a building or structure owner, to prepare a roof plan. Item iv of the MOL proposal: See the MOL s explanation for item iii above. (4) Where the building or structure does not have any adequate fixed supports in accordance with subsection (1), the Owner shall provide the Constructor with structural drawings for the building or structure, if available. v. If the roof plan does not identify appropriate numbers of fixed supports that are adequate for attaching the suspended work platform or boatswain's chair, and lifelines, if any, the ministry proposes to require, a) The building or structure owner to provide the constructor with structural drawings, if available, for the building or structure; Item v of the MOL proposal: Although the formatting of item (v) is different than ss.(4) and (5) of the SAE WG proposal, the content and intent are the same except for the addition of lifelines if any in the MOL proposal. Underlined words have proposed definitions Page 23 of 65