AN OVERVIEW OF THE NEW MIOSHA WALKING-WORKING SURFACES STANDARD

Transcription

1 AN OVERVIEW OF THE NEW MIOSHA WALKING-WORKING SURFACES STANDARD Michigan Safety Conference April 2018 LJB Booth 612 CRAIG GALECKA, P.E., C.S.P. PRINCIPAL, LJB INC. (517) ;

2 FOR MORE INFORMATION Craig Galecka, P.E., C.S.P. > > (517) > LJBinc.com > Booth 612

3 LEARNING OBJECTIVES 1. Summarize the content of the new regulation 2. Identify key changes with the new regulation 3. State actions to assist your organization in implementation

4 CALL TO ACTION 1. Read Regulatory Text 2. Determine what needs to be addressed and when 3. Plan communication and training for staff

5 AGENDA Background / context Key issues > Top 10 items Items not addressed Next steps: action plan

6 BACKGROUND / CONTEXT

7 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 7

8 HISTORY Federal OSHA 1910 Subpart D dated to 1971 > Proposed updates 1990, 1994, 2003 and 2010 > Final version November 2016, effective January 2017 MIOSHA General Industry Safety Standard Part 2. Floor and Wall Openings, Stairways and Skylights > Filed 1969 > Amended 1971, 1973, 1976, 1979 and 1989

9 GENERAL IND. STANDARDS AFFECTED Part 2. Floor and Wall Openings, Stairways and Skylights NEW Part 2. Walking-Working Surfaces Part 1. General Provisions - being amended Part 3. Fixed Ladders being rescinded Part 4. Portable Ladders being rescinded Part 5. Scaffolding being amended Part 6. Overhead and Gantry Cranes being amended Part 21. Powered Industrial Trucks being amended Part 25. Manlifts being amended

10 GENERAL IND. STANDARDS AFFECTED Part 27. Woodworking Machinery Part 33. Personal Protective Equipment Part 50. Telecommunications Part 52. Sawmills Part 58. Aerial Work Platforms Part 63. Pulp, Paper and Paperboard Mills Part 86. Electric Power Generation, Transmission and Distribution Part 94. Textiles ALSO Construction Standard Part 11. Fixed and Portable Ladders

11 NEW LOCATIONS Section Previous Subpart D Final Subpart D Definitions Scope and definitions General requirements General requirements Guarding floor and wall openings/holes Ladders Fixed industrial stairs Step bolts and manhole steps Portable wood ladders Stairways Portable metal ladders Dockboards Fixed ladders Scaffolds/rope descent systems Safety requirements for scaffolding Manually propelled mobile stands Duty to provide fall protection Fall protection systems (criteria/practices) Other working surfaces Training requirements

12 NUMBER OF FATALITIES Type of Fall Annual Falls Incremental Prevention Fatalities Prevented Fall from ladder 22% 57 High (20%) 11.4 Fall from scaffolding 5.2% 13 Very High (40%) Fall from roof 9.8% 25 High (20%) 5.1 Fall to lower level (NEC) % 67 Low (5%) 3.4 From other types of falls, less than 3 fatalities prevented not included TOTAL Total prevented = 3% of workplace fall fatalities

13 INSPECTION EXEMPTION When employers are inspecting, investigating, or assessing workplace conditions or work to be performed prior to the start of work or after all work has been completed. This exemption does not apply when fall protection systems or equipment meeting the requirements of have been installed and are available for workers to use for pre-work and postwork inspections, investigations, or assessments

14 OTHER EXCLUSIONS Agriculture > GI rules still apply for non-agricultural operations on a farm Rolling stock and motor vehicles > Will continue to consider comments

15 KEY ISSUES Top 10 Items of Interest

16 1. TRAINING REQUIREMENTS General for exposure Roof Equipment Authorized Person Training for exposed workers or equipment users By June 2, 2018 Competent Person Qualified Person

17 2. EQUIPMENT REQUIREMENTS Snaphooks and carabiners > Proof testing required to 3,600 pounds > Per ANSI Z required ultimate strength 3,600 pounds

18 2. EQUIPMENT REQUIREMENTS Maximum deceleration distance of 3.5 feet > Per ANSI Z FF lanyards, DD is 4 doesn t meet OSHA 12 FF lanyards, DD is 5 doesn t meet OSHA > For SRLs, arrest distance is free fall + deceleration distance Arrest distance = 54

19 3. 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

20 3. ROOF EDGE (INFREQUENT & TEMP.)

21 3. 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

22 3. ROOF EDGE Infrequent > Only on occasion > Not routine part of job > Examples: Annual maintenance Monthly replacement of batteries, filters, etc.

23 3. ROOF EDGE (FREQUENT)

24 4. LADDERS & STAIRS Additional types approved > Alternating tread-type stair (Was in MIOSHA Part 2) > Combination ladder > Mobile ladder stand platform Now includes requirements for spiral stairs and ship stairs

25 4. LADDERS & STAIRS Ladder safety systems required on new ladders greater than 24 feet > Starting in Nov MATCHES FED OSHA > Every ladder required in year 2036 Includes ladders attached to equipment, but not ladders that are integral part of machines: (a)(2).

26 4. LADDERS & STAIRS Fixed ladder details Item Old Rule New Rule Maximum rung spacing 12 inches inches Step across distance (step-thru ladder) Clearance between side rails (step-thru distance) inches 7-12 inches inches inches Portable ladders required to have anti-slip treatment, but fixed ladders have no such requirement

27 4. LADDERS & STAIRS Stairs details Item Old Rule New Rule Overhead clearance 84 inches 80 inches Handrail height inches inches Guardrail N/A 42 inches

28 4. LADDERS & STAIRS Stairs > Excludes: stairs serving floating roof tanks, stairs on scaffolds, and stairs on self-propelled motorized equipment. > Must support at least 5 times the normal anticipated live load Never less than a concentrated load of 1,000 pounds > Winding stairways can be used when the diameter of the tank or structure is at least 5 feet

29 5. GUARDRAIL 42 inches +/- 3 inches, aligned with construction industry Codified 19 clear opening requirement

30 5. GUARDRAIL Chains not included for ladder openings Parapet option excluded (combined height and width) Grandfather clause 36 inches excluded

31 6. NEW ASSESSMENT REQUIREMENT (d) requires workplace assessment > Didn t used to apply to fall protection.now IT DOES! OSHA intent is for proactive hazard identification No implementation or grandfather clause > Technically required on February 2, 2018

32 6. ASSESSMENT REQUIREMENTS Survey Select PPE Communicate Ensure proper fit

33 6. ASSESSMENT REQUIREMENT (d) requires workplace assessment > Written certification required What workplace evaluated Who certifies evaluation was performed Date of assessment > Example of compliant assessment in Appendix B

34 6. QUALIFICATIONS OF ASSESSOR? OSHA does not require third party assessment 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?

35 7. ROPE DESCENT SYSTEMS OSHA s 1991 RDS memorandum allowed the use of RDS provided they have sound anchorages. IWCA Committee > ANSI/IWCA I > Currently defunct after ruling by ANSI (b)(1)(i) > before any rope descent system is used building owner has identified, tested, certified, and maintained each anchorage

36 8. DOCUMENTATION REQUIRED Assessments Training Anchors > RDS > Others WWS load rating (includes many surfaces, such as roofs) > (b) > (d) (1)

37 9. TIME-SENSITIVE ITEMS Compliance Dates > Employee training June 2, 2018 Before exposure to fall hazards Equipment hazards Retraining Training understandable > Certification of anchorages December 2, 2018

38 9. TIME-SENSITIVE ITEMS Compliance Dates > Existing fixed ladders need cage, well, ladder safety system or PFAS February 2, 2018 > New ladders with ladder safety system or PFAS November 19, 2018 > All fixed ladders must be equipped with a ladder safety system or PFAS November 18, 2036

39 10. COMPETENT & QUALIFIED PERSONS Updated definitions > Subpart D and Subpart I for qualified > Subpart I for competent Qualified Person references > Training > Correction or repair involves structural integrity of WWS > Anchorages design, installed and used > Annual inspection of rope descent anchorages > Anchorage certification at least every 10 years Inspecting a knot (termination) in a lanyard or vertical lifeline

40 ITEMS NOT ADDRESSED

41 ITEMS NOT ADDRESSED FP for portable ladders (specifically excluded) (a)(2)(i) Amount of training Systems approach Certify active systems PE requirement in some cases

42 ITEMS NOT ADDRESSED FP for portable ladders (specifically excluded) Amount of training Systems approach Certify active systems PE requirement in some cases

43 ITEMS NOT ADDRESSED FP for portable ladders (specifically excluded) Amount of training Systems approach Certify active systems PE requirement in some cases

44 ITEMS NOT ADDRESSED FP for portable ladders (specifically excluded) Amount of training Systems approach Certify active systems PE requirement in some cases

45 ITEMS NOT ADDRESSED FP for portable ladders (specifically excluded) Amount of training Systems approach Certify active systems PE requirement in some cases

46 ACTIONS TO TAKE

47 TIMELINE TODAY Published 11/18/16 Employee Training 6/2/18 RDS anchorage certif. 12/2/18 Effective 2/2/18 Ladder safety systems 11/19/18

48 WHAT IS YOUR GOAL? Compliance Safety Risk management

49 OSHA V. ANSI Relevance of ANSI standards > Depth of requirements > Standards for each component and type of system > Fall protection program management > Active fall protection system design > Future: User guide for components (harnesses, lanyards, etc.) New revision of ANSI Z359.1 took affect on 8/14/2017

50 DEVELOP YOUR ACTION PLAN What steps do you take now? > Who is your team? > What are your priorities? > What happens now vs. later? Assessment Training Documentation items

51 RECOMMENDED READING Exhibit V-2 Key differences Tables V 6-9: where are the falls occurring? Table V-11 fatalities preventing, why only 29? Table V-17 delayed or grandfather clauses Appendix B: Fatal Facts outlines fall incidents that should be prevented

52 OTHER RESOURCES Blog series thespot.ljbinc.com > Answering FAQs on new OSHA fall protection regulations Recording of webinar on new regulations >

53 QUESTIONS

54 AN OVERVIEW OF THE NEW MIOSHA WALKING-WORKING SURFACES STANDARD Michigan Safety Conference April 2018 LJB Booth 612 CRAIG GALECKA, P.E., C.S.P. PRINCIPAL, LJB INC. (517) ;