A REAL-WORLD VIEW: IMPLEMENTING NEW OSHA FALL PROTECTION REGULATIONS

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1 A REAL-WORLD VIEW: IMPLEMENTING NEW OSHA FALL PROTECTION REGULATIONS Indiana Safety Conference March 2018 TRACEY RIEPENHOFF, P.E., C.S.P. LJB INC. (419) ; 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. 1

2 BACKGROUND / CONTEXT HISTORY 1971 Originated Updates Published LJB Inc. 2

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 Systems criteria (b) LJB Inc. 3

4 TIMELINE Published 11/18/16 Employee Training 5/17/17 TODAY Ladder safety systems 11/2018 Effective 1/17/17 RDS anchorage certif. 11/20/17 AUDIENCE QUESTION Have you reviewed the new regulations? LJB Inc. 4

5 COMMONLY ASKED QUESTIONS Roof 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 LJB Inc. 5

6 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 LJB Inc. 6

7 ROOF EDGE Infrequent > Only on occasion > Not routine part of job > Examples: Annual maintenance Monthly replacement of batteries, filters, etc. ROOF EDGE (FREQUENT) LJB Inc. 7

8 COMMONLY ASKED QUESTIONS Hazard Assessments NEW! ASSESSMENT REQUIREMENT (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 LJB Inc. 8

9 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 LJB Inc. 9

10 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 QUESTION Will you have to change how you evaluate fall hazards? LJB Inc. 10

11 COMMONLY ASKED QUESTIONS WWS assessments ARE YOU COMPLIANT? Stairs Ladders Platforms Roofs LJB Inc. 11

12 SAMPLE RESULTS PER Large chemical plant - compliant v. noncompliant items CATEGORY COMPLIANT NON-COMPLIANT TOTAL Stair Ladder Platform Roof Total ,119 SAMPLE RESULTS Stairs Ladders 55% noncompliant 72% noncompliant Platforms Roofs 62% noncompliant 100% noncompliant LJB Inc. 12

13 SAMPLE RESULTS WWS STRUCTURE CATEGORY NONE MINOR QP EVAL TOTAL Stair Ladder Platform Roof Total ,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 LJB Inc. 13

14 COMMONLY ASKED QUESTIONS Anchorages ROPE DESCENT SYSTEMS OSHA s (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 LJB Inc. 14

15 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 Z LJB Inc. 15

16 ANCHORAGE CASE STUDY Mixed use development tenants want clean windows Building owner working toward compliance > Certifying anchorages for fall arrest and work positioning 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 LJB Inc. 16

17 COMMONLY ASKED QUESTIONS Design Changes REQUIRED STAIR DESIGN CHANGES? Stairs details Item Old Rule New Rule Overhead clearance 84 inches 80 inches Handrail height inches inches Stair rail N/A 42 inches LJB Inc. 17

18 REQUIRED STAIR DESIGN CHANGES? Installed after 1/17/17 > 42 stair rail required Plus handrail on open sides > Handrail must be No retrofit requirement as long as it meets the minimum (f) 35 LADDER SAFETY SYSTEMS RULES? Ladder safety systems required on fixed ladders greater than 24 feet Jan 2017 Nov 2018 Nov 2036 Replaced or modified New ladders Retrofit LJB Inc. 18

19 REQUIRED LADDER DESIGN CHANGES? Fixed ladder details Item Old Rule New Rule Maximum rung spacing 12 inches inches Step across distance (step-thru ladder) inches 7-12 inches Clearance between side rails (step-thru distance) inches inches IMPACT TO GUARDRAILS? Chains not included for ladder openings Parapet option excluded Previous grandfather clause 36 inches excluded LJB Inc. 19

20 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 LJB Inc. 20

21 COMMONLY ASKED QUESTIONS Update Policies and Program POLICY/PROGRAM UPDATES Company policy OSHA 1910 Subparts D&I ANSI Z359.1 standard LJB Inc. 21

22 WHAT NEEDS TO CHANGE? Threshold Safe distance to roof edge WHAT NEEDS TO CHANGE? Awareness training vs. authorized person training LJB Inc. 22

23 WHAT NEEDS TO CHANGE? Ladder safety systems rules: required on fixed ladders greater than 24 feet Jan 2017 Nov 2018 Nov 2036 Replaced or modified New ladders Retrofit WHAT NEEDS TO CHANGE? Anchorage certification ANSI Z LJB Inc. 23

24 GAP ANALYSIS Current State Desired/Required State OTHER CASE STUDIES For practical tips LJB Inc. 24

25 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. 25

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. 26

27 AUDIENCE QUESTION On a scale of 1-5, how much does this impact your organization? ACTIONS TO TAKE LJB Inc. 27

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. 28

29 RECOMMENDED FIRST STEPS 1. Read Regulatory Text (pages 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 LJB Inc. 29

30 OTHER RESOURCES Blog series thespot.ljbinc.com > Answering FAQs on new OSHA fall protection regulations Recording of webinar on new regulations > AUDIENCE QUESTION What ideas do you have to address the new regulations? LJB Inc. 30

31 A REAL-WORLD VIEW: IMPLEMENTING NEW OSHA FALL PROTECTION REGULATIONS Indiana Safety Conference March 2018 TRACEY RIEPENHOFF, P.E., C.S.P. LJB INC. (419) ; LJB Inc. 31

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