PRACTICAL TIPS FOR

IMPLEMENTING NEW OSHA FALL

PROTECTION REGULATIONS
Occupational Health & Safety Magazine: Webinar

THOMAS KRAMER, PE, CSP – LJB INC.

 INTRODUCTION

  Thom Kramer, P.E., C.S.P.

>  22 years experience in fall protection industry
＞  Vice Chair ANSI Z359 Committee
+1 937-259-5120
•  Chairman of ANSI Z359.1 and .17
Tkramer@LJBinc.com

＞  American Society of Safety Engineers

•  VP Council of Professional Development

＞  International Society for Fall Protection, President

＞  Fall Protection “Phone-a-Friend”
 LEARNING OBJECTIVES

1.  Identify key changes with the new regulation

2.  State actions to assist your organization in

implementation
 CALL TO ACTION

1.  Read Regulatory Text (pages 82981 to 83006)

2.  Determine what needs to be addressed and when

＞  Where do you have similar situations?
＞  What can you apply from case studies?
＞  Ask implementation questions

3.  Plan communication and training for staff

4.  BONUS HOLIDAY GIFT (at end)

 AGENDA

  Overview

  How to:
＞  Hazard assessments
＞  WWS assessments
＞  Anchorage certification
＞  Update policies/program

  Next steps: action plan

 POLL QUESTION
Which of these aspects are you most interested in?
 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
  Only a few letters of interpretations on website
＞  NATE; RDS; others to come

7
 TIMELINE
TODAY
Ladder
Employee safety
Published Training systems
11/18/16 5/17/17 11/2018

Effective RDS
1/17/17 anchorage
certif.
11/20/17
 PREVIOUS WEBINARS

  March 1, 2017
＞  Top 10 key changes
＞  Items overlooked/omitted
＞  http://bit.ly/wwsregs

  August 2, 2017
＞  Answers to FAQs
＞  http://bit.ly/OSHAFAQ

  Find on demand at ohsonline.com → Webinars

HAZARD 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
 UNDERSTAND REQUIREMENTS

Two “types” of hazards

Duty to have Systems

fall protection criteria
1910.28 1910.29(b)
 UNDERSTAND REQUIREMENTS

  Written documentation required

＞  Who certifies evaluation was performed
＞  What workplace evaluated
＞  Date of assessment
 UNDERSTAND REQUIREMENTS

  Example of compliant assessment in Appendix B

1.  Assessment 4.  Adjustable features
•  Survey 5.  Reassessment
•  Sources 6.  Inspection
•  Organize data 7.  Cleaning and maintenance
•  Analyze data 8.  Disposal
2.  Selection
3.  Fitting
 UNDERSTAND REQUIREMENTS

Ensure
Survey Select PPE Communicate
proper fit
 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?
 POLL QUESTION
What data do you currently collect on fall hazards?
WWS ASSESSMENTS
 ARE YOU COMPLIANT?

Stairs Ladders

Platforms Roofs
 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
Stairs Ladders

55% non- 72% non-

compliant compliant

Platforms Roofs

62% non- 100% non-

compliant compliant
 SAMPLE RESULTS – WWS STRUCTURE

CATEGORY NONE MINOR QP EVAL TOTAL

Stair 73 160 8 241

Ladder 104 182 28 314
Platform 124 338 68 532
Roof 6 14 12 32
Total 307 694 116 1,119
 NONCOMPLIANT GUARDRAIL

•  Self-closing gates equipped with a toprail and midrail

•  January 17, 2017 compliance date: no grandfather

23
 SOLUTIONS

  Develop standard fabrication details to avoid future

noncompliance

  Focus on major deficiencies (not one inch of missing

clearance)

  Focus on high-traffic areas

ANCHORAGE CERTIFICATION
 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
 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
MIXED USE DEVELOPMENT – ANCHORAGE

  Why? Tenants want clean windows and existing system is

lacking documentation

  Documentation was load

testing during installation
＞  Anchorages for fall arrest
and work positioning
MIXED USE DEVELOPMENT – ANCHORAGE

  Owner wants to meet new regulation

＞  For records not lost
•  Straightforward, certification = documentation

＞  For records lost

•  More challenging with documentation lacking
–  Load testing

–  Other investigative effort required.

UPDATE POLICIES/PROGRAM
 POLICY/PROGRAM UPDATES

  Company policy   OSHA 1910 Subparts D&I

  ANSI Z359.1 standard

É
 ASSE CERTIFICATE PROGRAM

401- Fall Protection Certificate

Workshop: Feb. 6-8
  For more information:
＞ http://seminarfest.asse.org
 GAP ANALYSIS

Current State Desired State

 WHAT NEEDS TO CHANGE?

  Threshold   Safe distance to roof edge

 WHAT NEEDS TO CHANGE?

  Awareness training vs. authorized person training

 WHAT NEEDS TO CHANGE?

  Ladder safety systems rules: required

on fixed ladders greater than 24 feet

Jan 2017 Replaced or modified

Nov 2018 New ladders
Nov 2036 Retrofit
 WHAT NEEDS TO CHANGE?

  Anchorage certification

  ANSI Z359.6-2016
OTHER CASE STUDIES
For practical tips
 MEDIA – TRAINING CONTENT

  Why? Internal meeting discussing new reg and revising

training modules
  How? Gap analysis in conjunction with overall changes
  What metrics?
＞  Changes related to new OSHA regs
＞  Changes based on ANSI Z359 standards
＞  Content recommendations
＞  Length and delivery of training
 HOSPITALITY – PTD

  Why? Significant cost to rework new facilities

  How? Prevention through Design training

  What metrics?
＞  Documented lessons learned
＞  When incorporated during project life cycle?
＞  Documented changes with cost/benefits
 SCHOOL – REROOFING

  Why? Seminar to PMs

＞  “Certified” anchorage connectors vs. “certified” anchorage

  How? Paused – collaborated with maintenance team

  What metrics?
＞  Minimize use of PPE
＞  Use of new equipment for multiple buildings
 MANUFACTURING – TEMPORARY PPE

  Why? PPE installed wrong

＞  “Temporary” equipment permanently installed

  How? Survey of facility

  What metrics?
＞  Timeline
＞  Cost
＞  Document lessons learned
NEXT STEPS
 POLL QUESTION
Which topic(s) are most relevant for the next session?
 CALL TO ACTION

1.  Read Regulatory Text (pages 82981 to 83006)

2.  Determine what needs to be addressed and when

＞  Where do you have similar situations?
＞  What can you apply from case studies?
＞  Ask implementation questions

3.  Plan communication and training for staff

 CALL TO ACTION – PART 2

1.  Review existing training content (online or instructor lead)

2.  Assessment of facilities for all hazards

3.  Rework or create spec for new production lines and facilities

4.  Incorporate fall protection into re-roofing projects

5.  Address hazards identified during corporate audits

6.  Recertify existing fall protection anchorages (whether or not

for RDS)
 CALL TO ACTION – PART 2

7.  Educate designers on new regulations and include as PtD

8.  Inventory existing ladders and plan implementation

9.  Review and update your overall program after gathering

input from most, if not all, locations

10.  Take workshop for Managed Fall Protection Certificate

Program at ASSE’s SeminarFest
 ASSE CERTIFICATE PROGRAM

401- Fall Protection Certificate

Workshop: Feb. 6-8
  For more information:
＞ The home page: http://seminarfest.asse.org
 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
 POLL QUESTION
What are you doing next relative to the new regulation?
 PRACTICAL TIPS FOR
IMPLEMENTING NEW OSHA FALL
PROTECTION REGULATIONS
Occupational Health & Safety Magazine: Webinar

THOMAS KRAMER, PE, CSP – LJB INC

TKRAMER@LJBINC.COM + 1 (937) 259-5120