Issues with the Draft Fall Protection Code

Well, I’ve been told that I need to come up with a blog that might rattle some cages, here goes...but before, my apologies to my friends at DOSH. I do believe in their mission, but have heartburn with the draft fall protection code that is sitting in the wings.

Here are a couple of my issues.

First OSHA has exempted rolling stock from their definition of walking/working surfaces. - OSHA’s Definition - Walking/working surface means any surface, whether horizontal or vertical on which an employee walks or works, including, but not limited to, floors, roofs, ramps, bridges, runways, formwork and concrete reinforcing steel but not including ladders, vehicles, or trailers, on which employees must be located in order to perform their job duties.

Whereas, Washington State DOSH has not addressed vehicles, etc. in their draft rule. - DOSH’s Definition - Walking/working surface means any area including but not limited to floors, a roof surface, bridge, the ground, and any other surfaces whose dimensions are 45 inches or more in all directions, through which workers can pass or conduct work.

And since Washington triggers fall protection at 4 feet - The employer shall ensure that the appropriate fall protection system is provided, installed, and implemented according to the requirements in chapter 296-155 WAC, Part C-1 when employees are exposed to fall hazards of 4 feet or more to the ground or lower level when on a walking/working surface. I see an issue with an employee, say on a flat bed over 4 feet off the ground, and may have to be tied off or otherwise protected from falling. See how this can potentially be an issue for employers. Let’s have guard rails on equipment, yeah.

One other part of the draft regulation that may cause an issue for employers is work on steep sloped roofs (greater that a 4:12 pitch) because the new code will require fall protection on these steep slopped roofs at 4 feet:

Fall protection on steep-pitched and low-pitched roofs.
(a) Steep-pitched roofs. Regardless of the work activity, employers shall ensure that employees exposed to fall hazards of 4 feet or more while working on a roof with a pitch greater than 4:12 use one of the following:

(i) Fall restraint system. Safety monitors and warning line systems are prohibited on steep-pitched roofs;

(ii) Fall arrest system; or

(iii) Positioning device system.

I just thought I’d make you aware of what is coming down the pike. If you would like, you can read the entire draft fall protection code for yourself.

Stay safe

Eric C. Tofte

Director of Training

Office - 206-382-4090

Cell - 206-459-4843