Thursday, August 25, 2011
Issues with the Draft Fall Protection Code
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:
Director of Training