The Occupational Safety and Health Administration (OSHA) has released new fall protection regulations that went into effect on June 16. ESA members should be prepared to follow these regulations if technicians routinely work from elevated positions.
Since 1995, OSHA has required workers engaged in residential construction who are working six feet or more above a lower level to be protected by conventional fall protection through the use of guardrail systems, safety net systems, or personal fall arrest systems.
OSHA has been allowing employers to implement alternative fall protection and work procedures if the employer felt the conventional fall protection measures were infeasible or presented a greater hazard. Employers were able to implement the alternative protections without a prior showing of infeasibility or greater hazard and without a written fall protection plan.
OSHA did not intend for this to become permanent policy and on December 16, 2010, adopted new rules, STD 03-11-002 Compliance Guidance for Residential Construction¸ that allow for the use of alternative fall protection measures for particular types of residential construction work if an employer can demonstrate that conventional fall protection is infeasible or presents a greater harm. Such alternative fall protection measures must be included in a written, site-specific fall protection plan meeting OSHA's fall protection regulation. A written plan developed for repeated use for a particular model or style of home is considered site-specific.
Since June 16, those employers engaged in residential construction need to follow 29 CFR 1926 Subpart M Fall Protection Regulations.
The use of fall protection plans is limited to "residential construction” in which the structure will be used as a home and constructed with traditional wood frame materials and methods.
Note – The limited use of structural steel in a predominantly wood-framed home does not disqualify a structure from being considered residential construction.
Because of the broad definition of residential construction, ESA members working in homes where technicians are required to work from an elevated position of six feet or more must comply with OSHA regulations governing fall protection.
Sample, compliant plans developed by OSHA for alternative fall protection can be viewed at: http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10927
For more information on residential safety standards, visit OSHA's Residential Construction Industry page at http://www.osha.gov/SLTC/residential/index.html#additional.