construction business owner education and peer group program click to learn more

The Contractor Coaching Partnership Blog

Contractor; OSHA extends fall protection directive enforcement date

Posted by Mark Paskell on Sat, Jun 11, 2011 @ 09:28 AM

OSHA has announced that they will extend the 6/16/2011 date for Fall Protection Compliance until 9/15/2011. The new fall protection directive requires that contractors use fall arrest systems, nets and/or guard rails when working 6 feet above lower levels. If using these measures is infeasible the contractor must have written site specific plan in place on site. Contractors are required to have a written fall protection plan in place for fall hazards. (Note; OSHA assumes that contractors also have a Environmental Health and Safety (EHS) Manual in place)

No one told me..........

I am told by contractors that they never heard of this new directive until they were informed by The Contractor Coaching Partnership. This week we trained 30 contractors on the new Fall Protection Directive all who were looking to get their companies into compliance by 6/16/2011. 

                                             OSHA

The announcement explains that OSHA will give contractors more time to comply with a 3 month phased in extension. One contractor said OSHA is just like the EPA in releasing information to the residential construction industry. The contractor said they should be sending out information through the state licensing boards, building inspectors and lumberyards. We suspect that OSHA realized their outreach to the industry was not effective and therefore extended the date. 

CONTRACTOR ALERT; YOU MUST FOLLOW THE OLD DIRECTIVE (STD-03-00-001) DURING THE PHASE-IN PERIOD.

In other words you are required to have fall protection measures in place under the former standard. If you do you will likely avoid fines and penalties when visited by an OSHA compliance officer. If you do not then you can be cited.

Speaking to our OSHA instructor he says that if you are not using fall protection measures in line with the old standard this 3 month phase in period will not protect you. Our instructor went on to say that the majority of residential contractors are currently not up to speed with OSHA. He said the residential construction industry has been under the radar for many years with no attention from OSHA enforcement officers. That has now changed because OSHA made us a targeted industry last year. Our OSHA instructor said all companies with one or more employees are also required to have a EHS Manual customized to their business and hazards. 

In our fall protection classes this week 5 students said OSHA has visited them recently. (more on what for in a separate post)

Here is an excerpt from the article on the OSHA extension.............

The three month phase-in period runs June 16 - September 15, 2011. During this time, if the employer is in full compliance with the old directive (STD 03-00-001), OSHA will not issue citations, but will instead issue a hazard alert letter informing the employer of the feasible methods they can use to comply with OSHA's fall protection standard or implement a written fall protection plan. [If the employer's practices do not meet the requirements set in the old directive, OSHA will issue appropriate citations.]

The last statement is OSHA's nice way of saying if you did not get around to implementing fall protection standards from the old standard and you are caught, you will be fined.

We trained over 4500 contractors in the past year on RRP and most have told us they have no OSHA plans in place. The residential contractor now has several significant regulations and programs to implement into their business;

1. EPA RRP Lead Rule; become a Certified Firm and Certified Renovator

2. OSHA Lead in Construction; medical monitoring and respiratory standards

3. OSHA Fall Protection

4. OSHA EHS Manuals customized to their business.

Please let us know your thoughts......

mark the coach

"one voice for the residential construction industry"

Tags: osha fall protection