Last week in our RRP training at Brockway Smith a student reported about his experience at a recent OSHA Fall Protection Awareness seminar in Andover, Ma held by OSHA. He said there were a lot of angry roofers and contractors at the seminar. Pete told me that many of the contractors present were instructed to be there by OSHA.

Not Fall Protection Training

Pete also said this was a 90 minute overview of the OSHA Fall Protection Directive for the Residential Construction Industry. It is part of OSHA's national campaign and outreach for fall protection awareness. It was not a comprehensive training for contractors. In contrast our OSHA Fall Protection Training for the Residential Construction is industry is a 6.5 hour workshop where we cover Subparts M, X and L in great detail. We certify those who come to our training which includes 3 CEU's. We also provide written plans and instruction on how to complete them.

Contractors Tempers Flare

According to Pete one heated exchange occurred when the OSHA representative said that carrying shingles up a ladder on to a roof was unsafe. Some contractors in the room said what should we do and the instructor said pull them up using a rope! Pete said a few contractors walked out of the room ticked off. It appears that these contractors were not aware of the OSHA Standard in Subpart X that describes this item.

In the OSHA standards there is a provision that references ascending and descending a ladder without heavy loads or large objects.

OSHA Standard Subpart X 1926.1053(b)(22)

An employee shall not carry any object or load that could cause the employee to lose balance and fall.

[55 FR 47689, Nov. 14, 1990; 56 FR 2585, Jan. 23, 1991; 56 FR 41794, Aug. 23, 1991]

This provision was questioned and answered by OSHA (letter of interpretation)

"Although OSHA believes that small items such as hammers, pliers, measuring tapes, nails, paint brushes, and similar items should be carried in pouches, holsters, or belt loops, the language in the final rule would not preclude an employee from carrying such items while climbing a ladder so long as the items don't impede the employee's ability to maintain full control while climbing or descending the ladder. It is OSHA's belief that the employee's focus and attention while climbing up and/or down a ladder should be on making a safe ascent or descent and not on transporting items up and down the ladder. OSHA notes that an employee who needs to take a large or heavy object to a different level by means of a ladder can pull the object up or lower it with a handline."

This letter of interpretation does not say how many pounds or how large the object must be before you use a handline. A bundle of shingles weighs 80 pounds. A sheet of plywood is 4' x 8'.   

Read the OSHA standard again "An employee shall not carry any object or load that could cause the employee to lose balance and fall."

It is the employer's responsibility to make sure an employee is not subject to carrying a load that could cause the loss of balance. Based on the letter of interpretation heavy objects need to be lifted to the roof by handlines. Another option is booming or using a laddervator.

What are your thoughts? Are you aware of the standard above?

Note; Seats available for Fall Protection Training on 5/16/2012 Howe Lumber

and 5/22/2012 at Brockway Smith. 5/31/2012 at Rings End Lumber in Connecticut and 6/8/2012 at National Lumber in Mansfield Mass.