OSHA's Construction Industry temporary enforcement measures in residential construction ends on 3/15/2013. This was the fourth extension granted by OSHA since the new Fall Protection Directive went into effect on December 16th, 2010.
OSHA has given the industry over two years to get up to speed on the new fall protection requirements. OSHA has provided a lot of outreach and education on the subject.
Here we list an excerpt from OSHA on what they have done to help with education.
"OSHA has been working closely with the industry to assist employers in complying with the new directive. From Oct. 1, 2011 to Sept. 30, 2012, OSHA's On-site Consultation Projects performed more than 3,000 on-site visits, conducted close to 1,100 training sessions and delivered close to 500 presentations related to fall protection in residential construction. OSHA's regional and area offices also conducted more than 1,200 outreach activities on the directive."
It looks like we are now at the end of the outreach cycle and OSHA is expecting after two years of outreach that the residential contractors will now work with the new fall protection requirements.
Here is a recent picture of a crew working in Spencer, Massachusetts with no fall protection. They are waiting for more materials. What do you think of the flag with the crew looking on in the backdrop?
In this picture we have materials being unloaded without fall protection on the same Spencer, Massachusetts roofing project. Notice how the ladder is set on the gable end. This is a very common OSHA violation.
Some requirements for fall protection compliance:
- Employers must provide fall protection for their workers who are exposed to fall hazards 6 or more feet above a lower level.
- Employers are to use safety nets, guard rails or fall protection systems.
- Employers must have a training program and provide training to all workers prior to exposing the worker to a fall hazard.
- Employers must document the training for each worker.
- Employers need to have a written plan.
There have been a lot of injuries and deaths from fall in the past year especially in Region 1, New England. Just before my last class in Connecticut a man was killed while working on a new home site in Milford, CT.
Many contractors have come to our fall protection training because they were caught working without fall protection. For example in my last training at Ring's Ends Lumber in Stratford, Connecticut one contractor told the class he was fined for over $28,000 for violations. He ended up settleing at $12,000.00. Two items he was fined for: ladder not set 3 feet above the roof edge and not having a training program.
We predict as soon as spring hits OSHA will continue to focus their attention on the residential construction industry. Especially in New England states of Massachusetts, Connecticut, New Hampshire and Rhode Island.