I thought it might be helpful to outline the basic steps contractors need to take towards complying with OSHA Fall Protection protocol.
Like the previous three years, this year the number one citation is failure to have fall protection. Recent conversations with OSHA lead me to conclude that next year will be even busier. The lack of OSHA fall protection compliance permeates all sectors of the residential construction industry.
Fall Protection Training at Rings End in Stratford, Connecticut.
Here are the primary steps to take to become compliant with OSHA Fall Protection requirements. The person to do this needs to be a competent person. As the owner of the business it is your responsibility to ensure that your workers have a safe and healthy workplace.
- Read and learn OSHA Standards Subpart M, Subpart L, Subpart X. (Use the link for each and scroll through each section; Subpart M 1926.500-503, Scaffolds 1926.450-454, Ladders 1926.1050-1053)
- Determine how each standard applies to the hazards that your employees are exposed to. This is done by doing a Job Hazard Analysis (JHA) prior to starting your projects.
- Determine how you will protect your workers either by removing the hazards (Engineered Controls) or providing personal protective equipment such as a fall arrest system.
- Armed with the knowledge of reading the standards, determining the hazards and identifying the personal protective equipment you will use to protect your employees; write a fall protection plan including the requirements in each standard.
- Then a competent person must train your employees on the standards.
- After the training by a competent person have them read the written plan and have them sign it.
- After the training is completed, the competent person must certify their training by creating a Certificate of Completion.
- You must document the training and keep a record.
- Create and implement a safety meeting program. Require safety meetings or tool box talks on a frequent basis. Remember to document each meeting having each employee sign a sign in sheet.
- Write and institute an employee discipline policy and have each employee sign it. (Best practice is the three strikes and you are out policy)
- Physically observe your employees while they are working to make sure they are using the practices learned in the training and documented in your written plan. The training you provide for your employees must be effective. (OSHA says effective means the training shows up in practice in the field.)
- Remove any employees observed not working safe and retrain them before allowing them to be reinstated on the job. Make sure you document each occurrence.
Before you hire sub-contractors to work on your jobs this is the best practice;
(Note; Subs to be extra careful with are roofers, framers, painters, siding and gutter installers and trades that will be up on elevated surfaces. They pose a risk for an OSHA audit on your site if they are found working without fall protection measures)
Require that ALL sub-contractors provide you with proof that they are compliant with fall protection prior to allowing them to work on your job site. Use a subcontract agreement requiring compliance with your job safety procedures. Require them to provide to you a copy of their safety manual or written fall protection plan. Also require a copy of the certification of training for each sub worker that will work on your job site. NOTE: Do not personally train your sub-contractors as it will increase your liability in the event they are hurt on your job site.
Also frequently check in on your employees and subs to make sure they are working safe. The random site inspection is a great strategy to use. Let them know that you may stop by at any time on any given day.
Allowing unsafe contractors to work on your site can lead to OSHA job site audits that can lead to you the General Contractor getting fined.
Doing the above shows your commitment to safety, helps prevent injuries and deaths on your job sites and can help prevent unplanned OSHA audits, citations and fines.
If you feel uncomfortable dealing with these requirements yourself and want help on how to do the above feel free to contact me for advice and/or trainings.