What FMs Need to Know About New OSHA Regulations for Fall Protection

From rooftop maintenance to window washing to construction, glass replacement and wet sealing, exterior maintenance jobs at elevated heights come with increased safety concerns. That’s why there are regulatory requirements in place that building owners and facility managers need to follow.

However, some of these requirements have recently changed. To get some expert input on this topic, we turned to Christopher M. Everett, PE, of PENTA Engineering Group, Inc. He shared some key information on what these changes are, how they’ll impact your facility, and when they will take effect.

How Have OSHA Rules for Walking & Working Surfaces Changed?

According to the Occupational Safety and Health Administration (OSHA), falls from heights and working surfaces are one of the most common causes of work-related injuries and fatalities—accounting for an average of more than 200,000 serious injuries and 345 deaths each year in the United States.

To help prevent these hazards, OSHA issued a final rule to update general industry walking-working surfaces and fall protection standards. We asked Christopher to walk us through some of the most notable changes FMS need to be aware of. Here’s what he told us:

Rope Descent Systems

There several new regulations governing the use of rope descent systems (RDS) in 1910.27, so I would encourage everyone who operates a building that is accessed through the use of RDS to read the regulations. However, there are two primary areas of the regulation that will significantly impact the use of RDS:

  • 1910.27 (b) Rope Descent Systems-(1) Anchorages: This regulation clearly outlines the building’s responsibility to provide written documentation to their vendors indicting that their anchorage points have been load tested and inspected annually and are capable of supporting the OSHA required 5,000-pound load in any direction.
  • 1910.27 (b) (2) Use of Rope Descent Systems: This regulation prohibits the use of RDS at buildings in excess of 300 feet in height in most cases. It should be noted that it does allow for exceptions in cases where the use of other access means poses a greater hazard than the use of RDS, but this decision will need to be made by a qualified person on a case-by-case basis.

What you need to do to comply:

The two rules listed above will have a significant impact on both the users of this equipment as well as the owners and managers of buildings where RDS is used to during maintenance operations.

  • Buildings will either need to get anchors certified or have new anchors designed and installed
  • Buildings over 300 feet will likely be unable to use RDS and be forced to use other means (i.e., temporary or permanent suspended scaffolding) to access their buildings during maintenance operations
  • The requirements to provide written documentation of certified anchorage points must be implemented no later than November 20, 2017

Additional Rule Changes Facility Managers Should Be Aware Of

There are also several new rules not related to the use of RDS. These are rules that govern access to unprotected edges that create a fall hazard, as well as changes to the rules governing the use of permanent ladders. These rules will also have a significant impact on building owners and managers.

Fixed Ladders (Extending Greater than 24 feet Above Lower Level)

Existing Ladders

  • Each fixed ladder installed before November 19, 2018 must be equipped with a personal fall arrest system, ladder safety system, cage, or well

New Ladders

  • Each fixed ladder installed on and after November 19, 2018 must be equipped with a personal fall arrest system or ladder safety system

Work on Low-Slope Roofs

Less than 6 feet

  • When work is performed less than 6 feet from the roof edge, the employer must ensure that each employee is protected from falling by a guardrail system, safety net system, travel restraint system, or personal fall arrest system.

6 feet to 15 feet

  • The employer must ensure that each employee is protected from falling by one of the systems listed above.
  • The employer may also use a designated area when performing work that is both infrequent and temporary.

Greater than 15 feet

  • The employer must ensure employees are protected by one of the systems above—but the employer is not required to provide fall protection if the work is both infrequent and temporary.
  • The employer also must implement and enforce a working rule prohibiting employees from going within 15 feet of the roof edge without using fall protection.

Learn More About These New Regulations

Big thanks to Christopher Everett for providing us with this valuable information. It’s important to note that while this post highlights some of the key aspects of the new OSHA regulations, it doesn’t cover everything. So make sure you read all the regulations for yourself. You can find more information on the OSHA final rule here.

About PENTA Engineering Group, Inc.

PENTA is a multi-faceted engineering company that can address all of your facilities engineering, remedial design, as well as new construction needs. Learn more by visiting the PENTA website, or contacting Christopher Everett at (678) 282-1999 in the Atlanta office or Michael Bridgman at (615) 815-0260 in the Nashville office.