Dale Hamil
Technical Education Committee Member
Illinois Electric Works
The U.S. Occupational Safety and Hazard Administration (OSHA) recently released revised data for the top 10 OSHA violations for the 2019 fiscal year. For the ninth consecutive year, Standard Number 1926.501: General Requirements for Fall Protection lands at number one with 7,014 violations.
The OSHA fall protection standard seems relatively straightforward. OSHA requires that fall protection be provided for employees working at elevations of four feet in general industry workplaces, five feet in shipyards, six feet in the construction industry and eight feet in longshoring operations. EASA service centers fall into the “four-foot” category. There seems to be no logic associated with why a longshoreman can fall eight feet and a motor repairman can fall four feet.
When describing fall protection, most people think only of fall arrest; however, there are four generally accepted categories of fall protection: fall elimination, fall prevention, fall arrest and administrative controls.
- Fall elimination is simply moving or positioning the work to a height of less than four feet.
- Fall prevention is where guarding or personal restraint prevents approaching an unprotected edge.
- Fall arrest is a system that stops a person’s fall mid-flight. This system includes various lanyards, harnesses and personal protective equipment. Keep in mind that just wearing the harness is not enough. There also must be a rescue plan to retrieve the person in less than 20 minutes.
- Administrative controls might include such things as a full-time monitor to prevent persons from approaching an unprotected edge and should be used along with other measures.
Let’s explore fall protection scenarios we might encounter in an EASA service center. With very large electric motors, there are occasions where a mechanic may be working from a ladder or platform four feet or higher over the floor level. While there is no problem there, a violation could occur if the employee leaves the relative safety of the ladder or platform and works on top of the motor itself without fall arrest.
Loading a truck becomes problematic. Rigging a load on a truck flatbed, which is typically fewer than four feet fall distance, is not a fall protection violation. This instance can become an OSHA violation quickly if the employee is on a ladder, even a short one.
It is also a violation if there is a mezzanine, a platform or a stairway with an unprotected edge in your facility, allowing a drop of four feet or more.
If someone removes a vertical turbine pump or motor, there may be an opening left behind that has to be covered. Merely placing a substantial plywood sheet over the hole marked with a sign indicating “hole” with spray paint is enough. This sign does not have to be a work of art. Mark any unguarded trap door or opening to another level similarly.
Working on the roof for routine maintenance requires a fall restraint to prevent the worker from approaching the edge.
Working at heights on a motorized scissor lift is typically acceptable; however, working in a bucket lift or articulating manlift boom lifts requires fall arrest.
Avoid violating this standard. While receiving the violation from OSHA is decidedly awful, an employee injury is far worse.
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