OSHA/MIOSHA New 2011 Fall Protection Requirements

New 2011 Fall Protection Requirements

Are you in compliance with the new Fall Protection safety requirements of OSHA and MIOSHA?  If not, get your safety program in place now with fall protection procedures, plans and training.  Why?...because on June 16, 2011 all non-exempt workers above 6’ must be protected with conventional fall protection.  This applies to residential electricians, carpenters, plumbers, roofers and all construction trades.  And it means using guardrail systems, safety net arrest systems, personal fall arrest [or restraint] systems, or other conventional Fall Protection. 

In an April 4, 2011 memo, MIOSHA stated that “The number one cause of death and serious injury at residential construction sites is falls by employees working above the ground on roofs, ladders and scaffolding…."We know that most fatalities and serious accidents can be prevented when employers follow the rules and apply effective worker safeguards on every jobsite where hazards are present," said MIOSHA Director Doug Kalinowski. "We are working diligently to share information with employers and workers before these changes go into effect… Falls accounted for nearly one-third of the construction workplace fatalities investigated by the MIOSHA Construction Safety and Health Division over the past five years. The third most frequently cited violation was Rule 1926.501(b)(13) - Employees engaged in residential construction activities were not protected from falling 6 feet or more..."  

Is there any alternative?  Yes, but it is very rarely available, and it requires a lot of work.  To avoid using conventional Fall Protection, an employer must demonstrate in writing that all conventional methods are infeasible and use a written Fall Protection Plan specific to each job.  This may mean showing that each and every conventional method (including scissors lifts, ladders, scaffolds and every available product and technology) is infeasible or creates a greater hazard.  Then the employer must write, implement, train, supervise and revise a site-specific Fall Protection Plan in compliance with CFR1926.502(k); see Appendix A of MIOSHA CSS Part 45.  

Contact Terry Welsh of ASHA for training, written programs and procedures, consulting on and off site and ongoing safety and health management support.  Call Terry Welsh directly at 517 927-3177 or e-mail twelsh@ashasfety.com. Visit ASHA Safety, Inc. for more information.