osha - region iv. osha’s mission to assure so far as possible every working man and woman in the...

OSHA - Region IV

OSHA - Region IV

OSHA’s Mission

• To Assure So Far as Possible Every Working Man and Woman in the Nation Safe and Healthful Working Conditions...

OSHA - Region IV

Hierarchy of Fall Protection

• The less human effort for fall protection, the more effective the fall protection

EFFECTIVENESSMost Effective

Least Effective

HUMAN EFFORTLeast Effort

Most Effort

EliminateEngineered

WarningTraining

PPE

OSHA - Region IV

Fall Protection - General Requirements

• Where workers on a construction site are exposed to vertical drops of 6 feet or more, OSHA requires that employers provide conventional fall protection in one of three ways before work begins: – Placing guardrails around the hazard area– Deploying safety nets– Providing personal fall arrest systems for each

employee

OSHA - Region IV

Alternative Procedures

• Directive STD 3-0.1A - Plain Language Revision of OSHA Instruction STD 3.1, “Interim Fall Protection Compliance Guidelines for Residential Construction”

• Permits employers engaged in certain residential construction activities to use alternative procedures routinely instead of conventional fall protection

OSHA - Region IV

Residential

• Must be engaged in residential construction and performing one of listed activities

• Not Exempted!– Still obligated to comply with other OSHA

standards and conventional fall protection if alternative procedures are not used

unsafe practice

OSHA - Region IV

Residential Construction• Working environment, materials, methods and

procedures are essentially same as single-family homes or townhouses

• Characterized by: – Materials: wood framing (not

steel or concrete); Wooden floor joists and roof structures

– Methods: traditional wood frame construction techniques

• Discrete part of a large commercial building

OSHA - Region IV

Listed Activities• GROUP 1 - floor joists, floor sheathing, and roof sheathing;

erecting exterior walls; setting & bracing roof trusses and rafters

• GROUP 2 - concrete and block foundation walls and related formwork.

• GROUP 3 - when performed in attics and on roofs: installing drywall, insulation, HVAC systems, electrical systems (including alarms, telephone lines, and cable TV), plumbing and carpentry

• GROUP 4 - Roofing work - removal, repair, or installation of weatherproofing roofing materials such as shingles, tile and tar paper

OSHA - Region IV

STD 3-0.1A

• Do not need to show conventional fall protection is infeasible

• Fall protection plan is still required, but– does not have to be written

– not specific to the jobsite

• Each activity has its own set of alternative procedures Writt

en Plan

Not Required

OSHA - Region IV

GROUP 1- Alternative Procedures

• Fall protection plan found in Appendix E of Subpart M

• Height limitation – Structures up to 3 1/2 stories or 48

feet (including basement, two finished levels, attic)

– Measured from the base of the building, at the lowest ground level (including any excavation), to the point of greatest height

• Plan communicated to all employees on site subject to fall hazards

floor joists, floor sheathing, and roof sheathing; erecting exterior walls; setting and bracing roof trusses and rafters

OSHA - Region IV


• Employee training coverage of the Fall Protection Plan must include:

- Requirements of the plan- Understand procedures and follow instructions of

supervisor or foreman- Able to recognize unsafe/hazardous conditions and report

them to the employer

- Recognize when compliance with the Plan would create a greater hazard and inform the Competent Person before proceeding

• Concerns raised by employees must be addressed


OSHA - Region IV

• Employer must designate:– Competent Person– Qualified Person

– Crew Supervisor or Foreman

• Supervisor and/or foreman can be the competent and qualified person

GROUP 1- Alternative Proceduresfloor joists, floor sheathing, and roof sheathing; erecting exterior walls; setting and bracing roof trusses and rafters

OSHA - Region IV


• "Competent person" means one who is capable of identifying existing and predictable hazards in the surroundings or working conditions which are unsanitary, hazardous, or dangerous to employees, and who has authorization to take prompt corrective measures to eliminate them. Ref.1926.32(f)


OSHA - Region IV


• Competent person will:– be charged with implementing the plan– continually monitor

compliance with the plan including:• provision of training • the proper use of

controlled access zones


OSHA - Region IV


• "Qualified" person means one who, by possession of a recognized degree, certificate, or professional standing, or who by extensive knowledge, training, and experience, has successfully demonstrated his ability to solve or resolve problems relating to the subject matter, the work, or the project. Ref. 1926.32(m)

• Person is designated• Reviews & approves any changes to the plan


OSHA - Region IV


• Designated crew supervisor or foreman – responsible for the immediate correction of any

unsafe practice or condition


Unstable footing, scaffold re-erected with proper mud sill placement

OSHA - Region IV


• Controlled access zone (CAZ) - restricts access to a clearly designated area where a Group 1 activity is taking place

• The CAZ must meet the following requirements:• Boundaries - clearly marked eg.

signs, wires, tapes, ropes or chains• Crew supervisor/foreman monitors• Restricted access to authorized (trained) entrants• Final check - before work begins, the competent person

must ensure that all protective measures in the plan have been implemented


unsafe condition

OSHA - Region IV


• Plan Administration– Employer Enforcement

• Crew supervisor/foreman, Safety and Personnel department have the right to issue disciplinary warnings

• Unsafe practices or conditions must be corrected immediately


unsafe practice

OSHA - Region IV


• Plan Administration– Plan Changes/Review To The Plan

• Qualified person approves changes to Plan• Review Plan as the job progresses to determine the

need for additional practices, procedures or training• Retrain employees on any new procedures

– Accident Investigation• All accidents reported and investigated• Investigation documented• Review Plan in event of falls or other serious incidents


OSHA - Region IV


Installing Roof Trusses and Erecting RaftersAdditional Requirements• Walls Up To 8 Feet

– Use interior scaffolds, below the area where the trusses/rafters will be located

– Sawhorse scaffolds acceptable• Walls Over 8 Feet

– Falling Objects - restricted access during truss installation– Brace trusses before being used as a support– Designate the trained workers for top plate and peak work– Top plate workers have no other duties during truss erection


OSHA - Region IV


Working on top plate - Additional Requirements – First two trusses set from supported ladders– Once set, worker will climb ladder onto the

interior top plate to secure peaks

– Use previously stabilized trusses as support while other trusses/rafters are erected


OSHA - Region IV


Working at peak- Additional Requirements – While detaching trusses from cranes or securing trusses at

the peaks, worker may:• be positioned at the peak of the trusses/rafters• be stationed on the top of the ridge beam when it is the only feasible

way to secure rafters to the ridge beam

– Workers at the peak, in the web of trusses, or on top of the ridge beam must work from a stable position

• sit on a ridge seat (or the equivalent) or• position themselves in previously stabilized trusses/rafters, and lean

into and reach through the trusses/rafters

– Do not remain on or in the peak/ridge any longer than necessary


OSHA - Region IV


Roof Sheathing Operations -

Additional Requirements – Competent person must

determine when the roof system is stable enough to support conventional fall protection system anchorage

– Once roof system is stable enough for anchorage, personal fall arrest systems must be used


OSHA - Region IV


Roof Sheathing Operations - Additional Requirements – Provisions that can be apply until the roof

system is stable:


Qualified Workers Staging of Materials

Secure Footing/Weather Slide Guards

Falling Objects/Restricted Access

OSHA - Region IV


Roof Sheathing Operations - Additional Requirements • Only qualified workers• Secure Footing/Weather

– remove slip hazards– suspend roof sheathing

when wet– suspend roof sheathing

when winds > 40 mph• Stage materials for quick

access• Falling Objects - restricted access during sheathing

installation• Provide 4 inch slide guards


unsafe practice

Slide guard requirements for roof sheathing are different from those for roof work

(Group 4 Activity)

Roof Type Slide Guard Intervals

All roofs with pitch

On bottom row of roof sheathing install guard the full length of roof

Up to and including 9 in 12

13 foot intervals

Over 9 in 12

4 foot intervals

OSHA - Region IV

Installation of Floor Joists and Floor SheathingAdditional Requirements

– Designate trained workers– Stage materials for quick

access – Restricted access of

those not assisting - do not permit within 6 feet from the leading edge


unsafe condition

OSHA - Region IV


Installation Process of Floor Joists - Additional Requirements

– First floor joist or truss rolled into position and secured by workers on the ground, ladders, or sawhorse scaffolds

– Successive joists/trusses must be rolled into place and secured from platform

– Platform is built by laying a sheet of plywood over thepreviously secured floor joists or trusses


unsafe practice

OSHA - Region IV


Installation Process of Floor Sheathing Additional Requirements • First row of floor sheathing installed by workers

on the ground, ladders, or sawhorse scaffolds• After the first row of sheathing has been

installed, workers shall work from the established deck unsafe practice

OSHA - Region IV


Erection of Exterior Walls- Additional Requirements – Designate trained workers– Stage materials for quick access – Limit fall hazard exposure by cutting material away

from edge of deck– Paint warning line 6 feet

from the perimeter before any wall erection activities and provide monitor for those working near the unprotected edge


unsafe practice

OSHA - Region IV


• Procedures for protecting employees working at the top surface of block foundation walls, concrete foundation walls and related form work

concrete and block foundation walls and related formwork

unsafe practice

OSHA - Region IV


• Only trained workers allowed to work on the top of the foundation wall/form work, and only as necessary to complete the construction of the wall

• All formwork shall be adequately supportedbefore any worker may work on top of the form work


unsafe practice

OSHA - Region IV


• When adverse weather creates a hazardous condition, operations shall be suspended

• Impalement hazards shall be cleared from the area below workers or shall be properly guarded

• Stage materials for quick access


OSHA - Region IV


• Procedures for activities when performed in attics and on roofs: installing drywall, insulation, HVAC systems, electrical systems (including alarms, telephone lines, and Cable TV), plumbing and carpentry

activities when performed in attics and on roofsdrywall, insulation, HVAC systems, electricalsystems, plumbing and carpentry

OSHA - Region IV


• Only trained workers allowed to work in attics and roofs, and only as necessary to complete system being installed

• Stage materials for quick access• Impalement hazards shall be kept out of

the area below workers or shall be properly guarded

• Restrict access to areas below openings in ceilings to reduce falling object hazards

• When adverse weather creates a hazardous condition, operations shall be suspended

activities when performed in attics and on roofsdrywall, insulation, HVAC systems, electricalsystems, plumbing and carpentry

OSHA - Region IV


• Procedures for activities in roofing work (removal, repair, or installation of weatherproofing roofing materials such as shingles, tile and tar paper)

roofing work (removal, repair, or installation of weatherproofingroofing materials such as shingles, tile and tar paper

unsafe practice

OSHA - Region IV


• Roofs with eave height over 25 feet –Any Slope–Any Roof Type–Alternatives to the Requirements of

the Standards are not Available


unsafe practice

OSHA - Region IV


• General requirements:– Only workers trained to be proficient in the

alternative methods of fall protection shall be allowed onto the roof

– Affected employees shall be trained in specific awareness of fall hazards associated with work on roofs with rake edges

– Inspect for and eliminate any slipping hazards or take effective measures to have workers avoid slipping hazards

– Workers must wear appropriate footwear


OSHA - Region IV


• General requirements: – When adverse weather creates a

hazardous condition, operations shall be suspended

– Repair any roof deck damage

– Cover or guard any holes, including skylight openings


unsafe practice

OSHA - Region IV


• General requirements: – Erect and maintain ladders or scaffolds in

accordance to Subparts X and L – Trained employees in accordance with the

requirements of Subparts X & L– Do not ascend or descend

the roof's slope within 6 ft of the rake edge except where limitation would prevent work process


unsafe practice

OSHA - Region IV


• General requirements: – Do not store supplies and materials

within 6 feet of the rake edge or three feet where tile roof systems are being installed

– Keep area below eaves and rakes clear of impalement hazards or properly guard hazards


OSHA - Region IV


• For Roofs With Eave Height of up to 25 Feet

– Roof Slope (Any Roof Type): Up to 4 in 12

• Use either safety monitoring system that complies with 1926.502 or roofing slide guards

– Roof Slope (Except Tile or Metal Roofs): Over 4 in 12 and up to 8 in 12:

• Slide guards are required

• Tile or Metal Roofs - safety monitoring system may be used instead of slide guards

– Roof Slope over 8 in 12 - Alternatives not available


OSHA - Region IV


• Slide Guards:– Roof Slope: 6 in 12 or less

• Constructed of 2"x 6" (nominal) stock• No more than three rows of roofing material

(installed across the lower eave) shall be applied before installing the slide guards

• Roof jacks (or similar supports) shall be installed using nails long enough to withstand an employee sliding into the guard

• Face of the slide guard must be perpendicular to the surface of the roof

• Continuous slide guards along the eave


OSHA - Region IV


• Slide Guards:– Roof Slope: Over 6 in 12 (up to and

including 8 in 12):• Constructed of 2"x 6" (nominal) stock • Continuous slide guards shall be installed along

the eave• Install additional slide guards below each work

area at intervals not to exceed eight feet • Slide guards at the eave must be at about 90

degrees to the roof surface• Additional slide guards need not be continuous

or at 90 degrees to the roof surface


OSHA - Region IV

INTERIM FALL PROTECTION COMPLIANCE

GUILDELINE FOR RESIDENTIAL ROOFING WORK SLOPE EAVE TO

LOWER LEVEL FALL

DISTANCE

MINIMUM /REQUIREMENTS COMMENTS

4 in 12 or LESS

25 FEET or LESS

Can use safety monitoring system or roofing slide guards

MUST COMPLY WITH 1926.502(h) NOTE: See specific reqt’s. for roofing slide guards which depend on roof slope (next 2 categories)

6 in 12 or LESS

With

SLIDE GUARDS

25 FEET or LESS

Slide guards with roof jacks or equiv. Supports with min. 2"x 6" (nom.) Planks

Slide guards shall be installed continuously along the eave. Angle of guard shall be 90 deg. to roof

More than

6 in 12

up to & including

8 in 12

25 feet or less Slide guards with roof jacks or equiv. Supports with min. 2"x 6" (nom.) Planks

Continuous eave slide guards shall be installed plus slide guards shall be placed below work areas every 8 feet maximum (90 deg 10 deg)

Prepared by Parsippany A.O., 3/1/96

Slide guard requirements for roofing are different from those for roof sheathing (Group 1 Activity)

OSHA - Region IV

INTERIM FALL PROTECTION COMPLIANCE

GUILDELINE FOR RESIDENTIAL ROOFING WORK

SLOPE EAVE TO LOWER LEVEL

FALL DISTANCE

MINIMUM /REQUIREMENTS COMMENTS

8 in 12 or LESS

(TILE & METAL

ROOFS ONLY)

25 FEET or LESS

Can use safety monitoring system

May use safety monitoring system alone but, must comply with 1926.502(h)

Greater than

8 in 12

All roofs (over 6 feet)

Conventional fall protection shall be used. Ie: safety nets, guardrails or personal fall arrest systems

Must comply with 1926.502(d), 1926.502(c) or 1926.502(b)

Greater than

4 in 12

Greater than 25 feet

Conventional fall protection shall be used. Ie: safety nets, guardrails or personal fall arrest systems

Must comply with 1926.502(d), 1926.502(c) or 1926.502(b)

Prepared by Parsippany A.O., 3/1/96

Slide guard requirements for roofing are different from those for roof sheathing (Group 1 Activity)

OSHA - Region IV

CITATION POLICY

• The compliance officer must determine if STD 3-0.1A provides alternative procedures for the activity in question

• If there is a deficiency in the implementation of the alternative procedures

• Violation of 1926.501(b)(13) – duty to have fall protection –residential

• Possible violation of 1926.20 – construction, general safety and health program

• Other standards as applicable: scaffold, ladder, tools, electrical, PPE, etc.

OSHA - Region IV

QUESTIONS?

Please visit the OSHAwebsite at

www.osha.govor

call your local OSHA office

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