According to OSHA falls accounted for 259 out of 738 total deaths in construction for CY 2011. 1992 through 2005, fatal falls in construction have only increased, even though in 1995, OSHA provided interim fall protection guidelines for residential construction that allowed contractors to develop non-conventional methods to protect workers from falls.
Given that the construction season is in full swing, the new residential fall protection requirements announced December 16, 2010 which replace the Interim Fall Protection Compliance Guidelines for Residential Construction are being enforced as of March 15, 2013.
Under the requirements, workers engaged in residential construction six feet or more above lower levels are to be protected by “conventional fall protection methods”, such as restraint systems, guardrails, safety nets, personal fall arrest systems (PFAs), or scaffolds. Fall plans and slide guards (roof brackets) are not considered conventional methods.
The delay between the announcement and enforcement has provided time for employers to conduct training and adopt the new standards.
In order to use unconventional fall protection methods builders must show that OSHA’s standard methods are infeasible or would create a greater hazard than unconventional methods. When this is the case, the burden of proof falls to the employer who then must provide a written explanation of why the conventional fall protection systems are infeasible or pose a greater hazard. This must be outlined in a site-specific fall protection plan.
The following are links to the Residential Construction Fall Protection standards and OSHA Q&A:
- OSHA Q&A for Residential Construction Fall Protection
- Residential Construction Fall Protection Standards
- OSHA Guidance Document on Residential Construction
The bottom line is, unless they can be proved to be infeasible, (Infeasible - impossible to perform the work while using a conventional fall protection system, or that it is technologically impossible to use a conventional system), conventional methods must be used when the worker is or can reasonably be expected to be exposed to a fall hazard of 6ft or more.