Q&A On Interpretations of Fall Protection for Steel Erection
When it comes to OSHA’s fall protection requirements in steel erection, the final word can be found in the code at 1926.760. But good luck deciphering all the jargon with references to appendixes and other regulations.
In fact our Safety Manuals are partly an interpretation of this dense legalese into a personalized policy, combined with best practices and explanations of the tricky parts with important charts and forms to help ensure compliance.
But in the application of these rules, there are situations that arise where OSHA has to explain how their regulations work in the real world. And since the latest version of this final rule was published on January 18, 2001, OSHA has issued several interpretations from private businesses asking questions about problems they have come across.
Following is a summary of these interpretations in a Question and Answer format:
Q. How far from the unprotected edge of a surface that is 15 ft. above the lower level does a worker need fall protection?
A. There is no safe distance from an unprotected edge that renders fall protection unnecessary.
Q. Is moving from one point to another on a concrete wall to make initial connections of structural steel considered connecting work?
A. Because a connector is defined as an employee who working with hoisting equipment is placing and connecting structural members and their parts, they are considered a connector and at heights up to 15 ft. do not have to need fall protection, and at heights of over 15 to 30 ft. must be provided with a Personal Fall Arrest System (PFAS) and wear equipment necessary to be tied off (or be provided with another means of fall protection), and at heights above 30 ft. be protected by fall protection.
Q. Can an employer require employees to use fall protection at less than 15 ft.?
A. An employer’s company policy can set stricter standards than the minimum requirements in OSHA, such as requiring employees to use a PFAS at 6 ft.
Q. Can employees install a curtain wall in a Controlled Decking Zone (CDZ)?
A. Only employees who are connectors – because they are installing metal decking – are allowed in a Controlled Decking Zone (CDZ) and are exempt from the general steel erection fall protection threshold of 15 ft. high in favor of the connector threshold of 30 ft. or two stories.
Because installing a curtain wall doesn’t meet the metal decking definition, those employees are not allowed in the CDZ and must have fall protection at 15 ft.
Q. Can a guardrail system be used instead of a safety cable to meet the requirement for a perimeter safety cable?
A. OSHA regulations state that perimeter safety cables must be installed at the final interior and exterior perimeters of floors on multi-story structures as soon as the metal decking is installed. OSHA believes this system has several advantages, but other guardrail systems, such as wooden guardrails suffice as long as the following conditions are met:
- Workers installing the system are protected from falls
- System meets guardrail requirements
- It is durable to the conditions, such as weather and other steel erection work
- It doesn’t create a greater hazard during initial steel erection.
Q. Do perimeter columns have to extend beyond the roof level when the building has topped out, to meet the requirement of extending at least 48 inches above the finished floor?
A. The requirement to extend 48 inches above the finished floor is to permit installation of perimeter safety cables prior to erecting the next tier, so when the final tier is erected that requirement doesn’t exist because it applies to floors and not roofs. Still fall protection is required on the roof level at fall over 15 ft.
Q. Why is the steel erection fall protection threshold 15 ft. where the general construction threshold 6 ft.?
A. The special circumstances of steel erection can make conventional fall protection very difficult to deploy below 15 ft. The work usually starts at the top level, meaning anchor points above foot level are often limited or unavailable, and because of the nature of the structure, the available fall arrest distance is usually 15 ft.
Q. Is a CDZ control line a rigid structure? What can constitute a control line?
A. Control lines, that define the CDZ, are intended mainly as a visual warning. They can consist of ropes, wires, tapes or equivalent materials and must be rigged so it doesn’t sag less than 39 inches (1 m) from the floor and isn’t any higher than 45 inches from the floor. A non-mandatory Appendix advises that the material have a minimum breaking strength of 200 pounds, but this is to ensure it can withstand the conditions and not for direct physical contact like a warning line, which is erected 15 ft. from an edge and must have a minimum strength of 500 pounds.
Control lines may be cables, ropes, wires or tapes such as plastic tape. They do not have to be a horizontal cable, but can be a perimeter wall, guardrail system, or even a restraint system rigged so non-leading edge workers can’t access the area.
OSHA has interpreted the rule to say that high-visibility construction cones are not control lines because the gaps between the cones do not control access.
Q. Can an entire floor be designated a CDZ by limiting access to the entire floor, eliminating the need to mark the perimeter of the entire floor with control lines?
A. The regulation states a CDZ must have clearly marked boundaries and be 90 ft. by 90 ft. or less to ensure non connectors do not ignore the CDZ to do non-decking work. But because limiting access to an entire floor by controlling access points with a sign restricting access to CDZ workers and installing conventional fall protection as soon as each 90 ft. x 90 ft. section is completed, designating the entire floor a CDZ would be considered a de minimis violation (having no direct or immediate relationship to safety or health) because it would be a more effective way to decrease the likelihood other workers will enter the CDZ than limiting the size of the CDZ.
What Regulation Do You Find Confusing?
Practically every OSHA Regulation has a series of interpretations that at least one person needed clarification on. If there is a regulation that you want me to look at their interpretations, please leave a comment and check this space on a regular basis.
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