Category Archives: Fall Protection

All Skylights Require Fall Protection

The OSHA letter of interpretation regarding Skylights confirms that fall protection is required.

“29 CFR 1910.21(a)(1) … defines floor opening as: ‘An opening measuring 12 inches or more in its least dimension, in any floor, platform, pavement, or yard through which persons may fall, such as a hatchway, stair or ladder opening, pit, or large manhole.’

A definition given in Webster’s New Collegiate Dictionary (1977 edition) for ‘hatch’ is ‘an opening in the … floor or roof of a building’; the same entry gives ‘hatchway’ as a synonym.

Using these definitions, therefore, OSHA concludes that a skylight should be regarded as a hatchway, i.e., an opening in the roof of a building through which persons may fall. 29 CFR 1910.23(a)(4), therefore, requires that skylights in the roof of buildings through which persons may fall while walking or working shall be guarded by a standard skylight screen or a fixed standard railing on all exposed sides.

When a skylight screen is selected for safeguarding the opening, and in the event the skylight is constructed of plastic material subject to fracture (as glass would be), then the skylight must at a minimum be provided with a skylight screen capable of withstanding a load of at least 200 pounds applied perpendicularly at any one area on the screen.

On the other hand, a plastic skylight which can provide the necessary structural integrity to support the 200-pound load would not be required to be further safeguarded, since it would meet the intended function of a screen as well.

As expressed in 29 CFR 1910.23(e)(8), the primary function of the screen is to support at least a 200-pound load such as a person may place upon it. This provision further relates that the screen shall provide a minimum deflection so as not to break the glass; but that portion of the requirement may be inapplicable when no glass is present. (The concern for breaking the glass results from the possible fragment exposure to persons beneath the skylight.)”

Look for more OSHA letter of interpretation at:
http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=INTERPRETATIONS&p_id=19180

About CSG Safety Services Group, LLC: CSG Safety Services Group, LLC designs and installs window washing systems nationwide. CSG provides inspections, testing and certifications for all window cleaning equipment. CSG provides consulting up to full design/build services. The CSG Safety Services Group promotes window washing system solutions with safety, usability, and cost effectiveness in mind. www.windowwashingsystems.com.

Required Safety Measures for Building Owners

As OSHA shifts focus to enforcement, building owners need to understand new compliance requirements.

The American National Standards Institute (ANSI) include building owner compliance requirements under a general duty clause.

A new Window Cleaning Safety Standard holds building owners responsible for ensuring that worker safety and public protection standards are in compliance for window cleaning procedures in all buildings three stories and higher.

Buildings without appropriate anchor point for suspended work are non-compliant. Building work surfaces must be retrofitted with certified anchor points before any work can begin. Moving forward, new buildings three stories or higher design plans must have these anchor points.

For worker protection, the American National Standards Institute (ANSI) approved IWCA I-14.1-2001 holds building owners, property professionals, and window washing contractors responsible for:

  • Providing written documentation from a professional structural engineer that roof anchors are certified to withstand the expected load,
  • The documentation of maintenance and inspection of any permanent equipment being used for window,
  • Maintaining Manufacturer Instructions on all equipment including the load ratings, limitations, and intended use,
  • Ensuring that window cleaning contractor own equipment attached to any part of the building, is inspected to ensure that the anchor point will hold the expected load.

The Occupational Safety and Health Administration (OSHA) also holds building owners responsible for providing safe and healthful workplaces for their employees. Read more at CSGCARES BLOG.

Got OSHA Fall Protection Regulations?

Learn about the important OSHA Fall Protection Regulations for post-frame construction in CSG’s outline of fall protection needs and personal fall arrest system options to protect workers on roofs.

Federal OSHA, as well as Cal-OSHA, has found a high proportion of fatalities caused by falls occurred because of a lack of fall protection. Construction industry management must be responsible for fall protection to prevent accidents and avoid costly and reputation damaging Cal-OSHA citations.

Read Here – Fall Protection Regulations For Wood Frame Construction

Make sure your construction team is meeting these requirements:

Workers have the right to safe and healthful working conditions. The following precautions must be included in any fall protection plan.

  • Employees are protected whenever they are 6 feet or more above a lower level.
  • Employee is protected from falls and also from any falling objects.
  • Work surfaces must be examined and deemed structurally safe.

When conventional fall-protection is not possible or might create a greater hazard, a written plan addressing fall protection issues must meet these requirements:

  • Must be in writing, site-specific or by style/model and must maintained on site
  • Must be prepared by a qualified person and maintained by a competent person
  • Must include all measures addressing fall hazards

About CSG Safety Services Group, LLC: CSG Safety Services Group, LLC designs and installs window washing systems nationwide. CSG provides inspections, testing and certifications for all window cleaning equipment. CSG provides consulting up to full design/build services. The CSG Safety Services Group promotes window washing system solutions with safety, usability, and cost effectiveness in mind. www.windowwashingsystems.com.

 

Fall Protections citations

Think you can save money without a professional installation team?

Fall protection is the top OSHA-cited workplace safety violation with more than 8,000 citations last year. According to Federal OSHA, as well as Cal-OSHA, falls continue to be the leading cause of fatalities in construction.

A rise in falls due to lack of fall protection and recent changes in regulations for light-frame residential construction means more targeted random jobsite inspections  industry wide. Construction industry management must be responsible for fall protection to prevent accidents and avoid costly and reputation damaging Cal-OSHA citations.

OSHA citation fines cost companies, small and large, millions of dollars each year. Check out some routine OSHA citations for construction firms.

  • An unregulated scaffold at 30 feet with no fall protection gear or training for workers cost $62,000.
  • A firm with past OSHA violations issues was cited for $243,000 for having workers on a steep pitch roof without fall protection.
  • Average fines for not having a Hazard Communication Plan, Material Safety Data Sheets or maintaining employee training can cost $281.00 per violation.
  • Ladder related citations as high as $139,260 in proposed fines for issues including using a damaged extension ladder, improper ladder use, ladder unsecured or ladder not inspected prior to use.

The customer absorbs these costs when contractors fail to provide adequate fall protection on job sites in unexpected charges or fees for new documentation. New laws in California hold a building owner responsible for ensuring worker safety as required by OSHA regulations.

Work with a professional installation team with Fall Protection Consulting experience for your window washing systems or exterior building maintenance projects to prevent accidents and avoid costly and reputation damaging Cal-OSHA citations.

About CSG Safety Services Group, LLC: CSG Safety Services Group, LLC designs and installs window washing systems nationwide. CSG provides inspections, testing and certifications for all window cleaning equipment. CSG provides consulting up to full design/build services. The CSG Safety Services Group promotes window washing system solutions with safety, usability, and cost effectiveness in mind. www.windowwashingsystems.com.

Cal/OSHA Regulations for Working at Heights

Many working heights trades trigger the use of Cal/OSHA Fall Protection regulations. Effective training for working at heights should include safe work practices, worker’s rights, learning strategies in safety meetings and complying with rules and regulations. To start with any person working at heights should review Cal/OSHA information on Fall Protection.

Cal/OSHA Requirements in Construction

The specific Cal/OSHA safety requirements that apply to your employees depends on the jobsite-specific construction activities.

Cal/OSHA regulations related to Fall Protection in construction are found in Title 8 of the California Code of Regulations (T8CCR). The complete set of Title 8 regulations can be found at www.dir.ca.gov/samples/search/query.htm.

The following is an overview of the regulations in Title 8 for Fall Protection in construction (not all of the applicable Title 8 regulations are given below)

  • Article 16. Standard Railings (T8CCR 1620 – 1621)
  • Article 19. Floor, Roof and Wall Openings (T8CCR 1632 – 1633)
  • Article 21. Scaffolds – General Requirements (T8CCR 1635.1 – 1637)
  • Article 22. Scaffolds – Various Types (T8CCR 1640 – 1655)
  • Article 24. Fall Protection (T8CCR 1669 – 1672)
  • Article 2. Standard Specifications (T8CCR 3209 – 3239) in Subchapter 7. General Industry Safety Orders

About CSG Safety Services Group, LLC: CSG Safety Services Group, LLC designs and installs window washing systems nationwide. CSG provides inspections, testing and certifications for all window cleaning equipment. CSG provides consulting up to full design/build services. The CSG Safety Services Group promotes window washing system solutions with safety, usability, and cost effectiveness in mind. www.windowwashingsystems.com.