Entering a Dumpster

Q: We sometimes have an employee enter the dumpster on the jobsite to rearrange it. What would be the proper protection for this employee?

A: Proper PPE would need to be worn while performing this task. Cut/puncture resistant gloves, safety glasses, steel toes, etc. would need to be worn. Also, since there could be boards that have nails sticking out of them footwear with puncture resistance/steel reinforced soles would need to be worn. If the dumpster is 6 feet or higher and the worker needs to access it when it’s full proper fall protection would be required as well. To eliminate the need for fall protection, a company policy should be put in place that prohibits the worker from accessing the dumpster if the material is less than 42 inches from the top of the dumpster. Ladders can also be used outside of the dumpster if possible.

Fall Protection

Q: Is it acceptable to use a scissors lift from an elevated platform that has perimeter openings of 40 inches around the outside of the floor?

A:  Since the wall openings are 40 inches, it is required for workers working from the floor level to have fall protection.  In this case the horizontal lifeline and fall arrest harnesses are acceptable, as long as they are used in the proper form. 

Any employee using the scissors lift will be required to have their fall arrest harness secured and attached until entering the lift because of the 40 inch openings.  When in the lift, the wall structures and the curtain walls must act as a curbing system; that will not allow the lift to reach the edge of the floor, exposing the employees to the risk of driving the lift off the edge. 

This process must be made as safe as possible to ensure that the lift is incapable of driving over the curtain walls that are acting as the curbing system.  If there are any potential hazards that may occur, they must be addressed.  OSHA may be unclear with the use of equipment use from an elevated platform, but OSHA does state under the General Duty Clause that the employer must ensure a safe workplace for the employees.

Safety challenges can come up at any time, trust the OSH consultants at LSCI to help with your company's safety.

Aerial Lifts

Q: Is it acceptable to tie off inside a basket (lift) using a retractable safety cable and harness? 

A: It is a requirement to tie off when using an aerial lift in any form other than a properly guarded scissors lift.  OSHA requirements when using the personal fall arrest system state, when stopping a fall:

(iii) be rigged such that an employee can neither free fall more than 6 feet (1.8 m), nor contact any lower level.  [1926.502(d)(16)(iii)]

Lanyard Specifications

Q:  What is the fully open length of a 6' lanyard after its activated?  We are quoting a job with 10'6" floor to floor, they are saying we cannot tie to the beams, because the lanyard + activation added length + the body length is more than 10'6".  Do they make a 4' or 5' lanyard ?
A:  You usually add on an additional 3 feet to the length of a lanyard when it is activated.  OSHA and the fall protection manufacturers take 4 different lengths into consideration when they determine the safe fall distance:  the height of the wearer, the length of the lanyard, the 3 feet activation length, and a safety factor of 3 ½ feet. A 6’ tall person wearing a 6’ lanyard would need to be able to attach the lanyard at least 18 ½’ above the lower level. 

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Mobile Ladder Platform

Q:  Does a mobile ladder platform need to have fall protection?

A:  Yes, OSHA considers these types of ladders working surfaces and they need to have fall protection if they are 4’ or taller.

Fall Protection

Q: When using a fall arrest harness what are the load requirements dealing with the anchorage point?

A: The anchorage point must have a safety factor of at least two, i.e., capable of supporting at least twice the weight expected to be imposed upon or able to withstand 5,000 pounds.

Fall Protection

Q: When working on a low-slope roof that is less than 50 feet wide is a safety monitoring system alone permitted without any other means of fall protection or warning line system?

A:  Technically under OSHA’s regulations and interpretations it could be.  However, you need to ensure that your safety monitor is not preforming any other job tasks or even talking on the cell phone.  It is also important that there is no other means of fall protection that can be used.  If it is possible use a guardrail system, safety net, or personal fall arrest system.  Please see OSHA’s regulation and interpretation for more information.

1926.501(b)(10) "Roofing work on Low-slope roofs." Except as otherwise provided in paragraph (b) of this section, each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system. Or, on roofs 50-feet (15.25 m) or less in width (see Appendix A to subpart M of this part), the use of a safety monitoring system alone [i.e. without the warning line system] is permitted.

Horizontal Life Line

Q: Is it acceptable to fasten two D-Rings into the roof or structure, and string aircraft cable between them in order to create a mobile retractable tie off point?

 A: Horizontal lifelines shall be designed, installed, and used under the supervision of a qualified person, maintaining a safety factor of at least two. Also, Dee-Rings must have a minimum tensile strength of 5,000 pounds.  The lifeline should also be able to support 5,000 pounds of force for each employee attached.

Fall Arrest Harness

Q: When do fall arrest harnesses need to be replaced?

A: 29 CFR 1910.66 App C(e) (v) (7) Personal fall arrest systems or components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection unless inspected and determined by a competent person to be undamaged and suitable for reuse.

ANSI A10.32-2004 states the service life of fall protection equipment manufactured of synthetic fiber shall be 5 years unless otherwise specified by the manufacturer.

Working On A Roof In High Winds

Q:  Does OSHA have a defined wind speed where roof work should be stopped.

A:  Unfortunately, OSHA does not have a defined wind speed.  OSHA only mentions “high winds” in the regulations.  The responsibility to remove workers from the roof is given to the employer.  Ultimately it comes down to the supervisor on the job to stop the work once it is determined the wind is creating a dangerous situation for the workers.

Fall Protection

Q:  Do skylights need to be covered or guarded on the roof if the workers are tied off to a fall arrest harness?

A:  No, as long as the workers are properly tied off the skylights do not need to be covered.

Portable Ladders

Q: When employees are climbing ladders to do job tasks such as changing a light bulb do they need to be tied off?

A: No, fall protection is not required for employees climbing or working on portable ladders.

Fall Protection at Loading Docks

Q:  We would like to know if you have the OSHA requirements necessary for our loading dock area for a rail or barrier. We are in the midst of having our chains replaced with a more secure barrier. Our loading dock is about 5’ off the ground. Any information would be great.

A:  You’ll want to make sure the new barriers that you install meet the following criteria:

• Top rail at 42 inches in height and capable of withstanding 200 lbs of outward and downward force.  
• Midrail at 21 inches in height.

I’ve seen some facilities use 2x4 boards for these barriers.  They install brackets on the inside of the door that hold the boards.  They are then able to lift the boards out of brackets with ease in order to use the dock.  This seems to be a sturdy solution for a removable barrier at the dock.  This is just a suggestion as I’m not sure if this would work for your application. 

Scissor Lifts

Q: Do you need to wear a fall arrest harness when working in a scissor lift that that has a guardrail system around it?

A: No, you do not need to wear a fall arrest harness when working in a scissor lift if it has a proper guardrail system around it.  However, if the guardrail system is less than adequate, or the worker leaves the safety of the work platform, an additional fall protection device would be required.

Walking Working Surfaces

Q:  We have built a few small “platforms” to stand on to do some of our work.  When I say platform, I mean a small single step.  These “platforms” range from about 7-9 inches tall with a rectangular flat service of 18X18 inches on the small end, and 30X36 inches on the larger end. Is there an OSHA requirement that a surface area must be so large for a certain height? 

A:  Yes, OSHA does have requirements for steps.  The platforms you are talking about will be covered by those requirements for steps.  The regulations that will want to follow for the structure and surface area are as follows:

• 1910.24(c) "Stair strength." Fixed stairways shall be designed and constructed to carry a load of five times the normal live load anticipated but never of less strength than to carry safely a moving concentrated load of 1,000 pounds.
• 1910.24(d) "Stair width." Fixed stairways shall have a minimum width of 22 inches.

Regarding your question about the need for handrails, the only need for a handrail is if the platform is 4 feet or more above an adjacent floor or ground.  In your case the two steps that total 16 inches would not need a handrail:  click here to refer to 1910.23(c)(1) - 1910.23(c)(1)(iii).

Learn more about OSHA requirements, look to the experienced OSHA consultants available from Lancaster Safety.

Fall Protection

Q: What would the aisle width requirements be for a walkway that is 10 feet off the ground?

A:  1910.22(b) "Aisles and passageways."

1910.22(b)(1) Where mechanical handling equipment is used, sufficient safe clearances shall be allowed for aisles, at loading docks, through doorways and wherever turns or passage must be made. Aisles and passageways shall be kept clear and in good repairs, with no obstruction across or in aisles that could create a hazard.

 1910.23(c) "Protection of open-sided floors, platforms, and runways."

1910.23(c)(1) Every open-sided floor or platform 4 feet or more above adjacent floor or ground level shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides except where there is entrance to a ramp, stairway, or fixed ladder. The railing shall be provided with a toeboard wherever, beneath the open sides,

1910.23(c)(1)(i) Persons can pass,

1910.23(c)(1)(ii) There is moving machinery, or

1910.23(c)(1)(iii) There is equipment with which falling materials could create a hazard.

1910.23(c)(2) Every runway shall be guarded by a standard railing (or the equivalent as specified in paragraph (e)(3) of this section) on all open sides 4 feet or more above floor or ground level. Wherever tools, machine parts, or materials are likely to be used on the runway, a toeboard shall also be provided on each exposed side.

If the walkway is part of an exit, it would have to meet these requirements:

1910.36(g)(2) An exit access must be at least 28 inches (71.1 cm) wide at all points. Where there is only one exit access leading to an exit or exit discharge, the width of the exit and exit discharge must be at least equal to the width of the exit access.

Letter of Interpretation

Fall Protection

Q: How long can a person be suspended in a fall arrest harness?
A: The following is the regulation dealing with the rescue time for someone who has fallen and is being suspended by a fall arrest harness:

1926.502(d)(20) The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.  

The word “prompt” requires rescue be performed quickly, in time to prevent serious injury to the worker. OSHA does not have a set time in which an employee would need rescued, but recent studies indicate that a person may become unconscious within 5 minutes.

Fall Protection

Q:  What is required by OSHA for man lifts as far as fall protection?

A:  If you’re using scissor lifts a personal fall arrest harness is not needed if all four sides of the lift are protected by guardrails since they fall under OSHA’s scaffolding regulation.  If you’re using an extendable boom aerial lift then personal fall protection is required.  It’s OSHA’s policy that an employer will be in compliance with OSHA’s fall protection requirements for aerial lifts if one of these three means of fall protection are used:

• Use of a body belt with a tether anchored to the boom or basket (fall restraint system),
• Use of a body harness with a tether (fall restraint system), or
• Use of a body harness with a lanyard (fall arrest system).

If using a fall arrest system you need to be aware of the distance it takes to actually arrest the employees fall.  For example, if a 6’ person is using a 6’ lanyard the distance that would be needed to arrest the fall safely without hitting the ground would be around 18 feet.  This length is taking into consideration the distance that the lanyard could stretch and a 3’ safety factor that OSHA requires to be added into the total distance.

Fall Protection Policies for Residential Construction

Q:  Do you have any videos or material on the new OSHA policies for residential construction that I can show to my new hires?

A:  OSHA recently released a video, click here to watch.

Forklift

Q: Are there any requirements on how strong guardrails need to be when there is forklift traffic near the area?

A:  The only requirement for the strength of a guardrail is 200 pounds.  There is no regulation for guardrail strength for forklift traffic because it would have to be “extremely heavy duty.”  However, 29 CFR 1910.178(m)(6) states : “A safe distance shall be maintained from the edge of ramps or platforms while on any elevated dock, or platform or freight car.”  The best thing to do is effectively communicate and enforce safe driving practices while on the dock and ramp.  He mentioned that some companies have installed rumble strips near edges to warn drivers that they are getting close.