Recent OSHA Construction Standards
OSHA Rescinds the Interim Fall Protection Compliance Guidelines for Residential Construction
Effective June 16, 2011, the U.S. Department of Labor’s Occupational Safety and Health Administration (OSHA) issued a directive rescinding the interim fall protection compliance guidelines for residential construction (STD 03-00-001).
Before this new directive was issued, employers engaged in residential construction activities could use alternative methods of fall protection, such as slide guards and safety monitor systems, without first proving that conventional fall protection was infeasible or created a greater hazard.
Residential construction employers must now comply with 29 CFR 1926.501(b)(13).
To be considered residential construction, the work must meet both of the following criteria:
- The end use of the structure must be as a home.
- The building being built must be constructed using traditional wood frame construction materials.
- Interior walls of wood or metal stud framing.
- Exterior walls of wood, metal studs, masonry brick or block.
Generally, residential contractors must ensure that employees working six feet or more above lower levels be protected from fall hazards by use of guard rails, safety nets or personal fall arrest systems. The new directive allows for other fall protection methods as outlined in 29 CFR 1926.501(b), such as warning lines and safety monitoring systems, during roofing work on low-sloped roofs, 4-in. 12 pitch (vertical to horizontal) or less, that are 50 feet or less in width. Roofs more than 50 feet in width and greater than 4-in. 12 pitch slope must be protected by conventional fall protection methods.
It should be noted that the requirements for fall protection for residential construction work being done from scaffolds, ladders and aerial lifts are found in Subpart L and Subpart X of the 29 CFR 1926.
The following summary of requirements found in 29 CFR 1926.501 must now be followed by residential contractors:
- An effective fall restraint system can be used in place of a personal fall arrest system if the fall restraint system is rigged such that the worker cannot reach the fall hazard. It should be noted that the anchorage requirement for a fall restraint system is 1,000 lbs. — not the 5,000 lbs. required for fall arrest systems.
- If the employer can demonstrate that use of conventional fall protection methods are not feasible (cost cannot be the reason) or creates a greater hazard, a qualified person must:
- create and implement a written, site-specific fall protection plan in compliance with 29 CFR 1926.502(k);
- document in that plan, why conventional fall protection methods cannot be used;
- maintain a copy of the fall protection plan on site;
- include in the plan what alternative measures are to be taken to reduce or eliminate the fall hazards;
- identify in the plan those areas where conventional fall protection systems cannot be used; these areas must be marked as controlled access zones and controlled accordingly; and
- train all workers on site with respect to the fall protection plan.
More information is available on OSHA's Residential Fall Protection Web page.
OSHA Revises its Voluntary Outreach Training Program
On April 15, 2011, OSHA issued a communication revising its voluntary outreach training program. The “program guidelines” have been changed to “program requirements” and apply to all Outreach Training Programs.
The following is a summary of the changes. Outreach trainers will need to visit OSHA’s website at www.osha.gov for more information and specifics of the requirements.
Outreach Training Program enhancements include, but are not limited to:
- Trainer Code of Conduct
- Statement of Compliance
- Maximum classroom size of 40 students
- Limiting the amount of time using videos during training (not more than 25 percent of the time spent training).
- Revised rules for guest trainers.
- All construction classes must include four hours of Focus Four Hazards training.
- All 30-hour classes must include two hours of Managing Safety and Health.
- Maximum training time is 7 ½ hours per day.
- The new two-hour Introduction to OSHA module must be part of all classes.
- 10-hour classes must take a minimum of two days.
- 30-hour classes must take a minimum of four days.
- A 10-minute break must be provided after every two hours of instruction.
- A lunch break of a minimum of 30 minutes must be provided for each training session that lasts for more than six hours.
- Mandatory, elective and optional topics are still allowed.
- CPR and First Aid may be presented in conjunction with the training, but do not count toward fulfillment of the requirements.
Some additional requirements include:
- OSHA has assigned minimum time lengths for mandatory topics.
- If guest trainers are used, the primary trainer must teach a minimum of 50 percent of the class.
- At least one authorized trainer must be present at all times.
- Each outreach class must be completed within six months of its start date.
- Trainers must document training to their Authorized Training Organization within 30 days of class completion.
- Trainers must issue course completion cards directly to the student within 90 days of course completion.
- Trainers must retain outreach class records for five years.
More information can be obtained at the OSHA Outreach Training Program Page at http://www.osha.gov/dte/outreach/index.html