It is not uncommon to see fall protection being misused in general. For example, we often see improperly installed systems or PPE utilized incorrectly. Another example of this unfortunate reality is portable guardrail systems.

A major contractor recently recognized the ease with which manufactured guardrail systems can be improperly installed. These systems provide a convenient guardrail system and at times can replace traditional wood handrail systems as guardrail during construction. While these systems provide great flexibility, cost effectiveness, and ease of use, each manufacturer has different installation requirements that significantly affect their overall strength and effectiveness. They emphasize that for the guardrail to function properly, these systems typically have very specific set-up requirements for each manufacturer. The installation requirements must be followed for the entire system, similar to manufactured scaffold systems.

The following alert relates to a portable rail system that is becoming a common replacement for conventional wooden barriers for perimeter fall prevention. Most common on roofs, these devices are easily assembled, moveable, and re-usable while providing the protection specified by OSHA.

We recognize the value of these engineered systems compared to traditional wood handrail systems but is recommending that the installations be well planned and maintained on projects. Like manufactured scaffold, the focus must be on the assembly of the entire system for these to be safe and effective.

Assembly

• Inspect each component before use – every time you assemble or modify
• Use only the specified tool (torque wrench, Allen etc.) for connections
• Fall protection may be required to install these barriers
• These must be installed on a clean surface – they cannot slide on stones
• Certain systems require the base plate to be specifically oriented
• Many systems require a set-back from the edge being protected – most are 24”. Best practice is to never set these closer than 6 feet from the edge, unless the base can be mechanically fastened to the floor or roof diaphragm.
• These systems often require a specific end configuration so they are never free-standing

During Use

• Remove any damaged component from service and render unusable
• If the system is struck by anything it should be inspected and all connections examined and re-tightened as needed

Material Handling

Base plates are extremely heavy and should be wheeled into position using a “buddysystem” to deploy and collect them as workers have injured their backs moving these up flights of stairs to the roof. Be alert for electrical hazards

Final Note: You must read and understand the assembly directions supplied by the manufacturer and ensure these are installed exactly as instructed.

The types of equipment referred to in this section are as follows:

• Earthmoving equipment – scrapers, loaders, crawler or wheel tractors, bulldozers, off-highway trucks, graders, agricultural and industrial tractors, and similar equipment.

Note:  Specific rules for compactors and rubber-tired “skid-steer” equipment are reserved due to standards currently being developed.

Seat belts – are a requirement for all equipment that is covered in this section.  However, seat belts are not required for equipment which is designed – only for standup operation, and/or equipment that is not equipped with a roll-over protective structure or canopy protection. The reason behind the latter of these two exceptions is; if an operator was wearing a seatbelt with no roll-over or canopy protection, he/she could become trapped or crushed in the event of a roll-over, rather than being afforded the freedom of mobility (not bound by a seatbelt) to immediately vacate (leap or jump from) the equipment prior to or during a roll-over.

Access roadways and grades may not be used for movement of construction equipment or vehicles unless the roadway or grade is constructed and maintained to accommodate the equipment or vehicles safely.

All earthmoving equipment must have an operable service braking system that is capable of stopping and holding the equipment while fully loaded.

Bi-directional equipment such as rollers, compactors, front-end loaders, bulldozers, and other similar equipment must be equipped with an operable audible alarm (horn), audible above the ambient noise level.

No earthmoving or compacting equipment which has an obstructed view to the rear may be used unless the equipment is equipped with a reverse signal alarm or an employee signals that it is safe to move.

Lifting and hauling equipment such as lift trucks, stackers, etc., must have the rated capacity posted on the equipment/vehicle clearly and in plain view of the operator.  When auxiliary removable counterweights as provided by the manufacturer are used, those corresponding rated capacities shall also be posted/shown.  Ratings must not be exceeded.  Also, any modifications or additions to equipment that may affect the capacity ratings or safe operation of the equipment will require the manufacturer’s written approval.  When changes or additions are made, the equipment’s operating and maintenance instructions, plates, tags, decals, load ratings, etc. shall be changed/revised to reflect those modifications.

Equipment may not be equipped with a steering or spinner knob unless the steering mechanism is of a type that prevents road reactions from causing the steering wheel to rebound or spin.

Unauthorized personnel are not permitted to ride on powered industrial trucks.  When riding of trucks is authorized, then a safe place to ride must be provided.

The information as outlined in this article focuses primarily on the requirements for “vehicles” and “equipment” in the workplace or on the jobsite.  Please refer to these sections of the CFR (including Subpart-W Rollover Protective Structures: Overhead Protection) for a more in-depth review of these regulations.

This is part two of a two-part series on Equipment & Vehicles – General Requirements
Part One: Equipment & Vehicles – General Requirements Part 1

Equipment (1926.600)

Equipment that is parked or left unattended at night in an area that is adjacent to a highway in normal use, or a construction site where there will be work in progress, must be equipped as follows to identify the location of the equipment and to maintain overall safety:

• Appropriate lights or reflectors (or barricades equipped with appropriate lights/ reflectors).
• Parking brake must be set and wheels must be chocked (when parked on an incline).

When leaving your equipment overnight, not in use, or during repairs, such as a bulldozer, scraper blade, end-loader, dump bodies or other similar equipment, they shall be fully lowered or blocked, all controls set in equipment, they shall be fully lowered or blocked, all controls set in a neutral position, brakes set and motor stopped (unless the work being performed requires otherwise).

Any machinery, equipment, or parts that are held aloft or suspended by use of jacks, slings, or hoists, must be carefully blocked or cribbed to prevent the load from falling or shifting before employees or personnel are permitted to pass or work under or between the load.

Equipment cab glass must be “safety glass” type or equivalent, and must be free of any visible distortion or obstructions that may affect the safe operation.

If any work onsite or in the workplace will involve inflating, mounting, or dismounting of equipment tires installed on split rims, or rims with locking rings or similar devices; a safety tire rack, cage, or equivalent protective device must then be provided and used for personnel safety.

Motor Vehicles (1926.601)

The type of vehicles referred to in this section are those that operate within an off-highway jobsite, which is not open to public traffic.

All vehicles must be equipped with the following, and shall be maintained in operable condition:

• A service brake system
• An emergency brake system
• A parking brake system
• Two headlights (when visibility conditions require additional light)
• Two brake lights (regardless of light conditions)
• An adequate audible warning device (horn) at the operator’s station

In addition to the above listed items, all vehicles with cabs must be equipped with the following:

• Windshields and powered wipers (cracked or broken glass must be replaced)
• Operable defogging or defrosting devices (only in areas or conditions that require such)
• A cab shield or canopy to protect the operator when haulage vehicles are loaded by means of cranes, shovels, loaders, or similar equipment
• Seats firmly secured and adequate for all employees that are to be carried
• Seat belts (meeting the requirements of the Federal Motor Vehicle Standards)

Fenders must be equipped on all rubber-tired motor vehicle/equipment manufactured on or after 5/1/72. Mud flaps may be used in lieu of fenders where the vehicle is not designed for such.

In a case where the motor vehicle/equipment has an obstructed view to the rear, a reverse signal alarm audible above the ambient noise level must be used or an observer used to signal the operator when it is safe to back up.

Trucks that are equipped with dump bodies shall have a means of support, permanently attached, that is capable of being locked in a position to prevent the accidental lowering of the body while maintenance or inspection work is performed. Also, operating levers which control hoisting or dumping devices must be equipped with a latch or other device which will prevent the accidental starting or tripping of the device.

Tailgates of dump trucks equipped with trip handles must have the device positioned so that while dumping, the operator is in the clear.

All vehicles that are in use must be checked at the beginning of each shift to assure that the items outlined above are in safe operating condition and free of any damage that may cause failure. If any defects are found, they must be corrected before the vehicle is put back in service.

This is part one of a two-part series on Equipment & Vehicles – General Requirements
Part Two: Equipment & Vehicles – General Requirements Part 2