Myth #1 –A 5,000# anchor point is required for personal fall arrest

First of all, it is important to read the end of this paragraph! OSHA, and manufacturers of personal fall arrest equipment, have a minimum anchorage requirement of twice the anticipated with force to be applied on the system should a fall occur. This determination needs to be made by a qualified person, and/or an engineer. What this could mean in an extreme interpretation, would be that an engineer could actually determine the workers weight in particular, and design in anchorage system specifically for that workers weight at twice the anticipated force. Typical forces experienced with shock absorbing equipment is around 800 foot-pounds of force. Engineering to this typical value puts an anchor point at around 1600 foot-pounds minimum rated anchorage. The 5000 pound value was picked as a benchmark for a worker looking around and eyeballing a potential anchor point. Please note, however, that when it comes to fall Anchorage. More is usually better. Therefore, every attempt should be made to find the strongest anchorage possible, not just the minimum requirement.

Myth #2-fall restraint does not have a minimum anchor point rating

Fall restraint is when a person is rigged so that they cannot fall over the edge of an elevated platform. While it may seem intuitively true, that there would be a very small value used for restraint, it would seem that there would always be some value given by OSHA. The values I’ve been able to find is 3,500 pounds rated anchorage for restraint. While this may seem unusually high and restrictive (in that one could simply find a 5,000 pound anchor point and use PFAS) is a value that has been selected by OSHA. New fall restraint regulations are coming out shortly that may change this. While I personally think that in anchorage in the several hundred pound range would be sufficient, more is always better, ultimately.

Myth #3-if I fall in a harness, I need to simply wait for rescue

This is absolutely false. There is a phenomenon called suspension trauma, which may occur in a worker hanging from a harness, and being idle. The first thing you must do when hanging from a harness is to ensure that you are not bleeding somewhere. Check yourself over, and if you are bleeding use the proper first aid procedures to control or stop the bleeding. The next thing to do is to be aware that your legs hanging limp are going to cause blood pooling and a potentially fatal condition. Keep your legs active, especially your calves by pointing your toes, moving your legs, and trying to scoot back into your harness into more of a sitting position. What you’re trying to do is to keep the leg straps from cutting off circulation of the femoral arteries to your legs. In addition, workers from above may be able to pass down one or two ropes (or extension cords) with loops on the ends for you to put your feet into. They can then tie the ropes off and you could stand up in the stirrups and take some pressure off the harness straps. Again the important thing is to keep moving and active until rescue. After rescue, do not lie down! Remain in preferable a sitting position for 5 to 10 minutes and or, a standing position if you are able to or if someone can help hold you up. After about 10 minutes, you should be able to lie down with no problems. This allows any potentially toxic blood from your legs from overloading your heart muscles.

Myth #4-a standard shock absorbing lanyard is your best protection.

What has been the standard of the industry for decades, the standard six-foot shock absorbing lanyard is on its way out. New style lanyards now have stronger locking gates that can absorb the impact of a fall, allowing lanyards now to be wrapped back to themselves. This is especially convenient around scissors lifts, catwalks, and piping systems. However, even more importantly, is the advent of new lightweight self-retracting lifeline’s, or SRL’S. These SRL’s are now around the same price and weight as standard six-foot lanyards. However, SRL’s offer many advantages. They are effective at a much lower elevated height, even less than 6 feet above the lower level. They activate quicker, put less stress on the body, allow a lesser chance of hitting an object on the way down, and perhaps the most important feature, allow for self-rescue. There is very little strain on the body using an SRL as opposed to falling 6 feet with a shock absorbing lanyard.

Myth #5 – all fall arrest equipment, is the same.

On one hand, while all fall arrest equipment must comply with ANSI standards, equipment can vary widely among different manufacturers. There are complete fall arrest packages including an anchorage, vertical lifeline, shock absorbing lanyard and harness for $100. Then there is fall arrest equipment where the harness itself might run as high as $400. The differences will be in the ease-of-use and comfort when working and/or when hanging in the harness awaiting rescue. Generally speaking, the more expensive, the lighter weight and more comfortable the equipment will be. If you use fall arrest equipment on regular basis, it would probably pay to get the better equipment. There are no known cases of inexpensive personal fall arrest equipment failing due to their cost.

Therefore, let’s review some of these areas where jobsite and workplace violations frequently occur and offer some control measures on how to avoid these situations and comply with OSHA’s regulations. To do this, we’ll look at some of the various OSHA reports on “most frequently cited serious violations” for the following: The related Subpart section of the CFR (Code of Federal Regulations) follows each one listed.

• Fall Protection (Subpart M)
• Excavations (Subpart P)
• Stairways and Ladders (Subpart X)

Fall Protection

The three (3) most frequently cited serious violations are:

1. Failure to protect workers from falls of 6 feet or more off unprotected sides or edges, e.g. floors and roofs 1926.501(b)(1); (b)(10); and (b)(11).
2. Failure to protect workers from falling into or through holes and openings in floors and walls 1926.501(b)(4) and (b)(14).
3. Failure to provide guardrails on runways and ramps where workers are exposed to falls of 6 feet or more to a lower level 1926.501(b)(6).

Fall Protection Control Measures:

Again, by means of performing a jobsite hazard survey, you will determine where fall hazards may exist throughout the course of the project, then implement and train your workers on the necessary protective measures prior to startup. Protective measures may include any one or a combination of the following methods: personal fall arrest system, guardrail system, safety net system, positioning device system, controlled access zone, and/or safety monitor. Which method to use depends on the type of fall hazard.

• Wherever possible, use a mechanical lifting device to lift equipment or assembled items into place such as sections of roofing. This will eliminate or reduce the number of workers exposed to falls.
• Working platforms such as aerial lifts or scaffolds provide better working surfaces for your workers rather than walking top plates or beams.
• A hole is defined as an opening 2 inches in its smallest dimension in a floor, roof or other walking/working surface. Covers are to be placed over any holes and marked as “HOLE” or “COVER” to provide warning of the hazard.
• Where fall hazards exist, limit the number of workers in the area to only those who are qualified and necessary. Also, designate an employee as the “safety monitor” where fall hazards exist. This person will observe employees and alert them of any unsafe activity and any hazards that could cause them to trip or fall.

Excavations

OSHA lists twenty one (21) areas of the standard most frequently cited as serious violations (January 1990 to April 1996), they are:

1. Protection in Excavations 1926.652(a)(1)
2. Inspections .651(k)(1)
3. Loose Rock/Soil .651(j)(2)
4. Means of Egress .651(c)(2)
5. Vehicular Traffic .651(d)
6. Inspections .651(k)(2)
7. Water Accumulation .651(h)(1)
8. Loose Rock/Soil .651(j)(1)
9. *Walkways/Guardrails .651(1)(2)
10. Falling Loads .651(e)
11. Adjacent Structures .651(I)(3)
12. *Walkways/Guardrails .651(1)(1)
13. Sloping/Benching Systems .652(b)
14. Adjacent Structures .651(I)(1)
15. Design/Protective Systems .652(c)
16. Shield Systems Requirements .652(g)(2)
17. Shield Systems/General .652(g)(1)
18. Underground Installations .651(b)(4)
19. Hazardous Atmospheres .651(g)(1)
20. Surface Encumbrances .651(a)
21. Protective Systems .652(a)(2)

* Section 1926.651(1)(2) was deleted by the Federal Register number 40730, dated August 9, 1994 (final rule Subpart M of Part 1926 -Fall Protection). Basically, these two sections are now covered under the new fall protection regulations for the construction industry found in Subpart M as noted.

As you can see from the list above, contractors continue to be cited for numerous violations of the excavation regulation. This is partly due to the fact that with most excavation projects there are many elements to consider and have a clear knowledge of such as: soil classifications, shielding/shoring systems, sloping/benching methods, the effects of water accumulation, hazardous atmospheres, protection of existing underground structures/utilities, effects of adjacent structures, adjacent vehicular traffic, employee access in and out of the excavation, inspection methods, emergency evacuation plan, etc., and the list goes on.
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