Safety Tidbit 3.09 – Duty to have Fall Protection and Leading-Edge Work

Safety Tidbit 3.09 – Duty to have Fall Protection and Leading-Edge Work

Reference: https://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10757

I was headed to a store earlier this week. The store was in a strip mall in which each store had a little roof above the main entrance or the “porch” of the store. The top of the porch was about 10 feet high and jut out from the front wall about 3 feet. Above the roof of each store had the company sign or logo. I noticed a new store going in where another store had recently left and the construction company was busy taking down the old and putting up the new sign and making any repairs to the roof while they were up on top.

I’m sure you all know where I’m headed with this observation. Interestingly, the worker did have a harness on but was not tied off to anything. Of course, I stopped and asked the worker if she felt safe working up on the roof with a harness on but not secured to anything? She said there was nowhere to tie off and she was extra careful. I mentioned about OSHA’s requirements for fall protection in 1926.501(b)(1): “Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet (1.8 m) or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.” I reminded her that wearing a harness is only part of the personal fall arrest system.

She then commented that her boss told her if OSHA comes by that she was to explain to them that she is doing leading-edge work and it was infeasible to use the fall arrest system. I told her that even leading-edge work needs to have fall protection. If not in the form of guardrails, safety nets or personal fall arrest systems then the employer must establish a fall protection plan and implement it [1926.501(b)(2)(i)] unless the employer shows that it is in fact infeasible. I pointed to a scissor lift parked inside the store used for working on the ceiling as an alternative or the possibility of erecting a scaffold that would give protection. Not to mention the various commercially-available portable, temporary guardrail systems that can be bought or rented.

I explained that just because the means to be safe is not immediately known or available does not mean that it is infeasible to be safe. Proper planning on her boss’ part could have ensured her safety.

Hope this was helpful and thanks for reading my Safety Tidbits! Comments and questions are always welcome. ~ Bryan

P.S. If you have an interesting safety or health question please let me know.