Safety Tidbit 3.26 - Fall Protection on Truck Trailers

Safety Tidbit 3.26 – Fall Protection on Truck Trailers

Reference:       1910.28 – OSHA Walking Working Surfaces

                        OSHA 2007 Letter of Interpretation

I attended the OSHA 501 course this week. This is the certification course enabling me to teach the OSHA 10- and 30- hour outreach training classes. There was a discussion about the new walking-working surfaces standard. OSHA’s definition is Walking-working surface means any horizontal or vertical surface on or through which an employee walks, works, or gains access to a work area or workplace location. The top of a semi-truck bed seems to fit that definition. Thus, the discussion began since some folks have trucks that move supplies from a warehouse to a job site.

1910.28(a) requires: “employers to provide protection for each employee exposed to fall and falling object hazards. Unless stated otherwise…” Now on the Construction side in 1926 OSHA gives a specific exemption for trucks [1926.500(b)(2)]. However, in General Industry the exemptions include:

·       Portable ladders;

·       When employers are inspecting, investigating, or assessing workplace conditions or work to be performed prior to the start of work or after all work has been completed. This exemption does not apply when fall protection systems or equipment meeting the requirements of 1910.29 have been installed and are available for workers to use for pre-work and postwork inspections, investigations, or assessments;

·       Fall hazards presented by the exposed perimeters of entertainment stages and the exposed perimeters of rail-station platforms;

·       Powered platforms covered by 1910.66(j);

·       Aerial lifts covered by 1910.67(c)(2)(v);

·       Telecommunications work covered by 1910.268(n)(7) and (8); and

·       Electric power generation, transmission, and distribution work covered by 1910.269(g)(2)(i).

We could not find a letter of interpretation on the topic. Therefore, the take home message became, if you have trucks that move supplies from a warehouse or other storage location, that falls under General Industry standards, and the workers working on/from the trucks are 4 feet or more above the ground, they must be protected from falling by one or more of the following:

·       Guardrail systems;

·       Safety net systems; or

·       Personal fall protection systems, such as personal fall arrest, travel restraint, or positioning systems.

However, once on the construction site the employer is exempt from having to protect them from falling.

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.