29CFR 1926 Subpart M provides the requirements for fall protection. Subpart 1926.502 is the meat of Subpart M. It runs for several pages and covers:
(a) General
(b) Guardrail systems
(c) Safety net systems
(d) Personal fall arrest systems
(e) Positioning device systems
(f) Warning line systems
(g) Controlled access zones
(h) Safety monitoring systems
(i) Covers
(j) Protection from falling objects
(k) Fall protection plan
With 24 individual requirements, fall arrest systems requirements are the most challenging to comply with. Coming in second with 10 requirements each are positioning device systems and fall protection plan.
It’s essential that your fall protection program address each of these areas. As a first step to ensuring that, look for any holes and add a section for what’s missing. It’s not necessary that it be correct or complete at this point, only that it is addressed. For example, you find there’s nothing about personal fall arrest systems. For now, you can create that section and as a requirement simply state that personal fall protection must be used at elevations 6 ft or more from grade. That’s not complete, but it will at least eliminate a relatively common cause of fall fatalities.
If you try to upgrade the program all at once (for example, taking a Saturday and just doing it in one go), you will likely end up with something that is incorrect and incomplete — or the work may be continually deferred due to time constraints.
When you add a missing section, also add a note that it is incomplete but will be completed by X date. Then schedule that work so it gets completed by that date. Stagger the completion dates to make the work scheduleable. Using this modular approach gains you several benefits, such as:
- You now make people aware of the general issue (as denoted in the title of each section). Even without exact guidance or rules, this has a positive effect on safety.
- You show a commitment to completing the work in a reasonable time. This may help if an OSHA inspector reviews your program and finds holes.
- You break the work down into readily achievable chunks, which should increase the quality of the work by eliminating any symptoms of rushing to get it done.
- Everyone can see the company is taking fall protection more seriously than it did before.
In the next several installments, we’ll look at the requirements in more detail.
