29 CFR 1926 Subpart M provides the requirements for fall protection. Section 1926.502 is the meat of Subpart M. It runs for several pages and covers 11 topics. Now we’ll give three more of them a closer look:
(g) Controlled access zones.
(h) Safety monitoring systems.
(i) Covers.
Controlled access zones
A controlled access zone is an area you mark off to control who, if anybody, may enter the area. The area is defined by the control line or by a similar means of restricting access. Control lines must consist of ropes, wires, tapes, or equivalent materials. They must have flags or similar clear markings (of high-visibility material) at intervals not exceeding 6 ft.
There are some additional rules about the control lines, for example they must connect to the guard rail and be roughly parallel to the leading edge. The point of the control line is to keep people away from where they might inadvertently fall; if you keep that in mind when setting it up and also train employees to respect it, the likelihood of an OSHA citation for controlled access is pretty close to zero.
Safety monitoring systems
You may have a system in place whereby a designated competent employee monitors the safety of the other employees. This is a safety monitoring system. The monitor must comply with five requirements:
(i) Be competent to recognize fall hazards.
(ii) Shall warn the employee when it appears the employee is unaware of a fall hazard or is acting in an unsafe manner.
(iii) Be on the same walkway/workway and within sight of the monitored employee(s).
(iv) Be close enough to verbally warn the other employee(s).
(v) Not have other responsibilities that could distract the monitor from this task.
Covers
It’s often a good idea to cover holes, but the cover must be adequate to keep an employee from falling through the hole. OSHA specifically requires covers to be secured in place and capable of supporting, without failure, at least twice the weight of employees, equipment, and materials that may be imposed on the cover at any given time. Covers must also be color coded or marked with the word “hole” or “cover” to provide warning of the hazard.
OSHA doesn’t require it, but a smart employer will also instruct employees to avoid covers where practical. Don’t step on a cover when it’s just as easy to walk around it. This one precaution can make up for human error that would otherwise prove fatal. Ensure that employees know to immediately report any problems with covers.