Fall protection training required for staff, contractors exposed to fall of 4-plus feet

Remember to provide fall-protection training to any worker at your facility that may be exposed to a fall of more than 4 feet and ensure any contractors are also meeting the safety requirements under the newly revised OSHA general industry standard.

In addition, by November 19 of this year, any fixed ladders over 24 feet must be equipped with fall arrest or safety systems, as outlined in the revised standard. 

“These changes would most likely affect the hospital maintenance staff the most,” says Chris Salmasi, safety compliance advisor with SafeLink Consulting in Cumming, Ga.

Fall protection and training could include anyone working on a roof, servicing a HVAC system, inspecting or testing water towers, using a boom or scissor lift, or working on scaffolding over 10 feet in height, as well as other jobs often found on a hospital campus, says Salmasi.

While overall safety training in a hospital should include information on slip, trip, and fall hazards present in the workplace, the new fall protection requirements “would only affect employees who would be asked to perform work where they could be exposed to a fall of more than 4 feet,” notes Salmasi.

Revisions to OSHA’s general industry standard on walking and working surfaces and fall protection went into effect January 17, 2017, but in implementing the changes OSHA did provide more time for training, inspections, and installing physical protection systems as required in its final rule.

“The rule requires employers to protect workers from fall hazards along unprotected sides or edges that are at least 4 feet above a lower level,” according to OSHA’s fact sheet on the rule.

Other changes include requirements for the safety of those using rope descent systems and the physical protections required on fixed ladders over 24 feet tall.

On your campus, that could include window washers or construction contractors, among others.

The revisions to OSHA standard 1910.22(a) through 1910.22(d), “Walking-Working Services” general requirements, set several deadlines:

• May 17, 2017 — As of now, all workers who might be exposed to a fall of more than 4 feet must be trained on fall hazards and on the use of equipment to protect from falls.
• Nov. 20, 2017 — Also as of now, all anchorages for rope descent systems (remember those window washers) should be inspected and certified.
• Nov. 19, 2018 — You have eight more months to meet this requirement. Personal fall arrest or ladder safety systems must be installed on new fixed ladders over 24 feet and on replacement ladders/ladder sections. In addition, all existing fixed ladders over 24 feet must be equipped with a cage, well, personal fall arrest system, or ladder safety system.
• Nov. 18, 2036 — This is for your long-term planning. Cages and wells (used as fall protection) with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet must be replaced.

While training for slips, trips, and falls was always expected, the rule “adds a requirement that employers ensure workers who use personal fall protection and work in other specified high hazard situations are trained, and retrained as necessary, about fall and equipment hazards, including fall protection systems,” says OSHA.

These workers, says OSHA, must be trained by a qualified person to correctly identify and minimize fall hazards; use personal fall protection systems and rope descent systems; and maintain, inspect, and store equipment or systems used for fall protection.

When there is a change in workplace operations or equipment, “or the employer believes that a worker would benefit from additional training based on a lack of knowledge or skill, then the worker must be retrained,” states OSHA materials. And the training must be provided in a language and vocabulary that workers understand.

Remember to include falls safety when hiring a contractor to do work at your facility.

Under OSHA’s multi-employer citation policy, it is possible for your hospital as well as the contractor or subcontractor to be cited for an unsafe workplace or incident in which someone is injured or killed.

When dealing with a contractor, OSHA will expect a hospital to create a sitespecific safety program, supervise and enforce the safety protocols for that project and maintain authority to correct safety hazards, Salmasi says. Have regular safety meetings with contractors and subcontractors, document those meetings, and do regular inspections on site, he recommends.