COMING TOGETHER

Before I get into specifics, I’ll go out on a limb (with proper fall protection, of course), and say that in general, I note a sense of convergence in the new regulations. If there is an over-arching trend, it is that General Industry standards for walking-working surfaces and personal protective equipment are starting to look a lot like the 1926 Subpart M standards for Construction. That’s a good thing. Based on what we hear from customers, there is already enough confusion regarding OSHA regulations and which one(s) should be engaged with for a certain activity. When two workers can do the same job and be held to different safety standards, it’s time to take a step back and re-evaluate the situation.

MORE OPTIONS ARE BETTER

Perhaps the most wide-ranging change is the addition of personal fall protection systems and safety nets as a stated option for protecting workers from falls. The existing standard specifies only a “standard railing (or the equivalent…)” is suitable in such situations, which left many workers and supervisors at a loss to comply. In situations where workers chose a personal fall protection system over a guardrail, they could actually be levied a de minimis violation – under certain circumstances. By expanding the standards to allow more options to protect the worker, OSHA will allow employers/workers to use the system they feel protects them the best, and is most suitable for the specific situation. These include, but are not limited to: personal fall arrests systems, fall restraint, and work positioning systems. Surely many workers at one time or another have crossed the OSHA 1910 and 1926 standards line and been frustrated at having to change their preferred method of protection. This will no longer be the case.

YOU DON'T KNOW UNTIL YOU KNOW

Hand-in-hand with expanding the options for fall protection is the requirement for training. After all, if a worker does not know how to identify fall hazards, or to properly wear and use personal fall protection, what good is it? The good news is that workers will be even more knowledgeable about fall protection hazard identification and mitigation. The bad news is that you’ve already lost a month of time (of the 6 months OSHA has allowed) to be compliant with the new training standard. As stated in 1910.30 (a)(1), “…employers must ensure employees are trained in the requirements of this paragraph on or before May 17, 2017.” Even though the new regulations were released just ahead of the busy holiday season, the clock is ticking to get trained and to also document that the training has occurred. After all, if you can’t prove to OSHA you’ve been trained, how will they know you have?

STEP BY STEP

Fixed ladders are also severely affected by the update. To understand these changes, you will need to know two dates: November 19, 2018, and November 18, 2036. All existing fixed ladders taller than 24’ (those installed now, or until the cut-off) MUST have a cage, well, ladder safety system, or personal fall arrest system in place by November 19, 2018. This delay gives employers two years in which to get compliant with the current 1910.27 standard if they are not already. After November 19, 2018, all new or repaired fixed ladder installations over 24’ will no longer be allowed to have cages or wells as the sole means of fall protection, but must have a ladder safety system or personal fall arrest system. Employers will then have 20 years, until November 18, 2036, to replace all cages and wells on existing ladders and install a ladder safety system or personal fall arrest system. In a nutshell, after November 18, 2036, OSHA will no longer allow cages or wells on fixed ladder installations, period. For employers faced with the task of getting current with the existing standard, while technically you are allowed to install a cage and then replace it sometime over the next couple decades, why not just be ahead of the game and install the safest system now and save yourself the trouble of having to address the ladder again in the future??

AND WE'RE NOT DONE YET...

Is your head swimming yet? Mine too… As you can gather, the 1910 update includes some pretty comprehensive changes. But we’re not finished yet! For the sake of our collective sanities, I’m going to stop here and leave the rest of the changes for a second installment. Considering the updates already discussed, you’ve probably got enough work to do to get up to speed anyway. To read the 1910 update yourself, grab a cup (or gallon) of coffee, and follow this link. Until next time, Be Safe Up There!

**If you got this reference you must be a musician. If you didn’t, here’s the skinny: Everyone knows that there are scales in music; you’ve heard variations of these in every song you’ve ever heard, especially classical (look up Paganini for good examples). Combinations of the notes within a scale make a chord. These are what modern angst-filled troubadours strum in dimly-lit, woody coffee houses filled with sweater-wearing friends all across the nation. But what makes a chord? For a major chord, which could be considered the basic chord of any scale, it is the first, third, and fifth note of the scale. So, for a G major scale (G A B C D E F# G), a G major chord is G, B, and D, or 1, 3, 5. You can arrange these in any order you want (thus the 513 reference), but as long as you are playing the first, third, and fifth notes of the scale, you’ve got a major chord! Your third-grade teacher was right – math (and music) is everywhere! OK, lesson over, back to work!