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Slips, trips and falls are one of the most common hazards in municipalities. Whether it’s on an uneven sidewalk or just a slippery surface, slips, trips, and falls are often the cause of employee injuries. The final rule for walking working surfaces and personal fall protection systems was put into effect on January 17, 2017, for employers and employees under the Occupational Health and Safety General Industry Standards of 1910. 

This final rule benefits employers by providing greater flexibility in choosing fall protection systems. For example, employers can still use guardrail systems or a method of fall protection to include a harness and lanyard, but the new rule prohibits the use of body belts as a personal fall arrest system. The Occupational Health and Safety Administration estimates that 29 workers deaths and 5,842 lost workdays will be prevented each year as a result of the new rule.

Using a harness and lanyard, or using netting, allows the new fall protection requirements to be used following the construction standard requirements that have been in effect for more than 25 years. Cities must have a specific fall protection plan for each specific work area.

All fixed ladder systems must have personal fall arrest systems installed on new construction. All cages and wells with the ladder safety or personal climbing arrest systems on all fixed ladders taller than 24 feet must be replaced by November 18, 2036. Cities with water storage tanks are likely to have this exposure.

City employees working in areas higher than four feet off of the ground must have a means of fall protection. The work environment may include skylights, pits or dangerous machinery. The fall protection can be guardrails between 39 to 45 inches and midrails from 18 and 24 inches from the working level and toe boards. The top rail must be able to withstand 200 pounds of lateral weight without 2 inches of deflection. Deflection refers to designing the structure so that it can support a certain load. Remember, toe boards are required if employees work below an elevated work surface.

The new handrail/stair rail section can create challenges. The height provided by the grandfathered stair rail system applies to stairs installed before January 17, 2017. This allowed the top rail to serve as the handrail, provided that the top rail is 36 to 38 inches in height and meets all the other handrail requirements. For stair rails installed on or after January 17, 2017, the top rail and handrail must be separate. The top rail must be at least 42 inches in height and the handrail must be 30 to 38 inches in heights.

Remember, failure to provide and require the use of fall arrest systems is punishable by levels up to jail time. A roofing contractor was recently sentenced to 10 months in prison in Pennsylvania for lying to OSHA by indicating that a deceased employee wearing fall protection equipment on the roof. In reality, the employee was not wearing fall protection, and the employer did not provide fall protection.

A brief training class on how to properly have three points of contact while getting on or off any equipment and in and out of vehicles can potentially prevent slips, trips and falls. Contact loss control for three points of contact stickers that can be placed on equipment to help employees remember what to do. Employers should not forget to include stairwell and ladder trainings, since this is required training for all employees who use them.

Employees should be trained and retrained as necessary on all fall and equipment hazards. Training must include harness and lanyard inspection, and employees should be able to certify permanent anchorage points for their tie off systems. Since there is no annual requirement for retraining on fall protection, workers who are no longer proficient in the correct use of the personal fall protection systems and equipment, must be retrained. Cities should consider incorporating fall protection training into the annual safety training curriculum, although this is not required.

Both OSHA and SC OSHA sponsor an annual fall stand-down during May. A Safety Stand-Down is a voluntary event for employers that encourages employers to take a break and focus on "fall hazards" and reinforce the importance of "fall prevention.”

For questions on a city Safety Stand-Down event, fall protection or a review of fall hazard exposures, contact John Ciesielski, loss control consultant, at jciesielski@masc.sc or 803.354.4752.​