Tech Talk Blog

When Customized Guardrail is an Ideal Fall Protection Solution

Commercial and industrial grade HVAC units used to keep personnel and sensitive electronic equipment cool can sometimes be incredibly tall. This creates a situation in which there is no safe way to access the top of the units for maintenance work.

Per OSHA 1910 – accessing the top of these HVAC units – or for that matter, ANY equipment taller than 4 feet – requires fall protection to protect a worker who is on top of the equipment.

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Rooftop Guardrail vs. Horizontal Lifelines–What’s The Best Option?

A while back, we did a post titled “Why A Horizontal Lifeline May Be The Wrong Solution.”  The teaser title was click bait, but if you took the time to read the article, you came away with a simple explanation:  horizontal lifelines aren’t appropriate for low fall clearance applications where the worker can impact the ground before the system arrests the fall.  Today, we’ll compare and contrast two common solutions for rooftop applications–guardrail and horizontal lifelines.

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Anchorage Testing for Fall Protection Devices – Are You Doing Harm?

OSHA’s revised walking and working surface regulations, which took effect January 2017, includes specific language regarding testing anchorages used in support of window cleaning and facade maintenance equipment.

OSHA [1910.27(b)(1)(i)] states:

Before any rope descent system is used, the building owner must inform the employer, in writing that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting at least 5,000 lb (268 kg), in any direction, for each employee attached.

There has been much talk on how to verify a window washing anchor can support a 5,000 pound load. Some have contended that the anchor requires pull testing to 5,000 pounds, while others have argued that by the time the 5,000 pound pull test is complete, the anchor may sustain permanent damage that renders it unfit for use.

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Skylight Guardrail Fall Protection

Skylight Without Fall ProtectionDuring rooftop safety assessments, we often ask our clients to point out known fall hazards.  The most frequently mentioned rooftop fall hazard is the building’s leading edge.  From here, some clients mention roof elevation changes or access hatches, but most struggle to identify additional fall hazards that may trigger OSHA violations.  Sometimes the most innocuous feature—for example, a skylight—is the most troublesome omission because folks fail to see the potential dangers posed by areas that appear safe. 

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Do Your Permanently Mounted Fixed Ladders Still Comply with OSHA Regulations?

OSHA’s Slips, Trips, and Falls Regulations (Updated July 2017) cover a broad range of fall protection topics, including fixed ladders. For fixed ladders, the most important rule changes involve width and offset distance requirements.

In addition, importantly, cage systems will no longer be an acceptable protection device for ladders 24 feet and higher installed after November 19, 2018.

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24-Foot Rule for Mounted Access Ladders

If you’ve been looking into OSHA’s revised Walking Working Surfaces Regulations or have heard about the November 19, 2018 implementation of new regulations for permanently mounted ladders, you may still be confused about the height requirements related to the “24-foot rule.”

Your safety engineer or maintenance crew may have questions like these:

“What if the ladder is made up of sections that are less than 24’…do I need fall protection?”

“What if the ladder is only 20′ long, but starts 10′ above ground level?  What then?”

Whether an employer must equip a fixed ladder or ladder sections with fall protection depends on the distance a worker on the ladder could fall, not the length of any single section of the ladder.

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Did You Know?

Anytime that work is being performed on a roof that has a pitch of 4:12 or higher, fall protection must be used at all times?