[SML] OSHA Industrial Fall Protection

[Duncan Mahoney]

Greg Bennett asks:

<"Good Morning OSHA Gurus,

I have a question about the requirements for fall protection under OSHA; I remember a discussion a few years ago about fall protection on platforms, and remember there was an exemption for areas that were not "general access". In my current place of employment
(non-theatre/production) there is an upcoming meeting about the fall protection requirements for work on the roof of transportable shelters. We have two types; a vehicle-mounted shelter, and ISO-type containers, both of which have antennas that get installed on the roof.

There has been light discussion about this in the past, and it's generally been regarded as unfeasible (jokes about clipping a harness into a "skyhook", etc) but it sounds like they're actually getting pretty serious about it. I imagine there is probably already some kind of standard or exemption that exists in industry; I'm thinking about trucking and climbing on top of trailers such as tankers for inspection and loading.

I'm looking at the various sections (the general 1910 in particular) and can't find that kind of language anymore. Perhaps someone more familiar with OSHA and its intricacies has some ideas?">



As Bill Sapsis pointed out, there aren't exemptions from fall protection in OSHA.  There are some limited situations where you can employ an alternate plan, but the key word there is "plan" which has to be engineered, documented, trained, recorded and convincing enough that the inspector will agree that it is the best practice that can be achieved under the circumstances.  And you can almost always do better...  Particularly if this is a regular activity in your business.

There is a document about this from 2004 that would seem to allow for being on top of a trailer without fall protection, but it comes with a big disclaimer from OSHA that it may not reflect current policy

https://www.osha.gov/laws-regs/standardinterpretations/2004-03-10

The trucking and rail industries faced up to this problem a couple decades ago.  Facilities that load or inspect tankers and tops of vehicles now have an overhead rail system or something else for the lifeline attachment.

You could engineer the problem away, antennas that deploy from inside the vehicle, or a roof hatch next to the antenna mount with a restraint system to keep the technician away from the edge of the roof.

And jokes aside, mobile "skyhooks" are available.  Just 1 result from a google search:

https://maltadynamics.com/mobile-fall-protection/?creative=324591473279&keyword=portable%20fall%20protection&matchtype=b&network=g&device=c&gclid=Cj0KCQiA-rj9BRCAARIsANB_4AA4-anFS0eG4ppcO20288V9ch6TD6d0h6ntnYgYED556uHHJGqZ1GoaAojcEALw_wcB


HTH


Duncan Mahoney
Head of Technical Direction
Professor of Theatre Practice
University of Southern California School of Dramatic Arts

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