[SML] OSHA Industrial Fall Protection

[Dale Farmer]

Can you move the mounting points to the edges of the roof such that all 
the work normally needed can be done by someone leaning a ladder against 
the side of the thing and reaching everything while standing on the 
ladder?   I think this would make the entire discussion moot.  Also, 
making the job of the folks doing the work that much easier.

Dale

On 11/13/2020 12:54 PM, Duncan Mahoney via Stagecraft wrote:
> 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 
> <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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