Fall protection requirements and equipment varies depending upon where the work is being performed. The regulations can be confusing for some employees, so it is up to the manager or safety professional to understand the work, the environment the work is being performed in, and the equipment needed to mitigate the hazard of falling from height.
When Is Protection Required?
In general industry, which the Occupational Safety and Health Administration (OSHA) defines as all industries not included in agriculture, construction, or maritime, fall protection is required anytime there is a fall of 4 feet or more from an unprotected edge or side. In summary:
Except as provided elsewhere in this section, the employer must ensure that each employee on a walking-working surface with an unprotected side or edge that is 4 feet (1.2 m) or more above a lower level is protected from falling by one or more of the following:
(a) Guardrail systems;
(b) Safety net systems; or
(c) Personal fall protection systems, such as personal fall arrest, travel restraint, or positioning systems.
In most cases, since general industry is NOT a construction environment, fall protection is provided using guardrails that are required as part of building code. OHSA and building codes are very specific about how these guardrails are constructed. They must consist of a top rail, mid-rail, or balusters, and a toe-board. Code requires they be a certain height, withstand a certain weight load, and be constructed in a specific manner. Since the building you are working in is not under construction, guardrails are likely in place. If there are no guardrails, then a safety net or personal fall protection system (i.e. anchorage, lanyard, or harness) is required.
In construction, which OSHA defines as construction work, alteration, and/or repair, including painting and decorating, the requirements for fall protection are slightly different.
Each employee on a walking/working surface (horizontal and vertical surface) with an unprotected side or edge which is 6 feet or more above a lower level shall be protected from falling by the use of guardrail systems, safety net systems, or personal fall arrest systems.
Unlike in general industry, the construction standard for OSHA requires protection of a side 6 feet or more above a lower level. The means and methods of protection have not changed; you can still use guardrails, personal fall protection, or safety nets. However, the height at which height protection becomes required has changed. It is worthwhile to mention that OSHA 1910.269, Power Generation, Transmission and Distribution generally follows the construction standard for fall protection (1926 Subpart M) with some slight differences. These differences usually pertain to working on transmission towers, poles, and protection from falls due to electrical shock and flash.
What Is Required?
OSHA and building codes present very specific requirements for guardrails to properly protect employees from falls. Per OSHA’s general industry standard, guardrails must adhere to the following:
- The top edge height of top rails, or equivalent guardrail system members, are 42 inches, plus or minus 3 inches, above the walking-working surface. The top edge height may exceed 45 inches, provided the guardrail system meets all other required criteria.
- Midrails, screens, mesh, intermediate vertical members, solid panels, or equivalent intermediate members are installed between the walking-working surface and the top edge of the guardrail system as follows when there is not a wall or parapet that is at least 21 inches high:
- Midrails are installed at a height midway between the top edge of the guardrail system and the walking-working surface;
- Screens and mesh extend from the walking-working surface to the top rail and along the entire opening between top rails supports;
- Intermediate vertical members (such as balusters) are installed no more than 19 inches apart; and
- Other equivalent intermediate members (such as additional midrails and architectural panels) are installed so that the openings are not more than 19 inches wide.
- Guardrail systems are capable of withstanding, without failure, a force of at least 200 pounds applied in a downward or outward direction within 2 inches of the top edge, at any point along the top rail.
- When the 200-pound test load is applied in a downward direction, the top rail of the guardrail system must not deflect to a height of less than 39 inches above the walking-working surface;
- Midrails, screens, mesh, intermediate vertical members, solid panels, and other equivalent intermediate members are capable of withstanding, without failure, a force of at least 150 pounds applied in any downward or outward direction at any point along the intermediate member.
- Guardrail systems are smooth-surfaced to protect employees from injury, such as punctures or lacerations, and to prevent catching or snagging of clothing.
- The ends of top rails and midrails do not overhang the terminal posts, except where the overhang does not pose a projection hazard for employees.
- Steel banding and plastic banding are not used for top rails or midrails.
- Top rails and midrails are at least 0.25 inches in diameter or in thickness.
There are a few differences for temporary guardrails in the construction standard from the requirements set forth in the general Industry standard, but they are negligible. Many of these requirements for the construction of guardrails are used as part of building codes.
If a guardrail is infeasible, personal fall protection or a safety net must be used, and OSHA has very specific requirements for guardrail use and construction.
Personal fall protection must consist and adhere to the following, which is summarized from the construction standard:
- Connectors shall be drop forged, pressed or formed steel, or made of equivalent materials.
- Connectors shall have a corrosion-resistant finish, and all surfaces and edges shall be smooth to prevent damage to interfacing parts of the system.
- Dee-rings and snaphooks shall have a minimum tensile strength of 5,000 pounds.
- Dee-rings and snaphooks shall be proof-tested to a minimum tensile load of 3,600 pounds without cracking, breaking, or taking permanent deformation.
- Snaphooks shall be sized to be compatible with the member to which they are connected to prevent unintentional disengagement of the snaphook by depression of the snaphook keeper by the connected member, or shall be a locking type snaphook designed and used to prevent disengagement of the snaphook by the contact of the snaphook keeper by the connected member. Effective January 1, 1998, only locking type snaphooks shall be used.
- Unless the snaphook is a locking type and designed for the following connections, snaphooks shall not be engaged:
- directly to webbing, rope or wire rope;
- to each other;
- to a dee-ring to which another snaphook or other connector is attached;
- to a horizontal lifeline; or
- to any object which is incompatibly shaped or dimensioned in relation to the snaphook such that unintentional disengagement could occur by the connected object being able to depress the snaphook keeper and release itself.
- On suspended scaffolds or similar work platforms with horizontal lifelines which may become vertical lifelines, the devices used to connect to a horizontal lifeline shall be capable of locking in both directions on the lifeline.
- Horizontal lifelines shall be designed, installed, and used, under the supervision of a qualified person, as part of a complete personal fall arrest system, which maintains a safety factor of at least two.
- Lanyards and vertical lifelines shall have a minimum breaking strength of 5,000 pounds.
- When vertical lifelines are used, each employee shall be attached to a separate lifeline.
- Lifelines shall be protected against being cut or abraded.
- Self-retracting lifelines and lanyards which automatically limit free fall distance to 2 feet or less shall be capable of sustaining a minimum tensile load of 3,000 pounds applied to the device with the lifeline or lanyard in the fully extended position.
- Self-retracting lifelines and lanyards which do not limit free fall distance to 2 feet (0.61 m) or less, ripstitch lanyards, and tearing and deforming lanyards shall be capable of sustaining a minimum tensile load of 5,000 pounds (22.2 kN) applied to the device with the lifeline or lanyard in the fully extended position.
- Ropes and straps (webbing) used in lanyards, lifelines, and strength components of body belts and body harnesses shall be made from synthetic fibers.
- When work is to be performed near electrical power lines or equipment it must be Arc Rated.
- Anchorages used for attachment of personal fall arrest equipment shall be independent of any anchorage being used to support or suspend platforms and capable of supporting at least 5,000 pounds per employee attached, or shall be designed, installed, and used as follows:
- as part of a complete personal fall arrest system which maintains a safety factor of at least two; and
- under the supervision of a qualified person.
- Personal fall arrest systems, when stopping a fall, shall:
- limit maximum arresting force on an employee to 900 pounds when used with a body belt;
- limit maximum arresting force on an employee to 1,800 pounds when used with a body harness;
- be rigged such that an employee can neither free fall more than 6 feet, nor contact any lower level;
- This is 4 feet in the General Industry standard, as discussed previously
- bring an employee to a complete stop and limit maximum deceleration distance an employee travels to 3.5 feet; and,
- have sufficient strength to withstand twice the potential impact energy of an employee free falling a distance of 6 feet, or the free fall distance permitted by the system, whichever is less.
- The attachment point of the body belt shall be located in the center of the wearer’s back. The attachment point of the body harness shall be located in the center of the wearer’s back near shoulder level, or above the wearer’s head.
- Body belts, harnesses, and components shall be used only for employee protection (as part of a personal fall arrest system or positioning device system) and not to hoist materials.
- Personal fall arrest systems and components subjected to impact loading shall be immediately removed from service and shall not be used again for employee protection until inspected and determined by a competent person to be undamaged and suitable for reuse.
- The employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves.
- Personal fall arrest systems shall be inspected prior to each use for wear, damage and other deterioration, and defective components shall be removed from service.
- Body belts shall be at least one and five-eighths (1 5/8) inches (4.1 cm) wide.
- Personal fall arrest systems shall not be attached to guardrail systems, nor shall they be attached to hoists with few exceptions.
- When a personal fall arrest system is used at hoist areas, it shall be rigged to allow the movement of the employee only as far as the edge of the walking/working surface.
Falls are the number-one cause of injury and death in industry. Understanding when it is needed and how to employ it correctly, which includes providing the right equipment to prevent an employee fall, is important to mitigate that potential injury. More information and other specifics regarding fall protection can be found under OSHA 29 CFR 1910, General Industry Standards and Regulations in Subpart D – Walking and Working Surfaces and Subpart R – Special Industries, and in OSHA 1926, Construction Industry Regulations under Subpart M – Fall Protection.
Paul Chamberlain has been the Safety Manager for American Electrical Testing Co., LLC since 2009. He has been in the safety field for the past 21 years, working for various companies and in various industries. He received a Bachelor of Science in safety and environmental protection from Massachusetts Maritime Academy.