In January of 2012, the Safety and Health Department launched several new initiatives designed to “target the deadly dozen hazardous activities that lead to fatalities and disabling injuries.” The focus of this article is to highlight some of the serious fall hazards pertaining to steel erection and reinforcing steel installation. Following are job site illustrations that depict some of the primary hazards and regulatory requirements pertaining to fall protection. The standards used in this article reference the minimum requirements of the Occupational Safety and Health Administration (OSHA). Some states that operate under State Approved OSHA Plans may stipulate more stringent standards pertaining to fall protection requirements. Additionally, it is common for project safety requirements and contractor safety policies to require more stringent fall protection requirements.
OSHA Fall Protection Standard for Steel Erection Activities
The following OSHA Subpart-R standard pertains to ironworkers engaged in steel erection activities. The trigger-height for fall protection is 15 feet for all steel erection activities other than connecting and decking. This includes activities such as bolting, welding, plumbing, and detail work, etc.
1926.760(a) – “Except for connecting and decking activities, each employee engaged in a steel erection activity who is on a walking/ working surface with an unprotected side or edge more than 15 feet above a lower level shall be protected from fall hazards by guardrail systems, safety nets, fall arrest systems, positioning device systems or fall restraint systems.”
The trigger-height for fall protection is 15 feet for all steel erection activities other than connecting and decking. This includes activities such as bolting, welding, plumbing, and detail work, etc.
Avoiding Excessive Free-Fall Distance and False Sense of Security
The photograph above illustrates the improper use of fall arrest equipment that creates a “false sense of security.” Serious injuries have occurred when excessive free-fall distance has allowed ironworkers to strike the deck or other structural members below. When using a personal fall arrest system, special attention must be given to raising the anchorage point of the fall arrest system to reduce the potential free-fall distance. Following is the OSHA Subpart-M standard that addresses anchorage points and the hazard of excessive free-fall distance.
1926.502(d)(16) – “Personal fall arrest systems, when stopping a fall, shall be rigged such that an employee can neither free fall more than 6 feet, or contact any lower level.”
Anchorages used for attachment of personal fall arrest equipment such as the wire rope sling in this illustration must be capable of supporting at least 5,000 pounds per employee attached or designed and installed as part of a complete fall arrest system with a safety factor of at least two, and under the supervision of a qualified person.
Preventing Fall Hazards for Connectors
There has been much confusion regarding fall protection requirements for connectors. Under the OSHA Subpart-R standard, connectors are not required to tie-off between 15 feet and 30 feet while performing connecting activities for any type of structural member. However, there are special conditions that apply. Following is the OSHA standard that addresses fall protection requirements for connectors.
1926.760(b) - Each connector shall:
(1) Be protected in accordance with paragraph (a)(1) of this section from fall hazards of more than two stories or 30 whichever is less;
(2) Have completed connector training in accordance with 1926.761; and
(3) Be provided, at heights over 15 and up to 30 feet above a lower level, with a personal fall arrest system, positioning device system or fall restraint system and war the equipment necessary to be able to be tied off; or be provided with other means of protection from fall hazards.
Preventing Fall Hazards During Decking Activities
Falls during the installation of metal floor and roof decking accounted for nearly 23 percent of fatalities and remains one of the most hazardous activities that ironworkers perform. Ironworkers engaged in leading edge decking installation between 15-30 feet within a “controlled decking zone (CDZ)” are subject to special training requirements and provisions. Following is OSHA’s definition of a CDZ.
Controlled decking zone (CDZ) – “an area in which certain work (e.g., .initial installation and placement of metal deck) may take place without the use of guardrail systems, personal fall arrest systems or safety net systems and where the access to the zone is controlled.”
All ironworkers working within a CDZ must receive special training and comply with additional requirements pertaining to the establishment of a CDZ. One of the primary purposes and safeguards of a CDZ is to restrict access by other personnel that are not engaged in leading edge decking installation. Access to a CDZ is strictly limited to those employees engaged in leading edge work. Prior to commencement of any operations within a CDZ, the steel erection contractor must ensure that each employee has completed CDZ training in the following areas: 1) The nature of the hazards associated with work within a CDZ; and 2) The establishment, access, proper installation techniques, and work practices.
Preventing Fall Hazards During Reinforcing Steel Installation
The OSHA standard for reinforcing steel activities are different than steel erection and are contained in the OSHA Subpart-M—Fall Protection standard.
In the photograph above, the ironworker is using a wall belt and chain as a positioning device for installing reinforcing steel on a vertical curtain wall. This wall belt and chain is an acceptable means of fall protection under Federal OSHA clarification for horizontal or vertical movement on reinforcing steel assemblies up to a height of 24 feet. This distance is measured from the floor or ground to the ironworkers feet. Positioning devices or wall belts must be rigged so that an employee cannot free fall more than two feet.
Whenever work is performed above 24 feet, the OSHA clarification requires an additional personal fall-arrest system to be provided. This means when exceeding heights of 24 feet above a lower level, the use of a full body harness and an additional lanyard must be used in combination with the wall belt and chain. OSHA requires all ironworkers to be trained on the following fall protection areas.
• The nature of fall hazards in the work area
• Inspection procedures for fall protection systems
• The use and operation of fall arrest systems
Use of Positioning Device and Fall Arrest Equipment
The photograph above illustrates the ironworker using a positioning device in combination with a personal fall arrest system. It is common on many projects for the owner, controlling contractor, or signatory contractor to require the use of these systems to comply with their 100 percent fall protection policy. During work activities on vertical columns or curtain wall steel, the ironworker must be capable of recognizing the heights at which additional fall protection is required. Federal OSHA has promulgated an official letter of clarification that allows point to point (horizontal or vertical) movement on rebar assemblies up to 24 feet with the sole use of a positioning belt as a means of fall protection. However, when work is performed above 24 feet from a lower level, 100 percent fall protection is required. Positioning devices may be used in combination with a full body harness and lanyard to provide 100 percent fall protection during rebar installation above 24 feet. California is one of the states that operate under the provisions of a State Approved OSHA Plan that adopted a standard that allows “point to point (horizontal or vertical) movement on rebar assemblies up to 24 feet with the sole use of a positioning belt as a means of fall protection.” Regulatory requirements and project safety provisions pertaining to the use of positioning devices and personal fall arrest equipment throughout.
The “2012 Zero Fatality” campaign will challenge all members to “intervene and prevent unsafe conditions and unsafe acts” in the workplace. Falls from heights is one of the “deadly dozen hazards” that has lead to fatalities and disabling injuries during steel erection and reinforcing steel installation. This campaign will include hard-hat stickers and gang-box stickers for training facilities and local unions. I will continue to work closely with district councils, local unions, and IMPACT regional advisory boards throughout the United States and Canada to promote the International Association’s “2012 Zero Fatality” campaign by “targeting the deadly dozen hazardous activities that lead to fatalities and disabling injuries.”