Framing a multi-story residential building with the guardrail and window rail already in place. (Photo: Jan Thomas)

Many construction framers like to think that they fall into the “residential exemption” at 1926.501(b)(13) and .502(k) where they explain in a written fall protection plan that it is infeasible for them to use conventional fall protection systems.  I’ve seen one too many companies search for excuses instead of finding solutions. 

As I’ve pointed out in the past, there are so many products available today that provide common and leading edge fall protection.  Once the initial expense for this equipment is taken the crew’s production can increase and everyone goes home at the end of the day.

Or, you can do what this company has done and design and fabricate your own portable guardrail system.  I watched this job while 2 men installed lengths of their perimeter guarding system while working from a personnel hoist. Right after it was installed the team of framers came in and deck and set the outer walls.  It was precision, quality and production all based upon planning and design, not excuses.

Blackwell, Virginia water tower being repainted with fall protection in use! (Photo: Jan Thomas)

I have to admit, I took this photo as much for the “art” as for the science of appropriate fall protection displayed.  Note how the foreground power lines seem to intersect with the tower’s structural components as well as the safety lines?  Cool.

It’s also cool to be driving in rural Virginia and come across such a good example.  Believe me, I’ve seen plenty of recent examples of workers trying to make a living while trying not to fall (see my blog on Low Bid = High Risk).  And, be sure to check out the story published at eLCOSH  of two lucky workers who survived a water tower fall due to the same system shown in my photo.

Only one of several types of tie-off instructions put on modern scissor lifts. (Photo: Jan Thomas)

Last Friday I received a call from a client’s superintendent asking me to go over the reasoning and authority for tying off on scissor lift and other personnel hoists. This is the same question I’ve been answering for years and I’ve been answering it in the same way for years… specifically, “Despite what OSHA says, if the manufacturer has provided anchors points, please use them as they have been put there for your safety!”  

In Virginia, in the fall of 2006, my answer became a little stronger as I could now point to the “authority” of VOSH when someone wanted to argue with me that OSHA doesn’t require tie off on scissor lifts. 

Earlier this year I wrote our clients a memo on this topic – it applies to industrial worksites, construction and all sectors of employment in between.  Here is a link to that memo. 

By the way, the superintendent was being questioned by one of his disbelieving subs.  So I reminded him that the true answer to “Why do we have to tie-off?” is “Because it’s our rule!”

Great example of guarding the parapet edge when its dimensions don’t add up to the “parapet rule.” And, note the professional carpentry! This is a Taylor & Parrish job where the guardrails are always the best. (Photo: Jan Thomas)

I think all professionals have a tendency to pass-on answers based upon “rules” they have been told about but have not researched for themselves.  Such is the case with a “flat roof/parapet height rule” I was told to use back in my OSHA compliance days (hint – it’s not in the OSHA standards).

Yet, when I started consulting, I also started to check my advice to clients, being ready to pull out the necessary documents supporting my statements.  It’s so much easier to do this today with a robust internet but still some of the provenances of these “rules” are obscure.  And, not only are they hard to trace but many are not regulatory rules, only guidelines.  For example, if you have a flat roof with a parapet that is at least 30 inches tall and at least 18 inches wide, you may have sufficient protection, if you have limited exposure.  I added the part about limited exposure as I’m not truly comfortable with this “parapet rule.”

I believe this formula started as an architectural guideline.  Fall protection expert Dr. Nigel Ellis has discussed the parapet solution through all 3 editions of his Introduction to Fall Protection book (1988, 1993, 2001).  On May 2, 2003, OSHA published a proposed rule change for Subparts D and I of 29CFR1910.  At proposed Appendix A –  Fall Protection Systems,   you will find the following schematic with formula: 

I emailed Dr. Ellis recently to see if he still used this 30-inch + 18-inch rule – he calls it a flopguard.  He advocates that we all start using a 45-inch minimum high guardrail system – people around the world are getting taller!   Thanks, Dr. Ellis. It is great being able to converse with an expert.

So, to wrap up this blog, I want to say that I really do enjoy researching these fine points for our clients and I’ve got a list of them – almost all of which will make great future blog topics!  If you have an obscure “rule,” let me know and I’ll add it to the list!