Construction Fall Safety Stand-Down – Pt 2
Matt McNicholas, OSHA Safety And Health Specialist
Fall prevention. Employers have a huge obligation to prevent injuries and deaths. Matt McNicholas, CSP, of OSHA, details the second annual Construction Fall Safety Stand-Down, designed to create fall awareness. The nationwide event is May 4-15, 2015.
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In this podcast, Matt describes the three main responsibilities of an employer: Planning ahead to get the job done safely; providing the right equipment; training the exposed employees on how to use equipment safely.
Mr. McNicholas also explains facts about anchorage points, warning lines, designated areas and control zones.
In this podcast Matt also tells host Dan Clark about construction inspections. Matt has done over 1000 site inspections, and been with OSHA for 20 years.
Brandon Nys: Welcome to Safety Experts Talk. Take a look at our website at CreativeSafetySupply.com/podcast for related links in the transcript of this podcast.
Matt McNicholas: I’ve seen leaps and bounds, quite frankly, in terms of fall protection used over the course of my career here. But the bottom line is that, it’s still a leading cause of fatalities in construction, and it’s always in the top 10 issued violations of OSHA citations.
Dan Clark: Falls from height kill more people in construction than any other type of accident—almost 300 fatalities annually—prompting the Construction Fall Safety Stand-Down.
Hello, I’m Dan Clark. Today we’re talking with Matt McNicholas, CSP, Safety And Health Specialist with OSHA in Chicago. He’s been there for 20 years. Hello Matt.
Matt: How ya doin’, Dan?
Dan: I’m well. Thank you. How are you?
Matt: I’m doing great, thanks.
Dan: You had a long history doing construction inspections for OSHA. What is your role now there in Chicago?
Matt: Yeah, my role, I work in our regional office in Chicago. I’m essentially a technical support for our Region Five field staff—our compliance officers that are out doing the inspections. If they need any assistance, interpretations on information, information on regulations and what have you, I’m there to help them. If they need help out the field, to go on site for some more difficult type inspections, that’s one of my roles also.
Dan: Oh, so you’re, kind of, like the encyclopedia of the Chicago office, then.
Matt: I do my best!
Dan: Oh, that’s good. Well, this is the second annual Construction Fall Safety Stand-Down.
Dan: May 4th through the 15th of this year, 2015. Give us a little background on the reason for the Stand-Down.
Matt: Sure. Yeah, the purpose of the Fall Stand-Down is to raise awareness of preventing fall hazards in the construction industry. As you said, falls have been one of the leading causes of fatalities in the construction industry for years. With the start of the construction season approaching us here, this is a great time to get the word out.
Dan: Well, I understand that you went to the first Stand-Down there in the Chicago area. Tell me about what a typical Stand-Down might be like, and what did you experience last year?
Matt: The one I went to was in a suburb of Chicago. A general contractor was responsible for coordinating it. They simply had a toolbox talk on fall protection. We got there early morning. We went into their trailer and they brought all the workers in. Their safety director for the company just talked about fall protection in general and then specifically for their job and what was expected of them. And then my role was just to, kind of, reinforce the Stand-Down and what OSHA looks for in terms of fall protection, and just to essentially applaud them for their efforts of, like you say, paying these people to take a break from work and receive a little bit of training.
Dan: What should employers do in these Stand-Downs, and how long should they be?
Matt: It’s pretty open to the employer. Participants can simply take a break to conduct toolbox talk, like the job I was on last year to go over fall protection activities going on on their jobsite. I know other employers had had everybody bring their fall protection equipment to an area and they checked all the equipment to make sure it was in good shape and just generally discuss job specific hazards related to falls. And I know there were some instances last year also, the participants had a fall protection sales vendor come to their job site and put on a demonstration of a fall event. The bottom line is that it should provide an opportunity for employers and workers to talk about fall hazards and the means and methods of protection utilized on their jobsite.
Dan: If an employer doesn’t participate, and the employee is saying “hey, you know what? I really need to know about fall protection.” Are there ways that OSHA can provide any information during the Fall Stand-Down?
Matt: Absolutely. An employer always has the responsibility to provide the training to their employees on the jobsite. But if they’re looking for something more, anybody could visit our website, OSHA.gov. It has a plethora of information on the requirements and different means and methods of fall protection. If they don’t want to reach out to OSHA, they can also reach out to their various unions or trade associations that they may be affiliated with.
Dan: Right. I want to get into little bit about the nuts and bolts of fall protection, maybe for the first time safety manager or maybe a new employee has never really had to use any fall protection.
Matt: Yeah, sure. With a few exceptions, fall protection is needed in the construction industry when employees are exposed a fall of six feet or more to lower levels. That’s all explained in OSHA’s subpart M portion of our construction standards. In order to comply with the requirements, there’s three things we really want employers to do to ensure that employees are protected.
○ One is that you have to plan ahead to get the job done safely.
○ Second is that you provide the right equipment.
○ And third is that you train the exposed employees on how to use the equipment safely.
By doing those three things, you don’t get caught short of having an employee exposed to hazard and not being prepared to eliminate it.
Dan: Six feet is the limit.
Matt: That’s right. There are a few exceptions, though, in different industries. Steel erection has a different limit for fall protection, for example. But, for the vast majority of workers it’s going to be six feet.
Dan: Okay. So, fall protection includes guardrails, nets, things like that.
Dan: When should the guardrail system be used?
Matt: Well, there isn’t a specific time when a guardrail has to be used. It’s an option to be used when you get to that six-foot threshold limit.
Dan: And safety nets. Are they always appropriate?
Matt: That’s the same thing. That, that is one option. In my 20 years of experience, you don’t see safety nets regularly. The majority of times I’ve that during my inspections were during steel erection activity of a structural steel building or during bridgework. But, that is one of the options for fall protection.
Dan: One of the downsides is that the nets get in the way of the actual progress of the work, right?
Matt: There’s a number of reasons. It just isn’t practical sometimes, based on where they’re installed. There’s equipment, or materials, or something underneath where you’re working that you can’t just make a safety net work. When you get into the steel erection activities, bridge activities, that’s when you have very little around you for fall protection. You have many open spaces, and the nets become more practical.
Dan: Right. If you have fall protection systems, how are the attachment points identified?
Matt: Well, according to OSHA, subpart M, in our construction standards, an anchorage point for a personal fall arrest system has to be capable of supporting at least 5000 pounds per employee attached to the anchorage, or designed by a qualified person to maintain a safety factor of at least two, considering what the forces imposed on that fall arrest equipment’s going to be. So the bottom line is that you have to have somebody that’s qualified to know that this system can be used as intended.
Dan: When you say 5000 pounds of stress, when I hear about a 240 pound construction worker needing a 5000 pound test line . . . the first I heard about that I thought “That can’t be right.” But go ahead and explain why that is.
Matt: Well, the 5000 pounds is, kind of, a general number I think OSHA threw out there. If you don’t want to do all the calculations, with the help of an engineer or a qualified person, they felt that a 5000 pound anchorage point was adequate to hold the average worker with any tools they may have on them.
But, again, the other option is to have a qualified person design the anchorage point where it may be less than 5000 pounds, but, based on the forces that they intend that anchorage point to hold, they could design their own system with that safety factor of two built into it.
Dan: I see. If the construction worker falls, obviously at the very top of the fall, he’s still weighing 240 pounds. But when he reaches the 6 feet . . .
Dan: . . . that’s what the 5000 pounds for, then.
Matt: Absolutely. Yeah, there’s a lot more force from when you first start to fall, when there is no tension on that anchorage or your personal fall arrest system, compared to when that lanyard—or whatever you’re wearing—becomes deployed. The forces are very, very different. So, hence the 5000 pounds or designing the system with the safety factor.
Dan: Right. When you have an employer who is to provide the fall protection, and the training that goes with it—but they may not be well qualified to give that training—how are they to provide that? I mean, do they have to go out and get qualified and certified?
Matt: Well, we don’t specifically state on who have to provide the training. Under OSHA standards, in 1926.503, “employer to provide the training,” how that is done would be left to the employer.
Matt: Whether they have a qualified person in-house that can do that for them, or they bring somebody out to their job site or into their workplace to determine what type of work they’re doing, what kind of falls they’re exposed to, and have that individual provide training. But, how it’s done is not specifically stated in the OSHA requirements, or who does it. But the employer is responsible for having it done.
Dan: Oh, okay. As long as he has someone that is, to train his staff, then everything is fine.
Matt: Correct. The end result is to have the employees trained to able to recognize the hazards and eliminate the hazards. And however that’s done is up to the employer.
Dan: Okay. Please explain warning lines, designated areas and control zones.
Matt: Sure. The warning lines and control zones are options for fall protection in OSHA, subpart M, the fall protection and construction standards. And they’re only allowed on very limited basis.
For example, warning lines can only be used when you are doing roofing work. A roofing contractor doing flat roof work. Flat roof work is defined as a pitch of a roof less than 4 in 12. When there’s a company doing flat roof work, they are allowed to use warning lines which typically have to be installed six feet back from the edge of the roof. Now, when they’re working within those flags, there’s no means of fall protection required. When they go past those flags, towards the edge of the roof, the regulation spells out various types of fall protection that are required for those employees outside of those flags working towards the edge of the roof.
Control lines are used, again, only during certain activities, being precast concrete erection work, overhand bricklaying work, in certain residential homebuilding activities. In that case, the control line is set up behind the work where only the people allowed within those control lines are the workers involved in the work where the fall hazard exists. Typically the means of abatement of fall protection would be you have a safety monitor present that has the sole duty of watching these employees engaged in their work, and notifying them if they’re getting into situations that are hazardous.
Dan: Does he have to use an OSHA approved whistle to make sure everybody can hear him?
Matt: No, he just has to have a loud voice, which most construction workers do, when push comes to shove, I guess.
Dan: Yeah! Well, Matt, I have to ask you about your history in falls. Have you fallen yourself?
Matt: No, I have not luckily. Well, I guess, when I was a kid, out of trees and maybe out of bed. But, ah, but no. Not anytime recently as an adult, luckily.
Dan: Oh, that’s good. Have you witnessed falls?
Matt: I have not personally witnessed a fall either, luckily.
Dan: Well, great. Now let’s look back when you were an inspector. What would happen at a jobsite? Was the contractor all panicked; the employees running around crazy?
Matt: Well, over 12 years of being in the field and close to 1000 inspections, behaviors were various. We never tell anybody we’re coming to a job site. Everything is always unannounced.
Matt: Many inspections we did you can see, in plain view, that employees were exposed to the fall, and that’s what prompted the inspection.
There’s certainly the element of surprise when you walk on a job site and inform the employee that you’re with OSHA. Many times they know they were wrong, begin apologizing and showing the equipment they had that was in a trailer, or in their car, or what have you.
And then, quite frankly, there are instances over the years where you meet people and they really didn’t know what the rules were. And didn’t have a clue as to what they were going to do. They certainly understood that they were exposed to a fall, but weren’t sure what the requirements were.
That’s why we’re here. Besides, you know, enforcing rules, we’re also here to provide the outreach. Hence this Fall Stand-Down. We’re hoping to reach out to these millions of workers and many of them that may not know what the rules are.
Dan: What kind of effect do you think this outreach will have? You had 1 million workers contacted last year. 3 million expected this year. What kind of effect do you think that’s going to have on the fall rate, and the fatality rate?
Matt: Well, I guess the proof is in the pudding. I mean, when we get our statistics, we find out. But, I would just hope that it just becomes more of a second nature with fall protection. And, again, I’ve seen just leaps and bounds, changes, quite frankly in terms of fall protection used over the course of my career here with OSHA. The word’s really getting out. I think a lot of it taught now in apprenticeship schools, in different trade associations. Falls are just becoming a regular part of the business. Fall protection, I should say.
You see people in harnesses now. That’s just a regular part of their equipment that you never did before. So, reaching out to 3 million people and with the advertising that OSHA’s involved in this—on a friendly level—I think it just brings us, and the industry, just closer together.
Dan: I think it’s probably similar to the use of seat belts, because, it used to be, that no one used seat belts. You know, I mean the laws were passed that they’re required but there was so much of a macho attitude, “ah, I don’t need a seat belt.” Now, I mean, I can’t think of anybody that doesn’t wear one.
Matt: I agree with you. I mean, everybody wears a seatbelt now, myself included, whether I drive a block down the street. I think I do it just not even realizing I’m putting it on, and I do that.
And I do see that in the industry now. But the bottom line is that, it’s still a leading cause of fatalities in construction, and it’s always in the top 10 issued violations of OSHA citations. So, there’s still a lot of work to do. I think it’s really come leaps and bounds over the years, but that we still have a lot of work to do. And that’s the point of this Stand-Down and, in particular, extending it to two weeks to really get the word out there.
Dan: Great. Well, any final thoughts on preventing falls?
Matt: Well, I just think that the employers really have an obligation. That’s what, when I was in the field for many years, I always tried to impress that on the employer. The most important thing, I think, you can do is pre-plan a job.
I was on so many inspections where there were issues with fall protection, and, in speaking with the exposed employees, they’d relayed that they showed up on the job at seven in the morning. They were told to go to a specific location on the job. Lo and behold, they show up and there is a fall hazard through a hole, or off the end of the building, or something like that. Many of them just didn’t want to stop to take the time to find out how they could properly protect themselves and set up the systems, and set up equipment. They just want to get the job done.
So, I really think that employers have to focus on engineering fall hazards out of a project, whether that be in the design phase of a project, or, if that isn’t feasible, just being a step ahead of the game and knowing where these employees are going to be in the next day or two. And ensuring that the proper fall protection is going to be there for them when they get ready to work so there are no questions asked and they don’t get slowed down.
Dan: So, that employer or manager has to have eyeballs on the site and keep a close watch.
Matt: Absolutely. An employer has a large obligation, and that goes to the site management in particular. When your foremen are the people representing the company out there. They’re the ones that are out there 8, 10, 12 hours a day. As far as OSHA’s concerned, they are managers, and managers have a responsibility to ensure the safety of the employees on the jobsite.
Dan: Matt, this has been extremely informative and it’s really been great to hear your insight on fall protection and the Fall Safety Stand-Down. Thanks so much.
Matt: Dan, I appreciate the opportunity. Thank you.
Dan: Thank you. Our guest has been Matt McNicholas, CSP, Safety And Health Specialist with OSHA from his Region 5 office in Chicago. Thanks for joining us. I’m Dan Clark.
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Brandon: Thank you for joining us on Safety Experts Talk. If you have suggestions for future podcasts, send them to firstname.lastname@example.org. For more safety experts talking about safety news, OSHA regulations, PPE, lean, 5S, or Continuous Improvement, go to CreativeSafetySupply.com/podcast.
Scaffold, workers in hard hats image by US Navy / Jesse Lora 2012
Mr. McNicholas’ photo courtesy of OSHA