Fall Protection Systems
Inside this Article
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Working at height presents one of the greatest dangers to PV installers on the jobsite. If fall protection is not properly addressed, workers are put at risk while performing their duties, and employers are in violation of worker safety laws.
According to preliminary data provided by the Bureau of Labor Statistics, 635 workplace fatalities from falls occurred in 2010, down from a high of 847 in 2007. Of all the industries tracked, construction had the highest number of total fatalities in 2010— and 260 of the 751 construction fatalities recorded last year were the result of falls.
While these statistics are sobering, they tell only part of the story. The majority of workplace accidents are not fatal, but instead cause injuries resulting in lost worker income, lost company revenue, increased insurance rates and potentially lifelong health problems for injured workers. Understanding the hazards present on the jobsite and addressing them through proper training, planning and safe work practices is in the best interests of both employers and employees.
In this article I outline the laws and best practices for fall protection systems under federal Occupational Safety and Health Administration (OSHA) regulations. Some states have their own laws and rules of procedure that conflict with federal standards and require clear interpretation and guidance from state authorities. Where a state workplace safety program is in place, those laws take precedence over federal OSHA law. OSHA inspectors have historically considered PV installation to be a construction operation, regardless of any similarity to other classifications like roofing.
This article is intended solely to bring awareness to the risks and regulations governing fall protection in the workplace and is not a substitute for proper hazard evaluation, planning and training. You should use this article for reference only and research the laws applicable in your state.
OSHA Fall Protection Standards
Every employer should be intimately familiar with the requirements of the OSHA regulations governing the work they perform. The following is a brief introduction to the fall protection standards governing PV installations.
The Code of Federal Regulations (CFR) Part 1926, Title 29, applies to the construction industry in general, including PV installation activities. “Part 1926—Safety and Health Regulations for Construction,” or OSHA Standard 29 CFR 1926, includes 30 subparts (Subpart A through Subpart DD). Subpart M specifies fall protection requirements for the construction industry. Within Subpart M, there are four standards (1926.500 through 1926.503) and five optional appendixes (1926 Subpart M App A through 1926 Subpart M App E).
The specific standards that make up the federal OSHA requirements found in “1926 Subpart M—Fall Protection” are:
The OSHA website (osha.gov) contains the complete text for OSHA Standard 29 CFR 1926, including the fall protection regulations and recommendations found in Subpart M.
When to Use Fall Protection
Standard 1926.501 requires that employers provide fall protection systems whenever workers are exposed to fall hazards of 6 feet or greater to the ground or a lower level. This not only includes roofs in general, but also all unprotected roof sides and edges, leading edges, skylights, openings greater than 2 inches in their least dimension, work platforms, aerial lifts, hoist areas, excavations, formwork and reinforcing steel, ramps, runways and other walkways, dangerous equipment, and walking or working surfaces not otherwise addressed. Skylights are commonly overlooked fall hazards in rooftop PV installations and can sometimes be difficult to cover or protect. Other areas that present fall hazards—scaffolds, ladders, steel erections, cranes and so on—are covered in more detail in dedicated CFR 1926 subparts.