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OSHA’s New Fall Protection Standard

Words: Philip Adiarte OSHA’s new Fall Protection Standard, which became effective February 6, 1995, requires fall protection for workers at six feet or more above any lower level. The final rule covers all construction workers except those erecting structural steel. Previous OSHA regulations fell short of addressing many operations in which guardrails, safety harnessing equipment or nets aren’t feasible or pose a greater hazard. For the masonry contractor, compliance with the new rule is not very difficult.

The majority of masonry construction is performed from scaffolding or by the overhand method from an unprotected floor edge.

Scaffolds

The new fall protection standard doesn’t address work from scaffolding. A new scaffold safety standard is expected to be promulgated by OSHA in the near future. It’s very probable that any new scaffold standard will require guardrails to be installed when the working height reaches six feet. The current standard requires platforms more than ten feet above a lower level to be guarded.

If you are working from built-up scaffolding (tubular welded frame, Morgan-type, or similar), your masons tender’s platforms must currently be guarded on all open sides and ends. The bracketed portion(s) of the scaffold, where masons are building the wall is protected by the masons tender’s platform on one side and the wall on the other.

If you are working from suspended staging, such as Mason’s Adjustable Multiple Point Suspension scaffolding, the same guardrail requirements apply.

Overhand Bricklaying

Although working from the unprotected edge of a floor while constructing a masonry wall without fall protection is inherently dangerous, the MCAA has demonstrated to OSHA that overhand bricklaying and related work cannot be performed with guardrails in the way, and that the use of safety harnesses and nets are unfeasible.

OSHA permits overhand bricklaying to be performed without those “conventional” fall protection methods, provided a “controlled access zone” is established.

Controlled Access Zone (CAZ) means an area in which certain work, (e.g., overhand bricklaying) may take place without the use of guardrail systems, personal fall arrest systems, or safety net systems and access to the zone is controlled.

In a controlled access zone, only personnel critical to construction of the wall are allowed. This includes electricians or other trades who must be present to integrate pipe and/or other building components into the wall while it’s being built.

A controlled access zone consists of the following:
  • A zone where only enough guardrail is removed from the floor edge to accomplish one day’s work;

  • The zone (including all ends) is established by lines or other types of barriers that enclose the work area from the rest of the floor, positioned no more than 15 feet and no less than 10 feet back from the working edge;

  • The lines are secured to uprights (e.g., weighted base stanchions, columns, etc.) and flagged every 6 feet;

  • The lines have a minimum breaking strength of 200 pounds;

  • The lines are no less than 39” and no more than 50” above the floor;

  • Only personnel actually performing overhand work are allowed in the zone;

  • Reaching more than ten inches below the walking and working surface requires that employees be tied off or protected by guardrails, nets, etc.
Potential problems in the use of a controlled access zone are:
  • Ensuring other trades, with whom the mason has no contractual relationship(s), and therefore little control, stay out of the zone. Requires coordination with G.C./C.M./Owner.

  • Ensuring that when trades other than the masons are present, (to install electrical conduit, etc.), the work area doesn’t become overly crowded.
OSHA Rules and Regulations are minimum standards. Strict compliance with OSHA won’t guarantee you an injury-free worksite. While OSHA doesn’t require conventional fall protection systems to be used by workers performing overhand work at unprotected floor edges, it makes sense to examine work area(s) before beginning work to determine if suitable anchorage points for the installation of a horizontal lifeline are available.

While mason tenders must be mobile, personnel working on a wall do much of their work from a stationary position. If lifelines are up and out of the way and they don’t pose a tripping hazard, workers can secure their lanyards to the line and be protected from falls.

Fall Protection Plan

  • Prepared by a “qualified” person
  • Maintained at the site
  • State why conventional fall protection methods don’t work
  • Discussion of “supplemental” measures to be taken, e.g. ladders, scaffolding
  • I.D. each location/operation where plan will be implemented
  • Establish a Controlled Access Zone
  • Implement Safety Monitoring System
  • Investigate any “near misses”
  • Implement changes as required
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