January-February 2021

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34 PalletCentral • January-February 2021 OSHA By Adele L. Abrams, Esq., CMSP Don't Slip Up on FALL PROTECTION This Winter T he Occupational Safety & Health Administration (OSHA) has long placed an enforcement emphasis on prevention of slip, trip and fall (STF) injuries in both general industry and construction. To put it in perspective, about 20 percent of all disabling occupational injuries in the general industry sector result from falls (over 200,000 serious accidents/ year), and OSHA data indicate that 15 percent of all accidental deaths arise from STF incidents, second only to motor vehicles as a cause of fatalities. The Rules When OSHA updated its general industry standard in 2017, it came into alignment with many of the construction provisions but retained a distinct "four-foot" rule as a trigger for when some type of fall protection must be used. By comparison, OSHA uses a five-foot rule for maritime/shipyards and a six-foot rule for construction (plus 15-foot rule for structural steel construction – except in certain "state plan states" such as Maryland). Confused yet? Fall protection violations are now OSHA's most- cited standard, and because there are a lot of specific requirements, an employer can get cited for gaps in workplace inspections, in worker training, provision of personal fall arrest systems, or the improper use/ storage of personal protective equipment (PPE). Occupational STF hazards in the pallet workplace often occur on level surfaces such as floors that are slippery or have trip hazards such as cords, work tools or debris. These often result in non-fatal injuries, but fatalities are possible even at levels below four-feet elevation (the point at which OSHA mandates provision of fall protection – railings, cages, or personal fall protection systems are all options). OSHA does have some exceptions for temporary and infrequent work performed on low-slope roofs, where the person is more than 15 feet back from the unprotected edge. This would cover a worker who might occasionally go to the roof to change an HVAC filter, for example, but would not cover long- term work such as re-roofing or work performed closer to the edge. OSHA's general industry "fall protection" standards also cover worker falls from ladders, scaffolds, towers, aerial lifts, outdoor signs, roof hatches and similar heights, and include specifications for railings on work platforms and stairs, types of stairs, and for harnesses, lanyards and other fall protection system components. Workers must be trained on hazard recognition and mitigation, and work areas must be regularly inspected for slip, trip and fall hazards.

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