Tackling OSHA’s Top 10 Citations: 1926.501 - Fall Protection

Tackling OSHA’s Top 10 Citations: 1926.501 - Fall Protection

Jill James

Jill James

Chief Safety Officer

Jill James brings an unrivaled perspective on risk, regulation and liability. With 14 years of experience as a Senior OSHA Safety Investigator with the State of Minnesota, and nearly a decade in the private sector as a safety program manager, Jill is a passionate advocate for training ROI.

The following is an excerpt from Tackle OSHA’s Top 10.

Hosted by Chief Safety Officer Jill James, you can listen to the webcast on demand.


The interesting thing with fall protection is there's a couple of different fall distance numbers for you to know or remember.

So with the construction industry, any time an employee is exposed to six feet or more of a fall height, then they have to be protected by a guardrail system, a fall arrest system, a safety net system.

Tackling OSHA’s Top 10 Citations: 1926.501 - Fall Protection

So what we're seeing here is someone who's working without the benefit of fall protection, while they're landing that piece of concrete. So this would be a citable hazard. You know, they have their high visibility garment on, which you know, that's lovely, but it's not going to protect them from falling.

Maybe if they're working behind the guardrail system that you see in the photograph as well, that might be better. It's hard to tell on that particular photograph, if that guardrail system is properly constructed, if its top rail is the right height, and if the mid rail, which we can't really see from that angle, if it's the right height as well, so that would be something an investigator's eyes would look for, and if you're in the field of safety, and you're seeing those power lines in the background, I'm looking at those too, and thinking whether or not ... what the close proximity is of that employee to those power lines, and if that power's been disconnected there.

Tackling OSHA’s Top 10 Citations: 1926.501 - Fall Protection

Tackling OSHA’s Top 10 Citations: 1926.501 - Fall Protection

Something the know about this is that whenever you're using a ladder  to access another height, or another level, the ladder needs to extend at least three feet past the landing, so that the employee has something to hold onto, so three feet would be three rungs, assuming each rung is 12 inches between. So I don't know where those ladders are going off to in this particular picture, but it's something to know about the three foot landing.

So other things that my eyes would look for as an investigator, just some typical things in a general industry setting, so any non-construction activity, we'd be looking for four feet, so a hazard of four feet or more in a general industry setting is what the law is on the federal OSHA side, so those would be if you have a loading dock.

Think about a loading dock where maybe the garage door is open and there is not a vehicle inside, so if that loading dock fall height, from the dock to the ground below, is more than four feet, then you have to be protecting the employees who are in that area from falling. Could that be the garage door being closed? Absolutely. Could it be the chain that you often see pulled across a loading dock area? Yes it could, and as long as that chain is at a top rail height, of about 42 inches, and a mid rail halfway between, and it's nice and tight, and there's not a lot of deflection, you can protect people from falling in a loading dock.

Floor holes is another fall item to be looking for, so sometimes in maybe an expanded metal floor, between floors there'll be holes, maybe where a pipe chase used to be that's been taken out. There can be a floor opening or a floor hole that's just even a couple of inches wide, where tools or equipment could fall onto people below. You could be looking for that.

When you're doing your audits, also look for incomplete guardrail systems, so asking your employees where do they have to work? What sort of platforms are they climbing onto to do something? Maybe that's periodic maintenance, or changing out a particular part, and as you're doing your safety audits, be on the lookout for your guardrail systems, and really follow the continuity of a guardrail, to see if there's any gaps, anything that's been taken out, or maybe never was completed, to ensure that you have a top rail and a mid rail, and sometimes a kick plate, or a kick board at the bottom of the guardrail system, especially if there's an opportunity where tools or equipment could fall onto employees working below.

Skylights is a real classic fall hazard. Classic in that sometimes people will think that the skylight can hold the weight of a body, or someone leaning against it, and they're not manufactured for that, unless a particular type of screen has been added to them, so that's something to be mindful of. Often, on a rooftop, you'll see employers installing guardrail systems around skylight openings, to prevent people from going into them.

Then, work platforms is another thing to be asking, just be asking your employees as you're doing your safety audits. You know, "Where do you have to go, that's maybe not routine? Maybe there's something that you're doing in your work activity, or doing maintenance, that you have to get to a particular area. What sort of platform are you using? Where are you climbing to get somewhere, and then how are you protecting yourself from falling in those circumstances?"

So those would be sort of the low hanging fruit, if you will, of things that my eyes would be looking for, with regard to fall protection, so is fall protection training required for employees in the construction industry? Yes it is, and then in the general industry side, we're going to say yes to this one. This is kind of something new, where we really didn't have a lot of hard hitting, "We must do training on fall protection," until the walking-working surface law that you're probably familiar with was just updated, recently, and has a training component now, to do training on fall hazards in general industry settings.