Fall Protection for Competent Persons: Awareness (Construction)

Two things make a competent person

OSHA's construction rules define a competent person as someone who can do two things:

Knowledge without authority is not enough. If you can see the problem but are not allowed to stop the work or change it, you do not meet the definition.

Not the same as a qualified person

A qualified person has a recognized degree, certificate or professional standing, or extensive knowledge, training and experience, and has shown the ability to solve problems with the subject, the work or the project. In Subpart M, a qualified person handles design work, such as horizontal lifelines and fall protection plans.

Reference: 29 CFR 1926.32(f) · 29 CFR 1926.32(m) · 29 CFR 1926.502(d)(8) · 29 CFR 1926.502(k)(1)

Where Subpart M calls for a competent person

The fall protection rules name a competent person for these jobs:

• Training: each employee must be trained, as necessary, by a competent person qualified in the listed fall protection topics.
• Equipment after a fall: a personal fall arrest system that has caught a fall comes out of service until a competent person inspects it and decides it is undamaged and fit for reuse.
• Safety monitor: when a safety monitoring system is used, the employer must designate a competent person to watch the workers.
• Fall protection plans: putting a plan into action must be supervised by a competent person.
• Safety nets: when a drop test is unreasonable, the employer or a designated competent person can certify the net installation in a written record instead.

Reference: 29 CFR 1926.503(a)(2) · 29 CFR 1926.502(d)(19) · 29 CFR 1926.502(h)(1) · 29 CFR 1926.502(k)(4) · 29 CFR 1926.502(c)(4)(ii)

The 6-foot rule

In construction, a worker on a surface with an unprotected side or edge 6 feet or more above a lower level must be protected by one of three conventional systems:

Watch for these too

• Holes: a hole is a gap of 2 inches or more at its smallest dimension. Protect workers from falling through holes (including skylights) more than 6 feet above a lower level with covers, guardrails or fall arrest, and use covers to keep people from tripping or stepping into them.
• Dangerous equipment: below 6 feet, workers above dangerous equipment still need guardrails or equipment guards so they cannot fall into or onto it.

Scaffolds, ladders and stairways, steel erection and some other work have their own fall protection rules in other subparts.

Reference: 29 CFR 1926.501(b)(1) · 29 CFR 1926.501(b)(4) · 29 CFR 1926.501(b)(8) · 29 CFR 1926.500(a)(2) · 29 CFR 1926.500(b) "Hole" · 29 CFR 1926.500(b) "Guardrail system" · 29 CFR 1926.500(b) "Personal fall arrest system"

Before anyone goes up

Your checks start before the work does.

• Is the surface strong enough? The employer must determine that the walking or working surface has the strength and structural integrity to hold workers safely. No one works on it until it does.
• Is protection in place first? Fall protection must be provided and installed before the worker begins the work that needs it, not halfway through.

Falling objects

When workers are exposed to falling objects, each must wear a hard hat, and the employer must also do one of these:

• Put up toeboards, screens or guardrails to stop objects falling from above
• Put up a canopy and keep materials far enough from the edge that they cannot go over
• Barricade the area below, keep people out, and keep materials back from the edge

Reference: 29 CFR 1926.501(a)(2) · 29 CFR 1926.502(a)(2) · 29 CFR 1926.501(c)

Inspect a guardrail

Here is a guardrail along a floor edge.

Top rail

Top edge 42 inches, plus or minus 3 inches, above the walking/working level. It must hold at least 200 pounds applied outward or downward within 2 inches of the top edge, and under that downward load it must not sag below 39 inches. If workers use stilts, raise it by the height of the stilts.

Midrail

Needed (or screens, mesh or similar members) when there is no wall or parapet at least 21 inches high. A midrail goes halfway between the top edge and the walking/working level and must hold at least 150 pounds downward or outward.

Toeboard

When used to stop falling objects: at least 3½ inches tall, no more than ¼ inch gap at the bottom, and able to hold at least 50 pounds downward or outward.

Rail material

Top rails and midrails must be at least ¼ inch thick or in diameter. Steel or plastic banding is never allowed as a rail. Wire rope used as a top rail must be flagged with high-visibility material at least every 6 feet.

Simplified drawing for training only.

Reference: 29 CFR 1926.502(b)(1) · 29 CFR 1926.502(b)(2) · 29 CFR 1926.502(b)(3) · 29 CFR 1926.502(b)(4) · 29 CFR 1926.502(b)(5) · 29 CFR 1926.502(b)(8) · 29 CFR 1926.502(b)(9) · 29 CFR 1926.502(j)(2) · 29 CFR 1926.502(j)(3)

Hole covers and safety nets

Covers

A loose sheet of plywood over a hole is a trap. A proper cover is:

• Strong: able to hold at least twice the weight of the workers, equipment and materials that could be on it at one time. In roadways and vehicle aisles, at least twice the maximum axle load of the largest vehicle expected to cross it.
• Secured: fastened so wind, equipment or workers cannot knock it out of place.
• Marked: color coded or marked with the word HOLE or COVER.

Safety nets

• Install them as close as practical under the work surface, and never more than 30 feet below it.
• Inspect them at least once a week, and after anything that could affect them. Do not use defective nets.
• Remove tools and debris that fall into the net as soon as possible, and at least before the next shift.

Reference: 29 CFR 1926.502(i)(1) · 29 CFR 1926.502(i)(2) · 29 CFR 1926.502(i)(3) · 29 CFR 1926.502(i)(4) · 29 CFR 1926.502(c)(1) · 29 CFR 1926.502(c)(5) · 29 CFR 1926.502(c)(6)

Anchorage, harness, connectors

A personal fall arrest system is only as good as its weakest part. Check each one.

Reference: 29 CFR 1926.502(d) · 29 CFR 1926.502(d)(5) · 29 CFR 1926.502(d)(15) · 29 CFR 1926.502(d)(17) · 29 CFR 1926.502(d)(23) · 29 CFR 1926.502(d)(18)

Stopping the fall, and after

When it stops a fall, a personal fall arrest system used with a body harness must:

• Limit the maximum arresting force on the worker to 1,800 pounds
• Be rigged so the worker cannot free fall more than 6 feet, and cannot hit any lower level
• Bring the worker to a complete stop within a deceleration distance of 3.5 feet

Every day

• Inspect before each use for wear, damage and other deterioration. Take defective parts out of service.
• After a fall, remove the system right away until a competent person clears it.
• Plan the rescue. The employer must provide for prompt rescue after a fall, or make sure workers can rescue themselves.

Reference: 29 CFR 1926.502(d)(16) · 29 CFR 1926.502(d)(21) · 29 CFR 1926.502(d)(19) · 29 CFR 1926.502(d)(20)

Roof work, warning lines and safety monitors

A low-slope roof has a slope of 4 in 12 or less. A steep roof is steeper than 4 in 12.

• Roofing work on low-slope roofs (unprotected sides and edges 6 feet or more up): guardrails, safety nets or fall arrest, or a warning line combined with one of those or with a safety monitoring system. On roofs 50 feet wide or less, a safety monitoring system alone is allowed for roofing work. Other work on a roof that is not roofing work follows the general 6-foot rule.
• Steep roofs: guardrails with toeboards, safety nets or personal fall arrest.

Warning lines

Set up around all sides of the roof work area, at least 6 feet from the edge when no mechanical equipment is used. The line's lowest point, including sag, must be at least 34 inches high, and its highest point no more than 39 inches.

Safety monitors

The monitor must be a competent person who can recognize fall hazards, warns workers who seem unaware or unsafe, stays on the same surface within sight and talking distance, and has no other duties that pull attention away.

Reference: 29 CFR 1926.500(b) "Low-slope roof" · 29 CFR 1926.501(b)(10) · 29 CFR 1926.501(b)(11) · 29 CFR 1926.502(f)(1) · 29 CFR 1926.502(f)(2)(ii) · 29 CFR 1926.502(h)(1) · 29 CFR 1926.500(b) "Steep roof" · 29 CFR 1926.501(b)(1)

Fall protection plans

A written fall protection plan is a narrow option, not a shortcut. It is allowed only for leading edge work, precast concrete erection and residential construction, and only when the employer can show that conventional fall protection is infeasible or creates a greater hazard. OSHA presumes at least one conventional system is feasible, so the employer carries the burden of proving otherwise.

• Prepared by a qualified person, specific to the site, and kept up to date
• Explains why guardrails, nets or fall arrest cannot be used
• A copy with all approved changes is kept at the job site
• Carried out under the supervision of a competent person
• After a fall or a serious incident such as a near miss, the employer investigates and changes the plan if needed

Reference: 29 CFR 1926.502(k) · 29 CFR 1926.502(k)(1) · 29 CFR 1926.502(k)(3) · 29 CFR 1926.502(k)(4) · 29 CFR 1926.502(k)(5) · 29 CFR 1926.502(k)(10) · 29 CFR 1926.501(b)(13)

What the training must cover

The employer must train each employee who might be exposed to fall hazards to recognize those hazards and follow the procedures that reduce them. The trainer must be a competent person qualified in these areas, as they apply:

• The nature of fall hazards in the work area
• The right way to put up, maintain, take down and inspect the fall protection systems being used
• How to use guardrails, fall arrest, nets, warning lines, safety monitoring, controlled access zones and other protection
• Each worker's role in a safety monitoring system, when one is used
• Limits on mechanical equipment during roofing work on low-slope roofs
• Handling and storing equipment and materials, and putting up overhead protection
• Each worker's role in fall protection plans
• The standards in Subpart M

Reference: 29 CFR 1926.503(a)(1) · 29 CFR 1926.503(a)(2)

Records and retraining

The written certification record

The employer proves the training happened with a written record that shows:

• The name or other identity of the employee trained
• The date or dates of training
• The signature of the person who gave the training, or of the employer

Keep the latest training certification. If you rely on training from another employer, the record shows the date the employer decided that training was adequate.

When to retrain

Retrain anyone who no longer seems to have the needed understanding and skill. This includes, for example, when:

• Changes in the workplace make earlier training out of date
• New types of fall protection systems or equipment make earlier training out of date
• A worker's knowledge or use of the equipment shows they have not kept the needed understanding or skill

Reference: 29 CFR 1926.503(b)(1) · 29 CFR 1926.503(b)(2) · 29 CFR 1926.503(c)

Common test questions

What kind of person must a safety monitor be?

A competent person who can recognize fall hazards, on the same walking/working surface and within sight of the workers.

Rule: 29 CFR 1926.502(h)(1)

At what height is fall protection required in construction?

6 feet or more above a lower level at an unprotected side or edge, by guardrails, safety nets or personal fall arrest systems.

Rule: 29 CFR 1926.501(b)(1)

Practice these in the course