ADOSH Adopts Federal Fall protection Standard for Construction.
For the last two years ADOSH (Arizona Department of Occupational Safety and Health) has been in a legal struggle with FederalOSHA concerning their (ADOSH) “Residential Fall Protection Standards” or CFR 29 1926.500 or Subpart M. You may remember that in 2010 OSHA rescinded STD 03-00-001 which had provisions that allowed various types of fall protection or the lack of fall protection for home building.
ADOSH adopted new residential fall protection standards that were less restrictive than the federal standards. After which OSHA filled legal proceedings concerning Arizona’s State plan not adequately enforcing the Federal standards. So after many briefs and fillings and legal wrangling, as of February 6th, 2015 OSHA has rejected the Arizona State Plan of enforcement for Residential Fall protection. The official notice can be found at the ADOSH Main page or here; CLICK.
So if you work residential framing in Arizona and have taken Fall Protection Classes under the ADOSH standard you should arrange to retrain on the OSHA standard.
Here is a copy of the 2010 Residential Fall Protection Fact Sheet.
For Arizonans the rule to remember is that if you are above 6′-0″, you need a Fall Prevention/Protection system, period. There may be circumstances that allow you to use an alternate system, but you must document them and ensure that OSHA will accept the alternate and have a Fall Protection System in place. Under the ADOSH rule there were circumstances that allowed you to be as high as 15′ without a Fall Protection System in place. An alternative system does not include not having an FPS in place.
For the regulations concerning Residential Fall Protection visit the OSHA website at www.osha.gov and look at the “Regulations” tab under Construction” or simply click HERE to see the Subpart M Fall Protection.
For those of you whom have attended and OSHA Outreach Construction 10 or 30 hour class, you where taught the Federal OSHA standards and should already be aware of the rule.
At the end of the day, by requiring ADOSH to conform to the Federal Standard, OSHA has simplified training and understanding of the fall protection rules. I spent a lot of time reading the briefs of both OSHA and ADOSH. Truthfully I do believe ADOSH did have an argument towards the rules they adopted. The problem though was in that when you have a migratory work force in residential construction like we have in the United States, you must have some level of consistency in the Federal Standards and the State Plans of those states that have their own plan (such as Arizona). In order to create a State Safety Plan, the State has the burden of enforcing the minimum standard, or the Federal OSHA standard. State plans may elevate a standard and companies can elevate company policies, but the bare minimum is CFR 29.
If you need retraining you can contact us here at AzSafetyPlus.com to arrange for refresher training or initial training concerning the Federal OSHA Residential Fall Protection Standards. Falls are one of the most common workplace injuries in construction. Get your employees training on how to work safely at heights. As an employer you will benefit from safe employees and so will the families of the worker.
Be Safe at heights.