Question #1:
Is an employer, having employees exposed to fall hazards while performing
a listed group activity of the new interim policy, required to have a verbal fall protection plan?
Answer:
Yes, and failure to have such a plan would prompt the CO/IH to
recommend citations regarding the specific standard
covering the exposure. Example: If employees were engaged
in exterior wall installation and the employer did not
have any fall protection plan, then exposures
to fall hazards noted proximate to unprotected floor
edges would be cited under 29 CFR 1926.501(b)(1).
Question #2:
Are employees required to be trained in the requirements of the plan?
Answer:
Yes, and failure to train employees regarding a fall protection
plan would be a violation of 29 CFR 1926.503(a)(1).
Keep in mind this would preclude any use of the Interim
Fall Protection Guidelines and result in a violation
of the specific standard under Subpart M relating to their fall exposure.
Question #3: Is an employer required to have fall protection training certified?
Answer:
Yes, failure to provide such certification to a CO/IH requesting
such would prompt the CSHO to recommend citations under
29 CFR 1926.503(b)(1). This violation does not preclude
the use of the Interim Fall Protection Guidelines.
Question #4:
Is an employer, having employees exposed to fall hazards while performing
any listed group activity, required to have the plan's competent
person at site while employees are exposed to fall hazards?
Answer:
Yes, the plan=s competent person must be at the site when employees
are exposed to falls. Failure to comply with this provision
would prompt the CO/IH to recommend citations regarding
the specific standard covering the exposure. Example:
If the competent person is not on site and employees
are installing roofing material, a citation of 29 CFR
1926.501(b)(10) or .501(b)(11) shall be recommended, depending upon the roof slope.
Question #5:
If an employer has employees exposed to fall hazards while performing a
Group 1 activity located 20' above ground but due to a basement
excavation, the maximum fall potential at that area is 27', has a violation been committed?
Answer:
Yes, the CO/IH shall recommend citations relative to the specific
exposure. Example: If the CO/IH witnesses employees
performing exterior wall installation proximate to unguarded
edges having maximum fall potentials greater than 25'
then the CO/IH shall recommend a citation of 29CFR1926.501(b)(1).
Question #6:
If an employer allows employees to traverse/work from a concrete block
wall having a maximum fall potential greater than 13', or
allows exposures on a concrete block wall that is only 12'
tall, but is not adequately braced, has a violation been committed?
Answer:
Yes, cite 29 CFR 1926.501(b)(13) for the exposure where the maximum
allowable height has been exceeded; cite 29 CFR 1926.706(b)
as well as 29 CFR 1926.501(b)(13) for exposures occurring
on walls not braced that are greater than 8' in height,
and cite 29 CFR 1926.501(b)(13) for exposures on walls
less than or equal to 8' in height when inadequately supported.
Question #7:
Is an employer that has employees installing truss systems with a maximum
fall potential greater than 48' using the Interim Fall Protection
Guidelines in violation of the law?
Answer:
Yes, cite 29 CFR 1926.501(b)(13). The company needs a written
fall protection plan in accordance with 29 CFR 1926.502(k)
or conventional fall protection.
Question #8:
Is an employer that has employees installing a roof deck on a 10 in 12
slope surface with a ground to eave distance less than 25'
and having slide guards spaced every 4' in violation of the law?
Answer:
No, during roof decking operations employees can work regardless
of slope as long as they provide slide guards in accordance
with the new policy (in this case every 4 feet).
Question #9:
Is an employer that has employees storing roofing material within 6' of
rake edges during roofing operations in violation of the law?
Answer:
Yes, cite 29 CFR 1926.501(b)(10) or .501(b)(11) depending upon
the slope of the roof.
Question #10
If an employer allows employees to perform the installation of all floor
joists while standing upon the top plate, but has a fall
protection plan, is the employer in violation of the law?
Answer:
Yes, the employees must install the first four joists from scaffolds/ladders
at ground level, then establish a temporary deck in
order to install ensuing joists. Employees performing
this task from plates would result in the issuance of
a citation under 29 CFR 1926.501(b)(13).
Question #11:
Is an employer required to provide a monitor while employees are installing
exterior wall systems even when a painted warning line has
been established?
Answer:
Yes, cite 29 CFR 1926.501(b)(1) for noncompliance.
Question #12:
Can an employer use a painted warning line, 6' away from the edges of an
unguarded floor hole and the presence of a monitor, in order
to protect employees from falling through the hole during exterior wall installation?
Answer:
No, cite 29 CFR 1926.501(b)(4)(i or ii) depending upon whether
a falling-through hazard exists or whether a stepping-into
hazard exists.
Question #13:
If an employer installs 5 courses (rows) of shingles before introducing
slide guards at the eave area, has a violation of the law occurred?
Answer:
Yes, but only if employees installed the 4th and 5th
courses of shingles from the roof deck. If ladder jack
scaffolds are used, and the height of the scaffold is
less than 10' above ground, employees can establish
as many courses of shingles as they can reach without requiring any fall protection.
Question #14:
If employees performing roofing operations are observed on a 7 in 12
sloped surface that is provided with slide guards spaced
every 10 feet, has a violation occurred?
Answer:
Yes, cite 29 CFR 1926.501(b)(11). Slide guards on roof slopes
greater than 6 in 12 are required to be spaced every 8 feet.
Question #15:
If employees are performing roofing activities on an 8 in 12 sloped roof
that has slide guards spaced every 8' on a roof that has
an eave to lower level height of 30', has a violation been committed?
Answer:
Yes, since the use of conventional fall protection systems are
required regardless of slope when eave height exceeds
25' measured from lowest level (29 CFR 1926.501(b)(11)).
Question #16:
If employees are observed climbing throughout the webbing of trusses
that are not adequately braced (in accordance with HIB-91)
and located 15' above ground, has a violation occurred?
Answer:
Yes, two violations at a minimum. Under the General Duty Clause,
trusses must be adequately braced to guard against collapse/crushing
hazards and the fall hazard itself of traversing within
unstable trusses would be covered under 29 CFR 1926.501(b)(13)
and possibly 29 CFR 1926.501(a)(2) if truss failure
had occurred while employees were walking within the webbing.
Question #17:
When does a roof become a roof?
Answer:
As has been the previous policy, a roof does not become a roof
until the sheathing has been completely installed. Note:
Houses with roofs not contiguous with the main roof
(i.e., dormers, garage) would be considered separate roofs.
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