Kevin Ian Schmidt

Hazard Communication Program – Example

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According to OSHA, the purpose of the Hazard Communication Standard is “to ensure that the hazards of all chemicals produced or imported are evaluated and details regarding their hazards are transmitted to employers and employees.” The purpose behind the HAZCOM standard is that employers and employees have the right to know the hazards and identities of the chemicals they are exposed to and what precautions can be taken to protect themselves.

All companies have a requirement to comply with the HAZCOM standard, even if it is as simple as using cleaning chemicals.

Categories within the OSHA Hazard Communication Standard:

Hazard Classification

The first category, Hazard Classification (29 Code of Federal Regulations (CFR) 1910.1200 (d)) requires chemical manufacturers and importers to evaluate the chemicals produced in their workplaces or imported by them to determine the hazard classes, and, where appropriate, the category of each class. Mandatory classification considerations are given in 29 CFR 1910.1200 Appendix A (Health Hazard Criteria) and Appendix B (Physical Criteria).

Written HazCom Program

The second category is the Written Hazard Communication Program (29 CFR 1910.1200(e)). It requires employers to fully document the actions taken to comply with all of the provisions of the Hazard Communication Standard and to list the responsible person(s) for each area of the program. A copy of the written program must be made available, upon request, to all employees and OSHA officials.

Check Out: Hazard Communication Plan Explained

Labels and other Forms of Warning

The third category, Labels and other Forms of Warning (29 CFR 1910.1200(f)), requires chemical manufacturers, importers or distributors to ensure that each container of hazardous chemicals leaving their workplace is labeled, tagged or marked to GHS standards.

The GHS is a global hazard communication system developed by the UN that standardizes the way hazardous chemicals are classified and then communicated via safety data sheets and labels.

GHS compliant labels now have six standardized elements:

  1. product identifier,
  2. signal word,
  3. precautionary statements,
  4. hazard statements,
  5. manufacturer information,
  6. pictograms.

 

Safety Data Sheets

The fourth category, Safety Data Sheets (SDSs) (29 CFR 1910.1200(g)) requires that chemical manufacturers, importers or distributors provide SDSs for each hazardous chemical to downstream users to communicate information on the hazards. All of the information on the SDS must be in English and be available to employees working with or near the hazardous chemical. SDSs are now presented in a consistent user-friendly, 16-section format.

Sections of a SDS explained:

  1. Identification includes product identifier; manufacturer or distributor name, address, phone number; emergency phone number; recommended use; restriction on use.
  2. Hazard Identification includes all hazards regarding the chemical; required label elements.
  3. Composition information on ingredients include information on chemical ingredients; trade secret claims.
  4. First-aid measures include important symptoms/effects acute, delayed; and required treatment.
  5. Fire-fighting measures list suitable extinguishing techniques, equipment; and chemical hazards from fire.
  6. Accidental release measures list emergency procedures, protective equipment; proper methods of containment and cleanup.
  7. Handling and storage lists precautions for safe handling and storage, including incompatibilities.
  8. Exposure controls/personal protection list OSHA’s Permissible Exposure Limits (PELs); Threshold Limit Values (TLVs); appropriate engineering controls; and personal protective equipment.
  9. Physical and chemical properties list the chemical’s characteristics.
  10. Stability and reactivity list chemical stability and possible hazardous reactions.
  11. Toxicological information includes routes of exposure; related symptoms, acute and chronic effects and numerical measures of toxicity.
  12. Ecological information provides information to evaluate the environmental impact of the chemical(s) if it were released to the environment.
  13. Disposal considerations provide guidance on proper disposal practices, recycling or reclamation of the chemical or its container and safe handling practices.
  14. Transport information provides guidance on classification information for shipping and transporting of hazardous chemicals by road, air, rail or sea.
  15. Regulatory information provides guidance on classification information for shipping and transporting of hazardous chemicals by road, air, rail or sea.
  16. Other information includes the date of preparation or last revision.
Check Out How to Read an SDS Sheet for more information

Employee Information and Training

The fifth category, Employee Information and Training (29 CFR 1910.1200(h)), requires employers to provide employees with effective information and training on hazardous chemicals in their work area at the time of their initial assignment and whenever a new physical or health hazard is introduced into the area. The training must include methods and observations used to detect the presence or release of the chemical, physical and health hazards, protective measures, labeling and explanation of the SDS.

 

The OSHA Hazard Communication Standard, also known as HazCom, 29 CFR 1910.1200, is a U.S. regulation that governs the evaluation and communication of hazards associated with chemicals in the workplace.

Download & view the Hazard Communication Program – Example below

Hazard Communication Program - example

 

 

Bloodborne Pathogen Plan

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Bloodborne pathogens are diseases that can be carried in the bodily fluids of a person. Employees can be infected in many different ways within the workplace, such as while performing first aid, cleaning up after an accident, or even cleaning the bathrooms.

Many workplaces assume that bloodborne pathogen regulations don’t pertain to them, because they don’t require employees to serve as first responders, but many tasks beyond first aid can put employees at risk. To know if your employees are at risk of potential exposure to bloodborne pathogens, conduct a full job hazard assessment.

Learn how to conduct a job hazard analysis in this post

If it is identified in your workplace job hazard assessment, then your company may be required to have a bloodborne pathogen policy. A quality workplace policy is not all that is required, check out the forms here.

What is the OSHA Bloodborne Pathogens standard?

 

OSHA’s Bloodborne Pathogens standard (29 CFR 1910.1030) as amended pursuant to the Needlestick Safety and Prevention Act of 2000, prescribes safeguards to protect workers against the health hazards caused by bloodborne pathogens. Its requirements address items such as exposure control plans, universal precautions, engineering and work practice controls, personal protective equipment, housekeeping, laboratories, hepatitis B vaccination, post-exposure follow-up, hazard communication and training, and recordkeeping. The standard places requirements on employers whose workers can be reasonably anticipated to contact blood or other potentially infectious materials (OPIM), such as unfixed human tissues and certain body fluids  – Source

Check Out: Understanding OSHA Bloodborne Pathogens Standard

For more information concerning bloodborne pathogens, OSHA has a published fact sheet, available here.

For your convenience I provide the OSHA bloodborne fact sheet in an easy reader below:

OSHA Bloodborne Pathogen Fact Sheet

 

No policy template is all inclusive for a workplace, so I am providing 2 “boiler plate” programs, along with OSHA 3186 model policy for bloodborne pathogens.

Check Out: How to Persuade Your Staff to Wear Personal Protective Equipment

Download the 2 bloodborne pathogen policies below

 

Program 1

 

Program 2

 

Download and view the OSHA 3186 publication for Bloodborne Pathogen Exposure

osha publication 3186

 

 

Spill Response Plan – Training

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Developing an effective Spill Response Plan involves a lot of planning and thinking ahead to manage the worst type of spill that could happen. Take it step by step and decide how to handle each problem. Then obtain the necessary supplies and train all employees in their use. Last, anticipate and plan for a disastrous spill or an event that would trigger the 911 call. Train all employees thoroughly.

Developing A Spill Response Plan

An effective Spill Response Plan requires:

  • A complete evaluation of the work site.
  • Make an emergency evacuation plan for the area, work site, or building.
  • List the chemicals that are stored on-site, as well as their amounts.
  • Determine what constitutes a small spill that can be safely controlled and cleaned up by on-site personnel.
  • Decide what is a ‘large spill’.
  • Decide what will trigger a 911 call or one for the Emergency Response Team or HAZMAT Team.
  • Plan the most effective way to handle any spill that might occur.
  • Develop a recommended Spill Response for each chemical that is on-site.
  • Determine the amount of Spill Kits and containment supplies that will be needed and have them on-site, near the chemical storage area.
  • Determine what Personal Protective Equipment (PPE) will be needed to manage a spill of each chemical.
  • Be sure there is an adequate amount off PPE on hand.
  • Train all workers in the proper use of PPE.
  • Be sure that there are adequate numbers of fire extinguishers on-hand and employees know how to use them.
  • Make a list of emergency phone numbers and post several in highly visible places.
  • Make a list which contains the phone numbers of individuals that are to be contacted in the event of a spill.This should be kept in an area that is easily accessed by all personnel.
  • If different chemicals are added to the on-site inventory, the amount or type of spill containment supplies may need to be increased.
  • Employees and contractors who come on site must all be trained in the Spill Response Plan and how to use spill containment supplies such as drain plugs, dikes and socks to help avoid a release of the spilled chemicals into the environment.
  • Determine reporting requirements to federal, state and local agencies.
  • Designate personnel or a manager to handle this task. Necessary reporting forms should be available on-site.
  • Obtain SDS sheets for all chemicals on site.
  • Have SDS sheets readily available for employee use; this can be in a binder or electronically, as long as employee’s know how to access them when needed.
Check Out: How to Read an SDS Sheet

Employee Training for Spill Response

All employees and on-site contractors must be trained in:

  • Neutralizing and controlling chemical spills
  • Cleaning up hazardous wastes
  • How to use PPE
  • How to use a fire extinguisher
  • Basic First Aid
  • Management of used personal protective equipment (PPE)
  • Disposal of clean up materials
  • Disposal of hazardous waste
  • Handling the reporting requirements of state, federal and local agencies
  • Understanding the use of SDS Information Sheets
  • Understanding how to access SDS sheets in the company’s method of choice
Check Out: Budgeting for Training

Employees should be involved in the development of the Spill Response Plan and be able to recognize a spill that requires a 911 call. They should know the location of spill control supplies as well as spill kits. For the safety of all, every employee and contractor must be well trained and understand the Plan well.

The below training can be given in a classroom presentation, or as part of a self-learning style. Just ensure your company has a subject matter expert to answer questions.

Download & view the Spill Response Training below:

Spill Response Training

 

Powered Industrial Vehicle Policy

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Powered Industrial Vehicles(or Trucks) are used across many industries. Unfortunately many businesses, big and small, fail to follow OSHA guidelines when it comes to these types of machines.

What is considered a powered industrial vehicle?

This can be a piece of equipment that gets power from batteries, propane, gasoline, or other fuel source. The tires can be solid, pneumatic, or cushion. It can be driven inside, outside, or over rough terrain.

OSHA has 7 distinct classes of powered industrial vehicles, and you can see them here.

Electric Motor Rider Trucks is an overly broad classification, let’s look in-depth

Electric Motor Rider Trucks: These are any battery powered vehicle, in which the operator can sit or stand, in which product in handled with forks. Within this class there are many commonly used pieces of equipment:

  • Forklift: this is your standard, sit or stand equipment in which the forks go up and down. Some of these can only go to a height of 10-12′, commonly called a dock stocker for use within semi trailers, or other height limited areas. Some of these trucks can reach 300 inches high, commonly called high reach trucks, these are used in warehouses with high racking. The best and safest of these include cameras near the fork guards, so the operator can see where product is going high up.
  • Reach Truck: these are generally standing operator trucks, and besides the forks traveling up and down, the forks also travel forward, 2-3 feet. These trucks are good in narrow areas, such as warehouse or store aisles. The height of these trucks can range from short(10-12′) or tall(300″).
  • Swing Reach Truck: These are commonly called “Turret Trucks”, in which the operator travels in the air with the load. The forks travel up and down like a standard reach truck, they also move forward like a reach truck, but the forks also swing from side to side, so product can be moved on the sides without turning the truck.

I have forklift training available here, which is important to keeping employees in the workplace safe.

Also, if you’re looking for a bit more for your powered equipment program, I also have PE inspection books published on Amazon

Now, with the equipment better defined, let’s look at the importance of a powered industrial vehicle policy.

A powered industrial vehicle policy is the basis for safe operation of powered industrial equipment within a facility. It establishes standards for operating, training, and discipline. This policy has to be more than lip service, as powered equipment is heavy and dangerous.

The below policy goes further than the basics and includes a short sections on changing/charging batteries, dock safety, and maintenance. This ensures employees are aware of the additional hazards of this equipment.

 

Download & View the Powered Industrial Vehicle Policy below

 

Powered Industrial Vehicle Policy

 

Simple Incident Investigation Policy

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Accidents happen in the workplace. It’s an unfortunate but true fact. In despite of all the hard work companies do to avoid accidents, occasionally something goes wrong. When it does it’s important to conduct a thorough investigation into what went wrong. After all, it’s even more of a tragedy if someone else gets hurt or killed in the same way and there was something that could have been done differently to stop it.

The cause of some accidents is obvious, but that’s not always the case. By following clear and concise steps, investigators can uncover underlying causes of a mishap. An Accident Investigation has two main goals. One is to determine the cause of the accident. The other is to use this information to prevent similar accidents from happening in the future. Everyone in a company should be ready to help investigators solve the investigation. While this may be difficult for some employees, they need to be reminded of the ultimate goal of the investigation – a safer workplace.

How to Investigate an Accident Or Incident in 9 Easy Steps

Get the overall picture by interviewing the people who know most about the accident or incident. This will enable you to carry out a thorough accident investigation.

1) Create the “right” environment. Create an atmosphere of co-operation. Explain reason for the interview- prevention. Ask for person’s help. Ask your questions and listen carefully to the answers. Make notes and draw diagrams.

2) Interview as close as possible to the site of the accident/incident. This helps the accuracy of the witnesses because they are able to point and sometimes demonstrate what actually happened. At this stage, make absolutely certain you know where the witness was standing when the accident or the incident took place. This is because sometimes witnesses could not have seen what actually happened from where they were standing. There is a tendency for witnesses to assume what actually happened, even when they didn’t see it.

3) Discussions should be private When you interview the witnesses, interview them one at a time. This will give you better information and there is no conflict with witnesses arguing about what happened. If descriptions don’t match there is only one option. Re-interview

4) Get the person’s perception of the accident/incident. Make sure that there is no outside influence or bias and as you listen remember to try not to interrupt. At this stage you are gathering information only. There is no need to evaluate the accident or the incident until you have collected all the information possible.

5) Listen more than you talk. Encourage the person to talk, listen to the answers and help the person not to become defensive or accept any blame for the accident or incident. Remember, the more they talk, the more you will learn.

6) Repeat the story back once you have heard it Once you have heard the witness’s account firstly check your understanding by repeating the account back to the witness. This gives the person a chance to hear what they’ve said and correct or confirm it. The repetition allows the words and meanings to be matched.

7) End the discussion by thanking the person for their help. Thank the person for their help and cooperation and repeat that you are gathering information so that this sort of incident can be prevented in the future.

8) Note vital information at once. Make notes rather than try to write down the complete dialogue unless the person gave you some really critical information.

9) Keep open the opportunity for further communication. Give the person the opportunity to get back to you in case they remember something at a later date. It always pays to go back to the person the following day or so, and have a casual conversation about the incident. Often vital information is a gathered at this point.

Check Out: Incident Investigation: Top 10 Mistakes

While a lot can be learned from accidents, we can learn also learn from “near misses” as well. Those incidents that didn’t involve an accident but could have easily had terrible result. Make sure that near-misses are always reported so that your supervisor can address them. The information learned from a near-miss is far less expensive than what is learned from an accident. Remember, prevention is always the best cure.

No matter how safe workers do their jobs, an accident can always happen. Make sure you follow the basic steps to enable accident investigators to do their job correctly and find the “root cause” of the incident. An accident investigation can create a safer workplace and that’s good for everyone. Who knows it might save a life some day.

Download & view the Simple Accident Investigation Policy below:

CONDUCTING AN ACCIDENT INVESTIGATION

 

Workplace Safety Meetings – 7 Ways To Increase Their Effectiveness

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Have you ever wished your workplace safety meetings were more interesting, more engaging, more productive, and more rewarding?

Perhaps you desire to improve your work force’s knowledge of office safety or general ethics of safety at work- but you just run out of ideas on how best to do this.

Then you need not bother yourself again. I know it can be very demanding trying to bring out different workplace safety spices to make your safety meeting your local “OSHA Training” ground!

Listed below are the 7 tips to bring back life and passion into your safety meeting topics and general presentations.

  1. Have A Schedule Indicating Identified Topics and Presenters Well In Advance.

When you draw up your workplace safety meeting schedule, you provide the presenters ample time to prepare for the safety presentation therefore ensuring a better presentation the meeting.

Remember the 6 P’s?: “Poor Prior Preparation Produces Poor Performance”

So, draw up a schedule and post it conspicuously at your workplace.

 

Need topics to present on? We offer 12 months of safety meeting topics

 

  1. ALWAYS Allow For An Interactive (Question and Answer) Session:

Make it as informal as possible to encourage interactive participation.

This is one of the basic features of a successful safety meeting.

This session allow the workforce to ask questions, present scenarios for brainstorming, among others. Do not make it a monologue! Encourage the interactions.

  1. Use a Variety of Presentation Aids And Resources To Reinforce The Safety Lesson.

These include Safety Training Videos, Health and Safety Quizzes, Safety Puzzles, etc.

These also serve as spicing that engage the workforce and give them something to look up to.

  1. Institute Award & Recognition Program for Safety Meeting Presenters.

This encourages outstanding lesson presentations and also stimulates startling lesson presentations. Know what these boil down to?

Better Safety training for your workplace!

  1. Keep to your time frames. Ensure proper time management.

In as much as you will encourage mutual interactions during the session, you also need to strike a balance by having a moderator keep the time frames within your preplanned brackets.

Time management is very critical to the success of this workplace safety training sessions.

If you need more topics for Safety Toolbox Talks, I have many books available on Amazon, check them out here
  1. Ask Safety Lesson Presenters to Always Include Review Questions At The End Of The Presentation.

This also engages the listeners, reinforces the lesson shared and helps in lesson retention.

Besides, it also serves as a measure of the work group’s understanding of the safety lesson.

  1. Finally, let your workplace management be involved by always attending the safety meetings.

This show of commitment will ginger interest and seriousness within the workforce as well.

By carefully implementing the above outlined tips in your safety meetings, you will certainly improve the safety education of your workforce, as well as ensuring a better workplace safety standard at your work place.

Aerial Lifts

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Aerial lifts, often called scissor lifts, are powered and mobile platforms that are used for elevating workers to various heights, which exposes workers to fall hazards.

An aerial lift presents an interesting situation in the workplace. Many employers treat these as powered equipment, when by regulation, they are actually considered scaffolding and have different requirements. This isn’t to say that aerial equipment is to be used without training, but the training and records are different.

If your workplace uses a scissor lift, it is important to know how to operate the equipment safely and in compliance to all relevant regulations.

To learn more about OSHA regulations pertaining to scissor lifts, there is this handy fact sheet, put out by OSHA.

For convenience I am including it in reader view below.

OSHA3842
If you need other components of a powered equipment program, check out all I offer here

Why Aerial Lift Safety Training Matters:

  • OSHA estimates that there are about 68,000 fall-related injuries in the workplace each year.
  • OSHA requires equipment with aerial lifts to be designed and constructed according to certain standards. The primary goal is to protect the worker in the lift by providing fail-safe mechanisms that will prevent a free-fall descent of the work platform.
  • One of the primary hazards of working in aerial lifts is falling out of the lift.
  • If you work in aerial lifts or near them on the ground, you need to understand the hazards, the basic regulatory requirements, and the safety work practices that must be followed to prevent accidents and injuries.

NIOSH offers a free simultor for aerial lifts, which shouldn’t be used in place of full and proper training of operators, but can be used to augment the training offered in the workplace.

Below is the NIOSH Fact Sheet on Aerial Lifts and their simulator:

aerial lift simulator NIOSH

You can find the NIOSH Aerial Lift Simulator here

 

 

 View and download all components of an Aerial lift safety program below

aerial lift operator training policy

Key Points:

  • Aerial lifts are useful pieces of equipment but can also be hazardous.
  • Lifts must be operated properly to prevent accidents and injuries.
  • Only trained and authorized employees are allowed to use aerial lifts.
  • Inspect equipment and the work area before each use.
  • Understand and follow safe work practices, including wearing fall protection equipment.
  • Be especially careful when working around power lines.

 

 

 

No quality training program is complete without an evaluation, so ensure that employees are observed in their operation of the aerial lift by a competent person.

Aerial Lift Operator Evaluation

 

 

 

 

Even with well trained employees operating aerial lifts, safety in the workplace is only as good as the equipment being used. The aerial lift, like powered equipment, should be inspected daily, before use, to ensure it is safe to operate.

Like powered equipment, this inspection is not required to be written, but written forms allow for proper auditing of program compliance, while also providing a paper trail to address issues.

Scissor Lift Checklist

Accident Prevention Planning Form

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After conducting a thorough accident investigation, you will come up with corrective actions. These corrective actions need to be implemented for change management.

Corrective and preventative actions are generated from varying sources including safety meetings, inspections, accident investigations, unsafe act and unsafe condition reporting and from audits, and are simply measures that need to be undertaken to ensure that a particular requirement is implemented.

 

 

These actions can be either corrective actions or preventative actions;

  • a corrective action means a situation has been re-instated to its original state, so replacing a machine guard that was improperly removed that caused an injury is a corrective action;
  • a preventative action will put into place arrangements which will prevent a re-occurrence, to stop the machine guard from being removed improperly in the first place.

An action that many think of as “common sense” and “simple” continues to appear on 3rd party audit reports and OSHA/EPA citations year after year.  So why is something which is “common sense” and “simple” so difficult to comply with?  Often times we make something simple too difficult for our own good.  Lets examine the PSM/RMP requirements for tracking “recommendations” from process safety activities:

1910.119(e)(5) The employer shall establish a system to promptly address the team’s findings and recommendations; assure that the recommendations are resolved in a timely manner and that the resolution is documented; document what actions are to be taken; complete actions as soon as possible; develop a written schedule of when these actions are to be completed;  communicate the actions to operating, maintenance and other employees whose work assignments are in the process and who may be affected by the recommendations or actions.

1910.119(j)(5) Equipment deficiencies. The employer shall correct deficiencies in equipment that are outside acceptable limits (defined by the process safety information in paragraph (d) of this section) before further use or in a safe and timely manner when necessary means are taken to assure safe operation.

1910.119(m)(5) The employer shall establish a system to promptly address and resolve the incident report findings and recommendations. Resolutions and corrective actions shall be documented.

1910.119(o)(4) The employer shall promptly determine and document an appropriate response to each of the findings of the compliance audit, and document that deficiencies have been corrected.

Use of a tracking form is considered an accident prevention best practice

By using a tracking form, all corrective or preventative actions, can be tracked for compliance, or more importantly for quality of action taken.

With all of this in mind, look at the corrective action tracking form below, and see how it can aid your organization and corrective safety measures:

 

Accident Prevention Planning

 

 

Fatality, Amputation, and Hospitalization Report

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OSHA has specific reporting requirements for serious injuries that occur within a facility.

The OSHA notification requirements are as follows:

  • Hospitalization: This is for a work related hospitalization, and must be reported within 24 hours;
  • Amputation: This is for a work related amputation, and must be reported within 24 hours;
  • Loss of Eye: This is for a work related loss of eye, and must be reported within 24 hours;
  • Fatality: This includes all fatalities that occur within the workplace, and must be reported within 8 hours.

 

Note the difference of any fatality, being required to report within 8 hours AND for ANY fatality within a workplace.

For Example: if an employee suffers a heart attack, the fatality should result in a call to OSHA.

When these incidents occur, it is a turbulent time in the workplace. Having a process in place, with a basic form, such as this report helps keep the process streamlined.

This report includes all the information OSHA requires:

  • Business name;
  • names of employees affected;
  • location and time of the incident,
  • brief description of the incident;
  • contact person and phone number.

– Source

How does OSHA define “Hospitalization”?

OSHA defines in-patient hospitalization as a formal admission to the in-patient service of a hospital or clinic for care or treatment. Treatment in an Emergency Room only is not reportable.

How does OSHA define “amputation”?

An amputation is the traumatic loss of all or part of a limb or other external body part. This would include fingertip amputations with or without bone loss; medical amputations resulting from irreparable damage; and amputations of body parts that have since been reattached. If and when there is a health care professional’s diagnosis available, the employer should rely on that diagnosis.

If a fatality occurs within 30 days of the work-related incident, or if an in-patient hospitalization, amputation, or loss of an eye occurs within 24 hours of the work-related incident, then you must report the event to OSHA.

 

This form is a beneficial component of a total accident investigation program. If you feel your organization needs more components of an incident investigation program, find them here.

 

Download and view the Amputation, Hospitalization & Fatality report form below:

Fatality Report

Does your workplace need fall protection?

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Does your workplace need fall protection?

Do you know what is needed to keep your employees safe and within regulation?

Fall Protection Requirements in 1910 General Industry

OSHA requires some form of fall protection for employees working at heights greater than four (4) feet in General Industry (1910). Many are unaware that there are numerous other OSHA standards requiring fall protection at other heights; some are lower, some are higher, and some only apply (or do not apply) in certain situations.

There are Federal OSHA standards which mandate guardrails or some other form of fall protection system be utilized to protect workers from falls of greater than four (4) feet. Included among these are 1910.23(c), which requires a standard guardrail (or equivalent) be installed along unprotected edges of open-sided floors, platforms, and runways greater than four (4) feet above the floor or lower level. And in that same subpart you will find 1910.23(b), which requires fall protection (typically rails or covers) at wall and floor openings of various types, such as stairwells, chute openings, and ladder openings.

However, paragraph 1910.23(c)(3) requires a standard guardrail be installed along open sides of any open-sided floor, walkway, platform, or runway located above or along the side of  dangerous equipment, pickling or galvanizing tanks, degreasing units, and similar hazards, regardless of its height. And paragraph 1910.23(d)(1) requires a stair rail to be installed on each open side of any flight of stairs having four or more risers; on many smaller industrial stairs with just a few risers, this could easily be less than four (4) feet high. So there you have a couple of examples where fall protection is required at less than the four (4) foot threshold.

Check Out: Fall Protection Program

There are also numerous OSHA general industry standards for various types of scaffolding which require guardrails be installed along open sides and ends of work platforms, but only if they are located greater than ten (10) feet above the ground or floor. See 1910.28(b)(15), (c)(14), (d)(7), (f)(15), (g)(5), (h)(8), (k)(5), (m)(7), (o)(2), and (p)(7) for the specific requirements for rails to be placed on these types of scaffolds. However, there are a few types of suspended scaffolds, such as float or ship scaffolds [1910.28(u)], two-point suspension scaffolds [1910.28(g)(9)] and a boatswains chair [1910.28(j)] which require the worker(s) be protected from falls by wearing a “safety lifebelt” attached to a lifeline, regardless of the height. But the requirements for needle beam scaffolds [1910.28(n)] requires only those workers located 20 feet or more above the ground or floor and working with both hands be protected by a “safety life-belt” attached to a lifeline.

OSHA standard 1910.27(d)(1)(ii) requires fixed ladders be equipped with cages or wells on ladders of more than 20 feet (to a maximum unbroken length of 30 feet). However, fixed ladders on towers, water tanks, and chimney ladders that are over 20 feet in unbroken length may be equipped with suitable safety devices such as lifebelts, friction brakes, and sliding attachments in lieu of cages.

OSHA standard 1910.66(f)(5)(i)(G) requires that each working platform of powered platforms used for building maintenance be provided with a guardrail system on all sides. And standard 1910.66(f)(5)(ii)(M) requires a vertical lifeline be provided as part of a fall arrest system meeting the requirements of appendix C of that standard for each employee on a working platform suspended by two or more wire ropes  if the failure of one wire rope or suspension attachment would cause the platform to be upset. However, if a secondary wire rope suspension is used, then vertical lifelines are not required for the fall arrest system provided that each employee is attached to a horizontal lifeline anchored to the platform.

OSHA standard 1910.67(c)(2)(v) for aerial boom-lifts requires the user(s) to wear a body belt with lanyard attached to the boom or basket when working in the basket. There is no height specified for this requirement, which is related to the purpose of tying off; this is a body positioning device to keep the person from being thrown out of the basket, as opposed to a fall arrest system.

Check Out: Harness and Lanyard Inspection

There are also fall protection requirements appearing in several of the OSHA standards for specialty industries, such as those regulating paper, pulp, and paperboard mills. 1910.261(e)(4) requires that protective equipment be provided for persons working over water. Furthermore, OSHA standard 1910.261(e)(12)(i) requires that when platforms or floors allow access to the sides of continuous barking drums, a standard railing shall be constructed around the drums. And employees working around the broke hole for pulp and paper machinery must be protected from falling into the hole by a guardrail [see 1910.261(k)(13)(i)], or, in cases where the pulpers are located directly below the broke hole on a paper machine and the broke hole opening is large enough to permit a worker to fall through, any employee pushing broke down the hole must wear a safety belt attached to a safety belt line which is rigged so that it is impossible for the person to fall into the pulper [1910.261(k)(13)(ii)].

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