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Fall protection

Fall Protection Citation Prevention — Part 3

Oct. 6, 2023
Insight into the third, fourth, and fifth top subparagraphs cited under fall protection

OSHA reports that fall protection [1926.501] was the No. 1 most frequently cited standard in the 2022 fiscal year. In Part 2, we covered the first two subparagraphs cited under fall protection. Now we turn our attention to the last three.

1926.501(b)(10). Roofing work on low-slope roofs. This doesn’t apply to directly electricians, but it can be a strong signal for site safety deficiencies. For example, let’s say you’re working on a commercial building project. Perhaps it’s a warehouse and your task for the day is to install the overhead raceway to provide power for the high-bay lights. It’s essentially two stories above grade, so you’ll need the scaffolding crew to erect scaffolding.

At the same time, a crew has just started installing the membrane on the low-slope roof. You notice there’s no warning line system, no guardrail system, or any other barrier, and nobody is using any personal fall arrest system. Just how confident should you be about that scaffolding? And if people are out in plain sight violating basic roof safety requirements, what hidden electrical dangers might you encounter? Normal assumptions of safety compliance can’t be made. You have to assume that everything is done incorrectly until verified otherwise. So,  this rule, even though it doesn’t directly apply to you, is good to know.

Standard 1926.501(b)(11) applies to steep roofs. But unlike the low-slope roof requirements, there’s no mention here of doing roofing work. While it’s unlikely you would be installing HVAC systems on a steep roof, you could very well be installing lightning protection, lights, security cameras, or de-icing system components. If the sides or edges are unprotected — and either is 6 ft or more above lower levels — each employee must be protected from falling. The three acceptable methods are guardrail systems with toeboards, safety net systems, and personal fall arrest systems.

It’s best not to focus on the 6-ft aspect of this requirement as an absolute limit, but instead, to consider fall protection as height approaches 6 ft. You can fall less than one foot and break your ankle just due to the clumsiness of the position. Or you might fall onto something that won’t provide a safe landing. For example, if the edge is just a tad less than 6 ft above grade but there are 3 ft bollards in the fall zone, then it makes sense to take some measure such as installing a guardrail on that edge.

Standard 1926.501(b)(4) has to do with holes in the elevated walking/working surface. Among many other reasons, holes may exist in the floor to allow piping to run from one floor to another. A common practice is to cover these with plywood sheets and then red-tape the covered area. The use of such covers is one of the three permitted safety measures. Guardrail systems and personal fall arrest systems are the other two.

Where these holes exist, employees must also be protected against tripping and against objects falling through holes onto employees below. Use a mix of techniques, such as:

  • Cover the hole(s).
  • Create designated traffic paths that have people walking around, instead of through, an area that has these holes.
  • Distribute supplies and materials in a way that eliminates the need for people to traverse the area containing holes.
  • Use red barrier tape to limit access to only those employees who belong to a crew directly working with whatever the hole is for.
  • Use yellow barrier tape to limit access to floors with holes.
  • Task someone with routinely conducting visual inspections on hole covers to ensure they are in place.
  • Remind employees to report any deficiency, such as a missing cover.
  • Remind employees to stay alert on floors with holes, or when under holes in floors. No distractions such as casual conversation.
About the Author

Mark Lamendola

Mark is an expert in maintenance management, having racked up an impressive track record during his time working in the field. He also has extensive knowledge of, and practical expertise with, the National Electrical Code (NEC). Through his consulting business, he provides articles and training materials on electrical topics, specializing in making difficult subjects easy to understand and focusing on the practical aspects of electrical work.

Prior to starting his own business, Mark served as the Technical Editor on EC&M for six years, worked three years in nuclear maintenance, six years as a contract project engineer/project manager, three years as a systems engineer, and three years in plant maintenance management.

Mark earned an AAS degree from Rock Valley College, a BSEET from Columbia Pacific University, and an MBA from Lake Erie College. He’s also completed several related certifications over the years and even was formerly licensed as a Master Electrician. He is a Senior Member of the IEEE and past Chairman of the Kansas City Chapters of both the IEEE and the IEEE Computer Society. Mark also served as the program director for, a board member of, and webmaster of, the Midwest Chapter of the 7x24 Exchange. He has also held memberships with the following organizations: NETA, NFPA, International Association of Webmasters, and Institute of Certified Professional Managers.

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