The Occupational Safety and Health Administration’s second annual “National Safety Stand-Down” to prevent falls in the construction industry has just concluded. The 2015 initiative, which began May 4 and continued through May 15, invited employers in all areas of the construction industry to stop for a moment and talk with their employees about how to prevent the common fall hazards they face on a daily basis.
What can manufacturers learn from this construction initiative? Quite a bit, actually. While fall-related injuries and deaths are not as prevalent in manufacturing as they are in construction, where they are a leading cause of death, they still rank in the top three overall workplace accidents. And in manufacturing, just as in construction, the majority of them are preventable.
Understanding the most common OSHA regulations for fall safety that apply to the manufacturing industry, which are outlined below, is the first step toward creating a safer environment that helps to minimize and prevent not only falls, but also the potential for an OSHA citation.
Manufacturers would be wise to take a cue from their friends in construction and host their own safety stand-downs -- perhaps as a “toolbox talk” or a special meeting with lunch or snacks -- as a way to get their workers thinking safety and compliance first.
Walk This Way, and Keep It Clean
Modern manufacturing may not have been in mind when the old proverb “cleanliness is next to godliness” was coined, but it is certainly applicable today.
In Chapter 29, Section 1910 of the Code of Federal Regulations, where OSHA’s regulations are set forth, the government lays out the general requirements for safety with respect to walking and working surfaces (specifically, Section 1910.22). Serious injury can result from a fall caused by a walkway obstruction just as easily as it can from a fall from a ladder or down the stairs. Employers should take extra care to ensure their employees adhere to these guidelines, as these hazards can often be the most easily addressed and prevented.
OSHA’s regulations here read like a refrain of what many of us heard repeatedly throughout childhood -- essentially, all areas of the workplace must be kept in a clean, sanitary, and, to the extent possible, dry condition. It may sound like straight-up common sense, but the truth is, cleanliness is one of the most overlooked aspects of worksite safety. Make sure employees keep floors and passageways free from protruding or loose objects. In worksite areas that are frequently wet, maintain proper drainage and provide mats or other raised platforms so employees have a safe and dry place to stand. Passageways and aisles must have sufficient clearance from any nearby machinery or mechanical devices, especially where employees are required to make turns around potentially dangerous equipment.
This section also introduces the mandate that a cover or guardrail be provided to protect workers from any opening leading to a pit, tank, vat, ditch, or other potential hazard. More specific requirements for wall and floor openings are detailed in later sections.
Guard All Openings
The elevated walkways and surfaces frequently found in manufacturing workplaces present some of the most prevalent and serious fall dangers in the industry. Falling from a significant height, especially into or onto equipment and machinery on the manufacturing floor, could cause severe injury or death.
To protect employees from these types of hazards, Section 1910.23 relies mainly on guardrails or “standard railings” to serve as the primary method of fall protection. These are generally required to be 42 inches from the top rail to the floor, platform, or walkway level. They must consist of a top rail, an intermediate rail, and posts.
To maximize fall prevention at the workplace, there must be open communication between employers and employees on how to best maintain safe practices.
This regulation also creates a standard height of four feet to necessitate fall protection. Any open-sided floor, runway, platform, or wall opening four feet or more above an adjacent floor or ground level must be guarded by at least a standard railing. In addition to a guardrail, a toe board is required for all floor holes or open-sided floors where it is possible for an employee to fall through the opening, or where there is moving machinery below the opening.
In some circumstances, however, this regulation abandons the four-foot standard and requires fall protection regardless of height. For example, all floor openings, including stairways, ladderways, hatchways, and chute openings should be protected by at least a standard railing. But in certain cases, such as when a stairway is infrequently used and traffic across its opening prevents the use of a railing, a hinged floor opening may be used. Guardrails and toe boards are also required, regardless of height, where an open-sided floor, walkway, platform, or runway is above or adjacent to dangerous equipment such as chemical tanks or degreasing units.
Other floor openings, such as manholes, trapdoors, or pit openings, require additional safety measures. At a minimum, they all require covers—either a standard manhole cover or other floor opening cover. When the cover is not in place, the opening must either be constantly attended or otherwise be protected by a removable standard railing. In the case of a temporary floor opening, either a removable guardrail must be provided or the opening must be constantly attended.
Stairway Regs Are Steep
Today’s factories can have enough stairways in them to rival the famously mind-bending M.C. Escher lithograph Relativity. Manufacturers, however, are advised to be even more thorough with their guardrails and handrails.
The regulation governing stairways, Section 1910.24, applies to all fixed interior or exterior stairways used in general industry. This, therefore, includes all stairways around machinery and equipment, stairways going up or down floors or platforms, and stairways leading to or from openings or pits. Fixed stairs are required wherever regular travel between levels or platforms is routinely necessary. Spiral or winding stairways are typically not permitted except in very limited circumstances: Spiral staircases may be used as a secondary access point when a conventional stairway is not practical, and winding stairways are acceptable on tanks or other similar structures not less than five feet in diameter.
With respect to stairway construction, manufacturers have plenty to consider. For example, all fixed stairways must be able to carry five times their normal anticipated load and never less than 1,000 pounds. Fixed stairways must have a minimum width of 22 inches. The stairs also must be installed at angles to the horizontal of between 30 and 50 degrees. This regulation includes a table that provides acceptable combinations of stairway rise and run dimensions. So long as the stairway is constructed with an angle to the horizontal within the permissible range, however, different combinations may be used.
This regulation further provides extensive requirements regarding characteristics such as uniformity in rise height and tread width, slip-resistance of individual stairway treads and nosings, width of stairway platforms, proper placement of railings and handrails, and vertical clearance. While these regulations can seem as daunting and dizzying as Escher’s famous work, taking the time to inspect all stairways at your facilities and to work with knowledgeable counsel to make sure they are compliant will go a long way toward preventing falls -- and greatly reduce the risk of an OSHA citation or liability in the case of an accident.
Which Type of Ladder?
Ladder regulations may be even more tricky to navigate than those governing stairways. OSHA’s general industry regulations pertaining to ladders, Sections 1910.25–27, establish requirements for various types: portable wooden and metal ladders as well as fixed ladders.
Because these specific regulations and classifications are more complicated than other general industrial regulations, employers should take special care to review and understand the individual rules so that they can be clearly explained to employees. While the requirements between types can differ, at a minimum they all must be maintained in a useable and safe condition at all times and must be inspected at regular intervals depending on frequency of usage. As with other areas that require inspection, keeping documentation that shows regular inspection and maintenance is an essential component of managing risk.
Portable wooden ladders are classified according to their length, but no matter the length, they all must conform to certain minimum requirements. Common sense and OSHA will both tell you they must be free from sharp edges and splinters, and must upon visual inspection also be free from any apparent failures, decay, or irregularities. All hardware and fittings must be securely attached, and moving parts should operate free from binding. All metal bearings on the ladder should be frequently lubricated to promote ease of movement, but be sure no grease or oil gets on the rungs.
Portable metal ladders must be constructed with sufficient texture or otherwise be treated to minimize the possibility of slipping. The length of single ladders or individual section of a ladder cannot exceed 30 feet. A two section ladder cannot exceed 48 feet in length, and anything over a two-sectioned ladder cannot be greater than 60 feet. Depending on the overall length of the ladder, each section in a multi-section ladder must overlap the adjacent section by between three and five feet.
No matter what the ladder is made of, certain safety precautions must be followed when they are in use. Generally speaking, a ladder should be used in a manner so that the horizontal distance from its top support is one-quarter of the ladder’s length between the foot and the top support. This is also known as the ladder’s “working length.” Ladders must be placed so they have a secure and stable footing, should not be placed in front of doors that could open in the direction of the ladder unless the door is locked or guarded, should not be fastened together to create longer sections, and should not be placed upon any unstable base (such as boxes) to gain additional height. When going up or down a ladder, the climber must face the ladder.
Fixed ladders must be free of any splinters, sharp edges, or projections that could be a hazard to the climber. Fixed ladders that are 20 feet or higher must also include a fall protection device such as a cage, well, or other ladder safety device. When fixed ladders are used to climb higher than 20 feet, landing platforms must be provided for each 30 feet of height. Where a fixed ladder provides no additional fall protections, landing platforms are required after every 20 feet, rather than 30 feet. Each ladder section must be offset from any adjacent section.
The Bottom Line
While these regulations are not exhaustive, they do cover many of the potential fall hazards a manufacturing employee can and will face on a daily basis. As an employer, it is important to be familiar with these regulations, not only to ensure that the workplace is compliant, but also to understand how an employee can be exposed to particular fall hazards.
To maximize fall prevention at the workplace, there must be open communication between employers and employees on how to best maintain safe practices. Manufacturers can certainly benefit from the model OSHA established for stand-downs in the construction industry -- for which OSHA provides some helpful suggestions on its website -- in terms of addressing fall hazards proactively and conscientiously. A similar approach, tailored toward the risks manufacturers and their employees face, can have a positive effect on promoting a culture of fall prevention and ultimately making the workplace safer for employees.
Stefan A. Borovina is an attorney in the OSHA and Worksite Safety Practice Group at the law firm Goldberg Segalla. He defends clients in a wide variety of liability claims and counsels on minimizing OSHA liability and responding to citations. His credentials include the Department of Labor OSHA-30 Construction Training, and he is a frequent contributor to Goldberg Segalla’s OSHA: Legal Developments and Defense Strategies blog. He may be reached at [email protected].