Proactive with OSHA

We are figuring a high profile job with tile that is going to be a bitch to do. Two high towers (70 feet up) and a lot of scaffold built over the lower roofs to get to the upper roofs. I was laughing with my wife today in that I called and scheduled an appointment with the OSHA inspector for next week to go over my safety plan and the scaffold schedule for the job. tile is a bit different than shingles in that you really can't walk over the parts you have finished, so tie off points are a problem. It will be interesting to hear what he has to say before I start.

Much easier than waiting for them to show up and wondering what you forgot.

Say what you will. No good deed goes unpunished. These people are gathering names, and looking to punish examples, for the rest of us.

"Roofing work on Low-slope roofs." Except as otherwise provided in paragraph (b) of this section, each employee engaged in roofing activities on low-slope roofs, with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems, safety net systems, personal fall arrest systems, or a combination of warning line system and guardrail system, warning line system and safety net system, or warning line system and personal fall arrest system, or warning line system and safety monitoring system. Or, on roofs 50-feet (15.25 m) or less in width (see Appendix A to subpart M of this part), the use of a safety monitoring system alone [i.e. without the warning line system] is permitted.

1926.501(b)(11)

"Steep roofs." Each employee on a steep roof with unprotected sides and edges 6 feet (1.8 m) or more above lower levels shall be protected from falling by guardrail systems with toeboards, safety net systems, or personal fall arrest systems.

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=STANDARDS&p_id=10757

I called and for 20 minutes argued this line; "For purposes of determining the applicability of section 1926.501(b)(13), the term "residential construction" is interpreted as covering construction work that satisfies the following two elements: (1) the end-use of the structure being built must be as a home, i.e., a dwelling; and (2) the structure being built must be constructed using traditional wood frame construction materials and methods. The limited use of structural steel in a predominantly wood-framed home, such as a steel I-beam to help support wood framing, does not disqualify a structure from being considered residential construction."

http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=DIRECTIVES&p_id=4755

OHSA compliance officer said the ruling applies to ANY and ALL work being done 6' aboove the ground, and having 'edges' a person could fall from. Give them a holler Chuck. He stated you will be fined if 6' up on anything and not in compliance.

800) 321-OSHA

How's this. The term used is 'Residential Construction', and it does not draw a line between new and existing.

http://blog.msdsonline.com/2010/12/osha-dramatically-alters-fall-protection-requirements-for-residential-construction-workers/

I have been reading over the regs and I have yet to find where they include residential reroofing. Can someone point it out to me if I'm missing this. B) :) :) B) Deep Down In Florida Where The Sun Shines Damn Near Every Day

I was out on the site for 1 1/2 hours with the guy today going over the written plan and fine tuning it. actually it was quite interesting. We will re-write the plan for the job and then set up the scaffold and let him come out and inspect it again to get any additional input.

Read it closely Randy. If you're not fully compliant with the old rules, they take you to the cleaners.

BREAKING NEWS NEW OSHA fall protection regulations moved back to Sept. 16, 2011!

OSHA has decided to delay the enforcement of their new fall protection regulations. Indiana OSHA says that everyone should be in compliance with the new fall protection guidelines by Sept. 16, 2011, and OSHA will begin enforcing the guidelines on Oct. 1, 2011.

My ProActive Sotry:

Met w/ INSafe, Indiana Dep't of labor to get started. Basically a free consultation/ critique.

At one point he says to me: "By taking part in this program, my company will always get 15% off all OSHA fines"

"Great!" I sez, "but I hope I never have to use it!"

The look he gave me, reminded me that indeed, I am a Lamb being led to slaughter :(