Today, the final rule for Walking-Working Surfaces (29 CFR Part 1910, Subpart D) and Personal Protective Equipment (29 CFR part 1910, Subpart I) will be effective, specific to slip, trip and fall hazards (referred to as the final rule in this article).
We will briefly outline what is going to change for facade access and what the implications are for workers, employers, safety professionals and everyone who deals with working at height and facade access.
Reducing falls (from height)
Obviously, OSHA has a good reason to revise and update its standards. Falls from height and on the same level are the leading causes for work-related injuries and even deaths. A good indication for this is the annual top 10 most cited violations of OSHA standards, where the fall protection standard is leading the list since 2011.
OSHA states that this final rule will significantly reduce the number of worker deaths and injuries, with slip, trip and fall fatalities and injuries in particular. They have made an estimation that with implementing the final rule a total of 29 deaths and 5,842 injuries will be prevented annually in the United States. This alone is enough to implement such a rule.
Besides that, OSHA estimated that a total of 309,5 million USD is saved every year if this rule is fully implemented.
Changes for facade access solutions
Besides changes for fall protection systems, the final rule has impact on facade access solutions as well. The most important change affects Rope Descent Systems.
Rope Descent Systems (RDS)
Many workers who maintain facades of tall buildings make use of the Bosun’s chair or another form of a rope descent/abseiling system. They hang suspended on heights of 500 feet. Until now, the only standard that addressed requirements for the use of these systems was the ANSI Standard IWCA I14.1, which is not a law. In this final statement, OSHA issues requirements for the use of RDS and makes them federal law.
For workers using a rope descent system (like a Bosun’s chair )and building owners the final rule will have some big consequences:
The final rule states that the use of RDS is permitted. However, the rule adds a height restriction of 300 feet. This means that the use of a Bosun’s chair on a building higher than 300 feet is prohibited by law. So if a building is higher than 300 feet, other facade access solutions need to be used, like a suspended platform or a permanent facade access solution (BMU).
Besides that, building owners need to affirm by writing that permanent building anchors used for RDS have been tested, are certified and maintained in compliance with the requirements of §1910.66, paragraph (g) and (h). The anchors need to be capable of supporting a weight of 5.000 lbs for each worker attached.
Delayed effective day
Some provisions in the final rule have a delayed effective date from the 17th of January 2017 onwards. For inspecting and certifying permanent anchorages for rope descent systems the delayed effective day will be on the 17th of January 2018.
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OSHA’s final rule will have serious impact for those working at height, like employers, building owners and safety professionals among others.
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