Fall Protection

Fall Protection

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Walking-Working Surfaces and Personal Protective Equipment (Fall Protection Systems), Proposed Rule, Federal Register, May 24, 2010 This proposed rule would require improved worker protection from tripping, slipping and falling hazards on walking and working surfaces. The rule would revise and add detail to existing standards under portions of 29 CFR 1910. Revisions address fall protection such as guardrail systems, safety net systems, and personal fall protection systems (i.e. travel restraint systems, fall arrest systems, and positioning systems). A new section would make the general industry standards consistent with existing construction and maritime standards regulating fall protection. This addition provides employers with specific, prescriptive standards for personal protective equipment related to fall protection. Comments on the proposed rule are due August 23, 2010.

The proposal does not include specific requirements for fall protection from rolling stock or motor vehicles. However, OSHA has requested comments on whether such a rule would be necessary. If, in response to this issue, the Agency receives sufficient comments and evidence to warrant regulation, a separate rule would be issued.

Updates, Comments & Other Reports

March 2011 On March 7, ILTA submitted additional comments to the Occupational Safety and Health Administration on its proposed rule for Walking-Working Surfaces Personal Protective Equipment (Fall Protection). ILTA addressed specific questions regarding the economic feasibility of providing fall protection from rolling stock and motor vehicles at all terminal facilities. In the letter, ILTA provided information relating to existing fall protection equipment currently utilized at terminals as well as data on the costs associated with providing fall protection from tank trucks and rail cars at these facilities.

February 2011 OSHA has provided new instructions to its enforcement personnel for determining whether employers are in compliance with all workplace personal protective equipment (PPE) standards. The new guidance identifies all applicable standards and clarifies the types of PPE that employers must provide at no cost to the worker and the circumstances for which they are required.

January 2011 On January 20, ILTA testified at an informal hearing held by the OSHA on its proposed rule on Walking-Working Surfaces and Personal Protective Equipment. At the hearing, Peter Weaver, ILTA’s Director of Regulatory Compliance ad Safety, addressed three issues: 1) proposed requirements for travel restraint lines; 2) a separate rulemaking on fall protection from rolling stock; and 3) the absence of an explicit grandfather provision for existing guardrails. OSHA has asked ILTA to provide post-hearing comments on the economic feasibility of providing fall protection from rolling stock and motor vehicles at all terminal facilities. Additionally, ILTA has been asked to document the differences in cost between a retrofit installation and new construction.

August 2010 ILTA submitted comments to OSHA on its proposed rule for Walking and Working Surfaces Personal Protective Equipment (Fall Protection). The letter focused on two main points: 1) that a separate rulemaking on fall protection from rolling stock and motor vehicles is unwarranted; and 2) that travel restraint lines should have sufficient strength to withstand twice the potential impact energy of the design shock load, rather than be required to meet the more severe standard for lines designed to withstand forces resulting from a fall. For additional information, click here.

July 2010 The ILTA Health & Safety Subcommittee has formed a Fall Protection Rule Working Group to discuss the implications of OSHA’s May 24 proposed rule. Click here to view a 9-page summary of the 291-page rule and the provisions most relevant to the terminal industry. For more information, contact Katie Vassalli at kvassalli@ilta.org.

RELATED ILTA ARTICLES

ILTA provides a monthly newsletter to its membership. Members may log in to the Member Resources page to access archived newsletters. The following is a list of articles ILTA has published in its newsletter relating to Fall Protection.

ILTA Submits Additional Comments on Proposed Standards for Fall Protection, April 2011 Issue (p.4)
ILTA Testifies at OSHA Hearing on Fall Protection Standards, February 2011 Issue (p.4)
ILTA Submits Comments on Proposed Standards for Fall Protection, September 2010 Issue (p.4)
Proposed Rule Prescribes Performance Criteria for Fall Protection Systems, August 2010 Issue (p.4)