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The most commonly cited OSHA standard is 29 CFR 1910 Subpart D, Walking-Working Surfaces. It’s not surprising: the biggest causes of death in construction are falls and being struck by an object, both of which the standard tries to prevent.
Like much of the OSHA regulations, it tends to spell out the common sense approach. Railing, scaffolds, ladders, etc need to be well put together and guard against objects rolling off and smacking someone. People high up need harnesses and safety lines so they are not one slip away from a splat, and the harnesses need to be inspected just like a parachute. Lots of explicit listing of just how big a railing needs to be and what the spacing needs to be, etc. Like nearly every standard, it begins with a set of definitions for all of the words / concepts specific to the standard. For example:
Fall protection means any equipment, device, or system that prevents an employee from falling from an elevation or mitigates the effect of such a fall.
Self-evident, right? Well, these are legal documents, enforceable with fines and evil government lawyers (TM) Everything needs to be defined clearly. Take this example:
Opening means a gap or open space in a wall, partition, vertical walking-working surface, or similar surface that is at least 30 inches (76 cm) high and at least 18 inches (46 cm) wide, through which an employee can fall to a lower level.
This means openings smaller than the definition do not qualify. There are numerous cases in my job where the exact words of a regulation make all the difference. A chemical hazardous waste cannot be treated or neutralized outside of a proper facility. However, you can do all kinds of things with a chemical before it is declared a waste, including demonstrating a neutralization reaction. The fact that the result is non-hazardous is no problem. I did all kinds of demonstration reactions in my previous job, saving taxpayer money and my tiny budget.
Now, even with all this detail, sometimes things are not exactly clear, so the company writes OSHA and asks for an interpretation. Standard interpretations are used by OSHA inspectors, but are not on the same legal standard. I’ve run into quite a few standard interpretations that went a really annoying way. For example, Bloodborne Pathogens training requires a person to be available to answer questions as the person takes the training. Easy for in-person training, but for the online training offered to the midnight shift? It turns out using a voicemail or email box for questions is not good enough. Cue a few nights sleeping in my office. We have a better system at my current employer, but it is still a bit annoying.
The remarkable things is that I have usually found OSHA’s helpline to be genuinely helpful, and relatively common-sense. They run a safe harbor generally, so if you call and there is a problem, they are not going to pounce on you for it. If you have any questions on OSHA standards, feel free to post in the comments with a harness and properly anchored safety line.
(This is part of the group writing series on Work)Published in