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The Guardian Fall Team Blog

As promised, this week we return to the OSHA 1910 General Industry update. Last week we covered some of the major issues, and if you missed it, go back and have a read – there are some things you need to know. And now, without further delay, let’s continue to wade through the 1910 tome.

Got A Rope...Or An Anchor?

Rope descent systems, anchorages in particular, are also now addressed by the 1910 regulations. Instead of relying on consensus standards for anchor inspection and certification as in the past, OSHA now requires that before use, “…the building owner must inform the employer, in writing, that the building owner has identified, tested, certified, and maintained each anchorage so it is capable of supporting 5,000 pounds in any direction…” By OSHA’s own estimates, somewhere around “… 487,500 buildings will require annual inspections and decennial (every 10 years) certifications.” Of that total, OSHA estimates a tenth (48,750) of the buildings’ anchorages will need to be qualified, and 1,734 anchorages will need to be replaced. That’s a lot of work, and this on anchorages that are already installed and presumed to be in use. If you are on either side of a rope descent system, make SURE your anchorages have been inspected and certified by a Qualified Person – no excuses.

Qualifying Qualified

Speaking of Qualified Persons, OSHA changed the definition of “qualified” to be more in line with 1926.32(m), but fell short (despite several commenter’s wishes) to require a Qualified Person to be an engineer. OSHA pushed back on this suggestion by saying that because the rule required the “demonstrated ability to solve or resolve problems,” it would be more effective than an otherwise unproven degree. Basically, they are saying that actions speak louder than words; if you can prove through your past work and also certification testing that you are capable of “performing the required functions,” it shows that you possess the requisite knowledge of a Qualified Person. Furthermore, because 1910.27 requires anchorages for rope descent systems be inspected and certified before use and periodically thereafter, OSHA, “…believes that building owners will likely consult and work with engineers to ensure that all building anchorages…meet the requirements in 1910.27.”  This is sort of a “trust but verify” approach to the Qualified Person. OSHA is fine with non-engineers being qualified persons because their work will then be certified though testing that it meets OSHA’s strength requirements.

 

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More Power To you

Additionally, OSHA updated the definition of Competent Person to, as you might expect, align with the 1926 Construction standards. Whereas the existing definition stated a Competent Person, “…is capable of identifying hazardous or dangerous conditions…and of training employees to identify such conditions,” the new definition includes “existing and predictable hazards in any personal fall protection system…component…[and] application,” and very importantly, “…the authorization to take prompt corrective measures to eliminate the identified hazards.” This latter addition now confers much responsibility and authority to the Competent Person in the general industry setting. This change was partly in response to many commenters who expressed concern that having limited authority means that a Competent Person could identify a hazard, but could not do anything about it. Now, they can. Well, after they get the proper training of course. Just because OSHA has added a level of responsibility the Competent Person, doesn’t mean that an existing Competent Person (as defined by 1910 in General Industry) is fully prepared to make decisions regarding the new fall protection options. Remember: new rules, new training.  Now that the Competent Person will also assess fall protection solutions within the General Industry, they need to know what to look for – proper training is the answer.

It's Up To You

We hope our exploring the new 1910 regulations has helped you understand a bit more of how these changes will affect you and your operations in the years to come. Remember, the new regulations go into effect January 17, 2017, so by the time you read this, you are probably already under their authority. With that in mind, there’s a lot of work to do – so get going, and be safe up there.