Page 26 - OHS, October 2023

PPE: FALL PROTECTION Current OSHA Regulations for PPE Fit OSHA has existing standards around PPE for general industry, shipyard employment, maritime terminals, longshoring, and construction. ThThese standards “require employers to provide PPE when it is necessary to protect employees from job-related injuries, illnesses, and fatalities.”1 In most cases, employers are required to pay for PPE when it is used to comply with an OSHA standard. The general industry (29 CFR 1910.132(d)(1)(iii)) and mari- time (29 CFR 1915.152(b)(3)) PPE standards already include a specific requirement that employers select PPE that “properly fits” each affected employee. OSHA’s existing requirements at 29 CFR 1926.95 are drafted specifically for the construction industry. This construction stan- dard states that PPE “shall be provided, used, and maintained in a sanitary and reliable condition whenever it is necessary by reason of hazards,” and that when employees provide their own PPE, “the employer shall be responsible to assure its adequacy, including proper maintenance, and sanitation of such equipment.”1 However, OSHA’s current PPE standard from construction differs from the general industry and maritime versions, in that it does not include an explicit requirement that PPE properly fit each affected employee. OSHA’s Recent Notice of Proposed Rulemaking In July 2023, OSHA proposed a rule intended to clarify its PPE re- quirements for construction. The revision would “require explicitly that PPE must fit workers properly,” and “make properly fitting PPE an enforceable requirement rather than the non-mandatory sugges- tions contained in these \[ANSI\] consensus standards.”1 According to OSHA, “a clear and explicit enforceable requirement will help en- sure that employers provide employees with properly fitting PPE.”1 With this revision, the PPE fit requirement for the construc- tion industry would be consistent with general industry and maritime requirements and help ensure workers of all sizes have appropriate PPE. The new rule also takes into account the number of women working in the construction industry and the need for appro- priately sized PPE options for women, as historically, protective equipment was designed primarily to fit average-sized men.2 OSHA’s take is that “properly fits” means the PPE: ■ is the appropriate size to provide an employee with the necessary protection from hazards, and; ■ does not create additional safety and health hazards arising from being either too small or too large The idea is that with properly fitting PPE, employees are less likely to discard or modify it because of discomfort or interfer- ence with their work activities. 1 Some Considerations for Evaluating Fall Protection PPE In addition to keeping up with OSHA’s latest updates and provid- ing proper fall protection training for employees, here are a few things to keep in mind when looking for PPE that can accommo- date a range of worker sizes and needs: When donning a harness and determining fit, pay particular attention to ensure that buckles are connected and aligned cor- rectly, leg straps and shoulder straps are kept snug at all times, chest straps are located in the middle chest area, and leg straps are positioned and snug. When selecting fall harnesses, keep in mind certain features than can help improve comfort and adjustability, including: ■ Adjustable features allowing the worker to loosen or tighten the harness depending on the fifit ■ Contoured padding across the shoulders and back, helping to eliminate or reduce pressure points and chafing ■ Various size options designed to fit workers from 110 lbs. up to 400 lbs., and from 5 ft. tall up to 6.6. ft. in height - Keep in mind that the weight capacity noted on the har- ness label means the combined weight of the worker’s body, cloth- ing, and tools. A harness may be rated to a larger capacity (e.g., 400 lbs.) for OSHA and CSA standards, but to meet the ANSI standard, capacity must conform to the ANSI limits shown in large type on the label’s first page. Prior to donning a fall harness, the wearer should conduct a pre-use inspection, in addition to the periodic inspection con- ducted by a qualified, competent inspector. This formal inspec- tion process should include five key steps: 1. Inspect all webbing and stitching: Starting at one end of a webbing length, grasp the webbing with hands eight inches apart and flex the fabric. Look for any cuts, fraying, pulled or broken threads, abrasions, excessive wear, altered or missing straps, burns, UV damage, or heat and chemical exposures. 2. Inspect all metal or plastic components: Look for deforma- tion, cracks, corrosion, deep pitting or burrs, sharp edges, nicks or cuts, exposure to excessive heat or chemicals, and any other damage. Missing, loose, or improperly working parts should be noted. The D- ring should not be cracked, deformed, or otherwise damaged. 3. Inspect all load indicators: Load indicators are sections of the harness webbing that are folded over and stitched securely. Ripped stitching, even if only partially separated, is an indicator that the har- ness has been subjected to a fall and should be removed from service. 4. Inspect all labels: Make sure labels are readable and that the unique identifier for the harness is legible so that it can be marked properly on the log sheet. 5. Complete all inspection documentation: A formal inspec- tion is not considered complete until the paperwork is done. Cre- ate a log sheet if necessary, covering all the check points for the harness you use. While fall protection remains the most-frequently cited OSHA violation since 2010,3 with appropriate planning, fall protection train- ing, and properly fitting PPE, employers can help keep their teams safe and compliant with the latest standards while working at height. Dennis Capizzi is the Segment Marketing Manager for Protection Products at MSA Safety. During his career at MSA, he has been responsible for respiratory, thermal imaging cameras, communications, head/eye/face/hearing, and fall protection equipment across both the industrial and first responder market. REFERENCES 1. www.federalregister.gov/documents/2023/07/20/2023-15285/ personal-protective-equipment-in-construction 2. www.bls.gov/spotlight/2022/the-construction-industry-labor-force-2003- to-2020/home.htm 3. www.osha.gov/top10citedstandards 26 Occupational Health & Safety | OCTOBER 2023 www.ohsonline.com