Why is it that general contractors and their subcontractors say, after receiving a purchase order, that on this specific general industry project fall protection just isn't feasible regardless of whether new construction or a renovation is involved. It's a practice that has become all too common and one that must be halted in an effort to improve overall workplace safety and to satisfy OSHA requirements.

Despite 66 years of standards, rules, and regulations, workers continue to fall to their deaths. In fact, according to the Bureau of Labor Statistics, one-third of all occupational fatalities in the construction industry result from falls.

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Within the arena of general industry, the best way to control contractors' fall protection exposures on your site is to address them in your written construction bid documents, contract, and purchase order - keeping in mind that OSHA has established only minimum performance requirements. Your documents can and should set higher standards for protecting any individual exposed to a fall hazard at your site.

Bidding Documents - The Place to Start

Ask smart questions. Review current practices. Find out what your bidding documents and contracts say about contractor fall protection requirements for maintenance work, renovation projects, and new building additions. Generally, these documents contain only the succinct "all applicable OSHA requirements shall apply," which opens the door to various fall protection height requirements. Instead, your documents should clearly spell out site fall protection and performance requirements for contractors. The fact that workplace activities have such a wide range of "height above lower level" requirements dictating when fall protection must be used makes this all the more essential. For example, in construction fall protection is required at six feet for carpentry activities, at 10 feet when erecting or dismantling scaffolding, at 15 feet when installing steel deck, and at 30 feet for connecting steel beams to steel columns. In general industry, however, guardrails are required when maintenance or operation workplace activities are performed on any working surface four or more feet above the lower level.

A facility fall protection policy should specify that any foreseeable fall hazard exposure with the likelihood of causing serious injury or death to a person (i.e., employee, client, vendor, contractor, subcontractor) must be eliminated or controlled to protect that person. An example of such a fall protection plan policy is:

Whenever performance of any task would allow a worker to fall a distance of four feet or more, or any distance where the likelihood of a serious or fatal injury exists, the hazard of falling must be identified, evaluated, and controlled based on the hierarchy of controls.

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