Despite the possibility of compliance with existing regulations, fall exposures in construction and general industry continue to be found in work practice, especially with smaller contractors, and fall injuries and deaths continue to be the single highest construction death and survivor severity.
Regulations will always be a background to the worksite rules for safety but they should not be the only guide or reliance. Each contractor must be talked with, communicated with and held to account to a standard set of current safety rules.
Contractors can be put on notice in the bid and in advance of site arrival that fall protection is a "site-specific plan" requirement; this presentation provides methods to help ensure hazard control and exceed minimum standards.
Sub-contractors will bond with GC's if they are encouraged and acknowledged (and employed regularly).
When you request your contractors to leave their fall systems installed for other contractor use (if appropriate and including guardrails), it is only fair to accept responsibility for each system. This usually means that fall arrest systems must be engineered for proper risk transfer.
Contracts: The AIA contracts hold the general contractor accountable for all safety on-site so that if a subcontract delegates all responsibility to a subcontractor, that expectation will not be successful. A page in the contract specifying uniformity of fall protection rules such as a 6 ft trigger height for all subcontractors may not be agreed to by the steel subcontractor when he comes on site, preferring to follow OSHA 15/30 ft rules. Therefore the wording is crucial to avoid any ambiguity in the contract and to make sure that the contractor's rules are to be followed that are tighter than OSHA regulations.
OCIPS - owner controlled programs will usually produce safer worksites because the insurer loss control department has more say and there is more coordination of the subcontractors as a result. Some contractors are insured by workers' compensation carriers that have tighter rules than OSHA or state requirements
The preferred sub-contractor has an EMR rate of less than 1.0 and preferably less than 0.5 to demonstrate that safety practice is possible, alive and well.
Fall protection responsibility for anchorage points rests with the owner or general contractor when subcontractors use fall arrest equipment. This is to help avoid property damage due to high stresses transmitted when a fall occurs. A plan laying out the fall equipment application showing anchorage points must be site specific.
Ask your small contractors to recognize hazards and then in order: eliminate first, prevent second, protect with fall arrest systems as a third option.
Request your small contractors to prepare fall protection plans and to follow them - you will undertake to inspect frequently with trained observers.
