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OSHA Fall Protection – Beyond Construction (1926)?

OSHA Fall Protection - Beyond Construction (1926)?

OSHA Standard 1926 zeroes in on construction zone hazards. The guidelines and provisions protect workers from fall hazards, uneven ground, and perilous work conditions that come from literal shifting ground. However, dangerous conditions don’t end when construction projects are over. Warehouses, industrial facilities, and commercial buildings of all types continue to have hazards such as high ground, stairways and ladders, and mezzanine floors that don’t have a protective wall around the entire perimeter. Additional sets of OSHA standards, such as 1910, prescribe minimal mandatory safety measures for protecting people in finished constructions, such as a safety gate for ladders or extra wide safety gates.

As a safety coordinator or facilities manager, you must build strategies and work processes that address both time spans—when active construction is underway and when general maintenance and work operations are happening. Consider trip hazards, fall hazards, air quality, and everything in between so your facility has a plan that successfully facilitates OSHA dock safety. Use this guide to take a closer look at the differences between OSHA Standards 1910 and 1926, how to comply with both, and some of the most common scenarios to account for.

What Is the Difference Between OSHA Standard 1910 and OSHA Standard 1926?

OSHA’s fall protection standards cover a wide range of protection tactics that you can categorize into three broad types:

  • Highlighting potential hazards: Barriers, signage, and flags or ropes that mark either safe paths or dangerous areas give visual indications of where on-site personnel should and shouldn’t go.
  • Fall prevention hardware: These systems include a safety gate for ladders, an indoor swing gate solution, or another physical barrier that supports OSHA dock safety and mezzanine safety. They physically block personnel from accidentally stepping out of safe areas.
  • Fall protection gear: This category encompasses harnesses and wearable gear that catch personnel if they fall to mitigate the scope of injury or damage.

But that’s not the only way OSHA organizes mandated practices and safety standards. The administration has also created specific codes based on the application, or type of work site, where the fall hazards present themselves. 29 CFR 1926 regulations apply to construction and agricultural areas. While many different facilities can have fall hazards, construction sites have unique perils, such as missing walls, unstable flooring, holes in the flooring, and open floor edges. As a result, these environments require particularly stringent—and unique—mandates. For example, sub-categories of 29 CFR 1926 regulate where to mark the edges of under-construction floors so equipment stays six feet or ten feet away from the edge.

29 CFR 1910, on the other hand, is a far broader set of regulations. It governs the appropriate fall prevention processes for general worksites where there are fall hazards pertaining to maintenance and typical operations, such as inspection of rooftop HVACs or operating forklifts around an open warehouse dock door.

There are several differences between these two groups of standards. But as a general rule, think of 29 CFR 1910 as broadly applicable rules and 29 CFR 1926 as a niche set of rules for construction sites that add additional layers of mandatory safety practices.

Where Fall Protection Standards Apply to Finished Constructions

When you’re converting OSHA standards into actionable safety practices, you’ll see several areas that overlap. As construction sites are underway, the finished and in-progress builds will need the protections that 29 CFR 1910 mandate.

One key area of overlap is 1910 Subpart D, or the regulation of Walkiing-Working Surfaces. These regulations require the following fall prevention steps:

  • Regular inspections to keep pathways and surfaces free from debris and trip hazards, especially if the surfaces are regularly slick
  • Fast repairs for damaged surfaces and clear markings around damaged areas
  • Dual reciprocating barriers that are at least 39 inches tall to keep workers safe along elevated areas or near areas with controlled access
  • Mandatory worker training so personnel remain vigilant, use fall protection equipment appropriately and can identify common hazards

1910 Subpart D also mandates the use of the following equipment types:

  • 1910.23: Safety hardware around ladders, such as safety gates that prevent personnel from accidentally stepping down into the floor cavities around ladders
  • 1910.25: Fall protection hardware around stairs, such as self-closing gates that prevent personnel from tripping onto the stairs or the floor below
  • 1910.28: This standard sets out when the use of fall protection systems are explicitly required.

However, it’s important to note that OSHA sets mandates, regulations, and requirements. Safety gear and fall protection manufacturers design products that comply with these regulations, but OSHA does not approve products. Instead of looking for OSHA-approved options, look for high-quality manufacturers or suppliers with products that comply with specific standards on your list of requirements.

When Safety Standards Do Not Cross-Apply

However, it’s just as important to know when the standards differ as it is to know when standards apply to in-progress and completed constructions. 1910 Subpart F, for example, explicitly applies to permanent platform installations that are to be used for building maintenance. This set of standards does not apply to temporary scaffolding or suspended platforms used during construction. Construction-focused suspended scaffolds are instead governments by 29 CFR 1926 Subpart L.

Facilities managers must be careful, as applying the wrong class of standards can make your facility less safe for personnel, non-compliant with OSHA requirements, and severely at risk of liability claims and fines. If your facility has a suspended platform meant for maintenance tasks—cleaning, metal polishing, caulking, and so on—1910 Subpart F applies. If the suspended platform is meant for construction and structural changes, 1926 Subpard L applies.

Top Priorities for OSHA Compliance Protocols: Common Scenarios

When you’re creating protocols for your facility, make sure you have provisions for these common scenarios. Carefully assess each to determine whether it’s construction-oriented (29 CFR 1926) or for general maintenance and operations (29 CFR 1910):

  • Suspended platforms for exterior or interior work
  • A safety gate for ladders or indoor swing gate that is either a temporary or permanent fixture
  • Fall protection demands for in-development flooring and stories or permanent mezzanine with open edges
  • Machinery that needs guards and railing for inspections, climbing, and controlling access

As you identify different needs, also decide which types of equipment meet the facility’s specific needs. For example, determine which equipment and settings demand extra wide safety gates and where indoor swings are mandatory.

Build Out Your Facility for Improved Compliance

OSHA dock safety, flooring safety, and open-edge safety are all mandatory considerations, whether you’re in charge of an active build site or a completed building. Fabenco by Tractel designs and supplies fall protection hardware such as extra wide safety gates, fall protection harnesses, indoor swing gate solutions, and more for all workplace scenarios. Better yet, our hardware is built to comply with OSHA guidelines, CCOHS requirements, and local safety regulations.

Reach out today for expert assistance selecting the right safety solution for your facility.