The Occupational Health and Safety’s (OSHA) top 10 most frequently cited safety and health violations for fiscal year 2017 has been published. The list is published each year to bring awareness to the areas safety improvements in the industry need to be made. Violations that make the list are usually quite severe (e.g., lockout/tagout) and fall protection can present life-threatening situations. The list rarely alters from year to year, with just slight possible changes in order. This can be noted in the chart below, comparing fiscal year 2017 to fiscal year 2016.As we go through the line items from top to bottom, we see the first 5 are an exact match: general requirements for fall protection, hazard communication, scaffolding, respiratory protection, and lockout/tagout. While ranked the same, it’s important to note the number of incidents decreased from 2016 to 2017. We want that number of incidents to be as low as possible, and the downward trend from 2016 to 2017 in these top 5 violations is promising – progress is being made to ensure workplace safety.
As we continue down the list, we see ladders and powered industrial trucks have swapped places in the list, and machine guarding holds constant at number 8. But when we get to number 9 on the 2017 list, we see a NEW violation, that was NOT on the 2016 list: Fall Protection Training Requirements.
Fall Protection Training Requirements: OSHA Standard 1926.503
The addition of fall protection training requirements to the OSHA top 10 list is concerning and needs to be addressed with the same urgency as the list’s repeat offenders. Let’s take a look at the requirements in this standard to be compliant.
Employers must provide a training program for every employee exposed to fall hazards. The training must be taught by a qualified person and address the following: nature of fall hazards in the work area, correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used, use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, and controlled access zones. Following training, employees must be able to identify fall hazards and procedures to follow that minimize fall hazard risks.
A written certification record of the training needs to be kept on file, and contain the name of the employees trained, date of training, and signature of trainer or employer who required the training. Retraining is an important component of the fall protection training requirements standard. When the employer has reason to believe that an employee who has already completed training no longer has the understanding and/or skills required to properly identify fall hazards and procedures to minimize fall hazard risks, the employee MUST be retrained. This is obvious if there are changes in the workplace that render previous training obsolete, such as changes in the types of fall protection systems or equipment used. It is critically important that employers recognize inadequacies in an employee’s knowledge or use of fall protection systems or equipment. If an employee has not retained the understanding or skill they need to be safe from fall hazards, the individual must be retrained promptly.
Aim to Eliminate
With its appearance on the OSHA top 10 violations list for 2017, citations issued under the fall protection training requirements standard are on the rise across industries.
I challenge you to look at your own workplace. Could more be done to prevent fall hazards? Are your employees confident in identifying fall hazards and the ways to reduce these risks? Hold safety talks with your employees discussing a different safety topic each week. Look at OSHA QuickTakes Newsletters to analyze recorded injuries. Challenge your staff to determine the root cause of the accident, and actions that could have been taken to eliminate the risk. Experience a close call in your facility? Be proactive. Perform an accident investigation to learn the root cause to eliminate future risk and ensure it doesn’t happen again.
Industrial safety is my expertise – please reach out to me with any questions you may have regarding your workplace. I am here to help!