Fall Protection Made Easy(er)

Editor's Note: For the most up-to-date information on Fall Protection, visit SBCA's Fall Protection Topical Library page.

In the run up to enforcement of the new rules on September 16, it appeared that much would have to change in order for framers to comply, but that isn’t necessarily true. To understand why, let’s look at what OSHA is really requiring (because it hasn’t changed how trusses should be installed). Then, let’s explore what structural component manufacturers can do to assist the framing community in complying with those requirements.

What OSHA Really Wants

At the heart of it, OSHA wants assurances that framers are more focused on fall protection hazards on residential jobsites. What this really means is they want documentation that a “qualified person” (see pull-out for definition) has looked at each jobsite before erection begins and identified all the fall protection hazards that exist. It’s important to note this jobsite hazard assessment (JHA) must be site specific, but that doesn’t mean the approach, or a majority of the language in the JHA, can’t be uniform.¹

The new standard may mean for some framing crews that their fall hazard recognition and mitigation training needs to become more robust. Again, OSHA expects this training to be documented, and each framer who ends up working in an area where a fall hazard has been identified in that jobsite’s JHA should be able to demonstrate their knowledge of assessing fall hazards.²

Finally, if using conventional fall protection (guardrail systems, scaffolding, a safety net system or a personal fall arrest system) on a jobsite is infeasible, or would subject workers to greater risk of falling, a qualified person needs to document it, and spell out an alternate approach to eliminating fall hazards or limiting workers’ exposure to those hazards.³

Jobsite Packages, B11 & Tags, Oh My!

For a component manufacturer, the first course of action in addressing the new fall protection rules is to include a jobsite package with every component delivery. Including instructions on how components should be handled and installed and braced has always been an industry “best practice.” However, now it is imperative to also include instruction on how components should not be used with regards to fall protection.

Framers will now be implementing a wide range of fall protection measures on jobsites while installing roof component systems. The BCSI B11 Summary Sheet, Fall Protection & Trusses, has been revised to provide specific guidance to framers under OSHA’s new regulations. First and foremost, it alerts framers to the fact that individual trusses are not designed to handle the lateral loading that would occur should a worker fall while tied off to a truss (see Figure 1) that’s not fully braced in accordance with BCSI or fully sheathed.

A fall protection truss tag (see Figure 2) has been updated to provide the same guidance, and can be attached to each truss near the locations most likely to be used as either an anchorage or tie off point.

Further, the B11 warns framers of the dangers associated with utilizing various conventional fall protection equipment systems, and points out that while the equipment may be designed and rated for handling the forces associated with arresting falls, it is up to a qualified person to determine whether the system it is attached to can also withstand those forces.

The Alternate Approach, One Step at a Time

While the jobsite package, the B11 and the fall protection truss tag are all great tools, they don’t answer the customer service question, “Well, what should I do about fall protection while setting trusses?”

For the component manufacturer, the first part of the answer to this question is to stress scope of responsibility. The component manufacturer is responsible for designing, manufacturing and delivering a high-quality product; it is the responsibility of the framing contractor to properly handle, install, brace, and restrain the product, which includes utilizing it within a fall protection system. By providing guidance, the component manufacturer needs to be clear they are only providing “best practices” with regard to applying proper fall protection to an installed system of trusses.

The second part of the answer is to point out OSHA accepts that during the installation of an initial group of trusses in a roof system, the use of conventional fall protection may be either infeasible, or would subject workers to a greater risk of a fall.⁴

The framing contractor has two clear choices when installing a roof truss system: they can brace, restrain and/or sheath all (or a portion) of the roof system on the ground; or, they can implement an alternate fall protection plan where they restrain and diagonally brace an initial group of trusses to form a truss system that can be used as a tie off or anchorage point. No matter what approach they take, it has to be identified and detailed in the site specific JHA and fall protection plan.

During the 2011 BCMC Build project in Indianapolis, IN, a two-story home was constructed using the ground erection method, but with a twist. The entire second floor was framed on top of the first-floor decking (see below: top left), lifted off in sections (see below: top right), the walls were installed (see below: bottom left), and finally the roof was craned above the top plate (see below: bottom right). This is certainly not the only way to frame on the ground, but it is an elegant solution (a time-lapse video of this process can be seen online.) 

However, for various reasons, ground erection may not be the best approach, or even feasible, on some jobsites. Fortunately, SBCA has worked with OSHA officials to create an online resource to guide framers through the creation of a common sense alternate fall protection plan for the installation of an initial group of trusses. SBCA's step-by-step approach provides a comprehensive way to comply with OSHA’s fall protection regulations. The 11-step process is as follows:

1. Identify initial installation area, create a Controlled Access Zone (CAZ)
2. Identify competent workers for installation
3. Designate a safety monitor
4. Establish truss installation plan
5. Establish ground bracing procedure and lateral restraint locations
6. Set the first truss
7. Set the rest of the initial group of trusses
8. Install top chord diagonal bracing
9. Work within the trusses
10. Apply sheathing
11. Apply fall protection anchorage

Notice the steps are designed to provide guidance for the installation of an initial group of trusses, not the entire roof. Once the initial group is either fully restrained and diagonally braced according to the guidelines provided in the BCSI B1 and B2 Summary Sheets, or sheathed (the preferred method), only then can the roof truss system be used as an anchorage point for personal fall arrest equipment.

Each step is accompanied by illustrations and photographs, many from the B1 and B2, and all of it can be used by the framing contractor when putting together an alternative fall protection plan. On the first page of the guide, there is a link to OHSA’s alternate fall protection plan template. Next to each section of this template, there are hyperlinks to the corresponding online step that explains how it can be implemented.

Document & Differentiate

For component manufacturers, helping the customer (or themselves, if they also install their products) get a handle on how they should install structural components under OSHA’s new fall protection standards is not rocket science, but care must be taken.

First, always keep in mind your scope of responsibility. The component manufacturer is responsible for designing, manufacturing and delivering a high-quality product; it is the responsibility of the framing contractor to properly handle, install, brace, and restrain the product, which includes utilizing it within a fall protection system.

Second, provide clear instructions for installation and handling of components (like those found in the SBCA Jobsite Package, B11 Summary Sheet and Fall Protection Tag), and limit your liability in the event of a fall accident. Third, direct framing contractors to SBCA’s online step-by-step approach to installing
an initial group of trusses.

Finally, stress the fact that in the eyes of OSHA, each jobsite is like a snowflake, it’s unique. While the step-by-step approach can be used for virtually any residential project, the framing contractor is responsible for documenting their JHA for each site, and the alternate fall protection plan must be tailored to each project.

¹ See 1926 Subpart M Appendix E

² See 1926.503(a)(1)

³ See CFR 1926.501(b)(13) & 29 CFR 1926.502(k)(7)

⁴ See 1926 Subpart M Appendix E