Implemented in 2016, the OSHA rule updated and clarified standards and adds training and inspection requirements for all industries, including cell tower construction. The rule incorporated advances in technology, industry best practices, and national consensus standards to provide effective, cost-efficient worker protection. Specifically, it updated general industry standards addressing slip, trip, and fall hazards (subpart D), and added requirements for personal fall protection systems (subpart I).
Most of the rule became effective January 17, 2017, but some provisions had delayed effective dates. On Nov. 19 of this year, the rule requiring the installation of personal fall arrest or ladder safety systems on new fixed ladders over 24 feet and on replacement ladders went into effect. Additionally, as of Nov. 19, existing fixed ladders over 24 feet must be equipped with a cage, well, personal fall arrest system, or ladder safety system.
The National Association of Tower Erectors voiced its concern that a two-year delay would not be long enough for the tower industry to properly comply with the new rules affecting existing fixed ladders.
NATE said in a letter to OSHA when the new rule was imposed. “There are hundreds of thousands of communications towers and there are many thousands of rooftop sites that have to be evaluated and subsequently have engineering completed and modifications made. Our members are concerned that engineering, planning, zoning and permitting will certainly create situations where compliance is not possible.”
The next deadline for fixed ladder safety is 2036, when cages and wells (used as fall protection) will be required to be replaced with ladder safety or personal fall arrest systems on all fixed ladders over 24 feet.
Previous deadlines were: ensuring exposed workers are trained on fall hazards (May 17, 2017); ensuring workers who use equipment covered by the rule are trained (May 17, 2017); Inspecting and certifying permanent anchorages for rope descent systems (November 20, 2017).
OSHA estimates that these changes will prevent 29 fatalities and 5,842 lost-workday injuries every year.
The rules are designed to provide employers with greater flexibility in choosing a fall protection system. For example, it eliminated the existing mandate to use guardrails as a primary fall protection method and allowed employers to choose from accepted fall protection systems they believe will work best in a particular situation – an approach that has been successful in the construction industry since 1994. In addition, employers are able to use non-conventional fall protection in certain situations, such as designated areas on low-slope roofs.
As much as possible, OSHA aligned fall protection requirements for general industry with those for construction, easing compliance for employers who perform both types of activities. For example, the final rule replaces the outdated general industry scaffold standards with a requirement that employers comply with OSHA’s construction scaffold standards.