Creating a Site-Specific Fall Protection Safety Plan
As framers know, complying with OSHA’s conventional fall protection standard 29 CFR Part 1926 Subpart M can be difficult in certain circumstances. In acknowledgment of this, OSHA added Appendix E to the standard, which allows framers to create a fall protection safety plan specific to a jobsite (a “site-specific” plan). This plan can deviate from conventional approaches to fall protection. In creating a site-specific plan, a framer must “demonstrate that it is infeasible or creates a greater hazard to use conventional fall protection systems.” Appendix E does not provide framers with a specific procedure for putting a plan together but does specify that doing so should be the responsibility of a competent person capable of identifying existing and predictable fall hazards on the jobsite.
So what is OSHA looking for in a site-specific fall protection plan? The plan template provided in NFC’s FrameSAFE program provides an effective approach. The goal is to get framers to think in detail about how they will mitigate fall risks on each jobsite based on its unique conditions and the fall hazards it may present. For each item in Subpart M that a framer deems infeasible or hazardous (tie-off points, ladder use, etc.), OSHA requires an explanation about why compliance is not possible, or exposes workers to a greater hazard, and the framer’s proposed alternative. While these justifications must be applicable to a specific jobsite, there is nothing barring framers from using standardized responses from one site-specific plan to another.
The installation of roof trusses is a jobsite activity that typically needs a site-specific fall protection plan. In 2011, the Structural Building Components Association (SBCA) worked with OSHA to develop a step-by-step guide to help component manufacturers educate their customers on how to create a site-specific plan while standardizing as much of the language as possible.
“The guide gives framers a systematic approach and language they can use in addressing the common obstacle of finding an adequate fall protection tie-off point,” explains SBCA director of communications Sean Shields, who led the effort to develop the guide. “While trusses have very little lateral resistance individually, the guide demonstrates that when braced according to BCSI standards, a set of 3-5 trusses can serve as an effective tie-off point as an alternative to conventional fall protection methods.”
From this initial work, SBCA’s National Framers Council (NFC) developed a site-specific plan template as part of its FrameSAFE program. The template provides a standardized approach and language for addressing a broad range of compliance difficulties, such as requirements surrounding tie-off points, safety nets, ladder use, and exterior scaffolds. It also offers multiple options for creating a site-specific plan that reflects regional best practices. As NFC safety committee chair Ken Shifflett explains, “For every application, the end result is still the same; you have to protect the worker. But the means and methods of how you do it can be different on each jobsite in different parts of the country.”
It should be noted that while the template language in FrameSAFE can make creating a site-specific plan more straightforward, it is not intended to eliminate the framer’s responsibility to actively assess each jobsite and complete the template as appropriate. “You need to go in and read it and pick which option you think is best,” says Ken. Again, OSHA wants to see that a framer has truly put thought into how they will keep their employees safe, requiring the appropriate paperwork for each jobsite. Further, a framer is responsible for following the plan he submits as well as for ensuring that employees are trained accordingly.
To further these efforts, NFC has created a mentorship program where framer members who are new to FrameSAFE can reach out to more experienced members to learn about their approach to implementation in greater detail. Contact NFC to get involved in the mentorship program or with any questions about FrameSAFE and its site-specific fall protection plan template.
SBCA and NFC members and staff have generated a lot of helpful documentation and resources on this topic, which we have collected in our Fall Protection Topical Library. This resource pre-sorts the most valuable resources on a subject and arranges them into four main categories for easy navigation:
- Top Resources are intended to be the most thorough and pertinent sources of information on the topic.
- Best Practices are typically guidance documents that provide effective solutions to common problems associated with the topic.
- From SBC Magazine is a list of the most recent articles on the subject to be published in SBC Magazine, SBC Industry News, NFC Framing News or Energy Efficiency & Building Science News.
- Additional Information provides links to web pages and non-SBCA/NFC resources that provide additional insight on the topic.
If there is a topic you feel would make an important addition to the topical library, please contact staff to share your ideas.