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OSHA Issues New Regulatory Interpretations Covering Fall Protection, HAZWOPER and Crane Operation

 

In March and April of 2012, OSHA issued five new regulatory interpretations covering fall protection, HAZWOPER, and crane operation.

 

Fall Protection

 

OSHA clarified fall protection requirements for low-slope roofs less than 50 feet in width. OSHA re-affirmed that in these circumstances no other means of fall protection other than safety monitors are required and minimum offset distances from leading or unprotected edges are not required. OSHA also addressed the requirements necessary when using an aerial lift to place workers on such surfaces.

 

HAZWOPER

 

In response to a question regarding train derailment response operations, OSHA provided guidance on the type of employees who can be considered "skilled support personnel"  and "hazardous materials technician" during a hazardous waste emergency response. OSHA also verified the training necessary for persons who direct "skilled support personnel."

 

Crane Operation

 

In three separate interpretations, OSHA provided the following guidance/clarification:

  • Labeling and marking of outrigger beams does not meet the operational aid requirements of 29 CFR 1926.1416 which mandate the use of sensor/monitor equipment or temporary alternative measures.
  • Devices that automatically prevent the operation of equipment with improperly deployed outriggers are not required.
  • Hoist drum rotation indicators are required to indicate the direction of rotation, not just rotation speed and load movement direction.
  • OEM representatives demonstrating crane operation do not have to obtain crane operations certification if, while they are at a construction site, they only point out various controls and explains how they function. No certification is also required if the demonstration does not take place at a construction site.
  • Assembly/disassembly, inspection and testing of cranes not performed at a construction site is not subject to the requirements 29 CFR 1926.
  • The operator certification requirements of 29 CFR 1926.1427 do not generally apply to mechanics, inspectors or testers during assembly and disassembly activities.
  • Employers may not rely on ASME B 30.5-2004 or 2007 in determining what qualification requirements must be met by testers, inspectors and mechanics per 29 CFR 1926.1429.
  • Flags can be considered to sufficiently demarcate work areas to maintain a required clearance from overhead electrical power lines.

The full text of these interpretations can be found at  http://goo.gl/1cRtx

  

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Melanie Powers-Schanbacher

Telephone: 908.707.4001