Some companies may attempt to enforce safety policies that deviate from OSHA standards. Usually these companies allege that their own standards are safer and more stringent than OSHA’s. Those deviations, however, may ignore the tremendous effort and thought that is typically given to establishing the OSHA standards and may subject workers to new dangers.
For example, contrary to OSHA’s policy, general contractors may require all iron workers, including connectors performing leading edge work, to tie-off at heights over 6 feet. But in recognition that connectors need to be unfettered so they can escape an incoming load if necessary, OSHA’s Subpart R does not require connectors performing leading edge work to be tied off at 6 feet. In fact, OSHA regulation § 1926.760(a)(1) allows connectors not to use their personal fall protection to avoid hazards while working at heights between 15 and 30 feet. Further, workers engaged in decking in a controlled decking zone may work without conventional fall protection at heights between 15 and 30 feet.
When changes to OSHA Subpart R, and specifically regulation 1926.760, were being debated, The Steel Erection Negotiated Rulemaking Advisory Committee [SENRAC] was formed and gathered testimony on the various proposed rules. This was an exhaustive process spanning years and with input from various sectors of the industry.
Relative to fall protection, it was the general consensus that a skilled iron worker is at greater risk if he/she is tied off doing leading edge work. (See 66 FR 5246), It was noted that:
The major concern . . . was that connectors needed freedom of movement and requiring them to tie-off would hinder this. The concern, as stated previously, was that in the event of structural collapse, a connector would be forced to ride the structure to the ground if tied off, whereas he/she could jump free of the collapsing structure if he/she were not tied off. The ability to move without restraint in order to get away from incoming loads is also stated as a reason for connectors not to tie off. 66 FR 5246
Specifically represented at the hearings were ironworkers from Local 7, who “uniformly stated that they needed to remain unencumbered when they were working with hoisting equipment and some members recounted personal experiences where they were able to escape collapses and incoming steel only because they were not tied off.” (66 FR 5246).
Thus, while a uniform 6 foot tie-off rule may seem more stringent than the OSHA rules, the deviation from OSHA may subject an iron worker to new hazards rather than preventing them. Before deviating from industry standards, companies should carefully consider the policies underpinning those standards in the first place or the deviations may create unintended dangers.