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A Fall Protection Scenario

- December 12, 2016 by Guest Bloggers (View all posts by Guest)

I am walking a jobsite to conduct a Risk Assessment for a contractor when I come up to a excavation of 10-feet that is in plain sight and not protected from falling in to it.  First question, that enters my mind is, do I need fall protection to be near the excavation?  It’s 10 feet in depth and so the fall potential is there.  It is a construction site, so fall protection is required at 6 feet , or is it?  Would OSHA have a citation, and if so, what is it?

The answer is No.  Excavations do not need protection, unless there are other hazards, such as impaling hazards of unprotected rebar, or an auger machine, etc.  Why?  See 29 CFR 1926.501(b)(7)

  1. Each employee at the edge of an excavation 6 feet (1.8) or more in depth shall be protected from by guardrails systems, fences or barricades WHEN the excavations are not readily seen because of plant growth or other visual barrier;
  2. Each Employee at the edge of a well, pit, shaft and similar excavation 6 feet (1.8m) or more shall be protected from falling by guardrail systems, fences, barricades, or covers.

Per the letter of interpretation, dated December 05, 2012:  Under these provisions, if the trench is not readily visible because of plant growth or other visual barrier, fall protection is required.  Thus, unless the trench you are describing is obscured from view, THERE IS NO REQUIREMENT FOR FALL PROTECTION to be provided.

So, if the excavation has other hazards inside the excavation, they would likely cite the following: 

Dangerous Equipment – 29 CFR 1926.501(b)(8)  When working 6 feet or more above dangerous equipment, each worker must be protected by guardrail systems, safety net systems, or personal fall arrest systems. 29 CFR 1926.502(b)(8)(ii).

When working less than 6 feet above dangerous equipment, each worker must be protected from falling into or onto the dangerous equipment by a guardrail system or equipment guards. 29 CFR 1926.502(b)(8)(i).

Best Practices would be to protect the excavations and to provide fall protection, barriers, fencing to protect workers from open excavations.

Sometimes, worrying about enforcement standards can lead people to overthink safety, but there are other times when being overly focused on the standards can lead to a company missing out on an opportunity to improve safety.  Check out Leslie Stoll’s posts on a situation where looking at a scenario from only a compliance angle is not the best idea.