Michael Sladki, PE
Facilities Principal Engineer
ECS Mid-Atlantic, LLC
On January 17, 2017, OSHA issued their Final Rule for Walking-Working Surface and Personal Protective Equipment (Fall Protection Systems) 29 CFR Part 1910. It was exhilarating reading. You may be thinking, “I’m not planning on rappelling down the face of a building any time soon; I work in an office,” however, there are still real-world ways that this rule can impact us as engineers.
As a structural engineer, my primary duty is to the public. I have a responsibility to design safe buildings that meet the requirements of the local building code. By extension, that duty also applies to people who use the building once occupied. Here’s where it ties in with the OSHA Final Rule.
While the OSHA Final Rule is lengthy (read very, very lengthy!), and a number of the requirements do not, in fact, apply to buildings and their owners, some of the most important parts do. This article deals with the requirements associated with having someone (a contractor) accessing the façade of the building. Final Rule Paragraph (b)(1)(i) requires the Building Owner provide the employer (contractor) with a written statement identifying the tested, certified, and maintained roof anchorages capable of supporting at least 5,000 lbs. in any direction. There are a number of other requirements in the Final Rule, but this is the point where OSHA puts the responsibility on the owner of the building to provide safe means to access the façade.
These building owners, who are now under obligation to comply with the OSHA Final Rule are, in many cases, our ultimate clients. OSHA has placed a burden on them that we need to be aware of, so that we can better serve our clients.
A couple of thoughts:
- If you are a design engineer doing new design work, be aware of this requirement. Make sure that your structural system can handle these loads. Make sure that the Architect has appropriately located a roof anchorage system. In some cases, the Architect may defer to the General Contractor to include this work in their bid. They may, in turn, defer to a subcontractor. However, at some point, the Structural Engineer is going to be asked to give their blessing for the anchors that are up on that roof. Remembering our duty to the public, I would suggest that we get out in front on this issue and help ensure that our building owners are in compliance with the Final Rule.
- There are far more buildings already built than new ones being built. Many of these existing buildings may not comply with this Final Rule from OSHA, which does not distinguish between existing and new facilities. The owners of those buildings are also under an obligation from OSHA to provide safe access to their façade. Owners of existing buildings would be wise to come to a structural engineer for assistance. Professional engineers have a duty to protect the public and can be a valuable resource for these issues.
The OSHA Final Rule went into effect in January, and according to OSHA, will start being enforced in November 2017. The window of opportunity to address potential issues on existing buildings is closing fast. Keeping our duty to the public in the forefront of our minds, I encourage structural engineers to be a part of the solution and help their clients navigate these new requirements.