Many roofing contractors and roofing workers have a good working knowledge of the main provisions of the Occupational Safety and Health Administration's (OSHA's) fall-protection regulations under 29 CFR 1926.500-503, commonly known as Subpart M. However, one of the more obscure provisions of Subpart M—and one that receives little attention in worker training sessions or safety program content—is the requirement under 1926.502(d)(20) that "the employer shall provide for prompt rescue of employees in the event of a fall or shall assure that employees are able to rescue themselves."
This regulatory provision gives employers the responsibility of worker rescue but does not give any guidance for how rescue should be accomplished. Of further concern, OSHA guidance for the topic in the form of letters of interpretation has not provided much direction.
So what should you do to comply with the standard's demands? Following are methods of job-site rescue you may consider when developing a specific rescue-training program and recent product developments that may be useful.
In a recent letter of interpretation, OSHA stated "the word 'prompt' requires rescue be performed quickly—in time to prevent serious injury to the worker." The U.S. Centers for Disease Control and Prevention reports that suspension trauma—the condition that results after a worker's fall has been arrested and the worker remains dangling by his harness—quickly can cause death. Most experts agree target times for completing a rescue should be close to 5 minutes to avoid adverse health effects.
As to whether the OSHA prompt-rescue requirement demands a second employee always be present at job locations, OSHA states "... a single worker equipped with communication equipment that enables the worker to obtain help promptly would meet the requirement." Of course, this one-man safe harbor suggested by the standard neglects to consider the possibility that a worker who has been subjected to the forces imposed on his body by fall-arrest equipment will be incapable of using communication equipment for his rescue.
You should consider several factors when developing a comprehensive fall-rescue plan. Equipping workers with cellular telephones or two-way radios will allow them to contact co-workers or emergency responders for assistance. Telephone numbers for local emergency response agencies must be given to workers before any project begins.
Workers also must be trained to identify job-site resources required for successful rescue of a fallen worker. These resources might include extension ladders, forklifts, aerial lifts, scaffolding, and first-aid or medical supplies. In addition, many manufacturers of fall-arrest equipment make pulley-and-winch systems designed for attachment and lowering of a fallen worker. Inexpensive brake tube systems also can be used to lower a suspended worker safely. The critical element in the safe use of any of these systems is the proper training of workers in setup and function of the devices.
Training one-man crews in self-rescue should be considered, as well as acquisition of appropriate self-rescue equipment. Some such devices are synthetic ladders packed in pouches that can be carried by workers and attached to lifelines to allow descent to the ground or standing to relieve pressure from the harness. A self-rescue lanyard that deploys a synthetic ladder upon deceleration also is available. In addition, synthetic and rope loops that attach at the rope-grab connector to allow a worker to stand to relieve pressure on his legs also are available. Self-rescue methods involve a foot-wrap technique on a worker's lifeline and rappelling with the assistance of rope loops called "prussik loops," as well as a figure-eight descender, and are available from the Washington State Department of Labor and Industries.
You and your roofing workers should become familiar with job-site rescue methods and develop a fall-rescue plan that can be implemented easily and quickly. Be sure you have the necessary rescue equipment and knowledge, so if the time comes, you will be ready to use them.
Harry Dietz is NRCA's director of risk management.