On May 1, 2023, the Occupational Safety and Health Administration (OSHA) announced a National Emphasis Program (NEP) on fall protection. The NEP will take effect immediately and is being implemented to lower the amount of deaths and injuries due to falls. According to the National Safety Council, in 2020, 136 workers died and 127,680 were injured in “same level falls.” According to Bureau of Labor Statistics (BLS) data, of the 5,190 fatal workplace injuries in 2021, 680 were associated with falls from elevations. This accounts for approximately 13 percent of all deaths.
This NEP will affect all industries. The NEP provides OSHA compliance officers with procedures for locating and inspecting fall hazards and authorizes them to open inspections whenever they observe someone working at heights, including during inspections for other hazards and even during the officers’ normal workday travel. The goal of the NEP is to minimize fall-related hazards in all industries that could lead to serious injuries and deaths. Due to the amount of fall hazards in the Construction Industry, OSHA anticipates most of the inspections will occur in that industry. For construction related inspections, the inspectors will follow the protocols in this NEP. For non-construction related inspections, the NEP will focus on the following:
- Roof top mechanical work/maintenance
- Utility line work/maintenance (electrical, cable)
- Arborist/tree trimming
- Holiday light installation
- Road sign maintenance/billboards
- Power washing buildings (not connected to painting)
- Gutter cleaning
- Chimney cleaning
- Window cleaning
- Communication Towers
For other non-construction work activities where a worker is observed working at height, an inspection may be initiated upon approval by area office management. If an inspection is not warranted after entering the site and observing work activities, the Compliance Safety and Health Officer will conduct an outreach activity on fall protection and exit the site.
CSHOs are authorized to initiate inspections under the scope of this NEP whenever they observe someone working at heights. These observations may occur during the CSHO’s normal work-day travel or while on route to, from, or during, other OSHA inspections. In addition, the following NEP inspections will take place:
- Fall hazards referrals brought to the attention of the Area Office shall be evaluated, and, if appropriate, inspected.
- During all programmed safety and health inspections (such as national, regional or local emphasis programs), CSHOs shall observe the surrounding area for potential fall exposures and conduct an inspection under this NEP if any are present.
- During all un-programmed inspections (incidents, complaints, and referrals), CSHOs shall observe the surrounding area for potential fall exposures and conduct an inspection under this NEP if any are present.
If fall hazards are at your facility, is your company prepared for an OSHA inspection. Some things to consider. Do you have in place:
- Fall protection criteria to protect employees fall hazards exceed the standard
- Training on fall protection and the use of the fall protection or arrest systems utilized
- Inspection protocols for your fall protection equipment
Contact CMI is you have questions regarding fall hazards or need training on fall protection.
Written by Michael Schneider, CSP, Director, Health and Safety Services
