b'OSHA UPDATE CSIA 25T heOSHAFallProtectionStandardsthatyoudeterminetheintegrityofthesurface for Construction and General Industrybefore any of your employees begins to work on contain a requirement for determiningit. BE SURE YOU DOCUMENT THE ACTIONS the integrity of all walking and workingYOUTAKETODETERMINETHEINTEGRITY surfaces.ThisrequirementisclearlystatedinOFTHEWALKING/WORKINGSURFACE 29CFR1926.s01(a)(2)and1910.22(b).WhileEVERY TIME! I suggest that you keep all of these the language in these sections is not exactly therecords for the duration of the project plus six same, they each provide OSHA with the tools itmonths. This procedure should also be part of needs require you to determine the integrity ofyour training program. These inspections should all walking/working surfaces before any of youroccur at the start of the job and they should be employees steps onto them to do work. repeatedeverytimeanyworkisdoneonthe surface that might affect its integrity. Remember TheinterestingpointinconstructionisthatOSHAs enforcement techniques; if you have an theOSHAStandardrequirestheemployertoaccident in which an employee falls througha determinetheintegrityofanywalkingand/orwalking/workingsurfaceOSHAwillverylikely workingsurfaceonwhichitsemployeeswillnot accept your argument that it had not been worktosupportthemsafely.Butthesecondinspected because you did not feel that the work sentence(onewhichmanyemployersmiss)beingdonedidnotaffectitsintegrity.OSHA states:Employeesshallbeallowedtoworkwill most likely cite you under this standard and on those surfaces only when the surfaces havetakethepositionthatsincethesurfacefailed, therequisitestrengthandstructuralintegrity.something must have been done to it to affect Thissecondsentencecomesveryclosetoits integrity after your initial inspection.Finally, I therequirementsetbyWashingtonOSHArecommend that you use a qualified individual (WISHA) that requires the employer guaranteeto perform this audit whenever it is necessary.the integrity of any walking or working surface before an employee may work on it.In the stateSubcontractors and the ofWashington,theuseoffallprotectiondoesMulti-Employer Worksite Policynotsatisfytherequirementthattheemployer guaranteetheintegrityofthesurface.IhaveWhetheryouusuallyworkasageneral arealconcernthatOSHAcomplianceofficerscontractororasubcontractoryoumayfind couldinterpret29CFR1910.22(b)inthesameyourself in a situation in which you will contract way. However OSHA tries to enforce the secondoutpartofyourworktoanothercontractor, sentenceof1926,591(a)(2),itisclearthatatwhowillthenbecomeyoursubcontractor.The the very least the employer must determine theOSHAMulti-EmployerworksitepolicymayCentral States Insulation Associationintegrityofthewalkingandworkingsurfacecreateresponsibilityfortheemployersonthe before an employee steps onto that surface. Insite for the safety of employees other than their arecentcaseOSHArequiredtheemployertoown. This policy has resulted in much litigation inspect both the top and bottom of the surfaceat the Occupational Safety and Health Review when determining integrity. Commission and the Federal Appellate Courts. Basically, the position I have seen OSHA take is While any employee is inspecting a walking/ that if you have a management employee on a working surface for its integrity, that employeeconstruction site who observes the employees of must use a personal fall arrest system. The factone of your subcontractors working unsafely and that you are employing a guardrail or a warningin violation of an OSHA standard you may well line/safety monitor system as your means of fallbe cited, in addition to the employees employer, protection for employees working on a walking/ for failure to take corrective action to protect the working surface will not abrogate the requirementemployee. The only area in which I believe there continuedpg.26csiaonline.org'