b'Garys CornerupdateGary Auman, MRCA Legal CounselWarning Lines and Safety Monitors applicable to the roofing industry.This standard applies to T his may not apply to all of our members. But, Iall construction industry employers no matter what their recently learned, when doing some research for asize.ConstructionindustrystandardSection1926.50(e) client regarding a statement a compliance officerstates that in the absence of an infirmary, clinic, hospital, in Arizona OSHA made to them, that some state OSHA plansor physician, that is reasonably accessible in terms of time have modified the fall protection requirement for employersanddistancetotheworksite,whichisavailableforthe who are using a warning line and safety monitor system. Fortreatment of injured employees, a person who has a valid a very long time we have been taking the position that, ifcertificateinfirstaidtrainingfromtheU.S.Bureauof employees are all working inside the warning lines we doMines, the American Red Cross, or equivalent training that not need a safety monitor. This position has been agreed tocan be verified by documentary evidence, shall be available by OSHA in a letter of interpretation dated July 23, 1996. Ifat the worksite to render first aid.Much construction work all employees are within the warning lines and they are sixtakes place close to municipalities of some size.In most feet back from the edge of the roof and they are properlyof these cases, an emergency squad is many times within constructed, there is no fall exposure and therefore no need5-10 minutes of the job site and such a squad typically has a to warn employees who might be outside the warning lines. certified paramedic, EMT, or other trained provider.ArizonaOSHAhasadvisedmyclientthatevenifIf you are more than a reasonable time from a hospital, theabovescenarioisthecase,theystillrequireasafetyclinic, or infirmary, under this standard you are required monitor. They advised my client that they were adoptingto have a certified first aid provider onsite.The training the position taken by North Carolina. In Standards Noticeof that first aid provider must be verified by documentary 65, the North Carolina Department of Labor found the U.S.evidence which you need to have available to provide to an DOL interpretation to be in error. Without taking the timeOSHA compliance officer who might request it.to go into too much of the reasoning in this Notice, NorthThis brings into question whether having an emergency Carolina now requires a safety monitor be in place wheneversquad in close proximity to the worksite is sufficient, if it a warning line is used as a means of fall protection. would still take more than 5, 10, or 15 minutes to get an IbringthistoourmembersattentionbecauseIaminjured worker to an infirmary, clinic, hospital, or physician. now aware that at least one other state OSHA program hasThis standard was last amended on June 18, 1998.I have to taken a similar position. That state is, of course, Arizona.submit to you that 20 years ago when this standard was first As you know, state OSHA programs must require employerspromulgated, emergency squads may not have been staffed to meet Federal OSHA standards, or they can require moreby certified EMTs and/or paramedics.It would seem that strict standards. So, that is what North Carolina and ArizonahavingacertifiedEMTorparamedicwithinfiveorten havedone.ForthosememberswhoworkinstateOSHAminutes of a job site would be preferable to having a first aid states, you need to be aware of this and of the fact that thetrained employee who only has an opportunity to use his/state OSHA program in the state in which you work mayher training every few years. But, you are still challenged havetakenasimilarposition.RememberthatMichigan,with complying to the standard as it is written.Therefore, if Kentucky, Indiana, Minnesota, Iowa, Tennessee, North andyou want to avoid a citation when an inspection occurs, you South Carolina, Virginia, Wyoming, Utah, New Mexico andwill need to have someone onsite trained by the Red Cross, ArizonaareallstateOSHAstates.Thereareadditionalthe U.S. Bureau of Mines, or some other training program states other than those I have named, but the named statessuch as the National Safety Council where that training can are those our members are most likely to work in.be verified by documentary evidence on the site whenever a crew is working there.Some Important, but Little Known OSHA Standards inIn addition to having the trained first aid person on the the Construction Industry site, you must also have first aid supplies easily accessible The first standard I would like to touch upon brieflyon the site.The contents of a first aid kit must be checked istherequirementforemergencymedicalservices.Inby you, the employer, prior to it being sent out on each job myexperience,veryfewemployersintheconstructionsite and at least weekly on the job site to ensure that any industrypayattentiontothis.Thisquestionoriginallyexpended items have been replaced.In addition, 1926.50(e) came up with regard to another client, and as I respondedrequires that proper equipment for prompt transportation to them, I determined that this is something that is very 6 www.mrca.orgMidwest Roofer'